In May, the Securities and Exchange Commission (SEC) approved its interpretive guidance to management on implementing Section 404 of the Sarbanes-Oxley (SOX) Act of 2002. As a result of the guidance, the Section 404 compliance will require some re-education and application of new knowledge and principles.
What’s new with respect to this guidance? What hasn’t changed? What’s the impact and opportunity for management? How does the new guidance affect the role and responsibilities of the audit committee? This issue of The Bulletin explores these questions and introduces eight important decisions that warrant a fresh look by every SEC registrant subject to SOX compliance requirements.