The Sarbanes Oxley Act
after the enactment of the Dodd Frank Act
Dodd Frank Act and Whistleblower
Protection: Sarbanes Oxley on Steroids.
Welcome to the September 2010 edition of the Sarbanes
Oxley Compliance Professionals Association (SOXCPA)
newsletter
Dear Member,
For months we read in blogs and
some newspapers that the Sarbanes
Oxley Act is dead, or that it
is not important any more, as there are
other laws and
regulations that matter. Well, they are
all wrong.
The Sarbanes Oxley Act has become much
more important. It is a fact.
The two most important reasons
for that are:
1. The new US financial regulatory
reform, the Dodd Frank Act, amends some
sections of the Sarbanes Oxley Act. SOX is part of the new
regulatory reform. They did not delete the SOX provisions, they
have made them more strict and clever.
For example,
whistleblowers now have a monetary incentive
to report matters to the SEC (they may be entitled to as much as
10 percent to 30 percent of the monetary sanctions imposed).
Management should clearly
explain to all employees the importance of prompt reporting
of violations.
Public companies should do much more for complaints
submitted to audit committees or employee hotlines to address
areas of potential concern.
The Dodd-Frank Act also
provides an employee with remedies
against the employer that has violated the whistleblower
provisions of the Dodd-Frank Act.
These remedies include
reinstatement with the same seniority status that the
individual would have had, two times the
amount of back pay otherwise owed to the individual, with
interest, and even compensation for
litigation costs, expert witness fees, and reasonable attorneys’
fees.
Does it look like the
end of Sarbanes Oxley? No, it is Sarbanes Oxley on steroids.
According to the Dodd Frank Act, no
employer may discharge, demote, suspend, threaten, harass,
directly or indirectly, or in any other manner discriminate
against, a whistleblower in the terms and conditions of
employment because of any lawful act done by the whistleblower:
- In providing information to the SEC in
accordance with the provisions of the Dodd-Frank Act;
- In initiating, testifying in, or assisting in
any investigation or judicial or administrative action of the
Commission based upon or related to such information; or
- In making disclosures that are required or
protected under the Sarbanes-Oxley Act, the Securities Exchange
Act and any other law, rule, or regulation subject to the
jurisdiction of the SEC.
2. The US Supreme Court
denied to put the Public Company Accounting
Oversight Board (PCAOB) out of business, and now the PCAOB,
with its role clear and well understood, has decided to announce
new and stricter risk assessment standards.
Sarbanes Oxley becomes more
strict and mature.
The PCAOB imposes more sanctions
on accounting firms and managers that
don’t adequately supervise their staff.
The suite of risk assessment standards,
Auditing Standards No. 8 through No. 15,
sets forth requirements that enhance the effectiveness of the
auditor's assessment of, and response to, the
risks of material misstatement in the
financial statements.
The risk assessment standards
address audit procedures performed throughout the audit,
from the initial planning stages through the
evaluation of the audit results.
"These new
standards are a significant step in promoting sophisticated risk
assessment in audits and minimizing the risk that the auditor will
fail to detect material misstatements," said PCAOB Acting Chairman
Daniel L. Goelzer.
"Identifying risks, and properly planning and
performing the audit to address those risks, is essential to
promoting investor confidence in audited financial statements."
Auditing Standards Related to
the Auditor's Assessment of, and Response to, Risk (AS No. 8
through 15)
Auditing Standard 8 (AS No.
8) - Audit Risk. This standard discusses the auditor's
consideration of audit risk in an audit of financial statements as
part of an integrated audit or an audit of financial statements
only. It describes the components of audit risk and the auditor's
responsibilities for reducing audit risk to an appropriately low
level in order to obtain reasonable assurance that the financial
statements are free of material misstatement.
Auditing Standard 9 (AS No.
9) - Audit Planning. This standard establishes requirements
regarding planning an audit, including assessing matters that are
important to the audit, and establishing an appropriate audit
strategy and audit plan.
Auditing Standard 10 (AS No.
10) - Supervision of the Audit Engagement. This standard
sets forth requirements for supervision of the audit engagement,
including, in particular, supervising the work of engagement team
members. It applies to the engagement partner and to other
engagement team members who assist the engagement partner with
supervision.
Auditing Standard 11 (AS No.
11) - Consideration of Materiality in Planning and
Performing an Audit. This standard describes the auditor's
responsibilities for consideration of materiality in planning and
performing an audit.
Auditing Standard 12 (AS No.
