Sarbanes-Oxley Section 404 Survey Deadline Extended By SEC
Jan. 16, 2008
On Jan. 16, 2009 the U.S. Securities and Exchange Commission issued a press release announcing it has extended the deadline on its Sarbanes-Oxley Section 404 implementation survey; the new deadline is Jan. 31.
Participation in the survey is voluntary; companies are asked to provide their names in the survey. Links to the survey and additional information can be found in the press release.
The SEC is trying to gather information on registrants’ views and related data, as to the costs and benefits of internal control reporting under new guidance issued in 2007 by the SEC (management guidance) and Public Company Accounting Oversight Board (AS5, which replaced AS2), which were aimed at improving the cost/benefit balance and making internal control reporting more efficient and effective.
As announced in earlier press releases (e.g. SEC’s June 20, 2008 press release), the SEC intends to use information gained from the survey to determine if any further improvements in the rules are desirable for companies of all sizes, and in particular before small public companies (nonaccelerated filers) become subject to Sarbanes-Oxley Section 404(b), the requirement for external auditors to audit internal control over financial reporting, in addition to (by integrating it with) the existing audit of the financial statements.
Separately, on Jan. 15, 2009 the SEC published the (235-page) Record of Proceedings of its 27th Annual Government-Business Forum on Small Business Capital Formation. The forum was hosted by the SEC last November.
Prepared by Edith Orenstein, Director, Technical Policy Analysis, Financial Executives International (FEI). This summary does not represent FEI opinion unless specifically noted above.