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SEC Proposes Disclosure Rules on Internal Controls, Codes of Ethics and Audit Committee Financial Experts


by Sutherland Asbill & Brennan LLP View Firm Credentials
Washington Office

August 12, 2004

Previously published on January 7, 2003

On October 22, 2002, the Securities and Exchange Commission (the "SEC") proposed three new sets of rules to require SEC reporting companies to make disclosures regarding management's assessment of internal controls, codes of ethics and the identity of "financial experts" on the audit committee. The proposed rules would give effect to Sections 404, 406 and 407 of the Sarbanes-Oxley Act of 2002 ("Sarbanes-Oxley"). As with other SEC rule proposals under the Sarbanes-Oxley, the proposed rules would go beyond the requirements prescribed by Congress.


 

The views expressed in this article are solely the views of the author and not Martindale-Hubbell. This article is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance.




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