Proposed SEC Regulations Require In-House and Outside Counsel to Report Securities Violations
By KirD. Behre, Elizabeth H. Noe and Michael L. Zuppone
On November 21, 2002, the Securities and Exchange Commission issued proposed regulations to implement provisions of the Sarbanes-Oxley Act of 2002, requiring “up the ladder” reporting by inhouse and outside lawyers of suspected corporate wrongdoing. The proposed regulations will cover past, present and future material violations of the securities laws and breaches of fiduciary duty.