The Securities & Exchange Commission sent out and posted a document entitled, "Sample Letter Sent to Public Companies Asking for Information Related to Repurchase Agreements, Securities Lending Transactions, or Other Transactions Involving the Transfer of Financial Assets" yesterday. It says, "In March 2010, the Division of Corporation Finance sent the following illustrative letter to certain public companies requesting information about repurchase agreements, securities lending transactions, or other transactions involving the transfer of financial assets with an obligation to repurchase the transferred assets." It says, "​With regard to your repurchase agreements, please tell us whether you account for any of those agreements as sales for accounting purposes in your financial statements. If you do, we ask that you: Quantify the amount of repurchase agreements qualifying for sales accounting at each quarterly balance sheet date for each of the past three years. Quantify the average quarterly balance of repurchase agreements qualifying for sales accounting for each of the past three years. Describe all the differences in transaction terms that result in certain of your repurchase agreements qualifying as sales versus collateralized financings. Provide a detailed analysis supporting your use of sales accounting for your repurchase agreements...."

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