January 30, 2004

New NYSE FAQs on Corporate Governance Posted!

As predicted by Broc, the NYSE yesterday posted on its website a set of FAQs on the new corporate governance rules in Section 303A of its listed company manual. There are 51 FAQs (up from the 47 predicted).

Companies Choosy About Their Auditors

According to ratings and analysis service Auditor-Trak, in 2003 each of the Big 4 accounting firms lost more public company audit clients than it acquired. Smaller national firms -- Grant Thornton, BDO Seidman and McGladrey & Pullen -- collectively acquired 21% of the clients lost by their Big Four competitors. Perhaps more interestingly, 34% of the public companies that formerly used a Big Four auditor and made a change opted for a regional or local firm as a replacement. Any firm auditing public companies must register with the PCAOB of course; it would appear that perhaps the early claims that this requirement would lead to a further constriction of the universe of public auditors might have been off the mark.

Complying with SOX 404

There has been continued murmurings that the SEC will postpone the effectiveness of its new rules requiring management to report on its assessment of the company’s internal controls (see Broc’s Blog from January 14) but a recent survey conducted by PricewaterhouseCoopers found that a majority of companies are working earnestly to be prepared to comply on time. PwC reports that fully 95% of executives say that they expect their companies to meet the deadline for compliance with Section 404 but almost half admit that it will be hard to do.

It’s a Small World

And the themes underpinning Sarbanes-Oxley continue to resonate throughout. On Wednesday, a number of policy makers, business leaders, investors and other experts operating under the umbrella of the Latin American Roundtable on Corporate Governance issued its white paper on that topic. The Organisation for Economic Cooperating and Development, one of the groups working on the white paper, summarizes some of the key action items as “taking voting rights seriously; treating shareholders fairly during changes in corporate control and de-listings; insuring the integrity of financial reporting and improving disclosure; developing effective boards of directors; improving the quality, effectiveness and predictability of the legal and regulatory framework; and continuing regional co-operation.”

Meanwhile, the Financial Services Authority of Britain continues to keep up the pressure in Europe, having just levied its largest fine ever against a financial advisory firm for compliance failures. The fine, which was equal to almost one and a half million dollars, was assessed against a unit of Deloitte & Touche for failures related to its investment trust sales and other pension work.

Posted by Kimberley Drexler

January 29, 2004

Now Here is a Nice Proxy Statement or Two

Check out the new proxy statement from Hewlett-Packard - which includes lots of information in response to the new SRO requirements. Walt Disney also recently filed its proxy statement (see yesterday's NY Times for an article about the SEC's investigation into Disney's lack of disclosure regarding related parties).

Martha Stewart Teaches Us a Lesson

The case against Martha Stewart is being brought under atypical securities law theories. Even at this early stage, the case can teach us some lesson. Read more from an interview with Bruce Brumberg on What Compliance Lessons You Can Learn From the Martha Stewart Case.

NYSE Expected to Soon Issue More FAQs

I got some feedback on my blog yesterday about "direct" communications with directors and amended my entry slightly to indicate that officers, such as the corporate secretary, may indeed be appropriate "middlemen" between non-management directors and shareholders. Fortunately, this guessing game should soon be over as I hear rumors of 47 FAQs to be released shortly by the NYSE staff on their new governance listing standards.

As reflected in my amended entry, I have seen no written guidance saying the administration has to be by a "non-management employee." In the SEC's adopting release regarding shareholder/director communcations, the SEC noted that the company does not have to disclose who is handling the communications nor is a company required to describe the process. Nor does the SEC specify that the person has to be a non-management employee - instead, the SEC stated that "a company's process for collecting and organizing security holder communications, as well as similar or related activities, need not be disclosed, provided that the company's process is approved by a majority of the independent directors." See the SEC's commentary on this at footnote 118 and at footnote 59. [If you are looking for samples of what companies are disclosing about how investors can contact shareholders, we have them in our "Shareholder Access Portal"]

January 28, 2004

Untangling SFAS 150

One of the more complicated rulemakings in some time is SFAS 150 - even the effective date(s) are complicated. Under SFAS 150, an issuer must, in most circumstances, classify as a liability - not as equity - a financial instrument that falls into any of three specified categories. In certain circumstances, that could result in a freestanding financial instrument indexed to the issuer's stock price.

