UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION
SECURITIES EXCHANGE ACT OF 1934
Release No. 48549 / September 26, 2003
ACCOUNTING AND AUDITING ENFORCEMENT
Release No. 1875 / September 26, 2003
ADMINISTRATIVE PROCEEDING
File No. 3-11274
_________________________________________________________________
In the Matter of
ANALYTICAL SURVEYS, INC.,
Respondent.
_________________________________________________________________
ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND
IMPOSING A CEASE-AND-DESIST ORDER PURSUANT TO SECTION 21C OF THE
SECURITIES EXCHANGE ACT OF 1934
I.
The Securities and Exchange Commission ("Commission") deems it
appropriate that cease-and-desist proceedings be, and hereby are,
instituted pursuant to Section 21C of the Securities Exchange Act of
1934 ("Exchange Act") against Analytical Surveys, Inc. ("Respondent").
II.
In anticipation of the institution of these proceedings, Respondent
has submitted an Offer of Settlement ("Offer"), which the Commission
has determined to accept. Solely for the purpose of these proceedings
and any other proceedings brought by or on behalf of the Commission,
or to which the Commission is a party, and without admitting or
denying the findings herein, except as to the Commission's
jurisdiction over it and the subject matter of these proceedings,
Respondent consents to the entry of this Order Instituting
Cease-and-Desist Proceedings, Making Findings, and Imposing a
Cease-and-Desist Order Pursuant to Section 21C of the Securities
Exchange Act of 1934 ("Order"), as set forth below.
SNIPPETS:
SECURITIES AND EXCHANGE COMMISSION
ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING A
The Securities and Exchange Commission deems it appropriate that cease-and-desist proceedings
In anticipation of the institution of these proceedings, Respondent has submitted an Offer of
From 1997 to 2002, Respondent had facilities in several states, with its headquarters in
When Respondent won the bidding on a contract, its bid would become the contract price.
As part of formulating the bid, Respondent would estimate the production costs, or estimated
Respondent recognized revenue on the contracts using the percentage of completion method on a
Under the method, which is appropriate under Generally Accepted Accounting Principles and
Specifically, a company may recognize revenue by calculating the direct costs incurred to
On or about October 1, 1998 through on or about December 31, 1999, Respondent recognized
In some instances, when Respondent incurred direct costs on a contract equal to the total
In November 1999, Respondent issued a press release claiming revenue of $117.1 million and
Although the annual report reduced the revenue and net earnings that Respondent had announced
the audit committee of Respondent's board initiated a comprehensive review of contracts to
During the time of the events described above, individual employees of Respondent frequently
Also, each of Respondent's facilities was supposed to review its direct cost estimates
Pursuant to Section 21C of the Exchange Act, that Respondent cease and desist from committing
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