With Laurence Lese, Michael Margulis
On June 20, 2007, the Securities and Exchange Commission ("SEC") issued interpretive guidance ("Guidance") to assist management of public companies in evaluating their internal control over financial reporting ("ICFR"), as required by Section 404 of the Sarbanes-Oxley Act of 2002 and Rules 13a-15(c) and 15d-15(c) of the Securities Exchange Act of 1934 ("Exchange Act").