What is next? 196



  • I had a meeting today where there was a discrepancy on what it is to come after the company complies with SOX. Even though it was my belief that SOX compliance will be reviewed on an annual basis, seems that the organization I work for is planning to review it on a quarterly basis. Is that the legal requirement or it is at deiscretion of companies?
    Thanks and good day.



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  • I believe you havet to attest to it quarterly but only have to report it annually.



  • Depends on what section of the act you’re talking about…and how you implement.
    Section 302 requires your CEO and CFO to attest that your internal controls over disclosures not only are OK, but have been reviewed during the quarter. You also would have to disclose any significant changes to internal controls in 302. That cert calls for at least some level of effort, many companies rely on ‘sub-certifications’ from senior management to the execs, backed up by questionnaires, etc.
    404 is an annual cert, as of 12/31/XXXX, each year. As the DIA of my firm, and the person responsible for doing all the testing, I can assure you that MY company will be doing the 404 testing incrementally throughout the year, rather than all at once at the end.
    HTH
    Ben



  • Thanks for all your comments folks.
    That exactly meets my thought that, even though it has to be reported annually, the sensible idea is to establish some sort of periodic control that allows to split the burden and, beiseds will also allow a better feedback and feed forward flow.
    Ben, I can only say, ‘Courage mon brave’ as you seem you will have some fun with all the testing for the 404 section… 🙂
    Cheers,
    Ivan


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