According to a review of internal control disclosures made during the month February 2005, 18 companies disclosed material weaknesses in their internal control over financial reporting, and five companies reported deficiencies. Some of the latter disclosures were considered “significant” deficiencies. The total number of 23 disclosures is up slightly from the 18 reported in February […]
Internal Controls
An Analysis Of The (Non) Impact Of SOX 404
In what may be the great non-event of 2005, most companies that report material weaknesses in their internal controls under Section 404 of the Sarbanes-Oxley Act are getting a pass from investors. MARKET REACTION Charted below are stock market reactions to the 18 companies that disclosed “material weaknesses” in their internal controls during the month […]
Deloitte’s Chief Ethics Officer Talks Training, Benchmarking
This profile is the latest in a series of weekly conversations with executives at U.S. public companies who are currently involved in establishing and developing compliance programs. An index of previous conversations is available here. Describe your job for us. My job is to assist the 32,000 people who are part of the various Deloitte […]
SEC Extends SOX 404 For Small Public Companies
THE BASICS Compliance Dates “A company that is a non-accelerated filer, or foreign private issuer that files its annual reports on Form 20-F or Form 40-F, must begin to comply with these requirements for its first fiscal year ending on or after July 15, 2006.” Contacts Sean Harrison, SEC Division of Corporation Finance, (202) 942-2910 […]
Searchable Database: Controls & Procedures
Compliance Week has created the form below, which searches Item II 9A on Form 10-K and Item I 4 on Form 10-Q, entitled โControls and Procedures.โ
SEC Solicits 404 Feedback, Announces Roundtable Dates
As we reported in early February, the SEC has announced that it would host a roundtable on Section 404 of the Sarbanes-Oxley Act and would solicit feedback on implementation challenges. Details have finally been released. According to a Commission announcement last week, the 404 roundtable will be held at 9 a.m. on Wednesday, April 13, […]
SOX 404 Disclosures: Costs Higher Than Expected
In what may be the first analysis of costs incurred by companies while complying with Section 404 of The Sarbanes-Oxley Act of 2002, the Netherlands-based consulting firm of A.R.C. Morgan has found that companies are spending “significantly more than widely anticipated.” Unlike prior surveys or questionnaires regarding SOX 404 costs, which had been conducted by […]
Case Study: SOX 404 Software At Sky Financial Group
This “case study” is the latest in a series of articles aimed at helping public companies understand how other organizations are using technology to comply with new regulations and standards. These are not advertisements or marketing vehicles for the companies mentioned; Compliance Week’s editorial staff speaks with the public company that has deployed the technology, […]
SOX โCatch-22โ: Certifying Controls Later Found Weak
Companies that previously certified “disclosure controls and procedures” under Section 302 of Sarbanes-Oxley may find themselves this year in the uncomfortable position of having internal control audits under Section 404 reveal material weaknessesโwith regulators wondering why those flaws weren’t reported earlier. The SEC’s final rule implementing Section 302 of SOX requires company management to present […]
404 Disclosure: Experts Say Get In Front Of The Issue
Get in front of it while you can. Thatโs the message from experts regarding the disclosures of potential adverse opinions stemming from Section 404 of The Sarbanes-Oxley Act of 2002. As we covered last week in our analysis of internal control disclosures made during the month of January 2005 (see box at right), companies are […]


