Tag: SEC
SEC sends a message — to executives and their companies
by Cydney Posner In October 2013, SEC Chair Mary Jo White gave a speech at the Securities Enforcement Forum in which she declared an “enforcement mission” of the SEC to be implementation of the “broken windows” theory of crime deterrence made famous decades ago in NYC: “The [‘broken windows’] theory is […]
Whether 1992 or 2013 version of COSO framework — disclose in management’s and auditor’s internal control reports
by Cydney Posner Last week, I posted a piece regarding the “squishy” deadline (to borrow the term of art coined by the COSO Chair) for implementation of the new 2013 COSO internal control framework. As you may recall, the original 1992 COSO internal control framework is deemed by COSO to […]
Publish the list — hold the irony
by Cydney Posner As required by section 1502(d)(3)(C) of Dodd-Frank, the U.S. Commerce Department has compiled and posted (albeit more than a year late) a list of ”all known conflict mineral processing facilities worldwide.” Without the slightest hint of irony, Commerce notes that the list does “not indicate whether a […]
Academic study shows increases in insider sales prior to public release of certain SEC comment letters
by Cydney Posner Articles in Compliance Week and Forbes report on a recent academic study showing unusually high levels of stock sales by insiders in the period prior to public release of SEC comment letters that addressed revenue recognition issues, a topic that can often spell trouble at many companies. The level of […]