12) - Identifying and Assessing Risks of Material
Misstatement. This standard establishes requirements regarding the
process of identifying and assessing risks of material
misstatement of the financial statements. The risk assessment
process discussed in the standard includes information-gathering
procedures to identify risks and an analysis of the identified
risks.
Auditing Standard 13 (AS No. 13) - The Auditor's
Responses to the Risks of Material Misstatement. This standard
establishes requirements for responding to the risks of material
misstatement in financial statements through the general conduct
of the audit and performing audit procedures regarding significant
accounts and disclosures.
Auditing Standard 14 (AS No.
14) - Evaluating Audit Results. This standard establishes
requirements regarding the auditor's evaluation of audit results
and determination of whether the auditor has obtained sufficient
appropriate audit evidence. The evaluation process set forth in
this standard includes, among other things, evaluation of
misstatements identified during the audit; the overall
presentation of the financial statements, including disclosures;
and the potential for management bias in the financial statements.
Auditing Standard 15 (AS No.
15) - Audit Evidence. This standard explains what
constitutes audit evidence and establishes requirements for
designing and performing audit procedures to obtain sufficient
appropriate audit evidence to support the opinion expressed in the
auditor's report.
THESE STANDARDS MUST NOW BE
APPROVED BY THE SECURITIES AND EXCHANGE COMMISSION
The standards, if approved by the Securities and
Exchange Commission, will become effective
for audits of fiscal periods beginning on or after Dec. 15, 2010.
DODD FRANK ACT SECTION 922.
WHISTLEBLOWER PROTECTION
(a) IN GENERAL.—The
Securities Exchange Act of 1934 (15 U.S.C. 78a et seq.) is amended
by inserting after section 21E the following:
‘‘SEC. 21F.
SECURITIES WHISTLEBLOWER INCENTIVES AND PROTECTION.
‘‘(a)
DEFINITIONS.—In this section the following
definitions shall apply:
‘‘(1) COVERED JUDICIAL OR
ADMINISTRATIVE ACTION.—The term ‘covered judicial or
administrative action’ means any judicial or administrative action
brought by the Commission under the securities laws that
results in monetary sanctions exceeding
$1,000,000.
‘‘(2) FUND.—The term ‘Fund’ means the
Securities and Exchange Commission Investor Protection Fund.
‘‘(3) ORIGINAL INFORMATION.—The term
‘original information’ means information that—
‘‘(A) is derived from the
independent knowledge or analysis of a whistleblower;
‘‘(B)
is not known to the Commission from any other source, unless the
whistleblower is the original source of the information; and
‘‘(C) is not exclusively derived from an allegation made in a
judicial or administrative hearing, in a governmental report,
hearing, audit, or investigation, or from the news media, unless
the whistleblower is a source of the information.
‘‘(4) MONETARY SANCTIONS.—The term ‘monetary
sanctions’, when used with respect to any judicial or
administrative action, means—
‘‘(A) any monies, including
penalties, disgorgement, and interest, ordered to be paid; and
‘‘(B) any monies deposited into a disgorgement fund or other
fund pursuant to section 308(b) of the Sarbanes- Oxley Act of 2002
(15 U.S.C. 7246(b)), as a result of such action or any settlement
of such action.
‘‘(5) RELATED ACTION.—The term
‘related action’, when used with
respect to any judicial or administrative
action brought by the Commission under the securities laws,
means any judicial or administrative action brought by an entity
described in subclauses (I) through (IV) of subsection
(h)(2)(D)(i) that is based upon the original information provided
by a whistleblower pursuant to subsection (a) that led to the
successful enforcement of the Commission action.
‘‘(6)
WHISTLEBLOWER.—The term ‘whistleblower’
means any individual who provides, or 2 or more individuals acting
jointly who provide, information relating to a violation of the
securities laws to the Commission, in a manner established, by
rule or regulation, by the Commission.
‘‘(b)
AWARDS.—
‘‘(1) IN GENERAL.—In any covered judicial or
administrative action, or related action, the Commission, under
regulations prescribed by the Commission and subject to subsection
(c), shall pay an award or awards to 1 or
more whistleblowers who voluntarily provided original information
to the Commission that led to the successful enforcement of the
covered judicial or administrative action, or related action, in
an aggregate amount equal to—
‘‘(A)
not less than 10 percent, in total,
of what has been collected of the monetary sanctions imposed in
the action or related actions; and
‘‘(B)
not more than 30 percent, in total,
of what has been collected of the monetary sanctions imposed in
the action or related actions.