Check out my recent interview with Richard Flowers, Jeff Ellis and Brad Kulman on the Impact of SFAS 150 to help untangle this recent accounting pronouncement.

NYSE's Requirement to Communicate "Directly" with Independent Directors

I have been getting asked a lot of questions about the NYSE's new requirement under Section 303A.03 that listed companies disclose a method for interested parties to "communicate directly with the presiding director or with non-management directors as a group." The most common question is what is meant by "directly."

From what I hear, the NYSE staff has been saying that a company doesn't need to provide direct access to directors nor is it required to hire a third party. Rather, a non-management employee can undertake this task (it is unclear as to what constitutes a "non-management employee" - my guess is that it can be the corporate secretary or someone in the legal department - perhaps even if they are considered an officer).

However, this employee must be instructed from the non-management directors regarding what, when and how the directors want to review any communications. In other words, this employee can't make any independent decisions (and of course, can't share any communications with management unless instructed to do so by these directors). Obviously, it is wise to obtain these instructions in writing as part of a sound compliance program (and as CYA for the employee tapped as the "go-between").

January 27, 2004

SEC Filing Fee Changes Finalized

After months of waiting, President Bush has signed the bill that includes the SEC filing fee changes - the new rate of $126.70 per million is effective for any filing made after 10:00 pm today - not January 28 as originally announced.

New Binding Bylaw Amendment Proposal to Create Shareholder Committee

The IRRC reports that AFSCME has submitted a binding bylaw proposal to Eastman Kodak that would create a "majority vote shareholder committee." The proposal seeks - following a majority vote that is not adopted by the company - the creation of a committee comprised of the proposal’s proponents and other interested shareholders to communicate with the board regarding the proposal that got the majority vote.

Kodak has received majority votes on non-binding shareholder proposals for a number of consecutive years. Note that a similar type of proposal submitted to Kroger last year received the support of 47% of the votes cast.

First Credit Rating Agency Announces the Use of CGQ

Last week, Fitch announced that it will pay ISS to use its CGQ database as part of its creditworthiness assessment.

This is significant for ISS as all of the various rating agencies have been wooing the rating agencies for their business for quite some time. As to how much CGQ will mean to Fitch's overall analysis, that remains to be seen.

Clean-Up on Sample D&O Questionnaire for NYSE Companies

We have done a little clean-up on the first sample D&O questionnaire for NYSE companies that is posted in our "Sample D&O Questionnaires." This word file has been revised to remove the question as to whether the person has participated in the preparation of the financial statements of the Company or any current subsidiary of the Company at any time during the past three (3) years (this applies to Nasdaq companies; not NYSE companies). In addition, there is a new question dealing specifically with relationships with charitable organizations.

January 25, 2004

Nasdaq Posts a Form of Corporate Governance Certification

Following up on the superb analysis on SRO certifications in the Jan-Feb issue of The Corporate Counsel - which had just left the printers and should be in your mailbox very soon - Nasdaq just posted a Form of Corporate Governance Certification to be used by listed companies to certify as to a number of matters as required by its new governance rules.

This certification is not required by any single Nasdaq rule; rather it serves to address a number of rule requirements, including the nature of the audit committee's composition; adoption of the requisite audit committee and nominating committee charters; that the board has executive sessions for its independent directors; and that the company has - or will have - adopted a code of conduct.
Nasdaq-listed companies must file this certification with Nasdaq’s Listed Qualification Department immediately following the company's next annual meeting after January 15, 2004, but no later than October 31, 2004 (foreign private issuers and small business companies have until July 31, 2005).

Alan Dye's Section 16 Transcript is Up!

Members of the NASPP or Section16.net can access the transcript from the annual webcast that Alan Dye held recently regarding the latest developments on Section 16. Always an incredibly popular program - now in its 12th year - the transcript covers 36 distinct topics!

January 23, 2004

50 Nuggets Transcript is Up!

For TheCorporateCounsel.net members, we have posted the transcript from our "50 Nuggets in 50 Minutes II" webcast featuring Alan Dye and myself.

Categorical Standards for Director Independence

As discussed during the webcast, the topic for which I currently am getting the most questions involve categorical standards for director independence. Under new Section 303A.02(a) from the NYSE Listed Company Manual, listed companies must disclose that each independent director has no material relationships with the company - and the basis for any determination regarding any immaterial relationships. Alternatively, companies can disclose that they have adopted categorical standards to assist them in making independence determinations and make a general disclosure that the independent directors satisfy them.

