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Sarbanes-Oxley Section 404 Implementation

Practices of Leading Companies

Sarbanes-Oxley Section 404 Implementation by Robert A. Howell
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Section 404 of the Sarbanes-Oxley Act of 2002 requires management of public companies to include in their annual reports an assessment of the effectiveness of their financial controls. While the effort to comply with Section 404 has provided some valuable insights, the time, redeployment of people and other costs associated with the initial implementation is not sustainable. Evaluating the results and understanding leading practices of first year implementation activities in an important step to sustainability. This report describes the compliance practices of leading companies for a number of aspects of Section 404 as they transition from a “project” orientation to a sustainable “process.” Based on the experiences of the companies that participate on FEI’s Committee of Corporate Reporting.
Financial Executives Research Foundation; May 2005
58 pages; ISBN 9781933130040
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Title: Sarbanes-Oxley Section 404 Implementation
Author: Robert A. Howell; Cheryl de Mesa Graziano; William M. Sinnett