6.4 Restriction on Company’s Employment of Former Audit Personnel

The SEC’s independence rules mandate a “cooling-off” period before a member or former member of the audit engagement team can begin working for the registrant in an accounting or financial reporting oversight role. Accordingly, management and the audit committee need to consider these requirements when determining whether to offer employment to a current or former partner, principal, shareholder, or employee of the entity’s auditors. In addition, management and the auditor need to discuss employment of former auditor partners and professional staff at the entity and its affiliates to assess whether these employment relationships are permissible under the SEC’s independence rules during the financial statement periods included in the registration statement.