September 26, 2003

Going “Whole Hog” to Provide

In its definitive proxy statement filed September 24th, Micronetics discloses personal e-mail addresses for both of its audit committee members.

We doubt that many other companies will go this far to comply with the rules adopted by the SEC under Section 301 of SOX, which require that audit committees establish confidential, anonymous procedures for the receipt, retention and treatment of complaints regarding accounting, internal accounting controls or auditing matters. As you might recall, the SEC’s rules do not mandate specific procedures.

SOX Scorecard/Timeline for Small Business Issuers

Thanks to Faegre & Benson for contributing a SOX Scorecard and Timeline for Small Business Issuers that we have coded and posted in’s “Small Business” Practice Area. A quick glance at this excellent resource reveals that small business issuers really didn’t get cut much of a timing break from the SEC – all the effective dates are in 2003…

Faegre & Benson also contributed an annotated compensation committee charter and an annotated governance/nominating committee charter, which we have added to our Portals on those topics. Still seeking sample evaluations for those committees if you got one to share!

PCAOB Auditor Registration Update

Back on September 11th, I blogged at length about the costly nature of the PCAOB registration process and indicated that only 200 – of the likely universe of 700 – audit firms had registered.

On Tuesday, PCAOB Chair William McDonough testified before a US Senate Committee that the PCAOB has received almost 500 registration applications from U.S. accounting firms and that the first 38 of those applications were approved last week. That is more than I expected, but it still appears that a few hundred small firms said “fuhgedaboutit.”