What happens after the deadlines? 310
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The Act requires an annual certification by management that internal controls over financial statements are effective. This means on going monitoring and testing of all controls. Our company (as will most) will be doing quarterly reviews and updates to the documentation so that as of the year end date we are comfortable that our controls are adequate to cover all of the risks we have identified.
The Sarbanes Oxley work does not end on December 31st - it has only just begun.
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Actually management have to add a statement about their internal controls with the quarterly SEC filing - so testing has to be done quarterly too to provide something to support mangement’s statement.
Some of the higher risk controls will be tested even more frequently. IA’s work is never done…
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A question about ongoing compliance… my Firm is implementing new software in the 1st quarter, and they’re asking whether the new software (and processes that surround it) must be fully compliant prior to implementation.
Is that everyone else’s understanding? Or, is it feasible to implement the application, then identify and remediate any control deficiencies?