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Both the SEC and the PCAOB have recently issued revised compliance standards for public companies and independent auditors respectively. These new standards have been designed to reduce the cost and complexity of Section 404 compliance by encouraging a top-down, risk-based assessment of a company’s internal controls over financial reporting. Greater emphasis is now placed on the oversight role provided by boards of directors and audit committees, as well as on fraud detection and prevention. While compliance with Section 404 will first become effective for non-accelerated filers in at the end of 2007, both accelerated and non-accelerated filers now face the challenge of interpreting this new guidance and maintaining compliance with limited internal resources – time, money, and expertise.
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