Thousands of NT (“non-timely”) filings are disclosed every year, but only a small percentage seems to trigger a significant market reaction. A non-timely filing is a notice that a company needs additional time to file periodic financial statements. (See here and here for more … Continue reading
Author Archives: Olga Usvyatsky
Where Does Hertz Go From Here?
On May 13, 2014 Hertz (HTZ) notified the SEC that it wouldn’t be able to file its quarterly report (known as Form 10-Q) on time. In the filing (Form 12b-25, or NT 10-Q) Hertz disclosed that “additional work” was needed in order … Continue reading
An Initial Look at Conflict Minerals; Dodd Frank Section 1502
On April 14, 2014, the United States Court of Appeals for the District of Columbia Circuit issued a decision in National Association of Manufacturers, et al. v. SEC, et al., No. 13-5252 (D.C. Cir. April 14, 2014). The Court concluded … Continue reading
Terrorist Nation and OFAC Violations – SEC Comment Letters
Last week rumors hit the Street that BNP Paribas (EPA:BNP), one of the largest French banks, would settle with the US Department of Justice for a record $5 billion (or even $10bn, according to different sources). BNP is also facing criminal … Continue reading
2013 Comment Letters Trends and Analysis – Issues Breakdown
The Sarbanes-Oxley Act of 2002 requires the SEC to review the financial statements of every public company at least once every three years, while permitting more frequent reviews as needed. According to the SEC 2013 Annual Report, the agency reviewed … Continue reading
The Cost of an Error
A Latin phrase attributed to Seneca, errare humanum est, reminds us that to err is human. Although errors and mistakes may be unavoidable, they nevertheless tend to bear a cost, which sometimes can be quite significant. On April 28th, 2014 … Continue reading
Restatements: What’s in a Name?
Would a restatement by any other name still seem as bad? Financial restatements are increasingly leaving out a crucial word in their disclosures: “restatement” – the thing itself. This coincides with the continuing increase in the percentage of revision restatements, i.e., … Continue reading