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 10.03.25 | Publications SEC Staff Issues No-Action Relief to Simpson Thacher Concerning the Use of State-Chartered Trust Companies as Custodians of Crypto Assets Under the Advisers Act and 1940 Act 09.30.25 | Publications BIS Expands Export Restrictions to Foreign Companies 50% or More Owned by Listed Entities 09.29.25 | Publications Potential SEC Shutdown: Considerations for Public Companies and Impact on Capital Markets Transactions Related Services Related Practice Areas Corporate Capital Markets Debt Related Client Solutions Corporate Governance