On January 16, 2007 the SEC issued a sample letter that provides illustrative information for registrants to consider as they prepare reports to be filed with the Commission to correct errors in accounting for stock option grants. This letter is in response to inquiries received by the Division of Corporation Finance from several public companies requesting filing guidance as they prepare to restate previously issued financial statements for errors in accounting for stock option grants. The illustrative letter can be obtained from the SEC Web site.

Any questions regarding the sample letter provided by the SEC should be directed to the staff of the Chief Accountant's Office in the Division of Corporation Finance (202-551-3400).

In addition, the staff of the Office of the Chief Accountant is continuing to consider matters related to the accounting for stock options. Refer to the SEC Letter from September 19, 2006. If your clients would like to discuss the particular facts and circumstances of their stock option grants and the accounting conclusions reached, the SEC encourages you to contact Joe Ucuzoglu, Professional Accounting Fellow in the Office of the Chief Accountant at 202-551-5301 or Mark Barrysmith, Professional Accounting Fellow in the Office of the Chief Accountant 202-551-5304.