SEC Launches Survey Of Section 404 Costs, Benefits

Last week, the SEC launched its online survey of the costs and benefits of internal control reporting under Sarbanes-Oxley Section 404 and related rules of the SEC and PCAOB. The survey is available here: http://www.sec.gov/spotlight/404survey.htm. Responses to the survey are voluntary, and the SEC seeks responses from interested parties by year-end. As noted in SEC’s June 20, 2008 press release, the SEC extended the implementation date of the external audit of internal control under Sarbanes-Oxley Section 404(b) for smaller companies, in part to provide time to conduct and analyze the results of this survey, and determine if any further improvements to the rules can be made (following the 2007 SEC management guidance and PCAOB’s AS5 replacing AS2). Small co’s are currently subject to the requirement to provide a management report on internal control under Sarbox 404(a), and they are still subject to the regular audit of the financial statements, just not the additional audit of internal control under Sarbox 404(b) at this time. The SEC's survey could provide information that may potentially result in changes to the rules under Sarbox or the implementation thereof, and could potentially impact large as well as small public companies. Read more about the SEC’s Sarbox survey here.

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