August 23, 2006
I don't think there should be exclusions for size of company or country in which domiciled. We don't have different standards for listing requirements on our exchanges based on size or nationality of company. Such an approach is also likely to create gaming around cut off points. if 404 is too onerous, then the SEC should address SOX more broadly, rather than creating a two-tiered structure that makes little sense in terms of protection of investors for key control weaknesses.