Down for the Account: Steps to Take When Facing a Change in Accountant

A discussion of the steps a U.S. reporting company should take when facing the resignation or dismissal of its accountant. The Note explains the related Form 8-K disclosure requirements, including when past financial statements may no longer be relied on. It further discusses how a change in accountant may lead to the late filing of a Form 10-K or Form 10-Q, how to announce a late filing on Form 12b-25 and the related implications under SEC rules and NYSE and NASDAQ listing standards. Finally, the Note addresses the risk that a late filing may trigger a debt default and the importance of investor and creditor relations.