In the absence of DOL or SEC guidance, the debate rages – with differing opinions from different lawyers – about whether a 906 certificate is required for 11-Ks. Not that it is necessarily persuasive, but the 11-Ks filed so far don’t appear to contain certificates (although they could have been submitted supplementally as the SEC’s directive to file them as exhibits just came recently).
The ABA Task Force on Corporate Responsibility (chaired by James Cheek) issued its Final Report on March 31st. It is not yet available on the ABA’s website.
For Section16.net subscribers, today is the “Comparing the Section 16 Filers” programs – featuring key SEC staffers to describe the SEC’s new filing system – and 12 service providers to explain how they can add value. See more at http://www.section16.net/webcast0403/.