文档介绍：外文翻译
原文:
ment Letters Related to Internal Control Disclosures
The SEC notes that disclosure filings made with mission are in certain cases selected for staff review. If the staff at the SEC Division of Corporation Finance has questions or concerns related to a filing, or if the staff believes that the filings are plete or need to be improved, the registrant is sent ment letter. The registrant has 10 business days to reply to the SEC, and this is usually panied by a revised filing of the relevant disclosure form..
ment letters can provide insight into the SECs thinking on problem areas. In addition, by knowing the problems that the SEC is looking for, filers can avoid ing a target of such letters from the SEC. Since the questions raised by the SEC are often quite specific, comment letters are also useful to auditors and their clients looking for relevant SEC guidance on important areas.
Beginning in May 2005, the SEC began publicly ment letters issued on or after August 1, 2004. ment letters are available at the SEC's website; however, unless one knows the identity of a pany, it is difficult to search the SECs database ment letters related to specific topics. The Audit Analytics database (provided by Ives Group, Inc.) has recently ment letters related to the Russell panies. The authors used this database to identify ment letters issued during 2008 related to internal control disclosures.
Examining internal control disclosures is important because section 404(a) of the Sarbanes-Oxley Act (SOX) is now applicable for elerated filers. Section 404(a) requires management's assessment of internal controls, while section 404(b), which requires auditor attestation, will be required for fiscal years ending on or after December 15, 2009.
Recipients ment Letters
There were 60 ment letters in 2008 related to internal control disclosures by Russell panies. Three of ment letters were for subsidiaries, and another four were repeat letters when pany's initial response was