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Welcome to ZMW!
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 5, 2025) of 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
Binance case dismissed
On May 29 2025, the SEC dismissed with prejudice its long-running civil-fraud and registration suit against Binance and founder Changpeng Zhao. The surprise filing ends U.S. regulatory jeopardy for the world’s largest crypto exchange, signals an enforcement recalibration under Chairman Paul Atkins, and could reset compliance expectations for platforms.CorpFin staking guidance
On May 29 2025, the SEC’s Division of Corporation Finance declared that native, protocol-level proof-of-stake validation generally is not an investment contract, so ordinary validators needn’t register staking under the Securities Act. The long-awaited interpretation narrows enforcement risk and invites rulemaking to address service-provider models ahead.CFPB moves to pause litigation and rewrite Small-Business-Lending Rule (May 28, 2025) – In a motion to stay filed with the Southern District of Florida, the Bureau asked to halt all proceedings and compliance deadlines for the Section 1071 data-collection rule while it launches an expedited, fresh rulemaking. The filing signals the agency’s intent to scrap the 2023 framework and start over.
Section 1071 of the Dodd-Frank Act requires financial institutions to collect and report data on credit applications from small businesses, including those owned by women and minorities. The goal is to facilitate fair lending by identifying potential discrimination and improving access to credit. The data collected includes details such as loan purpose, amount, and applicant demographics.
Investor-alert series on “Relationship Investment Scams” (May 29)
FINRA published an Insight article and fact-sheet warning that fraudsters use social-media or text “wrong-number” messages to groom victims before pitching bogus crypto or FX trades (“pig-butchering” scams). Firms should expect questions from clients and may want to amplify FINRA’s red-flag checklist in their own outreach.
2015 Wells Fargo consent order terminated
29 May 2025 – The OCC closed its long-running 2015 enforcement order against Wells Fargo’s former financial-subsidiary structure, marking the 13th consent order lifted since 2019 and leaving only the Fed’s asset-cap order outstanding. The termination signals regulatory confidence in Wells’ remediation and clears a major hurdle to renewed balance-sheet growth.Sequestration order locked in
OMB’s May 30 deficit-control report triggered the President’s FY 2026 sequestration order, detailing across-the-board percentage cuts to every non-exempt direct-spending account. Unless Congress intervenes by Oct 1, the automatic reductions stand, binding agencies to the savings OMB calculated under BBEDCA; Medicare, farm-price supports and military retirement are exempt.Author’s comment - “Non-exempt direct-spending accounts refer to mandatory federal programs that are not protected by law from automatic budget cuts. These include spending on items like agricultural subsidies, student loan administration, federal employee retirement contributions, certain public health block grants, and vocational rehabilitation services.
These programs are funded by statutes rather than annual appropriations, but because they’re not explicitly exempt (like Social Security or veterans’ benefits), they are subject to across-the-board reductions, called sequestration; when deficit targets are breached under the Balanced Budget and Emergency Deficit Control Act.”
A thought from our Author Norm Osumi
As per this article in The Financial Times, the OECD has downgraded its global economic forecast, projecting the weakest growth since the pandemic, largely due to President Trump’s escalating trade war. Global growth is expected to slow to 2.9% in both 2025 and 2026, with the U.S. economy hit particularly hard, dropping to 1.6% in 2025 and 1.5% in 2026. The OECD warns that U.S. tariffs—now at the highest levels since World War II—are driving inflation higher and delaying Federal Reserve rate cuts. Trade tensions, policy uncertainty, and weak investment are dragging down growth prospects across most G20 countries. The OECD urges global leaders to strike trade agreements to mitigate the economic fallout.
"This OECD's report highlights how uncertainty stemming from our volatile U.S. trade policy is significantly dampening global investment and growth. This confirms the central role America plays in worldwide economic stability. Seemingly arbitrary elevating tariffs and the resulting inflation constraints limit the U.S. Federal Reserve's capacity to stimulate the economy through interest rate cuts. Consequently, our government's ability to address structural issues such as trade barriers and policy clarity emerges as crucial to mitigating these economic risks and reviving global economic momentum."
Ask the PCAOB Whisperer
Q. With the PCAOB’s recent crackdown on audit deficiencies and the SEC’s focus on material weaknesses, should aerospace suppliers with complex revenue recognition models expect more pressure from their auditors?
A: Absolutely. The PCAOB is turning up the heat, especially on revenue recognition, estimates, and internal control testing and the aerospace sector sits right in the blast radius. With long-term contracts, milestone billing, and multi-year delivery cycles, auditors are being pushed to dig deeper into cutoff procedures, percentage-of-completion methods, and the operating effectiveness of controls tied to them.
If you’re an aero supplier relying on “review-level” controls or spreadsheets managed by a single analyst, it’s time to reassess. Auditors don’t want narratives anymore—they want evidence of precision, oversight, and escalation paths. Expect more control deficiency elevation conversations; especially if your system can’t explain timing mismatches or cost reforecasts with audit-trail clarity.
Weekly Podcasts
We want to keep you engaged with meaningful topics, so we create weekly podcasts and host periodic webinars.
On this week’s ReportingNorms.ai, Norm Osumi dives into how MGX is shaking up the global tech industry with $100 billion in investments, game-changing partnerships (think Microsoft, Nvidia, and more), and a push to democratize access to advanced AI. Want to hear who’s giving AWS and GCP a run for their money? Tune in for the full story and get inspired by the future of tech! Listen now—don’t miss out!
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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