Audit Committee Financial Experts and Code of Ethics.

Mondaq Business Briefing, February, 2003

As discussed in our prior client advisory memorandum, the Sarbanes-Oxley Act directs the Securities and Exchange Commission to adopt rules to require disclosure of whether public companies have a financial expert on their audit committees and whether they have adopted a code of ethics for their senior financial officers. The final rules were adopted by the SEC on January 15, 2003. Most companies will be required to provide the new disclosures in annual reports on Form 10-K for fiscal years ending on or after July 15, 2003. Small business issuers will be required to provide the disclosure in annual reports on Form 10-KSB for fiscal years ending on or after December 15, 2003. Alternatively, companies that choose to include these disclosures in their proxy statement may...