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 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 11.17.25 | Publications SEC Division of Corporation Finance Announces Limited Engagement on Exclusion of Shareholder Proposals for the Upcoming Proxy Season Related Services Related Practice Areas Corporate Capital Markets Debt Related Client Solutions Corporate Governance