CLIFFORD CHANCE
December 21, 2006

Client Alert

SEC and PCAOB publish further guidance on Section 404 of the Sarbanes Oxley Act


For your holiday reading pleasure:

The Securities and Exchange Commission has released for public comment Interpretative Guidance to Clarify the SOX 404 Reporting Process. The proposed interpretive guidance is available here.

The Public Company Accounting Oversight Board published revised guidance for auditors on SOX 404. The proposed a new auditing standard is available here.

Happy holidays and we will send out a memo summarizing these actions very soon.

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David Bernstein
+1 212 878 8342
david.bernstein@cliffordchance.com

Sara Hanks
+1 212 878 8014
sara.hanks@cliffordchance.com

Richard Pritz
+1 212 878 8220
richard.pritz@cliffordchance.com

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