‘‘(2) PAYMENT OF AWARDS.—Any
amount paid under paragraph (1) shall be paid from the Fund.
‘‘(c) DETERMINATION OF AMOUNT OF AWARD; DENIAL OF AWARD.—
‘‘(1) DETERMINATION OF AMOUNT OF AWARD.—
‘‘(A)
DISCRETION.—The determination of the amount of an award made under
subsection (b) shall be in the discretion of
the Commission.
‘‘(B) CRITERIA.—In determining the
amount of an award made under subsection (b), the Commission—‘‘(i)
shall take into consideration—
‘‘(I) the
significance of the information
provided by the whistleblower to the success of the covered
judicial or administrative action;
‘‘(II) the
degree of assistance provided by the
whistleblower and any legal representative of the whistleblower in
a covered judicial or administrative action;
‘‘(III) the
programmatic interest of the
Commission in deterring violations of the securities laws by
making awards to whistleblowers who provide information that lead
to the successful enforcement of such laws; and
‘‘(IV)
such additional relevant factors as the Commission may establish
by rule or regulation; and
‘‘(ii) shall not take into
consideration the balance of the Fund.
‘‘(2) DENIAL OF
AWARD.—No award under subsection (b)
shall be made—
‘‘(A) to any whistleblower who is, or was at
the time the whistleblower acquired the original information
submitted to the Commission, a member, officer, or employee of—
‘‘(i) an appropriate regulatory agency;
‘‘(ii) the
Department of Justice;
‘‘(iii) a self-regulatory
organization;
‘‘(iv) the Public Company Accounting
Oversight Board; or
‘‘(v) a law enforcement organization;
‘‘(B) to any whistleblower who is
convicted of a criminal violation related to the judicial
or administrative action for which the whistleblower otherwise
could receive an award under this section;
‘‘(C) to any
whistleblower who gains the information through the performance of
an audit of financial statements required under the securities
laws and for whom such submission would be contrary to the
requirements of section 10A of the Securities Exchange Act of 1934
(15 U.S.C. 78j–1); or
‘‘(D) to any whistleblower who
fails to submit information to the
Commission in such form as the Commission may, by rule, require.
‘‘(d) REPRESENTATION.—
‘‘(1) PERMITTED
REPRESENTATION.—Any whistleblower who makes a claim for an award
under subsection (b) may be represented by counsel.
‘‘(2)
REQUIRED REPRESENTATION.—
‘‘(A) IN GENERAL.—Any
whistleblower who anonymously makes a claim for an award under
subsection (b) shall be represented by counsel if the
whistleblower anonymously submits the information upon which the
claim is based.
‘‘(B) DISCLOSURE OF IDENTITY.—Prior to the
payment of an award, a whistleblower shall
disclose the identity of the whistleblower and provide such other
information as the Commission may require, directly or through
counsel for the whistleblower.
‘‘(e) NO CONTRACT
NECESSARY.—No contract with the Commission is necessary for any
whistleblower to receive an award under subsection (b), unless
otherwise required by the Commission by rule or regulation.
‘‘(f) APPEALS.—Any determination made under this section,
including whether, to whom, or in what amount to make awards,
shall be in the discretion of the Commission. Any such
determination, except the determination of the amount of an award
if the award was made in accordance with subsection (b), may be
appealed to the appropriate court of appeals of the United States
not more than 30 days after the determination is issued by the
Commission.
The court shall review the determination made
by the Commission in accordance with section 706 of title 5,
United States Code.
‘‘(g) INVESTOR
PROTECTION FUND.—
‘‘(1) FUND ESTABLISHED.—There is
established in the Treasury of the United States a fund to be
known as the ‘Securities and Exchange Commission Investor
Protection Fund’.
‘‘(2) USE OF FUND.—The Fund shall be
available to the Commission, without further appropriation or
fiscal year limitation, for—
‘‘(A)
paying awards to whistleblowers as provided in subsection
(b); and
‘‘(B) funding the activities of the Inspector
General of the Commission under section 4(i).