Even though the new NYSE standards are not technically applicable yet, some of the NYSE companies that recently have filed proxy statements have addressed director independence determinations in their disclosure - and I have compiled these samples in "Determination of Director Independence" in our "Disclosure Analysis & Samples" Practice Area.

These samples also include Nasdaq companies, who must simply identify which directors are independent under Rule 4200 (this rule technically is applicable to these proxy statements - as the NYSE and Nasdaq have split as to effective dates of its new standards).

January 22, 2004

Investment Company Governance

The SEC has been quite active rulemaking in the area of investment company governance - last week, it proposed new governance standards for investment companies and codes of ethics for investment advisers.

Probably the most controversial aspect of the proposals is to require that at least 75% of a fund's board be independent directors - and that the fund board chairman be an independent director.

Loads of Law Firm Guidance for the Proxy Season

During the past week, the number of law firm memos on what to disclose during this proxy season in our "Proxy Season Resource Center" has more than doubled. And more are being added daily!

January 21, 2004

Doing Good Governance Doesn't Have to Be Hard to Do

Sung to the tune of Neil Sedaka's "Breaking Up is Hard to Do"...check out my interview with Jim Brashear on Holding Executive Sessions and Drafting Charters. Jim is Corporate Secretary of Sabre Holdings Corporation.

As Promised, SEC Going After Audit Firms

Last month at the AICPA conference, SEC Enforcement Director Stephen Cutler said that the SEC was preparing nearly a dozen cases against audit firms. Yesterday, the SEC started making good on that speech and charged two accounting firms of aiding and abetting a client's fraud and ignoring their professional duties.

In an administrative order, the SEC claimed that Grant Thornton "rented' out its name and prestige" to a small firm, Doeren Mayhew & Co. and that both firms failed to make a client - MCA Financial Corp. - disclose improper deals with related parties.

January 20, 2004

Reminder about Tomorrow's "50 Nuggets" Webcast

Don't forget tomorrow's webcast - "50 Nuggets in 50 Minutes II" - for members of TheCorporateCounsel.net. Broc and Alan Dye will be covering a host of proxy season & governance matters, among other timely items.

An audio archive and transcript will be posted following the live webcast. The non-member fee for this special webcast is $295. If you're not a member and you wish to access this important program and hear from Broc and Alan, you may simply take advantage of a no-risk trial to TheCorporateCounsel.net.

If you have not renewed your TheCorporateCounsel.net membership for 2004, you will not be able to access the webcast. You can renew online - or by fax by using this order form for TheCorporateCounsel.net. If you have renewal questions, send an email to info@thecorporatecounsel.net or call our HQ at 925.685.5111.

Corporate Executives are Apparently Not Eager to Repay Their Loans

A study put out last Friday by the Corporate Library reports that executives continue to owe their companies millions of dollars from loans that predated Sarbanes-Oxley's prohibition of the practice. (SOX put a stop to almost all corporate loans to insiders but did not require that pre-existing loans be repaid.) Interestingly, the Corporate Library found that of 23 companies in its study that were operating split-value life insurance programs, only 10 have suspended that benefit.

The study also evaluates the types of loans outstanding and circumstances under which companies have forgiven loans to insiders. Although outright loans are pretty easy to identify as now forbidden by SOX, there are a number of more difficult questions that have been left in the statute's wake. Broc will be hosting another webcast in three weeks that will explore cashless exercise and other murky areas arising out of SOX Section 402.

Posted by Kimberley Drexler

January 16, 2004

Our New "Corporate Governance Website" Portal!

Under the new NYSE listing standards, prior to their 2004 annual shareholder meetings, listed companies must create a corporate governance page on their websites. The bare minimum for compliance is a page that contains links to the company's governance guidelines, code of conduct, and the charters of the key board committees. The next tier of compliance is to include additional information (egs. list of directors, committee assignments), corporate documents (egs. articles, bylaws, policies). Top tier companies also include instructions for submitting accounting and whistleblowing complaints.

Thanks to Michael Goldblatt, we have posted a new "Corporate Governance Websites" Portal, which has links to various governance webpages that comply with some or all of the new NYSE requirements already.

