Thoughts On Internal Control Over Financial Reporting

As year-end approaches, many companies will be focused on preparing their annual reports.  Recent comments from various representatives of the Securities and Exchange Commission accounting staff emphasized the importance of maintaining strong and effective internal control over financial reporting ("ICFR").  At the American Institute of Certified Public Accountants Conference in Washington, D.C., SEC Chief Accountant Wesley R. Bricker and SEC Deputy Chief Accountant Marc Panucci both addressed ICFR.  Mr. Panucci stated that ICFR remains a significant area of focus for the SEC, including through the coordinated efforts of the SEC's Office of the Chief Accountant, the Division of Corporation Finance and the Division of Enforcement.  Mr. Panucci also noted that earlier this year, the SEC brought and settled a case against an issuer, members of its management, the audit partner and the issuer's third-party consultant involving the inadequate evaluation of an