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 July 25, 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

  • Christine Hunsicker / CaaStle – $250 million offering-fraud charges (LR-26352, July 18 2025)
    On July 18 2025, the SEC sued CaaStle founder Christine Hunsicker for a $250 million offering fraud. She allegedly fed investors doctored audit reports and financials that overstated revenue by 7,300 %, hid dilutive share issuances, and falsely touted profitability. The SEC seeks injunctions, disgorgement, penalties, an officer-director bar, and DOJ parallel criminal action.

  • Cognizant ex-executives Gordon Coburn & Steven Schwartz – FCPA case dismissed (LR-26351, July 15 2025)

    On July 15 2025, the SEC voluntarily dismissed its long-running FCPA civil action against former Cognizant CEO Gordon Coburn and COO Steven Schwartz, filing a joint stipulation with prejudice. The Commission emphasized the dismissal was a policy judgment rather than a merits decision, hinting at a softer stance on legacy overseas-bribery enforcement.

  •  Imer Gomez / Helios Venture Fund – $9 million adviser fraud (LR-26349, July 14 2025)

    On July 14 2025, the SEC charged Texas adviser Imer Gomez, K&G Investment Solutions, and Helios Venture Fund with stealing roughly $9 million from clients. Gomez allegedly promised double-digit returns and 75 % insurance, never traded, sent fake account statements, and spent the money on luxury items and Ponzi-style payouts. Injunctions, disgorgement, and penalties sought.

  • Withdrawal of State-Official Notification Rule (Docket CFPB-2025-0016, 90 FR 34165)
    Responding to significant adverse comments, the CFPB on July 17 2025 withdrew its May direct-final rule that would have abolished 12 CFR 1082’s requirement that state attorneys general notify the Bureau before enforcing the Consumer Financial Protection Act. The reversal preserves state-federal coordination until a full rule-making occurs.

  • Comptroller issues statement on enactment of the GENIUS Act (NR 2025-73 • July 18)

    The Comptroller of the Currency, Jonathan V. Gould, issued a statement on July 18 regarding the enactment of the GENIUS Act. This new law extends OCC oversight to non-bank payment stablecoin issuers, establishing a new regulatory framework for digital-asset firms that will require new licensing and supervisory regimes.

  • Agency Downsizing & Reorganization Progress Check-ins

    A joint memorandum from the Office of Personnel Management (OPM) and the Office of Management and Budget (OMB) reminds agencies that their Phase-2 Agency Reorganization and Reduction Plans (ARRPs) must contain detailed timelines, clearly defined reductions in force (RIF) triggers, and monthly progress reports; the next submission was due 16 July. OMB is asserting a central oversight role in monitoring workforce cuts mandated by recent executive orders.

    Impacts: (1) tighter OMB-validated milestones; (2) earlier identification of positions vulnerable to RIF; (3) heavier monthly reporting workload; (4) less agency discretion over pacing downsizing; (5) increased accountability for missed targets.

A thought from our Author Norm Osumi 

As discussed earlier in the news highlights, the CFPB’s reversal of its direct-final rule to abolish the state notification requirement is a major win for consumer protection. By maintaining 12 CFR 1082, the Bureau ensures state attorneys general must continue to notify the CFPB before independently enforcing the Consumer Financial Protection Act. This coordination helps avoid duplicative or conflicting enforcement actions and promotes better information-sharing. For consumers, it means stronger, more consistent oversight of predatory practices and financial abuses.

The July 17, 2025 withdrawal (Docket CFPB-2025-0016, 90 FR 34165) signals a commitment to transparency and cooperative federal-state efforts in safeguarding consumer financial rights. Had the rule passed, it would have marked a shift away from structured cooperation between state and federal enforcers. While states would gain more autonomy, the collective effectiveness of consumer protection especially against large, complex financial actors would likely have been diminished. The CFPB’s July 17, 2025 withdrawal preserves this critical coordination framework.  Please see my Podcast, The ReportingNorms, Episode 8 where I discuss how deregulation has affected the CFPB.  This rule reversal is a great example of how the CFPB continues to protect customers as intended.

Ask the PCAOB Whisperer

Changes are happening at the PCAOB after the SEC requested Chair Erica Williams’s resignation on July 22 and installed longtime insider George Botic as acting chair the next day. The Commission also opened applications for all five board seats, signaling a top to bottom reset that could temper the watchdog’s aggressive posture. Over the next six to twelve months we should expect a holding pattern: no new audit standards, a pause on headline grabbing enforcement, and budget friction as the SEC questions salaries and staffing growth. Quality control reforms already adopted will still march toward implementation, yet projects on firm governance, cybersecurity and AI may slip into 2026. Once a new board is seated, observers foresee a more measured agenda that balances investor protection with audit cost. Auditors should monitor budget hearings, shortlist leaks, and any slowdown in China work paper inspections to carefully gauge the incoming board’s true appetite for oversight.

Weekly Podcasts

We want to keep you engaged with meaningful topics, so we create weekly podcasts and host periodic webinars.

In our latest ReportingNorms.ai episode, Takashi Ueki dives into how transparent data modeling and pipeline consistency can boost business agility and trust across teams. Discover why democratizing data access is a game-changer and how to strike the right balance for your business. Tune in to the full episode now and take your HR analytics to the next level!

Tune in to hear more.

Here’s the audio version of the same:

To watch more podcasts, visit and follow us on ReportingNorms.ai.

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