SOX 404 Compliance

Ever since its first year of required compliance in 2004, Sarbanes-Oxley and Section 404 in particular has been criticized for the excessive cost and disruption it created for companies. The public debate about whether its been worth the effort has at times reached a fever pitch, as recently noted by the former Chairman of the SEC, Harvey Pitt[1], “As costs mounted, and auditors became defensive in their audits of internal control, a crescendo of criticism and despair arose, ultimately persuading the PCAOB and the SEC to revisit their prior guidance to make the beneficial purposes of the SOX 404 more obtainable, with lower costs and more focused efforts”. In this regard, certain statements from both the SEC and PCAOB December releases especially stand out[2]. At the same time, greater use of a risk based approach seems to reflect a return to the original principles of SOX and certainly of the COSO Framework.

[2] SEC Release # 33-8762, 34-54976 (12/15/06) and PCAOB Release # 2006-007 (12/19/06)

About the Author

Christopher D. Coigne CPA, CIA, CFE is the Senior Manager of Client Services and Product Development for BI International. For the past 5 years Chris has worked extensively with organizations seeking compliance with Sarbanes-Oxley (SOX).  He has performed materiality planning and risk assessments, led facilitated control discussions, participated in client SOX Project Management Organizations, and overseen global control testing.  Other projects have included managing outsourced Internal Audit activities, performing forensic and fraud investigations to aid in management’s deterrence and detection of fraud, and working to develop a web-based SOX and Internal Audit tool.

A graduate of Rowan University, Christopher’s experience includes public accounting financial audits, controllership in the insurance industry, internal audit management at Philadelphia-based ARAMARK, and consulting work for a variety of global organizations including McDonald’s, Sony, ING and Waste Management.