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                          STANDARD MOTOR PRODUCTS, INC.
                              37-18 Northern Blvd.
                           Long Island City, NY 11101

                                October 25, 2007

Ms. Stephanie Hunsaker
Associate Chief Accountant
Division of Corporate Finance, Mail Stop 5546
United States Securities and Exchange Commission
100 F Street, N.W.
Washington, D.C. 20549

Re:      Standard Motor Products, Inc. ("SMP" or "the Company")
         ANNUAL REPORTS ON FORM 10-K FOR THE YEARS ENDED 2005 AND 2006

Dear Ms. Hunsaker:

We are writing to seek the approval of the Staff (the "Staff") of the Securities
and Exchange Commission (the "Commission") of our request to obtain a waiver of
the requirement to furnish separate audited or unaudited financial statements
for each 50 percent or less owned entity pursuant to Rule 3-09 of Regulation S-X
in the Company's Annual Report on Form 10-K for the years ended December 31,
2005, 2006 and 2007. We are also requesting a waiver of the requirement to
provide summarized financial data pursuant to Rule 4-08(g) of Regulation S-X in
the Company's Annual Report on Form 10-K for the year ended December 31, 2005.

As of December 31, 2005, SMP held an equity interest in five separate joint
ventures, two of which, based upon the income test within the definition of
"significant subsidiary" (Rule 1-02(w)(3) of Regulation S-X), exceeded the 20%
threshold for determination of whether separate audited financial statements are
required to be filed with respect to such joint ventures (Refer to the attached
Exhibit A).

In the course of its review of SMP's Annual Report on Form 10-K for the year
ended December 31, 2006, the Staff inquired as to how we had considered the
requirements of Rules 3-09 and 4-08(g) of Regulation S-X related to each of our
joint ventures for the periods covered by our filing. Through our discussions
with the Staff, we explained that we had believed that we were below the
required disclosure thresholds for joint ventures based on our interpretation of
ADRP Topic Two ID1a, which we originally understood as precluding the income
averaging rule in loss years strictly in the case of Rule 3-05 of Regulation
S-X. However, based on the Staff's comments, we agree with the Staff's
interpretation of calculating the thresholds enumerated under the Rules which
preclude the use of the averaging computational rule in a loss year for the
purposes of Rules 3-09 and 4-08(g) of Regulation S-X. Without the availability
of the 5 year averaging rule, the requirements for financial statement inclusion
and additional note disclosure under Rules 3-09 and 4-08(g) of Regulation S-X
were triggered for the year ended 2005 for certain of the Company's joint
ventures. Please see Exhibit A for the revised calculation demonstrating how the
inclusion requirement was triggered in 2005.
<PAGE>


To provide additional background information and to facilitate your assessment
of our request, we have included a discussion below of the relevant facts and
circumstances surrounding the joint ventures for which we seek the Staff's
waiver to furnish separate financial statements:

o    Please refer to Exhibit A, which summarizes the financial information of
     the Company and each of its equity investments in the determination of the
     income test within the definition of a "significant subsidiary" (Rule
     1-02(w)(3) of Regulation S-X). Please note that the joint ventures were not
     found to be significant in the determination of the investment test within
     the definition of a "significant subsidiary" (Rule 1-02 (w)(1) of
     Regulation S-X for the period 2001 to 2006).

o    Please refer to Exhibit B, which breaks out the 2005 and 2006 financial
     information of the Company and each of its equity investments. This
     represents the type of information required to be disclosed pursuant to
     Rule 4-08(g) of Regulation S-X.

o    BLUE STREAK ELECTRONICS, LTD ("BSE")

     Since established in 1992, SMP has maintained a 50% ownership interest in
     this joint venture. The joint venture remanufactures on-board computers for
     the automobile aftermarket. The headquarters and manufacturing facility of
     BSE are located in Canada. BSE has the same fiscal year end as SMP, which
     is December 31, and its financial statements are not audited. In 2005, BSE
     was significant at 35%, whereas for all other years presented (2001 through
     2004, and 2006) BSE was not significant. As shown in Exhibit A, between
     2001 and 2006, our share of BSE's pre-tax annual income has varied by no
     more than approximately $300,000, ranging between $307,000 and $587,000.

o    TESTAR, LTD. ("TESTAR")

     Since established in 1995, SMP has maintained a 50% ownership interest in
     this joint venture. The headquarters and manufacturing facility of Testar
     are located in Israel. The joint venture produces software products for use
     in on-board computers for the automobile aftermarket. The joint venture has
     a fiscal year end of December 31 and is not audited by the Company's
     independent accountants, but rather by a different firm pursuant to local
     accounting and auditing standards. In 2005, Testar was significant at 26%,
     whereas for all other years presented (2001 through 2004, and 2006) Testar
     was not significant. As shown in Exhibit A between 2001 and 2006, our share
     of Testar's pre-tax annual income has varied by no more than approximately
     $250,000, ranging between $188,000 and $421,000.

