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July 25, 2005
Mail Stop 4561
VIA U.S. MAIL AND FAX 1-314-506-5560
Mr. Eric H. Brunngraber
Chief Financial Officer
Cass Information Systems
13001 Hollenberg Drive
Bridgeton, Missouri 63044
RE: Cass Information Systems
Form 10-KSB for the year ended December 31, 2004
Form 10-QSB for the quarter ended March 31, 2005
File no. 333-44497
Dear Mr. Brunngraber:
We have reviewed the above referenced filings and have the
following
comments. We have limited our review to only your financial
statements and related disclosures and will make no further review
of
your documents. In our comments, we may ask you to provide us
with
information so we may better understand your disclosure. Please
be
as detailed as necessary in your explanation. After reviewing
this
information, we may or may not raise additional comments.
Please understand that the purpose of our review process is to
assist
you in your compliance with the applicable disclosure requirements
and to enhance the overall disclosure in your filing. We look
forward to working with you in these respects. We welcome any
questions you may have about our comments or on any other aspect
of
our review. Feel free to call us at the telephone numbers listed
at
the end of this letter.
Form 10K for the year ended December 31, 2004
Consolidated Statements of Income, page 25
1. Tell us your basis for recording gains from the sale of
investment
securities within revenues. Reference is made to Rules 5-03 and
9-04
of Regulation S-X.
Notes to Financial Statements, page 28
Note 1. Summary of Significant Accounting Policies, page 29
2. Please expand on your accounting policy as it relates to your
information services revenue. Specifically, tell us how you earn
and
record revenue from each of your three revenue streams, freight,
utility and telecommunication.
Note 7. Equity Investments in Non-Marketable Securities, page 36
3. We note that you converted your investment in a private imaging
company from a convertible debenture into Common Stock and own a
19.99% equity interest. We also note that your policy for non-
marketable equity investments in which the Company owns less than
20%
is accounted for under the cost method. Tell us how you recorded
this investment on your financial statements given your funding
commitments and your basis in GAAP for your treatment.
* * * *
As appropriate, please respond to these comments within 10
business
days or tell us when you will provide us with a response. Please
file your response on EDGAR. Please understand that we may have
additional comments after reviewing your responses to our
comments.
We urge all persons who are responsible for the accuracy and
adequacy
of the disclosure in the filings reviewed by the staff to be
certain
that they have provided all information investors require for an
informed decision. Since the company and its management are in
possession of all facts relating to a company`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.
In connection with responding to our comments, please provide, in
writing, a statement from the company acknowledging that:
* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filings; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement
has
access to all information you provide to the staff of the Division
of
Corporation Finance in our review of your filings or in response
to
our comments on your filings.
You may contact Kelly McCusker, Staff Accountant, at (202) 551-
3433
or the undersigned at (202) 551-3413 if you have questions.
Sincerely,
Cicely D. Luckey
Branch Chief
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Mr. Brunngraber
Cass Information Systems, Inc.
July 25, 2005
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