As we reach year-end 2004, it is appropriate to take stock (pardon the pun) of the corporate governance reform initiatives reflected in the Sarbanes Oxley Act of 2002 and its regulatory progeny.
More than two years after it was enacted, directors and executive officers of
publicly traded companies, and their advisors, are still responding to the
dramatic changes to the rules of corporate governance wrought by the
Sarbanes-Oxley Act of 2002 and the new Securities and Exchange Commission (SEC)
and stock exchange rules that followed. Seeking to shore...
One of the most difficult aspects of providing advice regarding Sarbanes-Oxley developments is remembering the phase-in periods for regulations that do not become immediately effective. As we approach the 2004 New Year, we write this article to remind practitioners of the changes taking effect in applicable disclosure rules.We begin with the good and the...