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The SEC announced its intention to issue guidance for management on how to comply with Section 404(a) of the Sarbanes-Oxley Act.  The agency will issue a Concept Release and provide an opportunity for public comment before issuing the guidance.

The SEC also announced its intent to inspect efforts by the Public Company Accounting Oversight Board (PCAOB) to imporve Section 404 oversight.  The SEC also will postpone application of the Section 404 filing requirements for the smallest company filers, but made it clear that all public companies will be required to comply with the internal control reporting requirements of Section 404.