OFFICE OF
THE CHIEF ACCOUNTANT

June 26, 2000

Ms. Amy A. Ripepi
Chairperson
SEC Regulations Committee
Arthur Andersen LLP
33 West Monroe Street
Chicago, IL 60603-5385

Dear Amy:

In response to requests that the SEC staff received from a number of accounting firms and registrants to defer the implementation date of Staff Accounting Bulletin (SAB) No. 101, Revenue Recognition in Financial Statements, the staff released today SAB 101B that defers the implementation date of SAB 101 until no later than the fourth quarter of fiscal years beginning after December 15, 1999. The only reason for the deferral is to provide registrants with sufficient time to assess and implement the guidance in SAB 101. In addition, we expect to continue developing, along with working groups from the accounting profession and industry, a frequently asked questions (FAQ) document that provides answers to a number of the implementation questions that we have received to date. The FAQ will be made available on the SEC's web site at sec.gov.

Prior to registrants' implementation of SAB 101, we remind registrants and their auditors of the disclosure requirements of SAB Topic 11-M, Disclosure of the Impact that Recently Issued Accounting Standards Will Have on the Financial Statements of a Registrant When Adopted in a Future Period; AICPA professional standards section AU 9410, Item 3, The Impact on an Auditor's Report of an FASB Statement Prior to the Statement's Effective Date; and Regulation S-K, Item 303, Management's Discussion and Analysis of Financial Condition and Results of Operations. The staff plans to ensure compliance with these disclosure requirements in its reviews of registrants' filings with the Commission.

If you have further questions, please contact Richard Rodgers, Scott Taub, Eric Jacobsen, or me at (202) 942-4400 or Robert Bayless at (202) 942-2850.

Sincerely,
/s
Lynn E. Turner
Chief Accountant