Internal Control Over Financial Reporting (Section 404 Requirements)

Effective September 29, 2005, the SEC extended by one year the compliance date for the inclusion of management’s annual report and auditor attestation in Form 10-Ks for companies that are "nonaccelerated filers." These "nonaccelerated filers," including foreign private issuers that are "nonaccelerated filers," will now only be required to include (i) the management’s report on internal control over financial reporting, and (ii) the auditor’s "attest" report on management’s assessment of internal control over financial reporting in their Form 10-K for fiscal years ending on or after July 15, 2007 rather than July 15, 2006. "Accelerated filers," and foreign private issuers that are "accelerated filers" and file annual reports on Form 20-F or Form 40-F, must still comply with the report on internal control over financial reporting and related requirements in their annual reports for fiscal years ending on or after July 15, 2006. The full text of the SEC’s release can be found at http://www.sec.gov/rules/final/33-8618.pdf.

Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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