Orrick discusses In re Polycom and the SEC’s Continued Focus on Internal Controls

Over the past year, the SEC and other regulatory agencies have initiated an increasing number of investigations into companies based on allegations of inadequate internal controls and/or a system for reporting those controls. (For more on internal controls and a discussion of recent regulatory activity in this area, see Jason M. Halper & Jonathan E. Lopez, et al., Assessing the Increased Regulatory Focus on Public Company Internal Control and Reporting, Bloomberg BNA: Securities Regulation & Law Report, Oct. 6, 2014, available at: http://s3.amazonaws.com/cdn.orrick.com/files/BloombergBNA.pdf.)

“Internal controls” are the procedures and practices instituted by a company to manage risk, … Read more