Potential Effects Of SEC Financial Reporting Proposal

By Stephen Quinlivan, Bryan Pitko and Jaclyn Schroeder (May 21, 2019, 4:10 PM EDT) -- Current U.S. Securities and Exchange Commission reporting requirements establish three different filer statuses, categorizing issuers subject to Exchange Act reporting requirements as non-accelerated, accelerated and large accelerated filers. Section 404(a) of the Sarbanes-Oxley Act, or SOX, requires almost all SEC reporting issuers, regardless of filer status, to establish and maintain internal control over financial reporting, or ICFR, and have their management assess the effectiveness of their ICFR.

A significant requirement that applies to accelerated and large accelerated filers, but not to non-accelerated filers, is the need for an ICFR auditor attestation. This involves having the independent accounting firm that prepares or...

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