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BOL Conferences Top Gun 23
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#1105915 - 01/06/09 03:42 PM Sox
COMPLIcated Offline
Diamond Poster
Joined: Mar 2003
Posts: 1,035
I am trying to see if we will have to comply with Sarbanes Oxley in the future. We are not publicly traded. We are FDIC Supervised and I read that non-publicly traded FDIC supervised banks must comply with SOX at $500 million in assets or more. Is this fact?

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#1106450 - 01/06/09 10:55 PM Re: Sox COMPLIcated
Curious Banker Offline
100 Club
Joined: May 2004
Posts: 184
You are confusing SOX with FDICIA. You must be publicly traded for SOX. Not so with FDICIA. FDICIA is much much easier but does require additonal testwork and audit oversight. Hope this helps you.

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#1106514 - 01/07/09 05:51 AM Re: Sox Curious Banker
Dazed and Confused Offline
Gold Star
Dazed and Confused
Joined: Feb 2006
Posts: 250
Big XII South
There was a FDIC proposal in 2007 (FIL-96-2007) that proposed to make some changes to Part 363 in regard to audit and reporting requirements for banks with assets over $500 million (including non-public banks). The proposal did not suggest that such institutions should comply with SOX ... but the proposal included SOX-like provisions. I have not read or seen anything since. I presume the economy and failing institutions diverted their attention.

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#1127968 - 02/11/09 04:56 PM Re: Sox Dazed and Confused
this is it Offline
Joined: Jun 2006
Posts: 92
I have wondered about this as well. At previous institutions (mutual - not publicly traded) we always referred to FDICIA. At my new bank (mutual - not publicly traded), management says SOX. I haven't wanted to correct them because I wasn't sure (not being an accountant). So just to check the experts here...we would not be subject to SOX (but subject to FDICIA)?

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#1143851 - 03/12/09 12:28 AM Re: Sox this is it
mmumm Offline
100 Club
Joined: Jul 2008
Posts: 163
Santa Cruz, California
we are traded on the OTCBB, does this mean we have to comply with Sarbanes-Oxley?

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