The Company respectfully requests that the Staff grant relief from the
requirement to file separate audited financial statements of the aforementioned
equity investments in the Company's Annual Report on Form 10-K for the year
ended 2005 in accordance with Rule 3-09(a) of Regulation S-X, as well as from
including unaudited financial statements in its Annual Report on Form 10-K

                                      -2-
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filings for the two succeeding years 2006 and 2007. We are also requesting that
the Staff grant relief from the disclosure requirements provided under Rule
4-08(g) of Regulation S-X for the Company's Annual Report on Form 10-K for the
year ended December 31, 2005. The reasons for such requests are as follows:

     a)   Except for fiscal year 2005, our joint ventures have not triggered the
          full financial statement filing requirements of Rule 3-09 of
          Regulation S-X, nor the financial information disclosure requirements
          of Rule 4-08(g) of Regulation S-X. As mentioned above, over a 6 year
          period, the variability in our share of the results of each of BSE and
          Testar was between $250,000 and $300,000. Furthermore, the Company
          does not expect that any of its joint ventures will rise to
          significance under the above-noted Rules in the foreseeable future. As
          the results of the joint ventures have been very stable and not
          material to SMP in absolute terms since inception, we respectfully
          submit to the Staff that the addition of financial statements would
          not add useful information to our filings (see Exhibit B).

     b)   During the Company's 2005 fiscal year, while there had not been a
          significant change in the results of our joint ventures, the "greater
          than 20%" inclusion threshold was triggered under subsection (3) of
          Rule 1-02(w) of Regulation S-X (the "income test"), due to the
          Company's unusually small loss from continuing operations in that
          year. This loss was driven mainly by a unique significant adverse
          impact to our gross profit (over $10 million reduction) resulting from
          the integration of the largest acquisition in SMP's history which had
          occurred 18 months prior. Please note that this issue was resolved in
          2006 where we returned to a more traditional level of gross profit.

     c)   Included in the Company's loss from continuing operations for the 2005
          fiscal year was a one-time curtailment gain for new participation
          restrictions to its post retirement plans, with a favorable impact of
          about $4.0 million. Without this one-time curtailment gain, the
          Company's consolidated loss would have been $5.4 million and, as such,
          would not have triggered the "greater than 20%" threshold under
          subsection (3) of Rule 1-02(w) of Regulation S-X (the "income test")
          for any of its joint ventures since equity income of BSE and Testar
          would be 9.2% and 6.7%, respectively, of the Company's adjusted
          pre-tax consolidated loss. We respectively bring to the attention of
          the Staff that strict application of the rules results in a
          requirement that is unreasonable given that subsection (3) of Rule
          1-02(w) of Regulation S-X has not been triggered for any of the
          Company's joint venture investments in any of the six years from 2001
          through 2006 except for 2005 and as a result of a one-time curtailment
          gain. Furthermore, please note that the curtailment gain is not an
          event that will likely occur in the future, nor has it happened in the
          past.

     d)   Given the significant fluctuations in SMP's internal operating result
          components, and given the stability and small results of our joint
          ventures, we respectfully submit that the joint ventures,

                                      -3-
<PAGE>

          individually, did not have a measurable impact on the fluctuations of
          SMP's consolidated results and that adding the separate financial
          statements of BSE and Testar would not in and of itself, measurably
          improve the understanding of our financial statements for the periods
          concerned.

     e)   As mentioned, since the Company generated a loss from continuing
          operations in 2005, the Company was prohibited from applying the
          five-year income averaging method in computing the income test. Had
          the Company been able to use the five-year income averaging method,
          the 20% significance threshold would not have been exceeded for any of
          the aforementioned equity investments. As a point of reference, the
          Company would have generated positive income, thus availing itself of
          the averaging rule, had it generated a mere $348,000 of additional
          pre-tax income, which is 0.2 of 1% of our gross profit in 2005.

