More than 5,000 companies have spent much time, energy, and professional fees grappling with the Section 404 requirements of the Sarbanes-Oxley Act. Getting the job done was tough. The environment was dynamic as regulations and advice were emerging, and the stakes were high with the threat of public consequences for failure to meet deadlines or requirements. Project teams endured late nights and juggled last-minute requests and scope extensions while suffering through regular and detailed scrutiny from audit committees and company boards. And then there was the expense: Sarbanes-Oxley compliance cost the average company in excess of $5 million.
Learning from the experience to develop a more measured approach is the next challenge, as the Securities and Exchange Commission itself recommended: "Both management and external auditors must bring reasoned judgement and a top-down, risk-based approach to the 404 compliance process."
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