Without these additional requirements, multinational companies already face significant time and quality assurance challenges, and we therefore also suggest that there should be no attempt to shorten the 45 day time frame for submission of Form 10-Q as the SEC has contemplated. We, for one, would do so. Also, we do not believe that new formal requirements for interim reviews will materially shift work activity, or any cost, from the year-end audit process. The Audit Committee Report rule as proposed will significantly blur the public's perception of the roles and responsibilities of management, the Audit Committee and other members of the board of directors. It is currently clear, and should remain so, that the financial statements are the responsibility of company management, and that fair presentation is not an optional obligation that is then enforced by the company's audit committee.
Current regulations require extensive disclosure and discussion by management.
The financial statements are subject to audit on an annual basis by independent public accountants. The Audit Committee should not then be required to state that it is unaware of misleading or untrue statements or omissions. Assuming those circumstances came to the Audit Committee's attention, the statements and disclosures would be modified before release to the public to solve the matter. Should any report be required, the report should be on an annual basis and be part of the Form 10-K, rather than the proxy statement, to keep financial disclosures together. We do not agree with requiring signatures above the Audit Committee member names.