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Hi,
I’m trying to do a little research…..was hoping for a start….
For example, let’s say I go public today (2009), what is the first year I have to be SOX 404 compliant? Is it the the same for small or large company? Non-Accelerated or Accelerated file?
If IPO start sometime this year, will I have to be full compliant by end of this year, or since I just became public, I have till end of next year?
If possible, can you post a link for the source…..maybe an SEC ruling/site….
Thanks in advance
Currently the rules are different for accelerated and non-accelerated filers, since non-accelerated filers are not yet required to comply with SOX. All that is scheduled to change for listed companies whose fiscal year ends after 12/15/09. It might be extended, but the feeling seems to be that any additional extensions are unlikely.
What exactly is re-performance testing ?
It sounds like it’s more of the external auditors performing a test of controls that internal audit has already performed. Is that correct?
If so then, how would an external auditor re-perform a control around revenue?
You are correct that re-performance testing is the external auditors actually re-performing the control in question to see if they arrive at the same conclusion as management. Because of the time and expense involved, re-performance should only be done for the most high-risk controls (i.e. impacting material, in-scope balances, and/or the risk of control failure is great due to some factor – excessive judgement required by performer, complexity of accounting principle being applied, etc.