When engaged in an ambitious effort, be it climbing a mountain, building a house, or writing a novel, many people have a tendency to quicken their pace once the long-sought goal finally comes into view. The same holds true for Sarbanes-Oxley Section 404 compliance projects. Many months have gone into documentation, testing, and remediation, and […]
Internal Controls
Small Company Confesses To Violation Of SOX 402
A specialty chemical company recently informed the Securities and Exchange Commission that it violated new rules prohibiting loans to executives. It also said a deficiency identified by its auditor caused the company’s disclosure controls and procedures not to be effective at a โreasonable assurance level.โ Although the case involves a very small company, it provides […]
Q&A With EVP, CFO Of $1.4 Billion PSS World Medical
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. Rumor has it you printed T-shirts for your Section 404 project team. True? We did. One of the fun parts […]
Compliance With Section 404 Costing More Than Expected
According to a recent study conducted by Financial Executives International, complying with Section 404 of The Sarbanes-Oxley Act will cost public companies over 60 percent more than previously anticipated. The study, which surveyed 224 public companies with average revenues of $2.5 billion, pegged the total cost of “year one” compliance at $3.14 million. That’s a […]
36 Internal Control Disclosures In July
SECTION 404 The July Data View The Actual Internal Control Disclosures From July View Sample Disclosures Of Remediation Efforts From July According to a review of regulatory filings during the month of July, 36 companies disclosed material weaknesses or significant deficiencies in internal controls, or provided material updates on the status of their control-improvement processes. […]
Q&A With VP Internal Audit, Ethics At $1.6b PETCO Animal Supplies
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 is available here. So, have any pets yourself? Oh yes. I have two rat terriers; theyโre in the terrier dog […]
Q&A With Tyco SVP Governance Eric Pillmore
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. You volunteered for this jobโlots of people would guess youโre a glutton for punishment. What was your thinking? Well, it […]
SEC, PCAOB Staff Comment On SOX 404 FAQs
At a recent teleconference hosted by financial print giant RR Donnelley, SEC Division of Corporation Finance Director Alan Beller and Public Company Accounting Oversight Board Member Daniel Goelzer fielded a variety of questions and recommended filers “listen to the music” being played in the FAQs. The session was produced by legal publisher Glasser LegalWorks, which […]
U.K. Turnbull Guidance Will Be Reviewed, Updated
The U.K.-based Financial Reporting Council announced recently that it would reviewโand likely updateโthe 1999 Turnbull Guidance. The 14-page “Turnbull Report,” published in September 1999 by the Institute of Chartered Accountants in England and Wales, includes guidance for implementing sound internal controls for U.K. companies listed on the London Stock Exchange. Though the report is widely […]
Where Do We Go From Here? ROI A Priority, But Not Widely Tracked
As companies race toward the Nov. 15 deadline for the internal control provisions of Sarbanes-Oxleyโubiquitously known as โSOX 404โโthe last thing on most compliance executivesโ minds is next yearโs compliance requirements. INGREDIENTS According to experts, there are three core elements to ongoing complianceโpeople, process, and technology. 1. People According to Stephen Wagner, chairman of the […]


