Section 404 Compliance: Lessons Learned for the Next 12 Months

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The Bulletin: Volume 2, Issue 8

In 2006, the Securities and Exchange Commission (SEC) held a roundtable discussion on the second year experiences with the internal control reporting and attestation provisions of the Sarbanes-Oxley Act of 2002 (SOX). The following week, both the SEC and Public Company Accounting Oversight Board (PCAOB) announced their plans to follow-up on the roundtable results and feedback they received.

Because of these developments and because many accelerated filers are either preparing for or executing their third year Section 404 assessments, it is a good time to reflect on lessons learned. In this issue, we articulate seven lessons for improving Section 404 assessment and compliance processes.

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