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The United States Army Corps of Engineers (Corps) is the sole permitting authority under Section 404.
404 cost reductions resulting from the SEC's recent actions, the final report also will inform any decision to improve the efficiency and effectiveness of Sec.
While a total of 75 percent of survey respondents said that their company had a team responsible for overseeing the implementation of Section 404, for example, companies' risk management departments were only represented on 23 percent of those teams.
2 (AS2), as well as SEC inspections of PCAOB efforts to improve Section 404 oversight.
A recent survey of 1,000 companies by KPMG's 404 Institute, an open forum with more than 15,000 members organized around the exchange of ideas and leading practices regarding SOX Section 404 compliance (www.
The external auditor's section 404 responsibility is to critically evaluate the design and effectiveness of management's internal controls over financial reporting, test as necessary, form an opinion and communicate significant deficiencies and material weaknesses to management and the audit committee.
We think CEOs should seize this opportunity to start pressing for a revision to Sarbox itself, primarily Section 404, which requires companies to have "appropriate controls" over virtually every internal process.
Section 404: The Most Difficult and Complex Aspect of Compliance--Section 404 has created the greatest overall concern in that it establishes direct management responsibility for the assessment of internal controls.
Sarbanes-Oxley represents among the most significant changes to financial reporting since the Securities Exchange Act of 1934, and Corporate America is investing hundreds of millions of dollars on Section 404 compliance," said Timothy P.
This useful guide articulates significant technical issues and provides direction for managers--including CEOs, CFOs, internal auditors and other participants--on implementing section 404.
GLO CPAs will advise on and embrace many SOX 404 regulation topics, including: the basic requirements for management under section 404, the cost of implementation, accelerated filers - compliant as of 2004, the final deadline and required management and auditor assessments and reports for internal controls with non-accelerated filers, new PCAOB guidance for auditors, changes from AS2, new effective dates and reasons for postponing them, new SEC proposals including new guidance for management assessments, and proposed changes to rules and regulations.
The 404 Blog is written and managed by Edith Orenstein, FEI Director, Technical Policy Analysis, who says feedback is welcome, so feel free to post comments.
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