The SEC’s Chief Accountant announced that a number of companies may be unaware they fall under the disclosure requirement for Emerging Growth Company status under the JOBS Act.
As a result of this status, the JOBS Act requires these companies to disclose such a status in their public filings with the SEC. This disclosure and the resulting status has impacted both the accounting and auditing sides of the business, requiring these companies to act accordingly. The SEC has also issued Frequently Asked Questions guidance to address these requirements and status under the JOBS Act. Further, the PCAOB will also be limited in requiring mandatory audit rotation for these Emerging Growth Companies.
In short, the JOBS Act is still a work in progress, and it will be interesting to see its long-term applications on the public filings of these Emerging Growth Companies.