‘‘(3)
DEPOSITS AND CREDITS.—
‘‘(A) IN GENERAL.—There shall be
deposited into or credited to the Fund an amount equal to—
‘‘(i) any monetary sanction collected by the Commission in any
judicial or administrative action brought by the Commission under
the securities laws that is not added to a disgorgement fund or
other fund under section 308 of the
Sarbanes-Oxley Act of 2002 (15 U.S.C. 7246) or otherwise
distributed to victims of a violation of the securities laws, or
the rules and regulations thereunder, underlying such action,
unless the balance of the Fund at the time the monetary sanction
is collected exceeds $300,000,000;
‘‘(ii) any monetary
sanction added to a disgorgement fund or other fund
under section 308 of the Sarbanes-Oxley Act
of 2002 (15 U.S.C. 7246) that is not distributed to the victims
for whom the Fund was established, unless the balance of the
disgorgement fund at the time the determination is made not to
distribute the monetary sanction to such victims exceeds
$200,000,000; and
‘‘(iii) all income from investments made
under paragraph (4).
‘‘(B) ADDITIONAL AMOUNTS.—If the
amounts deposited into or credited to the Fund under subparagraph
(A) are not sufficient to satisfy an award made under subsection
(b), there shall be deposited into or credited to the Fund an
amount equal to the unsatisfied portion of the award from any
monetary sanction collected by the Commission in the covered
judicial or administrative action on which the award is based.
‘‘(4) INVESTMENTS.—
‘‘(A) AMOUNTS IN FUND MAY BE
INVESTED.—The Commission may request the Secretary of the Treasury
to invest the portion of the Fund that is not, in the discretion
of the Commission, required to meet the current needs of the Fund.
‘‘(B) ELIGIBLE INVESTMENTS.—Investments shall be made by the
Secretary of the Treasury in obligations of the United States or
obligations that are guaranteed as to principal and interest by
the United States, with maturities suitable to the needs of the
Fund as determined by the Commission on the record.
‘‘(C)
INTEREST AND PROCEEDS CREDITED.—The interest on, and the proceeds
from the sale or redemption of, any obligations held in the Fund
shall be credited to the Fund.
‘‘(5) REPORTS TO
CONGRESS.—Not later than October 30 of each fiscal year beginning
after the date of enactment of this subsection, the Commission
shall submit to the Committee on Banking, Housing, and Urban
Affairs of the Senate, and the Committee on Financial Services of
the House of Representatives a report on—
‘‘(A)
the whistleblower award program,
established under this section, including—
‘‘(i) a
description of the number of awards granted; and
‘‘(ii) the
types of cases in which awards were granted during the preceding
fiscal year;
‘‘(B) the balance of the Fund at the beginning
of the preceding fiscal year;
‘‘(C) the amounts deposited
into or credited to the Fund during the preceding fiscal year;
‘‘(D) the amount of earnings on investments made under
paragraph (4) during the preceding fiscal year;
‘‘(E) the
amount paid from the Fund during the preceding fiscal year to
whistleblowers pursuant to subsection (b);
‘‘(F) the
balance of the Fund at the end of the preceding fiscal year; and
‘‘(G) a complete set of audited financial statements,
including—
‘‘(i) a balance sheet;
‘‘(ii) income
statement; and
‘‘(iii) cash flow analysis.
‘‘(h) PROTECTION
OF WHISTLEBLOWERS.—
‘‘(1) PROHIBITION AGAINST
RETALIATION.—
‘‘(A) IN GENERAL.—No
employer may discharge, demote, suspend, threaten, harass,
directly or indirectly, or in any other manner discriminate
against, a whistleblower in the terms and conditions of employment
because of any lawful act done by the whistleblower—
‘‘(i)
in providing information to the Commission in accordance with this
section;
‘‘(ii) in initiating, testifying in, or assisting
in any investigation or judicial or administrative action of the
Commission based upon or related to such information; or
‘‘(iii) in making disclosures that are required or protected under
the Sarbanes-Oxley Act of 2002 (15 U.S.C. 7201 et seq.), the
Securities Exchange Act of 1934 (15 U.S.C. 78a et seq.), including
section 10A(m) of such Act (15 U.S.C. 78f(m)), section 1513(e) of
title 18, United States Code, and any other law, rule, or
regulation subject to the jurisdiction of the Commission.
‘‘(B) ENFORCEMENT.—
‘‘(i) CAUSE OF ACTION.—An
individual who alleges discharge or other discrimination in
violation of subparagraph (A) may bring an action under this
subsection in the appropriate district court of the United States
for the relief provided in subparagraph (C).
‘‘(ii)
SUBPOENAS.—A subpoena requiring the attendance of a witness at a
trial or hearing conducted under this section may be served at any
place in the United States.
‘‘(iii) STATUTE OF
LIMITATIONS.—
‘‘(I) IN GENERAL.—An action under this
subsection may not be brought—
‘‘(aa) more than
6 years after the date on which the
violation of subparagraph (A) occurred; or
‘‘(bb)
more than 3 years after the date when facts
material to the right of action are known or reasonably should
have been known by the employee alleging a violation of
subparagraph (A).
