Non-accelerated filers may still be hoping for yet another delay in full compliance with Section 404 of Sarbanes-Oxley, but the wise ones should prepare for the inevitable now rather than risk incurring more audit costs later this year.
Small filers have evaded Section 404 for years, with its costly requirement to assess and audit internal controls over financial reporting. Only this year have they begun compliance with Section 404(a)—management’s assessment of internal controls—but the truly fearsome provision has always been 404(b), requiring an external audit of internal control.
As it stands now, small filers must comply with Section 404(b) for ...