April 3, 2013
As General Counsel for a NASDAQ listed company, The InterGroup Corporation ("INTG"), I am surprised that there are no exceptions to the proposed rule for smaller reporting companies. The proposed Internal Audit Function will impose an additional financial burden on smaller reporting companies and it appears to be at odds with the relief provided for smaller reporting companies related to audits of internal controls under SOX 404.
I believe that smaller reporting companies should be excluded from this proposed rule.
Thank you.
Michael G. Zybala