In a post-Sarbanes-Oxley world, in-house counsel of public (and private) companies have reason to worry that the SEC might turn its attention to their clients. The SEC is funded to take action; its budget for enforcement has increased exponentially in recent years. What happens if your company becomes the subject of an SEC investigation? How do you respond appropriately? This article will set forth some practical steps in-house counsel should consider in the event that her company receives notice that it is under SEC scrutiny.
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