Internal controls over financial reporting
Internal controls over financial reporting sits at the center of regulatory scrutiny for U.S. financial and capital markets firms, with the U.S. Securities and Exchange Commission and the Public Company Accounting Oversight Board both pressing for tighter documentation, faster remediation timelines, and cleaner audit trails after a run of material weakness disclosures in 2023 and 2024. The Financial Industry Regulatory Authority adds a parallel layer for broker-dealers, particularly around supervisory control testing under Rule 3120. No quiet period is coming: both the SEC and PCAOB have open rulemaking and inspection priorities that directly touch how firms design, test, and certify controls.
Watch
- PCAOB AS 2201 inspection findings on IT general controls across broker-dealer audits
- SEC Staff Bulletin guidance on CEO/CFO certifications under Sarbanes-Oxley Section 302 and 906
- Material weakness disclosure trends in 10-K filings: remediation timelines drawing comment letters
- FINRA Rule 3120 supervisory control annual reporting cycle: Q1 deadline pressure for calendar-year firms
- PCAOB proposed amendments to AS 2101 scoping rules for multi-entity financial groups
Recent material activity in Financial & Capital Markets
Active monitoring in place across Financial & Capital Markets. Material developments related to internal controls over financial reporting will appear here as they are published.