News & Analysis as of

ICFR Publicly-Traded Companies Sarbanes-Oxley

Cooley LLP

What are the latest trends in SOX 404 reporting?

Cooley LLP on

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

Stinson - Corporate & Securities Law Blog

Preliminary Planning for the 2021 Proxy Season

Our preliminary list of important planning considerations for the 2021 proxy season is set forth below. Directors’ and Officers’ Questionnaires; Committee Charters - We have identified only a few possible changes to...more

Stinson LLP

SEC Amends Filer Definitions; Provides SOX 404(b) Relief for Certain SRCs

Stinson LLP on

The SEC has adopted amendments to the accelerated and large accelerated filer definitions to exclude smaller reporting companies with annual revenues of less than $100 million. As a result of the amendments, these smaller...more

Orrick, Herrington & Sutcliffe LLP

SEC Expands Smaller Reporting Company Relief

Internal Control Over Financial Reporting and Filing Deadlines - On March 12, 2020, the Securities and Exchange Commission adopted amendments to the definitions of “accelerated filer” and “large accelerated filer.”...more

Stinson - Corporate & Securities Law Blog

Expanded Analysis: SEC Amends Accelerated Filer and Large Accelerated Filer Definitions, Provides SOX 404(b) Relief

On March 12, 2020, the Securities and Exchange Commission adopted long-awaited amendments to the accelerated filer and large accelerated filer definitions with the stated goal of “reduc[ing] unnecessary burdens for certain...more

Mayer Brown Free Writings + Perspectives

New Definitions of Accelerated and Large Accelerated Filer

The Securities and Exchange Commission adopted amendments to the accelerated filer and large accelerated filer definitions, which impact the Sarbanes-Oxley Act of 2002....more

Akin Gump Strauss Hauer & Feld LLP

SEC Proposal Would Relax ICFR Auditor Attestation Requirement for Certain Smaller Reporting Companies

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

White & Case LLP

SEC Continues on the Path of Simplifying Public Company Requirements

White & Case LLP on

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

WilmerHale

CAQ Expands CECL and ICFR Resources

WilmerHale on

Last week, the Center for Audit Quality released two new resources—an updated Guide to Internal Control over Financial Reporting (ICFR Guide) and a new Tool for Audit Committees: Preparing for the New Credit Losses Standard...more

Stinson - Corporate & Securities Law Blog

SEC Proposes to Modify Filer Definitions and Obligations under SOX 404(b)

Current SEC reporting requirements establish three different filer statuses that categorizes issuers subject to Exchange Act reporting requirements as non-accelerated, accelerated, and large accelerated filers....more

Skadden, Arps, Slate, Meagher & Flom LLP

Capital Markets Alert – Public Market Advocacy Groups Release Guidance

On April 27, 2018, the Securities Industry and Financial Markets Association (SIFMA), the U.S. Chamber of Commerce and Nasdaq, along with certain technology and biotechnology groups, released a policy paper titled “Expanding...more

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