January 15, 2004

New Pension Plan Disclosures Now Required

In late December, the FASB issued a revised FAS 132 regarding employers’ disclosure about pensions and other postretirement benefit plans. The new standard requires that companies provide the public with more details about their plan assets, benefit obligations, cash flows, benefit costs and other relevant information. This disclosure now is required in quarterly and annual financial statements - since the new guidance is effective for fiscal periods after December 15, 2003, companies will need to comply in their next quarterly and annual report.

For the first time, companies are required to give a breakdown of plan assets by category, such as equity, debt and real estate. A description of investment policies and strategies and target allocation percentages - or target ranges - for these asset categories also are required in financial statements. The new FAS doesn’t change required disclosures about defined contribution or multi-employer plans.

The FASB has advised that when prior periods are presented for comparability purposes, those periods should be restated to comply with the new guidance. The FASB also acknowledges, however, that it’s not always practical to obtain the prior period information; but in that situation, a company should disclose in its financial statement footnotes all information that is available and describe the information that was excluded.

SEC Issues Guide for Investors on Executive Compensation

The SEC has posted a brochure for investors designed to help them locate compensation information in company reports, including types of compensation and what is filed with the SEC, and where to locate information about executive pay (e.g. proxy statements, 10-Ks).

More on Preparing Executive Compensation Tables

In Broc's interview with Alan Kailer on Preparing the Executive Compensation Tables, the complexities of preparing the compensation tables for the proxy statement are explored. In addition to this useful interview, in the "Proxy Season Resource Center," we have posted an updated memo on this topic from Alan with contains more extensive analysis – with excellent charts - on how to prepare the executive compensation tables.

Posted by Kimberley Drexler

January 14, 2004

Disclosure of Internal Control Deficiencies Grow

Even though the SEC already has delayed the effective date once, my money is that the SEC will again delay the effective date of the Section 404 internal control reports. Right now, "accelerated filers" are required to file their first report for fiscal years ending after June 15, 2004 (all others can wait until their fiscal years end after April 15, 2005).

Since the PCAOB still has not acted on its proposal to set attestation standards, "something's has gotta give" as Jack Nicholson would say. [personal note - due to a receding hairline, back in college days I would pretend that my name was "Pat Nicholson" and Jack was my uncle - no girls bit that I can recall.]

Not surprisingly, the number of companies that are disclosing that they have deficiencies in their internal controls has slowly grown. In fact, there have been rumblings that the SEC would be disappointed if there failed to be a significant number of these disclosures. We have updated our list of sample disclosures in this area at Internal Controls - Deficiencies and Weaknesses Identified in the "Disclosure Analysis and Samples" Practice Area.

January 13, 2004

Reminder about Tomorrow's Section 16 Webcast

Don't forget tomorrow's special webcast - "Alan Dye on the Latest Section 16 Developments" - for members of the NASPP and Section16.net. You can ask questions and learn the latest Section 16 practice tips from Alan Dye!

An audio archive and transcript will be posted following the live webcast. The non-member fee for this special webcast is $495. If you wish to access this important program, you may simply take advantage of a no-risk trial to Section16.net or the NASPP.

If you have not renewed your Section16.net or NASPP membership for 2004, you will not be able to access the webcast - scroll down to yesterday's blog for info about how to renew right away!

ISS Releases Updated Voting Policies

As Pat McGurn predicted in our October webcast - "The Wildest Proxy Season Ever: Forecast for 2004" – ISS has amended its voting guidelines for this year. This update includes many significant changes, the most drastic of which will affect stock-based incentive plans. The new policies are effective for shareholder meetings held on – and after - February 1, 2004.

More details about ISS’ updated policies are provided in an interview with Pat McGurn on Changes in ISS’s 2004 Voting Guidelines – as well as in two extensive memos from ISS posted in our “Proxy Season Resource Center” (they are also linked from Pat's interview).

January 12, 2004

Proper Use of Boilerplate

We have launched an exciting new monthly feature - "Carl's Corner"! This feature is written by well known lawyer, Carl Schneider who is Of Counsel and former Chairman of Wolf, Block, Schorr and Solis-Cohen's Corporate Law Department in Philadelphia.

Carl's first feature is about how to use - and not use - boilerplate in corporate agreements. Carl has a unique way of conveying practical guidance on matters that many of us take as a "given" without pausing to reflect - so check this "Corner" out! [If you are seeking the PLI Notes that formerly resided where "Carl's Corner" now sits, they are in our "Notes from Conferences" section of "Sarbanes-Oxley Law Firm Memos.]

Ill Will on the 6th Floor?

