51, requires that registrants apply that guidance and, if applicable, consolidate entities based on characteristics other than voting control no later than the period ending March 15, 2004, or December 15, 2004 for small business issuers.
In instances where the registrant lacks the ability to dictate or modify the internal controls of an entity consolidated pursuant to Interpretation No.
For purposes of applying this guidance, we make no distinction between those equity method investments for which the registrant is required to file audited financial statements pursuant to Rule 3-09 of Regulation S-X and those where no such requirement is triggered.
Q: If a registrant consummates a material purchase business combination during its fiscal year, must the internal control over financial reporting of the acquired business be included in management’s report on internal control over financial reporting for that fiscal year?
We encourage management to keep these goals in mind as they confront and consider questions of judgment and interpretation with respect to internal control over financial reporting.
The staff understands that registrants, investors, auditors and others seek definitive answers to their questions and concerns in this initial assessment of internal control over financial reporting.
Registrants, investors, auditors and others should keep in mind, however, that one of the main goals of the Sarbanes-Oxley Act of 2002 is to enhance the quality and accuracy of financial reporting and increase investor confidence in the financial markets.
A: As discussed above, we would typically expect management’s report on internal control over financial reporting to include controls at all consolidated entities.
However, we acknowledge that it might not always be possible to conduct an assessment of an acquired business’s internal control over financial reporting in the period between the consummation date and the date of management’s assessment.