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ICFR COSO

Jones Day

Are You Ready for "New GAAP" Revenue Recognition? SEC Disclosure Considerations

Jones Day on

"NEW GAAP" REVENUE RECOGNITION - In 2014, the U.S. Financial Accounting Standards Board ("FASB") issued new revenue standards under Accounting Standards Codification ("ASC") 606, Revenue from Contracts with Customers...more

Cooley LLP

Whether 1992 Or 2013 Version Of COSO Framework — Disclose In Management’s And Auditor’s Internal Control Reports

Cooley LLP on

Last week, I posted a piece regarding the “squishy” deadline (to borrow the term of art coined by the COSO Chair) for implementation of the new 2013 COSO internal control framework. As you may recall, the original 1992 COSO...more

Cooley LLP

Is It OK To Delay Implementation Of The New COSO Framework?

Cooley LLP on

With the original 1992 COSO internal control framework deemed by COSO to be “superseded” as of December 15, 2014, companies are fast approaching the deadline for adoption of the updated 2013 COSO framework, But is it really a...more

Morgan Lewis

Recent SEC Enforcement Action on Internal Control Despite No Other Alleged Violations

Morgan Lewis on

A recent SEC-settled administrative action is another reminder of the SEC’s focus on internal control over financial reporting (ICFR). Although prior SEC ICFR charges have been accompanied with allegations of false financial...more

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