Improved Documentation and Guidance Can Help Strengthen Corporation Finance’s Disclosure Review Program, Report No. 586

Title Full

Date Issued

Tuesday, August 26, 2025

Submitting OIG

Securities and Exchange Commission OIG

Agencies Reviewed/Investigated

Securities and Exchange Commission

Components

Division of Corporation Finance

Report Number

586

Report Description

Improved Documentation and Guidance Can Help Strengthen Corporation Finance’s Disclosure Review Program, Report No. 586

Report Type

Audit

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

Open Recommendations

This report has 3 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
1	No	$0	$0
We recommend that DRP management update policies and internal guidance to (a) require that staff document the reasons and relevant risk factors for conducting elective annual report reviews, (b) provide clear direction for scoping annual report reviews, and (c) require that staff document scoping decisions.
2	No	$0	$0
We recommend that DRP management coordinate with the SEC Office of the General Counsel to finalize the Sarbanes-Oxley Act of 2002 section 408(b) guidance, including a description of all six factors to be considered when selecting issuer filings for elective reviews, and finalize its interpretation of the minimum review period mandate from section 408(c) of the Act.
3	No	$0	$0
We recommend that DRP management consider developing a plan that prioritizes Disclosure Review Program goals and requirements in the event of significant staffing decreases and/or significant workload increases.