As a de facto representative of foreign issuers, Keith Holmberg, vice president of Financial Control Processes of British Petroleum, joked that his peers overseas watched regulatory developments in with amusement in 2004 — an emotion that has gradually turned into fear.
Nonetheless, Holmberg himself seemed relatively sanguine about whether management has been given enough guidance to complete a 404 assessment:
"BP has essentially finished our first year assessment. I have to say that when I saw the question I wrestled with it, because we have not spent a lot of time saying we don't have enough guidance as to what management's assessment should be."
He went on to note that he felt the lack of management guidance was actually a boon to BP. "I'd say we benefited because we didn't have as much guidance as our auditors and were not constrained and bounded as our auditors were."
That said, he added, additional guidance last year has been a help to BP. "We have significantly changed materiality levels for what we've looked at this year and gotten very quick agreement from our external auditors— so quick," he noted to general laughter, "that I wonder if we didn't push far enough."
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