‘‘(II) REQUIRED ACTION WITHIN 10
YEARS.—Notwithstanding subclause (I), an action under this
subsection may not in any circumstance be brought
more than 10 years after the date on
which the violation occurs.
‘‘(C) RELIEF.—Relief for an
individual prevailing in an action brought under subparagraph (B)
shall include—
‘‘(i) reinstatement with the same seniority
status that the individual would have had, but for the
discrimination;
‘‘(ii) 2 times the amount of back pay
otherwise owed to the individual, with interest; and
‘‘(iii) compensation for litigation costs, expert witness fees,
and reasonable attorneys’ fees.
‘‘(2) CONFIDENTIALITY.—
‘‘(A) IN GENERAL.—Except as provided in subparagraphs (B) and
(C), the Commission and any officer or employee of the Commission
shall not disclose any information,
including information provided by a whistleblower to the
Commission, which could reasonably be expected to reveal the
identity of a whistleblower, except in accordance with the
provisions of section 552a of title 5, United States Code, unless
and until required to be disclosed to a defendant or respondent in
connection with a public proceeding instituted by the Commission
or any entity described in subparagraph (C).
For purposes
of section 552 of title 5, United States Code, this paragraph
shall be considered a statute described in subsection (b)(3)(B) of
such section.
‘‘(B) EXEMPTED STATUTE.—For purposes of
section 552 of title 5, United States Code, this paragraph shall
be considered a statute described in subsection (b)(3)(B) of such
section 552.
‘‘(C) RULE OF CONSTRUCTION.—Nothing in this
section is intended to limit, or shall be construed to limit, the
ability of the Attorney General to present such evidence to a
grand jury or to share such evidence with potential witnesses or
defendants in the course of an ongoing criminal investigation.
‘‘(D) AVAILABILITY TO GOVERNMENT AGENCIES.—
‘‘(i) IN
GENERAL.—Without the loss of its status as confidential in the
hands of the Commission, all information referred to in
subparagraph (A) may, in the discretion of the Commission, when
determined by the Commission to be necessary to accomplish the
purposes of this Act and to protect investors, be made available
to—
‘‘(I) the Attorney General of the United States;
‘‘(II) an appropriate regulatory authority;
‘‘(III) a
self-regulatory organization;
‘‘(IV) a State attorney
general in connection with any criminal investigation;
‘‘(V) any appropriate State regulatory authority;
‘‘(VI)
the Public Company Accounting Oversight Board;
‘‘(VII) a
foreign securities authority; and
‘‘(VIII) a foreign law
enforcement authority.
‘‘(ii) CONFIDENTIALITY.—
‘‘(I) IN GENERAL.—Each of the entities described in subclauses (I)
through (VI) of clause (i) shall maintain such information as
confidential in accordance with the requirements established under
subparagraph (A).
‘‘(II) FOREIGN
AUTHORITIES.—Each of the entities described
in subclauses (VII) and (VIII) of clause (i) shall maintain such
information in accordance with such assurances of confidentiality
as the Commission determines appropriate.
‘‘(3)
RIGHTS RETAINED.—Nothing in this section shall be deemed to
diminish the rights, privileges, or remedies of any whistleblower
under any Federal or State law, or under any collective bargaining
agreement.
‘‘(i) PROVISION OF FALSE INFORMATION.—A
whistleblower shall not be entitled to an
award under this section if the whistleblower—
‘‘(1)
knowingly and willfully makes any false, fictitious, or fraudulent
statement or representation; or
‘‘(2) uses any false
writing or document knowing the writing or document contains any
false, fictitious, or fraudulent statement or entry.
‘‘(j) RULEMAKING AUTHORITY.—The Commission shall have the
authority to issue such rules and regulations as may be necessary
or appropriate to implement the provisions of this section
consistent with the purposes of this section.’’.
(b)
PROTECTION FOR EMPLOYEES OF NATIONALLY RECOGNIZED STATISTICAL
RATING ORGANIZATIONS.—Section 1514A(a) of title 18, United States
Code, is amended—
(1) by inserting ‘‘or nationally
recognized statistical rating organization (as defined in section
3(a) of the Securities Exchange Act of 1934 (15 U.S.C. 78c),’’
after ‘‘78o(d)),’’; and
(2) by inserting ‘‘or nationally
recognized statistical rating organization’’ after ‘‘such
company’’.
