This memo describes the documentation requirements for each process deemed in-scope for a company’s compliance efforts related to Section 404 of the Sarbanes-Oxley Act (SOX).

The three levels of documentation described correlate to the overall financial element and process rating as determined by the SOX Project Steering Team during Phase I and agreed upon by the external auditor. The initial levels of process documentation set forth in Phase I of the SOX project varied upon prioritization of the financial statement element (high or medium) to which the process was linked, as well as the applicability of entity-level controls.