On September 18, 2006, WLF filed formal comments with the Securities and Exchange Commission (SEC) regarding the SEC’s application of Section 404 of Sarbanes-Oxley. In particular, WLF supported the SEC’s proposal to extend the compliance deadlines for smaller public companies to provide their management’s reports on internal control over financial reporting (ICFR) under Section 404. WLF further urged the SEC to develop clearer and more flexible guidance for management regarding its evaluation and assessment of ICFR, and to adopt relevant recommendations of the SEC’s Advisory Committee on Smaller Public Companies to ease the undue burden of Sarbanes-Oxley on the regulated community.