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The SEC Has a Few Questions for You

(continued)

• Reserve judgment. Refrain from coming to any conclusions until the internal and external groups have gathered all the facts, evaluated the data, and made recommendations.

• Be thorough. Make sure to address all the points raised in the SEC comment letter to avoid another round.

• Engage constructively. Keep your responses concise, transparent, and thoughtful. Explain the business and the issues it faces just as you would to an important stockholder. Avoid taking an adversarial tone. — S.J.


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Reader CommentsDisplaying 1 of 1

  • Firozali A Mulla

    May 31, 2010 11:58 AM ET

    Give credit where credit is due

    Give credit where credit is due, goes the expression, but in this week's words the credit is misplaced. Each of these … more

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