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
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
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
Recently, in connection with the Securities and Exchange Commission’s consideration of proposed amendments to the definition of “smaller reporting company,” the Commission had an opportunity to consider including in the...more