TheCorporateCounsel.net

November 5, 2002

The SEC has posted its proposing release regarding rules on use of non-GAAP financial measures, including amendments to S-K for use of such measures in SEC filings and amendments to 8-K to require filing of certain press releases and ammouncements of earnings. Comments are due 30 days after publication in the federal register. These proposed rules would implement Sarbanes-
Oxley 401(b). The release is at http://www.sec.gov/rules/proposed/33-8145.htm.

The SEC has posted its proposed rules regarding off-balance sheet disclosure in MD&A at http://www.sec.gov/rules/proposed/33-8144.htm.