Publications Memos Go Back Application of the Sarbanes-Oxley Act to Voluntary Filers of Periodic Reports with the SEC 06.23.03 This memorandum details how the SEC has begun to clarify application of the Sarbanes-Oxley Act of 2002 to so-called "voluntary filers". Authors and Contacts Gregory Grogan Partner [email protected] +1-212-455-2477 Related Insights 01.07.26 | Publications Section 16 Reporting to Apply to Directors and Officers of Foreign Private Issuers 12.09.25 | Publications SEC Agrees to Terminate Remaining Undertakings Under the Global Research Analyst Settlement 12.04.25 | Publications SEC Division of Examinations Announces 2026 Examination Priorities Related Services Related Practice Areas Corporate Capital Markets Debt Related Client Solutions Corporate Governance