Sections 302 and 906 of the Sarbanes-Oxley Act (SOX) lay a foundation for restoring investor confidence in the integrity of public reporting. Building on that foundation, Section 404 requires management to file an internal control report with the annual report on Form 10-K. The proposed Securities and Exchange Commission’s (SEC) rules make the Section 404 requirements effective for fiscal years ended after September 15, 2003. This time frame will give the Public Company Accounting Oversight Board (PCAOB) an opportunity to establish the relevant attestation standards.

In this issue of The Bulletin, we address in detail Section 404 of SOX.