Comment on 4-497

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RECEIVED FEB 2 8 2005 Investing in communities February 25, 2005 Jonathan G. Katz, Secretary Securities and Exchange Commission 450 Fifth Street, NW Washington, DC 20549-0609 Re: File Number 4-497 Dear Mr. Katz: The Mortgage Bankers ~ssociation' recently solicited the views of members that are subject to the Sarbanes-Oxley Act of 2002 (the "Act") regarding the law's impact on the mortgage banking industry and, more specifically, whether MBA should support calls for the appeal or amendment of sections of the legislation. Interestingly, while our members expressed unanimous support for the Act's objectives of promoting greater integrity and responsibility in corporate financial reporting and disclosure, they also agreed that the manner in which Section 404, Management assessment of internal controls, has been implemented within the mortgage banking industry has served to undermine these objectives by unnecessarily reducing investors' investment returns. Our members are so concerned about the high costs of complying with Section 404 that they have requested that I convey their observations to you, along with a request that they be given the opportunity to discuss them with SEC staff and the staff of the Public Company Accounting Oversight Board (PCAOB). MBA Position MBA agrees with the intent and goal of the Act. We believe CEO and CFO accountability is appropriate and that a formal structure for management and their auditors to opine on the ...

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Zien

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English

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