     f)   The Company will provide the required aggregate summarized financial
          information of its equity investments as prescribed by Rule 4-08(g) of
          Regulation S-X in a footnote to its amended Annual Report on Form 10-K
          for 2006 and for its upcoming Annual Report on Form 10-K for the year
          ended December 31, 2007. In addition, we propose to expand the
          disclosure of such note, breaking out the information for BSE and
          Testar individually as set out in the attached Exhibit B in
          satisfaction of the Rule 3-09 requirement to present separate
          financial statements of each joint venture. We believe this specific
          disclosure for BSE and Testar provides the readers of SMP's financial
          statements more meaningful information than a full set of financial
          statements, particularly given the unusual circumstances leading to
          the significance threshold exceeding 20% in 2005. As Exhibit B shows,
          except for the pre-tax income threshold as previously discussed, all
          of the other summarized financial data are no greater than 2% of the
          corresponding amounts of SMP. Inclusion of separate financial
          statements for BSE and Testar under the circumstances may be more
          confusing to the reader given their relative insignificance to SMP.

     g)   The Company believes obtaining full audited financial statements
          pursuant to Rule 3-09 of Regulation S-X and amending its prior filings
          to include the disclosure required by Rule 4-08(g) of Regulation S-X,
          will result in undue difficulty and considerable expense while
          providing little additional useful information in our filings. As
          described above, the Company's independent accountants do not audit
          our joint ventures. The increased scope requirements, along with the
          need to present the financial statements in accordance with US GAAP
          and, in some cases, translate them to English, will result in
          additional costs to the joint venture companies and to the Company.

In summary, the Company understands that it technically meets the requirements
of Rule 3-09 of Regulation S-X to furnish separate audited financial statements
in the Company's Annual Report on Form 10-K for 2005 and unaudited statements in
its Annual Report on Form 10-K for 2006 and 2007. Furthermore, the Company
recognizes that is also meets to the requirements to provide the summarized
financial data under Rule 4-08(g) of Regulation S-X in its annual financial
statements for the above-mentioned years. However, given the fact patterns

                                      -4-
<PAGE>

presented above, we respectively request the Staff consider the additional cost
and administrative burden on the Company to comply with the Rules, and consider
our view of the limited utility to the investing public of providing the audited
financial statements and separate disclosures of BSE and Testar. As mentioned
earlier, in satisfaction of the rules, we propose to expand our financial
information disclosure under Rule 4-08(g) of Regulation S-X in our amended 2006
Annual Report on Form 10-K, currently under review, as well as in our upcoming
2007 Annual Report on Form 10-K. Therefore, we respectfully request the Staff's
approval with our request to obtain a waiver from the requirements to file
separate audited financial statements for BSE and Testar for the year ended
2005, as well as unaudited financial statements in its filings for the two
succeeding years 2006 and 2007, and from the requirements to disclose financial
information in accordance with Rule 4-08(g) of Regulation S-X for 2005.

The Company would like to bring to the Staff's attention that it undertakes to
appropriately apply the requirements of the rules addressed in the foregoing
should the circumstances dictate their applicability in the future. As mentioned
earlier, we do not expect that the rules will be triggered in the near future.

Please contact the undersigned or Carmine Broccole, our Vice President General
Counsel, or Luc Gregoire, our Corporate Controller, at 718-392-0200, if you have
any questions regarding this matter.

                                             Very truly yours,


                                             /s/ James J. Burke
                                             ------------------
                                             Chief Financial Officer and
                                             Vice President Finance


cc:  Mr. Kevin Vaughn, Branch Chief - SEC / Mailstop 6010
     Mr. Martin James, Senior Assistant Chief Accountant - SEC / Mailstop 6010
     Mrs. Tara Harkins, Staff Accountant - SEC / Mailstop 6010
     Mrs. Mary Ropes, Grant Thornton


                                      -5-
<PAGE>

<TABLE>
<CAPTION>

                                                                                                                           Exhibit A
                                                           Standard Motor Products, Inc.
                                                               Rule 3-09 Summary
                                                     --------------------------------------

                                                 2001*           2002         2003           2004*           2005             2006
                                             -----------   -------------  -------------   ------------   ---------------  ---------
<S>                                             <C>           <C>           <C>            <C>             <C>             <C>
Consolidated income before tax*                 $ 523         $ 14,171      $ 1,954        $ (13,333)      $(1,405)        $ 15,657

Averaging rule where applicable                10,300                         8,345



