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About This Document: The SEC notes that disclosure filings made with the commission 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 incomplete or need to be improved, the registrant is sent a comment letter. These comment letters can provide insight into the SEC's thinking on problem areas. There were 60 SEC comment letters in 2008 related to internal control disclosures by Russell 3000 companies. Three of the comment letters were for subsidiaries, and another four were repeat letters when the company's initial response was not satisfactory to the SEC. SOX requires that companies include information about any changes in internal controls in their quarterly 10-Q filings. SOX specifies two different types of controls -- disclosure controls and internal controls over financial reporting.

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SEC Comment Letters Related to Internal Control Disclosures

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SEC Comment Letters Related to Internal Control Disclosures

Lewis F Davidson; K Raghunandan; John Wrieden

The CPA Journal; Aug 2009; 79, 8; Docs

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