SEC Issues Additional Guidance for Sarbanes-Oxley Compliance
On April 13, 2005, the staff advisors to the Senior Executives Group attended an SEC Roundtable on the implementation of internal control reporting requirements. Roundtable participants spoke on the issues and challenges that arose from implementing Section 404 of Sarbanes-Oxley. Generally, the participants recognized that Section 404 has produced benefits for public companies. However, many were concerned about the cost of compliance. While a portion of these costs are attributed to initial start-up expenses, there may have been some unnecessary costs due to "duplicative and misfocused efforts".
In recognizing the need for a more effective and efficient process, the Securities and Exchange Commission released, on May 16, additional guidance on reporting requirements. In recent Press Release the Commission highlights the main principle of the guidance:
"An overarching principle of this guidance is the responsibility of management to determine the form and level of controls appropriate for each company and to scope their assessment and the testing accordingly." (May 16, 2005 Press Release)
As the Commission continues to monitor the implementation of the internal control reporting requirements, the Senior Executives Group will report on salient developments.
The SEG will analyze the items raised in the SEC Statement and how it relates to the work of the SAS 70 Web site. The staff will reach out to members of the SAS 70 Advocacy Committee in the coming week to begin leveraging the work that has been accomplished relating to www.sas70standard.com. Questions should be directed to the attention of Douglas Taggart of the staff at 646.637.9273.
Joint Pair Off Working Group - Buyside Survey to be Completed by Heads of Operations at Asset Management Firms
The AMF STP Committee, The Bond Market Association STP Steering Committee and The Bond Market Association Operations Council recently formed a Joint Working Group on Pair Offs. This working group is designed to include participation from the buyside, sellside, custodians and utilities, namely FICC, and its goal is to create a generic solution for netting Pair Offs. Both bi-lateral and multi-lateral netting will be considered.
In order to help the working group to establish a framework of the issues that the buyside is contending with, a simple, seven-question survey has been developed. The staff invites you to complete the survey through the link below.
Click here to complete the Pair Off Survey
If you have any questions regarding this survey or the Joint Pair Off Working Group, please contact Elisa Nuottajarvi at The Asset Managers Forum at 646-637-9266.