Now that the wait for the 404(b) reprieve is over, it appears that a new trend is emerging to investigate 404(a) statements more closely, as expressed in recent articles on investor and auditor sentiment regarding the legislative change. We are hearing from auditors directly that they will be applying more scrutiny to 404(a) statements made by their clients in their financial reports, to ensure that there is a real basis for self-certification. The newly aggressive SEC and DOJ are expanding personnel and focusing on Corporate Governance and the role of Audit Committees, Directors and Company Officers in Compliance and Financial reporting.
