Article by Gordon H. Hayes, Jr.,Jocelyn M. Arel, Miguel J. Vega, Anne G. Plimpton, Jeffrey M. Held, Brian E. Pastuszenski, Jordan D. Hershman
Recently the Securities and Exchange Commission ("SEC") issued final rules mandated by Section 404 of the Sarbanes-Oxley Act of 2002 (the "Act") requiring companies subject to the reporting requirements of the Securities Exchange Act of 1934 (the "Exchange Act") to:
- include in their annual reports a report of management on the company’s "internal control over financial reporting" (a new term defined by the SEC in the final rules); and
- provide in their quarterly reports management’s evaluation of any change in a company’s internal control over financial reporting that occurred during the quarter and that has materially affected, or is reasonably likely to materially affect, the company’s internal control over financial reporting.
