"The interpretations don't change the law," says Phyllis Deiso, a partner and SEC practice leader with RSM McGladrey Inc., "but are intended to clarify it."

Last month the SEC issued several CD&I's that addressed, among other topics, questions on : Changes in and Disagreements with Accountants on Accounting and Financial Disclosure, as well as : Changes in Registrant's Certifying Accountant.

One of the more significant clarifications addressed the occurrence of reportable events that requires the company to issue a Form 8-K; according to the SEC, companies must file 8-K's to announce major events that shareholders should know about. Just what shareholders should know, however, isn't always clear, says Robert Wild, a Chicago-based partner with Katten Muchin Rosenman LLP focusing on federal securities law disclosure and compliance matters."Sometimes it's black and white; sometimes it's gray," according to Wild.

For instance, in question 111.03 (within the SEC's numbering scheme for questions) regarding Item 304, the SEC said that a company must report when its accountant says that the internal controls necessary to develop reliable financial statements didn't exist, even if the company has corrected the deficiencies before the end of the subsequent interim period.