Jim DeLoach, Protiviti, Inc.
As companies take stock of their focus on "pass/fail" compliance with Section 404 of the Sarbanes-Oxley Act, it is time to reflect on the objectives and costs of the effort. While the SEC's new guidance to management and the PCAOB's revamping of AS2 will help improve the cost-effectiveness, senior management has a more important opportunity to focus on quality and sustainability. This article asserts that every organization should take a step back to evaluate how to transition from the narrow focus on pass/fail compliance to a cost effective, sustainable and value-added process.