Big4Guy

Sarbanes Oxley Section 404 implementation project to be successful needs to be a enterprisewide program. I have had the oppurtunity to assist many Fortune 500 companies in their quest for Sarbanes Oxley Compliance. I am clearly seeing a pattern with such huge corporations as to how they go on and handle a complaince project like Section 404 compliance. I would like to share some of my learnings from big corporations. These are common mistakes you could avoid in complying with Section 404 of the Sarbanes
Oxley.

1. Tone at the Top - Section 404 compliance projects are most successful when they are coordinated at the top level. The CFO Chief Financial Officer or CEO Chief Executive Officer supported by Audit Committee and senior management can set the correct tone for 404 compliance.

2. Make Realistic Timelines - When planning for Section 404 make sure your timelines and resource requirements are realistic. Make sure you have planned for time overruns and additional resources.

3. Status Reporting - Reporting progress and milestones of the 404 project to the audit committee, Board of Directors, and external auditors on a regular basis can go a long way in streamlined compliance. Status reporting to above mentioned forums also avoids any bad surprises later on.

4. Focus on Risk Management - One thing all companies learnt was that efforts for planning, documenting, evaluating, testing took more than the planned time in Year one. Going forward, for streamlining processes
focus needs to be more on risk management. This can significantly improve the compliance effort.