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Though routine, review of a public company’s financials by the Securities and Exchange Commission’s (SEC) Division of Corporate Finance (Corp Fin) can, in unique circumstances, lead to an enforcement action and should not be taken lightly. This is especially true given the backdrop of an announcement by the SEC’s enforcement division regarding its creation of a new Financial Reporting and Audit Task Force and statements by the staff reflecting a refocus of efforts on accounting cases. The SEC’s settlement with PACCAR, Inc. (PACCAR) for relatively minor issues that did not involve fraud allegations, or even a financial restatement, demonstrates how the staff is pursuing less significant violations and reinforces that disclosure revisions or accounting errors identified during a Corp Fin review could trigger such charges.

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