Mr. Jonathan Katz
Secretary
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609

Re: File No. S7-03-00

Dear Mr. Katz:

The Association for Financial Professionals (AFP) welcomes this opportunity to forward to the Securities and Exchange Commission (SEC) comments on the proposed additions of Item 302(c) to Regulation S-K to specify disclosures to be provided by registrants concerning changes in valuation and loss accrual accounts and Item 302(d) to Regulation S-K to elicit certain information concerning tangible and intangible long-lived assets and related accumulated depreciation, depletion, and amortization.

AFP represents approximately 15,000 finance and treasury professionals who work in all areas of the finance profession for companies from all industrial groups. These organizations are generally drawn from the Fortune 1000 companies and the largest middle market companies. We maintain information on the job responsibilities of our members. Over half of our members have the title of CEO, CFO, Comptroller, Treasurer, Vice President, or Manager. Thus, they have a strong interest in the issues you are addressing.

Our Government Relations Committee addressed the issue of abusive "earnings management" by public companies which has prompted the SEC's proposed addition to Items 302(c) and 302(d) of Regulation S-K at its June meeting. The committee expressed agreement with the SEC's view that abusive "earnings management" is a problem. Such practices are not only unfair to investors, they are unfair to other companies who present an accurate picture of their financial condition to the capital markets. We agree that the proposed rules will at least partially rectify these problems by providing investors with more transparent, better detailed disclosures concerning changes in valuation and loss accrual accounts and in the underlying accounting assumptions, and more detailed information to assess the effects of useful lives assigned to long-lived assets.

Managements and their auditors need guidelines so that all companies will be presenting themselves to investors and the public in a fair and impartial manner. Such guidelines would be beneficial to all companies and their suppliers of capital. However, we are concerned that the guidelines not be so specific and detailed so as to place an unnecessary and excessive burden on the financial officers who prepare financial reports for the investing public. If reporting requirements do become excessively burdensome, the goal of keeping investors adequately informed and achieving equity among companies that use the capital markets will be more difficult to achieve.

We hope these comments are helpful.

Sincerely,

/s/ Frank P. Curran
Vice President
Government Relations and Technical Services
Association for Financial Professionals