4th qtr testing deadlines 2234

  • I am new to the SOX world and am leading a project with significant resource constraints. We have finished Interim testing and I am trying to schedule for 4th quarter testing. Can anyone tell me if it is acceptable to do 4th qtr testing after Jan 1 and if so is there a deadline requirement. Thanks any help would be appreciated

  • The only deadline would be your SEC filing deadline when you have to report on the effectiveness of your controls.

  • You can test controls anytime prior to filing your 10k, as kymike stated.
    Keep in mind that you should allow time for remediation and retesting of those controls that fail. We’re on the fiscal calendar year and I am targeting 1/31/08 for Q4 test results to be finalized, with remediation efforts, if necessary, to occur in February.
    Hope this helps.

  • donc, when is your year-end?
    kymike is correct to state that the SEC filing deadline is the drop dead date
    Igor is also right to point out about allowing time for remediation.
    The key point is you can undertake Q4 testing after year-end and before SEC filing BUT should you find any material weakness during this period then you have no time to remediate because your year-end date has already passed which would then point to an adverse SOX opinion. The only exception to this rule is where you have a control that only operates after year-end such as a consolidation control which in my book can still be remediated before you finalise your accounts.

  • Would there really be ample time to remediate even if you did your testing in the last month of Q4? If an exception is identified during Q4 testing that required major remeditation efforts to correct, would it really matter if you identified on December 15th or January 15th? We’re a non-accelerated filer so this is year one for us, and while based on prior quarter testing I don’t foresee any exceptions occurring that would rise to a material weakness, I am concerned about the timing of our testing in general.

Log in to reply