Shares of Salesforce.com (CRM) are lower in early trading after the SEC posted to its website prior correspondence the regulator had with the company regarding its accounting and reporting. In one letter, dated September 17, 2012, related to the company's 10-K filing for 2012, the SEC staff recommended changes to the way the company discusses and analyzes its financial condition and operating results. The company responded in that September letter, stating it intends to provide additional disclosures commencing with it Form 10-K filing for the fiscal year ended January 31, 2013. Salesforce also made specific replies to suggestions about its reporting of revenue by geography, income taxes and legal proceedings. In a letter dated December 13, 2012, the SEC told CFO Graham Smith it had completed its review, but added, "We remind you that our comments or changes to disclosure in response to our comments do not foreclose the Commission from taking any action with respect to the company or the filing and the company may not assert staff comments as a defense in any proceeding initiated by the Commission." In early trading, shares of saleforce.com are down $4.43, or 2.54%, to $170.22.