Compliance into the Weeds - SOX Compliance, PCAOB Inspections and Audits
Compliance into the Weeds-Episode 57-SOX Reform or Not?
Compliance into the Weeds-Episode 51, the PCAOB and Compliance
Compliance into the Weeds-Espiode 47
Everything Compliance-Episode 12
Day 5 of One Month to Better Investigations and Reporting-the Board’s Investigation Protocol
Compliance into the Weeds-Episode 30-SOX 404(b)
FCPA Compliance and Ethics Report-Episode 145-SEC Enforcement of the FCPA, Part II
As you probably recall, SOX 404 requires public reporting companies to disclose the effectiveness of their internal control over financial reporting. SOX 404(a) public companies to provide an assessment of ICFR by management;...more
On March 12, the SEC voted (by a vote of three to one, with Commissioner Allison Lee dissenting) to approve amendments to the "accelerated filer" and "large accelerated filer" definitions to provide a narrow carve-out for...more
On March 12, the SEC voted (by a vote of three to one, with Commissioner Allison Lee dissenting) to approve amendments to the accelerated filer and large accelerated filer definitions to provide a narrow carve-out for...more
In an effort to reduce compliance costs for public companies, the Securities and Exchange Commission (SEC) proposed amendments on May 9, 2019, that, in part, relax the requirement for certain “smaller reporting companies”...more
New Proposed Rules Aim to Eliminate Auditor's Attestation Requirement on Internal Controls under SOX 404(b) for Smaller Reporting Companies with less than $100 million in Revenues - On May 9, 2019, the SEC proposed...more
[This post has been updated primarily to reflect the contents of the proposing release as well as the statement of Commissioner Hester Peirce.] Those of you who expected the SEC to go big and propose raising the current...more
This is National Small Business Week and, to kick things off, the SEC today held a brief roundtable featuring representatives of small business and investment funds in a discussion of the challenges of raising funding outside...more
You probably recall that, under SOX 404(b), all public reporting companies, other than non-accelerated filers, are required to obtain an auditor attestation regarding the effectiveness of their internal control over financial...more
In this speech before the 36|86 Entrepreneurship Festival in Nashville, Tennessee, SEC Chair Jay Clayton discussed, among other topics, the coming agenda for public companies designed to “encourage capital formation for...more
The SEC has voted to amend the definition of the term “smaller reporting company” as used in its rules and regulations. Under the amended definition, which takes effect on September 10, 2018, SRCs are companies that...more
This Thursday, the Securities and Exchange Commission will hold an open meeting to consider, among other things, proposed amendments to the definition of “smaller reporting company” (SRC), as well as proposed amendments to...more
The Justice Department and the Securities and Exchange Commission have dedicated more time and energy to understanding a company’s internal controls and enforcing basic requirements that companies maintain effective internal...more
Without holding an open meeting, the SEC has proposed changes to the definition of a “smaller reporting company” that would raise the financial cap from “less than $75 million” in public float to “less than $250 million,”...more
The SEC has proposed amendments that would increase the financial thresholds in the “smaller reporting company” definition. The proposal to update the definition would expand the number of companies that qualify as smaller...more