Now that the first deadline related to Section 404 of The Sarbanes-Oxley Act has come and gone, companies are focusing on quarterly disclosures of changes in internal controls over financial reporting mandated by Item 308(c) of Regulation S-K.
A provision somewhat forgotten amid the chaos of 404, Item 308(c) requires companies to “[d]isclose any change in the registrant’s internal control over financial reporting identified in connection with the evaluation [of internal controls] that occurred during the registrant’s last fiscal quarter … that has materially affected, or is reasonably likely to materially affect, the registrant’s internal control over financial reporting.”
