31. 17 C.F.R. §§ 205.1–.7 (2006). See Sarbanes-Oxley Act of 2002, Pub. L. No. 107-204, § 307, 116 Stat. 745, 784 (codified at 15 U.S.C. § 7245 (Supp. IV. 2004)).

Both lawyers and public companies should establish procedures to implement compliance with Part 205. Law firms and law departments within public companies should consider the adoption of formal procedures for reporting and consulting with respect to potential violations by issuers to determine if action is required to comply with Part 205. Issuers should determine whether establishment of a QLCC is desirable. If so, a QLCC should be formed with authority in place prior to the effective date of Part 205.If you would like to discuss these new rules, the Sarbanes-Oxley Act, or their implications, please feel free to call a Kramer Levin attorney1 See Sarbanes-Oxley Act of 2002, Pub. L. No. 307, 116 Stat. 745 (codified as amended at 15 U.S.C. 7245 (2002)). Section 307 of the Act requires the SEC to prescribe minimum standards of professional conduct for attorneys appearing and practicing before the SEC in the representation of issuers including a rule:.