Update on Internal Controls

Last night I was speaking with a couple of attorneys in the SEC's Division of Corporation Finance who informed me that they are, not surprising, closely monitoring the early internal controls disclosures. They also said that the Division is frequently requiring companies to amend their Form 10-Ks for internal controls disclosures. In this regard, they pointed me to David Lynn's (Corp Fin's chief counsel) "top five" list of SEC comments on internal controls disclosures which he articulated in the "Demystifying Internal Controls Disclosures" panel discussion on February 2, 2005. The transcript from the program is available on thecorporatecounsel.net. So, as you're preparing Form 10-Ks, you should probably look this over.

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