Effective Dates and Compliance Dates of
Rulemaking under Sarbanes-Oxley Act of 2002

As of March 18, 2003

Section Number / Effective Date / Compliance Date / Issue
302(a) / August 29, 2002 / August 29, 2002 / Certification of Disclosure in Companies’ Quarterly and Annual Reports
403 / August 29, 2002 / August 29, 2002 / Accelerated Filing Deadline on Forms 3, 4 and 5 for Change of Beneficial Ownership Reports by Officers, Directors and Principal Security Holders under Section 16(a) of the Securities Exchange Act of 1934
409 / November 15, 2002 / Phase-in period for accelerated filers begins for companies with fiscal year ending on or after December 15, 2002 / Acceleration of Periodic Report Filing Dates and Disclosure Concerning Web Site Access to Reports
306 / January 26, 2003 / January 26, 2003, except that certain Form 8-K filing requirements become effective on March 31, 2003 / Insider Trades During Pension Fund Blackout Periods
306(b)(2) / January 26, 2003 / January 26, 2003 / Regulation BTR: Interim Final Rule Relating to Notice of Blackout Periods to Participants and Beneficiaries
406-407 / March 3, 2003 / Fiscal years ending on or after July 15, 2003 (December 15, 2003 for audit committee financial expert disclosure for small business issuers) / As to Companies other than Investment Companies: Code of Ethics for Senior Financial Officers and Disclosure of Audit Committee Financial Expert
302; 406-407 / March 1, 2003 (May 1, 2003 for Form N-SAR certification removal) / Generally between March 1, 2003 and May 1, 2003, with various rules differentiating between fiscal periods ending before, or on or after, April 1, 2003 and July 15, 2003 / As to Investment Companies: Code of Ethics for Senior Financial Officers and Disclosure of Audit Committee Financial Expert
802 / March 3, 2003 / Audits and reviews completed after October 31, 2003 / Retention of Records Relevant to Audits and Review
401(b) / March 28, 2003 / March 28, 2003 (for earnings releases and other items, the compliance date is for any date, or period ending, on or after March 29, 2003) / Regulation G: Conditions for Use of Financial Information Containing Non-GAAP Financial Measures (including furnishing a reconciliation to GAAP for non-GAAP information contained in earnings releases)
401(a) / April 7, 2003 / Fiscal years ending on or after June 15, 2003 (off-balance sheet disclosure) and December 15, 2003 (table of contractual obligations) / Disclosure in Management’s Discussion and Analysis about Off-Balance Sheet Arrangements and Aggregate Contractual Obligations
301 / [1] / To be decided / Standards Relating to Listed Company Audit Committees
303 / [2] / To be decided / Improper Influence on Conduct of Audits
Title II
(201-206 and 208) / May 6, 2003 / Transition dates up to May 6, 2004 in determining impairment of accountant’s independence, and up to May 6, 2003 for calculating periods of service / Strengthening the Commission’s Requirements Regarding Auditor Independence
403 / [3] / To be decided / Mandated Electronic Filing and Web Site Posting for Forms 3, 4, and 5
501(a) / [4] / To be decided / Treatment of Securities Analysts by Registered Securities Associations and National Securities Exchanges
307 / August 5, 2003 / August 5, 2003 (but comment period extended for “noisy withdrawal” provisions) / Implementation of Standards of Professional Conduct for Attorneys
404 / [5] / To be decided / Management Assessment of Internal Controls

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[1]Proposed rules are pending, and the Sarbanes-Oxley Act of 2002 requires final rules by April 26, 2003.

[2]Proposed rules are pending, and the Sarbanes-Oxley Act of 2002 requires final rules by April 26, 2003.

[3]Proposed rules are pending, and the Sarbanes-Oxley Act of 2002 requires final rules by July 30, 2003.

[4]Proposed rules are pending, and the Sarbanes-Oxley Act of 2002 requires final rules by July 30, 2003.

[5]Proposed rules are pending, but there is no effectiveness deadline mandated by the Sarbanes-Oxley Act of 2002 for such rules.