- Zero Material Weakness
- Posts
- Welcome to Zero Material Weakness!
Welcome to Zero Material Weakness!
Stay ahead of audit red flags with practical insights and real-world tips to fix internal control weaknesses before they’re found.

Welcome to this edition (week ending June 26, 2025) of Zero Material Weakness (ZMW) — a newsletter built for CFOs and controllers who want to stay ahead of material weaknesses before they become audit red flags. Whether you're preparing for SOX compliance, managing IPO-readiness, or just tightening up your internal control environment, this newsletter brings practical insights, industry trends, and real-world examples straight to your inbox. Our goal? Help you fix what’s weak, before the auditors find it.
News this week
Crypto gets (a bit) closer to the options market: the Commission extended its decision deadline to Aug 7 on a Nasdaq ISE rule filing that would allow FLEX options on the iShares Bitcoin Trust spot-ETF (Release 34-103286, June 17).
Author’s comment - Why this matters: Keeps the first exchange-listed options on a spot-Bitcoin ETF alive; approval would open new hedging/arb tools for institutions and retail alike. The extension shows the SEC is still weighing market-structure and investor-protection concerns but hasn’t rejected the idea outright.
Withdrawal from headline enforcement suits (filings through 20 June)
During the week the CFPB voluntarily exited multiple high-profile cases—most notably the Credit Acceptance sub-prime auto-loan action—leaving state attorneys general to litigate alone. The agency has now abandoned about 18 federal lawsuits since January, signalling a broad retreat from expansive UDAAP enforcement and recalibrating defendants’ litigation risk.Expanded IPO exemption for BDCs (Partial Amendment 1 to SR-FINRA-2025-001, posted 18 Jun 2025)
Amendment 1 broadens the planned exemptions from Rules 5130 and 5131 so both exchange-listed and private business-development companies may participate in IPO allocations, provided they weren’t formed to funnel new issues to restricted persons—potentially boosting demand from private-credit investors and supporting capital-raising flexibility for underwriters and issuers.Payments-fraud RFI (Bulletin 2025-12, June 16)
On June 16 the OCC, Fed and FDIC issued Bulletin 2025-12 and an RFI asking banks, businesses and service providers for ideas—spanning data-sharing, supervision, Fed services and public outreach—to curb surging check- and payments-fraud losses, signaling possible new rules and sharper exam focus.Cost Accounting Standards (CAS) Administration renewal (OMB 9000-0129)
OMB’s June 16 action re-authorises CAS Administration filings—practice-change notices and revised disclosure statements. Although only ~600 contractors are CAS-covered, compliance still consumes roughly 318 000 burden-hours yearly. The extension safeguards audit visibility into accounting-practice shifts that directly affect contract pricing, cost allowability and CAS enforcement.
A thought from our Author Norm Osumi
“The recent decision by the Consumer Financial Protection Bureau (CFPB) to withdraw from enforcement actions against firms like Credit Acceptance Corporation is deeply concerning. These companies have been accused of issuing high-interest loans that often lead to vehicle repossessions and prolonged debt cycles for vulnerable consumers. By stepping back, the CFPB appears to be neglecting its duty to protect those most at risk of financial exploitation. This move not only undermines the agency's mission but also sends a troubling message that predatory lending practices may go unchecked.It's imperative that consumer protection remains a priority, ensuring that all individuals have fair access to financial services without the threat of abuse.”
Ask the PCAOB Whisperer
A: Scan the reports’ common findings list—control testing, revenue recognition, group audits—because inspectors often extrapolate themes across firms and geographies. Use that list to quiz your auditor on how they’ve remediated similar deficiencies in your 2024 audit cycle and what extra procedures (if any) they’ll layer onto 2025.
Weekly Podcasts
We want to keep you engaged with meaningful topics, so we create weekly podcasts and host periodic webinars.
Want to know the real secret behind building lasting business relationships? In our new episode of ReportingNorms.ai, we break down why trust and open communication are at the heart of every partnership, old or new. Plus, we dive into why “sales” isn’t a dirty word, but actually the lifeblood of any thriving company. Curious to learn more? Catch the full episode for a deeper look into how these fundamentals drive success!
Tune in to hear more.
Here’s the audio version of the same:
To watch more podcasts, visit and follow us on ReportingNorms.ai.
Like what you see? Subscribe now and join a growing network of finance leaders building stronger, audit-ready companies.
Reply