Final SEC Regulations Require In-House and Outside Counsel to Report Securities Violations
By KirD. Behre, Elizabeth H. Noe and Michael L. Zuppone
On January 29, 2003, the Securities and Exchange Commission issued final regulations to implement provisions of the Sarbanes-Oxley Act of 2002, requiring “up the ladder” reporting of suspected corporate wrongdoing by in-house and outside attorneys. Entitled “Standards of Professional Conduct for Attorneys Appearing and Practicing Before the Commission in the Representation of Issuers,” the regulations cover material violations of the securities laws and breaches of fiduciary duty.