July 19, 2007
I suggest the significant deficiency would be defined as "a deficiency, or a combination of deficiencies, in internal control over financial reporting that is less severe than a material weakness, yet important enough to merit attention by thoese responsible for oversight of a specific registrant's financial reporting".
In my opinion, a deficiency which is considered as a significant deficiency by one company may not be thought of a significant deficiency by another company. When we define the term "significant deficiency" only for a "specific registrant", the term will be understood much easier, at the same time, it will be more supportive for the management's own judgement.