Comments on Proposed Rule: Disclosure Required by Sections 404, 406 and 407 of the Sarbanes-Oxley Act of 2002

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Date Received
Date Letter Type Commenter Name
Public Comment Dirk Leisewitz Timmermann, Acting General Manager and CEO, COMPAIA CERVECERIAS UNIDAS S.A. (United Breweries Company, Inc.)
Public Comment Lee Squire
Public Comment Linklaters
Public Comment Martin Lowy
Public Comment Samuel C. Thompson, Jr., Professor and Director of the Center for the Study of Mergers and Acquisitions, University of Miami School of Law; Professor and Director of the Center for the Study of Mergers and Acquisitions, UCLA School of Law
Public Comment Arnold C. Hanish, Executive Director, Finance and Chief Accounting Officer, Eli Lilly and Company
Public Comment BDO Seidman, LLP
Public Comment By Robert S. Singley, Vice President and Assistant Secretary, Wells Fargo & Company
Public Comment C. James Prieur, Chairman, J. Kermit Birchfield, Lead Independent Trustee and Chairman of the Audit, MFS/Compass Group of Funds
Public Comment Cary Klafter, Director of Corporate Affairs, Legal Department, Intel Corporation
Public Comment Charlotte M. Bahin, Director of Regulatory Affairs, Senior Regulatory Counsel, America's Community Bankers
Public Comment Cleary, Gottlieb, Steen & Hamilton
Public Comment Craig E. Polhemus, CAE, CGFM, President & CEO, AVI, Inc
Public Comment Craig S. Tyle, General Counsel, Investment Company Institute
Public Comment Crane H. Kenney, Senior Vice President, General Counsel & Secretary, Tribune Company; Jose M. de Lasa, Senior Vice President, Secretary and General Counsel, Abbott Laboratories; Stanley L. Ferguson, Senior Vice President and General Counsel, USG Corporation; Stewart S. Hudnut, Senior Vice President, General Counsel & Secretary, Illinois Tool Works Inc.; Mary Ann Hynes, Senior Vice President, General Counsel & Assistant Secretary, IMC Global Inc.; Jim L. Kaput, Senior Vice President & General Counsel, The ServiceMaster Company; Anastasia D. Kelly, Senior Vice President and General Counsel, Sears, Roebuck and Co.; Julian A. Oettinger, Senior Vice President, General Counsel and Corporate Secretary, Walgreen Co.; Roderick A. Palmore, Senior Vice President, General Counsel and Secretary, Sara Lee Corporation; D. J. Smith, Senior Vice President, Secretary and General Counsel, Archer-Daniels-Midland Company; Marschall I. Smith, Vice President and General Counsel, Brunswick Corporation
Public Comment David K. Owens, Executive Vice President, Business Operations, Edison Electric Institute
Public Comment E. E. Thiele, Senior Vice President, Rowan Companies, Inc.
Public Comment Gerald S. Backman, Chairman of the Committee on Securities Regulation, Business Law Section, New York State Bar Association
Public Comment Guillaume Bastiaens, Vice Chairman, Donaldson Company, Inc.
Public Comment Harry J. Argue, CAE, Executive Vice President/CEO, Wisconsin Bankers Association
Public Comment Janet M. Dolan, President and CEO, Tennant Company; Director, Donalson Company,Inc.
Public Comment Jeff Noddle, Chairman & CEO, Supervalu Inc.
Public Comment John E. Baumgardner, Jr., Chair, Committee on Investment Management Regulation of the Association of the Bar of the City of New York
Public Comment John M. Rintamaki, Chief of Staff and Secretary, Ford Motor Company
Public Comment Karen Robards, Audit Committee Chair, Mercury Funds, Inc., Mercury V.I. Funds, Inc., Mercury Master Trust, The Europe Fund, Inc., Merrill Lynch Funds for Institutions Series
Public Comment Ken Wasch, President, Software & Information Industry Association
Public Comment Kendrick B. Melrose, Director, Donaldson Company, Inc.
Public Comment Kenneth W. Crawford, Vice President and Corporate Controller, Kaydon Corporation
Public Comment Kevin Sharer, Chairman of the Board and Chief Executive Officer, AmgenOne
Public Comment KPMG LLP

Last Reviewed or Updated: Dec. 18, 2025

File Number
S7-40-02
Release Number
33-8138
34-46701
IC-25775
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