Last Wednesday, SEC Commissioner Roel Campos issued a dissent to the SEC's enforcement settlement regarding the Heartland Group. It is extremely rare for a Commissioner to issue a dissent in an enforcement action (much more common to do so regarding a rulemaking, albeit even that is quite rare).

As I blogged about back on December 14th, the SEC took the unsual action to go after the independent directors of this mutual fund in this settlement. Campos believes the Commission was too lenient with the Heartlands independent directors and more meaningful sanctions should have been levied against the directors.

Add this dissent to the well-publicized split over shareholder access (Donaldson, Campos and Goldschmid are "for"; Atkins and Glassman are "against") and you can easily envision a not-so-peaceful co-existence on the 6th floor of 450 5th St. these days (all of the Commissioners have their offices on the 6th fl. of the SEC's HQ).

By the way, it appears that a SEC roundtable on shareholder access will be held sometime in late January/early February.

Grace Period Over!

If you have not renewed your subscription to either TheCorporateCounsel.net or Section16.net, please be aware that you won't have access to the sites starting today.

For Section16.net members, this means you won't have access to the upcoming webcast - "Alan Dye on the Latest Section 16 Developments" - next Wednesday. For TheCorporateCounsel.net members, you wouldn't have access to the "50 Nuggets in 50 Minutes II" webcast on the 21st.

You can renew online - or by fax by using this order form for TheCorporateCounsel.net or this order form for Section16.net. If you have renewal questions, send an email to info@thecorporatecounsel.net or call our HQ at 925.685.5111 (the HQ opens at 8 am West Coast time).

January 9, 2004

Our Server Woes

If you have experienced problems accessing content on our sites, we apologize and are working hard to fix them. In the meantime, try using "TheCorporateCounsel.com" instead of "TheCorporateCounsel.net." In many cases, this has solved any inability to access content.

NYSE Changes FAQ 19 regarding Shareholder Approval of Equity Comp Plans

Just in case you didn't notice, after the FAQs were first released, the NYSE staff confirmed that 401(k) plans, 423's and parallel excess plans are exempt from the shareholder approval requirement portion of the rule (notwithstanding FAQ 1) - but also confirmed that these plans are subject to approval by the independent compensation committee or the majority of independent directors as well as the requirement that NYSE be notified when the exemption is used.

The NYSE staff revised FAQ 19 to clarify this through the addition of a second paragraph - below is the revised FAQ 19:

"19. When will an amendment to a 401(k) plan be considered a material revision?

Only if it affects the company stock aspects of the plan in a way that is otherwise a material revision. For example, adding to or changing investment funds - other than a company stock fund - to such a plan would not be considered a material revision.

401(k) plans are exempt from the shareholder approval requirement of the rule, but the Exchange does require listed companies to seek and obtain approval by their independent compensation committee or a majority of their independent directors for any material revision to an exempt plan. In addition, the Exchange must be notified when a listed company utilizes an exemption (see questions 22 & 26)."

January 8, 2004

Grace Period Ends This Saturday! So Renew Today!

If you have not renewed your subscription to either TheCorporateCounsel.net or Section16.net, please be aware that you won't have access to the sites starting this Saturday.

For Section16.net members, this means you won't have access to the upcoming webcast - "Alan Dye on the Latest Section 16 Developments" - next Wednesday. For TheCorporateCounsel.net members, you wouldn't have access to the "50 Nuggets in 50 Minutes II" webcast on the 21st.

You can renew online - or by fax by using this order form for TheCorporateCounsel.net or this order form for Section16.net. If you have renewal questions, send an email to info@thecorporatecounsel.net or call our HQ at 925.685.5111.

Our New Shareholder/Director Communications Survey

We have posted a new Quick Survey on Shareholder Communications with Directors - so please weigh in!

The final results are available from our "Director Education/Orientation" survey.

IRS Comes to Its Senses Regarding Confidentiality in M&A

In February 2003, the IRS issued tax avoidance regulations that created a broad category of transactions for which disclosure was required if they included conditions of confidentiality. In the minds of many practitioners, the category was created too broadly because it included many transactions that couldn't have any tax avoidance consequences, including many M&A transactions.

As a result of this bizarre position, many practitioners have been recommending that the confidentiality provisions of most M&A agreements be modified to exclude tax-related matters.

