September 11, 2002

Note that there is some debate – and lack of clarity in the SEC’s adopting release – about whether a company’s traditional “internal controls” (those that relate to financial reporting, as described in the AICPA Codification of Statements on Auditing Standards (AU ยง 319)) has to be evaluated every 90 days. Most practioners are viewing these traditional “internal controls” as a subset of the new “disclosure controls” requirement – and thus evaluation of these traditional “internal controls” would be required each quarter.

As with many of the issues being debated, it is quite possible that this sentiment among practitioners might change – or that the SEC might issue clarifying guidance to the contrary.