          BSE                                 565   5%         587  4%      459  5.5%       472   -4%      498  -35%        307   2%
          Testar                              313   3%         308  2%      394  4.7%       421   -3%      364  -26%        188   1%
          Valeo                               (67) -1%         (91)-1%     (283)  -3%         6    0%      181  -13%        455   3%
          Iberia                                -   0%        (121)-1%     (240)  -3%       (61)   0%     (102)   7%        (63)  0%
          BSE - EUROPE                         58   1%           -  0%     (273)  -3%       (85)   1%        -    0%         28   0%
          Wu Han                              (25)  0%        (383)-3%      (30)   0%         -    0%        -    0%          -   0%
          Other                                 -   0%          52  0%        -    0%         -    0%       15   -1%          -   0%

Individually > 20% triggers 3-09?             No-all         No-all         No-all          No-all        Yes: BSE,          No-all
                                                                                                           Testar
Aggregation of incomes or losses
  > 10% = Rule 4-08(g) met?
          Aggregation of JV's With Income       No   9%       No   6%       No  10%         No  7%        Yes  75%         No   6%
          Aggregation of JV's With Losses       No   1%       No   5%       No  9%          No  1%         No  7%          No   0%
                                             -----------   -------------  -------------   ------------   ---------------  ---------


          * Before extraordinary income or loss
          Per computational rule, equity income added back when consolidated loss vs. equity income and vice versa


          -----------------------------------        -----------------------------
          Averaging 2001                             Averaging 2003
          ---------------------                      -----------------

              2001       $ 523                               2003        $ 1,954
              2000      13,116                               2002         14,171
              1999      12,029                               2001            456
              1998      25,834                               2000         13,116
              1997 A        --                               1999         12,029
                      ---------                                         ---------
          average     $ 10,300                       average             $ 8,345
                      ---------                                         ---------

                      A=Loss
          -----------------------------------        -----------------------------
</TABLE>



                                      -6-
<PAGE>

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<CAPTION>
                                                                                                                    Exhibit B

                                                            Standard Motor Products, Inc.
                                                                 Rule 4-08 Disclosure

                                                                       2005
                                                                      (000's)
                                                                                                                          SMP
                           BSE                Testar             Valeo          Iberica              Total JV'S        Consolidated
                           --------------    ------------      -------------    ---------------      -------------     ------------

<S>                         <C>      <C>    <C>      <C>      <C>      <C>      <C>      <C>         <C>      <C>       <C>
Rule 1-02 (bb) (1) (i)
Current assets              5,665     1%      1,078    0%       2,026    0%      1,820       0%      10,588     2%         455,690
Non-current assets          2,634     1%         11    0%         186    0%        172       0%       3,003     2%         197,354
Current liabilities         1,800     1%        113    0%       1,521    1%        582       0%       4,017     1%         285,922
Non-current liabilities     2,554     1%         22    0%         581    0%      1,470       1%       4,627     3%         181,415

Rule 1-02 (bb) (1) (ii)
Net sales                   8,540     1%      1,389    0%       2,841    0%      2,075       0%      14,845     2%         830,413
Gross Profit                4,462     2%      1,013    1%         369    0%       (366)      0%       5,478     3%         185,980
Income from continuing
  operations                  968   -55%        893  -50%         352  -20%       (383)     22%       1,830  -103%          (1,770)
Net Income                    968   -27%        893  -25%         352  -10%       (383)     11%       1,830   -52%          (3,545)



                                                                       2006
                                                                     (000's)
                                                                                                                            SMP
                           BSE                Testar             Valeo          Iberica              Total JV'S        Consolidated
                           --------------    ------------      -------------    ---------------      -------------     ------------

Rule 1-02 (bb) (1) (i)
Current assets              5,223     1%        213    0%       3,088    1%      1,921       0%      10,444     2%         461,838
Non-current assets          2,661     1%          7    0%         224    0%         36       0%       2,928     2%         178,254
Current liabilities         1,412     1%         69    0%       1,595    1%        678       0%       3,754     1%         278,525
Non-current liabilities     2,443     1%         42    0%         644    0%        949       1%       4,079     2%         170,868

Rule 1-02 (bb) (1) (ii)
Net sales                   7,563     1%        520    0%       4,240    1%      1,932       0%      14,255     2%         812,024
Gross Profit                3,318     2%        147    0%         899    0%        588       0%       4,952     2%         205,220
Income from continuing
  operations                  688     8%         66    1%         904   10%       (113)     -1%       1,545    17%           9,163
Net Income                    688     7%         66    1%         904   10%        342       4%       2,000    21%           9,411

</TABLE>

                                      -7-










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