SEC Remediation

[ERISA-Bubs]

We had an SEC audit recently, and the SEC found some issues that they say require remediation.

I don't want to get into too much detail about the actual issues, but we would like to remediate them by contacting the affected parties directly and explaining to them the issue and what we are doing to correct it.  We do not want to put anything in writing.  While we want to fully correct the issues, we do not want to risk any reputational harm that may stem from having written documentation out there, implying that we did something nefarious.

Is anyone aware whether the SEC ever allows "oral" remediation?  Are there any examples out there of this ever happening?

The SEC handbook defines remediation as "dismissing or appropriately disciplining wrongdoers, modifying and improving internal controls and procedures to prevent recurrence of the misconduct, and appropriately compensating those adversely affected."  We intend to do this; we just want to do it orally.

Thank you all!