In a recent post, we discussed trends in Sarbanes-Oxley Act Section 302 Disclosure Controls and Procedures (“DC&P”, or “SOX 302”) filings, and highlighted some reasons why disclosure controls may be of interest to investors and stakeholders. In this post, we look at … Continue reading
Category Archives: Disclosure Controls (SOX 302)
SEC Comments on a BNY Mellon Capital Ratio Error
The recent turmoil surrounding Deutsche Bank, and speculations that one of the largest European banks may not survive without a bailout, yet again bring to light the importance of capital reserves that banks are required to hold. It should come … Continue reading
Ineffective Disclosure Controls, 2005-2015
Last month, we released a report looking at long-term trends in Internal Control over Financial Reporting (ICFR) SOX 404 disclosures. In this blog, we supplement that analysis with a look at the management-only assessments required by Section 302 of the Sarbanes-Oxley Act (SOX … Continue reading
Hain Delays Filing: What to Expect
Hain Celestial Group (NASDAQ: HAIN) announced on Monday, August 15 that it would delay the release of its fourth quarter and fiscal year 2016 financial results. The reason? The company was investigating certain revenue arrangements with distributors. During the fourth quarter, the … Continue reading
Non-GAAP Metrics in SAB 99 Materiality Analyses
The pros and cons of non-GAAP metrics have been discussed in more than a few recent articles. Proponents of non-GAAP frequently claim that GAAP contains many ambiguities and loopholes, and that non-GAAP metrics can be more current and relevant. Opponents sometimes … Continue reading
Non-GAAP and SOX 302
In a recent post on his blog, The Accounting Onion, Tom Selling added some thoughts to the ongoing debate surrounding non-GAAP disclosures. He proposed some additional requirements that he thinks could help improve non-GAAP reporting. One of the suggestions was that … Continue reading
Walmart Reports Material Weakness
In a 10-Q filed yesterday, September 9th, Walmart disclosed a significant deficiency that rose to the level of material weakness in its SOX Section 302 Disclosure Controls and Procedures assessment. The deficiency related to the company’s application of lease accounting. According to … Continue reading