As part of the Sarbanes Oxley compliance, the management certifications for control relating matters require the CEO and the CFO to certify disclosures about controls in the periodic report itself. The SEC has made certain changes to the 10-K and the 10-Q forms. Item 14 has been added to Form 10k and item 4 has been added to Form 10Q.

These new items in the 10k and 10Q forms require the conclusions of the CEO and the CFO about the effectiveness of issuers disclosure controls, based on an evaluation of the controls as of a date within 90 days prior to the filing date of the quarterly or annual report. One thing which the SEC does not provide is the form and extent of the disclosure required. This is confusing since SEC has not specified whether the CEO / CFO must describe any deficiencies or weaknesses, even when on an overall basis management has concluded that disclosure controls are effective. I believe that this will get clarified automatically over a period of time as the industry practice develops.

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