February 20, 2003

The SEC is open…and Chairman

The SEC is open…and Chairman Donaldson is on the job. Yesterday, the SEC posted its final rules on definition of “dealer” whereby it excluded banks for certain de minimus transactions – see

For subscribers, we have conducted informal surveys of recent disclosures regarding disclosure controls and procedures – and posting reports on corporate websites – and analyzed the results. These results are in the “Disclosure” section of our “Practice Areas” at