On December 29th, the IRS came to its senses and issued new regulations that narrowed the category so that it no longer affects traditional M&A. So, the recommended modification to exclude tax-related matters is no longer needed in most cases.

Learn more from recent law firm memos on this topic posted in the "Confidentiality Agreements/Privilege" section of our Mergers & Acquisitions Practice Area.

January 7, 2004

U.S. Postal Service Hinders Proxy Material Bulk Mailings

If you have read our January E-Minders, you already know about this action that I consider as the early favorite for "craziest action by a regulatory agency" for 2004. ADP Investor Communication Services has been informing companies of a new issue that could affect the ability to deliver proxy materials via bulk mail. According to ADP, the U.S. Postal Service recently changed its interpretation of its rules that determine if mail qualifies for Standard Mail (formerly known as “3rd class bulk”). This change revolves around the inclusion of what is considered personal information when using Standard Mail.

ADP provides telephone/Internet voting and householding services by the use of unique control numbers. Apparently, the Postal Service challenged ADP on documents containing instructional language for voting and enrollment processes that referred to these control numbers and deemed this information as personal - thereby disqualifying the materials from being processed as Standard Mail. As a result, ADP is changing its forms to conform to the new interpretations.

However, the Postal Service is applying its new interpretations to any reference to personal information contained in any enclosure in the mailing, including the proxy statement. This results in a conflict with the SEC’s plain English movement. For example, the common statement in proxy statements that a shareholder should vote via the telephone or Internet by entering "your" control number on the enclosed form may preclude the mailing from qualifying as Standard Mail. This potentially could force a company to deliver its proxy materials via First Class which would be much more expensive.

ADP recently met with John Nolan, Deputy Postmaster General, to address this personal information issue and Mr. Nolan assured ADP that the Postal Service would work with ADP to make them aware of any issues and arrive at a cure. I suspect we will be hearing more on this issue as the proxy season unfolds.

January 6, 2004

First Samples of Shareholder Communication Disclosure

The first proxy statements addressing the new SEC requirements regarding disclosure of the shareholder/director communication process are starting to be filed. The new requirements are applicable to any proxy statements that are mailed on or after January 1st.

For example, here is the disclosure from SunAir Electronics, whose proxy statement was filed yesterday:

"The Board provides a process for stockholders to send communications to the Board or any of the Directors. Stockholders may send written communications to the Board or any the Directors c/o Secretary, Sunair Electronics, Inc., 3005 S.W. Third Avenue, Fort Lauderdale, Florida 33315. All communications will be compiled by the Secretary of the Company and submitted to the Board or the individual Directors on a periodic basis. It is the Company's policy that the Directors who are up for election at the Annual Meeting attend the Annual Meeting. All of the nominees up for election at the 2002 Annual Meeting of Stockholders attended the 2002 Annual Meeting of Stockholders."

UGI Corp.'s Proxy Statement (also filed yesterday) indicates that this company was not prepared for the SEC's action:

"The Company is considering the establishment of procedures by which Shareholders can send communications to the Board of Directors or to the non-management directors as a group. The Company will post those procedures on its website upon their adoption."

We will continue to post useful samples in "How Shareholders Can Contact Directors" in our "Shareholder Access" Portal.

Bert Denton's View of the World

Bert Denton has been one of the more controversial activists for some time - but now some of his ideas have come into their own as part of governance reform. Members can learn more in this interesting interview with Bert Denton on Improving Shareholder Returns With Better Governance.

January 5, 2004

Another One of Those New Year's Lists

And yes, I am getting new blogging software this year. This software doesn't allow for columns...

Out During 2003/In for 2004

- Harvey Pitt/William Donaldson
- CEO Perqs/CEO Certs
- AICPA/PCAOB
- Peek-a-Boo/P-Cob (nah, just checking to see if you're paying attention)
- Reporting "Up"/Reporting "Out"
- Private Analyst Meetings/No Earnings Guidance
- Walk with Your Feet/"Just Vote No"
- "Elevator Music"/MD&A with Feeling
- Non-Audit Services/Internal Controls Documentation Services
- Weekly Industry Newsletters/Blogs!

Of Course, Don't Forget to Renew

A New Year means that your membership should be renewed because all of our subscriptions run on a calendar year. You can renew online, fax or regular mail by going to our "Renewal Center" and keep this puppy afloat.

And for law firms, its never too late to enter into a firmwide license and avoid the hassle of id's and passwords (and save money to boot).