How Nov. 15, 2004 Deadline for Sarbanes Oxley 404 Compliance Affects YouPublic companies have 90 days from
end of their fiscal year to comply. For those with market capitalization of $75 million or more, this clock starts on Nov. 15, 2004; while all others with less than $75 million market capitalization begin July 15, 2005.
Fast Relief for Sarbanes Oxley Section 404 Compliance
Section 404 of
Sarbanes-Oxley Act requires management to confirm
effectiveness of their IT and financial controls in an "internal control report", which is contained within
annual report (10-K) issued to
public. But what exactly is an internal control report, and why is it important to you?
The Section 404 Internal Control Report
First,
internal control report must affirm management’s responsibility for controls and procedure, and second, it must contain an assessment of
effectiveness of
internal controls and procedures for financial reporting. Although both of these issues might at first appear difficult to solve, they are actually not as hard as you would think.
Management’s Responsibility for Controls and Procedures
Affirming management’s responsibility for controls and procedures means more than to simply say management believes in or trusts their system. The affirmation will also need to include a program for a code of ethics for senior financial officers. The program must include prompt disclosures of any changes to your ethics program. So how do you do this?
Business Ethics and Compliance Program
You can easily implement a business ethics program using a step-by-step guide for developing your firm’s business ethics and compliance program. This manual will save you time researching, writing and editing your program. It provides sample policies, surveys, forms and training session outlines that are fully editable using MS Word. And it is also fully endorsed by The National Association of Corporate Directors (NACD) as a tool to maintain a culture of integrity.