February 27, 2006

Thanks to Ted Frank and Walter Olson for inviting me to do some posting over here on corporate governance matters.
I just caught up with this draft report by the SEC’s Advisory Committee on Smaller Public Companies. It’s got a lot of interesting stuff in it, including a proposal to exempt the smallest firms from mandatory compliance with SOX’s internal controls provision. I'm skeptical whether this goes far enough. SOX is bad for all firms -- it's not just about small firms. Also, there's only so much the SEC can do about SOX -- Congress needs to act. Here's some thoughts and suggestions.