This profile is the latest in a series of weekly conversations with executives at U.S. public companies who are currently involved in establishing and developing compliance programs. An index of previous conversations is available here. Tell us about your role as chief risk officer. What’s in your job description? Risk management is a function at […]
Internal Controls
Posted inInternal Controls
SEC Committee To Study Impact Of SOX On Small Cos.
The Securities and Exchange Commission announced Dec. 16 the creation of an advisory panel to examine the impact of The Sarbanes-Oxley Act and other securities laws on smaller public companies. The move is part of an initiative to alleviate the regulatory burden on small issuers—one that has been gaining momentum in recent months at the […]
Posted inInternal Controls
Q&A With Nationwide’s General Counsel & Secretary
This profile is the latest in a series of weekly conversations with executives at U.S. public companies who are currently involved in establishing and developing compliance programs. An index of previous conversations is available here. How much of your job is specifically compliance, versus other legal duties you have? First, technically my position is responsible […]
Posted inAccounting & Auditing
SEC Accountant: Do Not Disguise 404 Weaknesses
At a national accounting conference last week, Securities and Exchange Commission Deputy Chief Accountant Andrew D. Bailey Jr. reminded companies that they must provide detailed descriptions of material weaknesses, and should not make any attempt to veil or hide them. “I want to remind registrants that they need to provide complete, robust, and transparent disclosures,” […]
Posted inInternal Controls
Q&A With Microsoft’s Dir. Technical Accounting, Reporting
This profile is the latest in a series of weekly conversations with executives at U.S. public companies who are currently involved in establishing and developing compliance programs. An index of previous conversations is available here. You are ‘director of technical accounting and reporting’ at Microsoft. Walk us through what that means. I’m responsible for answering […]
Posted inInternal Controls
Will SEC Delay Of SOX 404 Make A Difference?
As was widely expected, the Securities and Exchange Commission has given companies whose market float is less than $700 million an additional 45 days to meet many of the requirements of Section 404 of the Sarbanes-Oxley Act. “The Commission has become increasingly concerned that many smaller accelerated filers may not be in a position to […]
Posted inAccounting & Auditing
Moody’s Questions Ability To Audit Around Deficiencies
In October 2004, Moody’s Investors Service opened a Pandora’s Box with the issuance of a special comment paper titled “Section 404 Reports on Internal Control: Impact on Ratings Will Depend on Nature of Material Weaknesses Reported.” With the start of the first Sarbanes-Oxley reporting season just around the corner and more than 500 public confessions […]
Posted inInternal Controls
Nov. 2004 Internal Control Disclosures: Remediation
Below is a sample list of companies making internal control remediation disclosures during the month of November 2004. Please be aware that the excerpts below are just that: excerpts. The complete SEC filings are available for those who would like to review the complete disclosures in greater detail. For related information on the list below, […]
Posted inInternal Controls
Neither Significant Nor Material: Deficiencies Described
During the month of November, several companies disclosed “deficiencies” in controls—sometimes related to one specific control—that were neither significant deficiencies nor material weaknesses. Below are examples of those disclosures. Please be aware that the excerpts below are just that: excerpts. The complete SEC filings are available for those who would like to review the complete […]
Posted inInternal Controls
Internal Control Disclosures Jump In November
THE FILINGS The Disclosures Please note that due to the volume of disclosures in November, we were forced to break them into two files, below: Part I: November 1 To November 14 Part II: November 15 To November 30 According to a review of regulatory filings, the number of companies disclosing material weaknesses or significant […]
