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August 9, 2008 - Posted by ccoigne | Uncategorized | | 4 Comments

4 Comments »

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

Comment by Kashif | May 7, 2009 | Reply
- 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.
  
  Comment by ccoigne | July 20, 2009 | Reply
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?

Comment by Erica | July 1, 2009 | Reply
- 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.
  
  Comment by ccoigne | July 20, 2009 | Reply

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About

Ever since its first year of required compliance in 2004, Sarbanes-Oxley and Section 404 in particular has been criticized for the excessive cost and disruption it created for companies. The public debate about whether its been worth the effort has at times reached a fever pitch, as recently noted by the former Chairman of the SEC, Harvey Pitt[1], “As costs mounted, and auditors became defensive in their audits of internal control, a crescendo of criticism and despair arose, ultimately persuading the PCAOB and the SEC to revisit their prior guidance to make the beneficial purposes of the SOX 404 more obtainable, with lower costs and more focused efforts”. In this regard, certain statements from both the SEC and PCAOB December releases especially stand out[2]. At the same time, greater use of a risk based approach seems to reflect a return to the original principles of SOX and certainly of the COSO Framework.

[1] Compliance Week, March 2007 issue

[2] SEC Release # 33-8762, 34-54976 (12/15/06) and PCAOB Release # 2006-007 (12/19/06)

About the Author

Christopher D. Coigne CPA, CIA, CFE is the Senior Manager of Client Services and Product Development for BI International. For the past 5 years Chris has worked extensively with organizations seeking compliance with Sarbanes-Oxley (SOX). He has performed materiality planning and risk assessments, led facilitated control discussions, participated in client SOX Project Management Organizations, and overseen global control testing. Other projects have included managing outsourced Internal Audit activities, performing forensic and fraud investigations to aid in management’s deterrence and detection of fraud, and working to develop a web-based SOX and Internal Audit tool.

A graduate of Rowan University, Christopher’s experience includes public accounting financial audits, controllership in the insurance industry, internal audit management at Philadelphia-based ARAMARK, and consulting work for a variety of global organizations including McDonald’s, Sony, ING and Waste Management.

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SOX 404 Compliance

Sarbanes Oxley Sections 302 and 404