Financial Reporting: 2016 Mid-Year Update

We are pleased to offer our clients and friends this mid-year update on financial reporting and issuer disclosure enforcement activity in 2016. The level of attention regulators are paying to financial reporting and disclosure remains quite high. That has meant not just a large number of enforcement actions but also a very public and concerted effort by the policy divisions within the SEC to influence corporate behavior in specific reporting areas.

The cases include garden-variety accounting fraud matters, disclosure cases, and internal controls violations. And individuals were named in most of these cases. The non-enforcement effort to shape behavior includes an all-hands-on-deck focus on non-GAAP (generally accepted accounting principles) measures, proposals to significantly alter Regulation S-K disclosures, and new PCAOB proposals and requirements for audit reports and the reporting on audit partners. Against this backdrop, the whistleblower program continues to