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Must identified significant deficiencies be disclosed either as part of management’s report on internal control over financial reporting or elsewhere in a registrant’s periodic reports?

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Must identified significant deficiencies be disclosed either as part of management’s report on internal control over financial reporting or elsewhere in a registrant’s periodic reports?

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10

A registrant is obligated to identify and publicly disclose all material weaknesses. If management identifies a significant deficiency it is not obligated by virtue of that fact to publicly disclose the existence or nature of the significant deficiency. However, if management identifies a significant deficiency that, when combined with other significant deficiencies, is determined to be a material weakness, management must disclose the material weakness and, to the extent material to an understanding of the disclosure, the nature of the significant deficiencies. In addition, if a material change is made to either disclosure controls and procedures or to internal control over financial reporting in response to a significant deficiency, the registrant is required to disclose such change and should consider whether it is necessary to discuss further the nature of the significant deficiency in order to render the disclosure not misleading. A registrant’s auditor that is aware of a signific

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