(c) SECTION 1514A OF TITLE 18, UNITED STATES
CODE.—
(1) STATUTE OF LIMITATIONS; JURY TRIAL.—Section
1514A(b)(2) of title 18, United States Code, is amended—
(A) in subparagraph (D)—
(i) by
striking ‘‘90’’ and inserting ‘‘180’’; and
(ii) by
striking the period at the end and inserting ‘‘, or after the date
on which the employee became aware of the violation.’’; and
(B) by adding at the end the following:
‘‘(E) JURY
TRIAL.—A party to an action brought under paragraph (1)(B) shall
be entitled to trial by jury.’’.
(2) PRIVATE SECURITIES
LITIGATION WITNESSES; NONENFORCEABILITY; INFORMATION.—Section
1514A of title 18, United States Code, is amended by adding at the
end the following:
‘‘(e) NONENFORCEABILITY OF CERTAIN
PROVISIONS WAIVING RIGHTS AND REMEDIES OR REQUIRING ARBITRATION OF
DISPUTES.—
‘‘(1) WAIVER OF RIGHTS AND REMEDIES.—The rights
and remedies provided for in this section may not be waived by any
agreement, policy form, or condition of employment, including by a
predispute arbitration agreement.
‘‘(2) PREDISPUTE
ARBITRATION AGREEMENTS.—No predispute arbitration agreement shall
be valid or enforceable, if the agreement requires arbitration of
a dispute arising under this section.’’.
(d)
STUDY OF WHISTLEBLOWER PROTECTION PROGRAM.—
(1)
STUDY.—The Inspector General of the Commission shall conduct a
study of the whistleblower protections established under the
amendments made by this section, including—
(A) whether the
final rules and regulation issued under the amendments made by
this section have made the whistleblower protection program
(referred to in this subsection as the ‘‘program’’) clearly
defined and user-friendly;
(B) whether the program is
promoted on the website of the Commission and has been widely
publicized;
(C) whether the Commission is prompt in—
(i) responding to—
(I) information provided by
whistleblowers; and
(II) applications for awards filed by
whistleblowers;
(ii) updating whistleblowers about the
status of their applications; and
(iii) otherwise
communicating with the interested parties;
(D) whether the
minimum and maximum reward levels are adequate to entice
whistleblowers to come forward with information and whether the
reward levels are so high as to encourage illegitimate
whistleblower claims;
(E) whether the appeals process has
been unduly burdensome for the Commission;
(F) whether the
funding mechanism for the Investor Protection Fund is adequate;
(G) whether, in the interest of protecting investors and
identifying and preventing fraud, it would be useful for Congress
to consider empowering whistleblowers or other individuals, who
have already attempted to pursue the case through the Commission,
to have a private right of action to bring suit based on the facts
of the same case, on behalf of the Government and themselves,
against persons who have committee securities fraud;
(H)(i)
whether the exemption under section 552(b)(3) of title 5 (known as
the Freedom of Information Act) established in section
21F(h)(2)(A) of the Securities Exchange Act of 1934, as added by
this Act, aids whistleblowers in disclosing information to the
Commission;
(ii) what impact the exemption described in
clause (i) has had on the ability of the public to access
information about the regulation and enforcement by the Commission
of securities; and
(iii) any recommendations on whether the
exemption described in clause (i) should remain in effect; and
(I) such other matters as the Inspector General deems
appropriate.
(2) REPORT.—Not later than 30 months after the
date of enactment of this Act, the Inspector General shall—
(A) submit a report on the findings of the study required
under paragraph (1) to the Committee on Banking, Housing, and
Urban Affairs of the Senate and the Committee on Financial
Services of the House; and
(B) make the report described in
subparagraph (A) available to the public through publication of
the report on the website of the Commission.
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Contents
1.
Risk
Professionals
2.
Compliance
Professionals
3.
Sarbanes
Oxley
Professionals
4.
Basel
ii
Professionals
5.
Solvency
ii
Professionals
6.
Hedge
Funds
Professionals
7. Members of the
Board
of Directors
Dear
member,
Thank you for reading our
monthly newsletter.
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Best
Regards,
George Lekatis
President of the Sarbanes Oxley
Compliance Professionals Association
General Manager, Compliance
LLC
1200 G Street NW Suite 800, Washington DC 20005, USA
Tel: (202) 449-9750
Email:
lekatis@sarbanes-oxley-association.com
Web:
www.sarbanes-oxley-association.com
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