Assessing the Increased Regulatory Focus on Public Company Internal Control and Reporting

Orrick, Herrington & Sutcliffe LLP
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Over the past few months, the Securities and Exchange Commission (‘‘SEC’’) has publicly stated its increasing focus on public company internal controls and related reporting obligations. In February of this year at the Practicing Law Institute’s SEC Speaks conference, Ryan Evans from the SEC’s Office of the Chief Accountant identified internal controls as an ‘‘important issue’’ and an ‘‘ongoing area of focus.’’

Then, in July, Kara Brockmeyer, who heads the SEC Enforcement Division’s FCPA unit, called the Commission’s renewed emphasis on internal control reporting ‘‘a wake-up call,’’ and noted that companies must do their best to ‘‘ensure that the right internal controls are in place and operating.’’ Tellingly, charges brought by the SEC against organizations for violating internal control reporting rules appear to be on the rise. Likewise, the Financial Industry Regulatory Authority (‘‘FINRA’’) and the U.S. Treasury Department have shown an increased interest in this area as well.

Originally published in Bloomberg BNA's Securities Regulation & Law Report, 46 SRLR 1950, 10/06/2014.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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