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The Latest from the SEC: An Analysis

BY Robert Barker
November 01, 2003

On October 15, 2003, David Lynn, Chief Counsel of the Division of Corporation Finance for the U.S. Securities and Exchange Commission (SEC), discussed recent rulings in a conference call sponsored by Glasser Legal Works. The call was moderated by Brian Lane, Gibson, Dunn & Crutcher LLP; David Martin, Covington & Burling; and Meredith Cross, Wilmer, Cutler & Pickering. Each of the moderators had formerly been in a significant position with the SEC's Division of Corporation Finance. Mr. Lynn disclaimed any relationship between his views and those of the SEC or any member of the SEC staff.

Introduction

As a result of the Sarbanes-Oxley Act of 2002 (the Act) securities laws and regulations have been changing rapidly, making compliance take longer and cost more. The conference call was a general overview of some of the changes affecting disclosure compliance – including those under Section 404 of the Act — and other new reporting issues at the SEC. A full transcript of the call is available at http://www.realcorporatelawyer.com/programs/cle10-15-03tran.html. What follows is a summary of some parts of that discussion, mixed with some references to the text of the proposed rules.

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