Deadline Looms for Issuers to Share SOX 404 Costs with SEC

Public companies have until Jan. 31 to take advantage of an opportunity to give input to the SEC on their experience with Sarbanes-Oxley (SOX) section 404 implementation.


The SEC has solicited feedback through a voluntary survey as part of its ongoing cost-benefit study of SOX section 404 implementation. “We encourage all companies with Section 404 experience to participate,” James Overdahl, the SEC’s chief economist said in a press release. “The survey provides companies with an opportunity to share their experiences and provide a comprehensive set of facts on the effectiveness and efficiency of compliance with the rules established pursuant to section 404.”


The survey, which is open to any company with section 404 compliance experience, was slated to close Jan. 16 but has been extended to Jan. 31. User IDs and passwords required to complete the survey were sent to SEC registrants. If you have lost your survey password or would like to request one, send a request with your name, title and company to


The SEC plans to pay special attention to smaller companies that are scheduled to begin complying with section 404(b) requirements at the end of this year, according to an SEC press release.


The SEC’s cost-benefit study will help the Commission assess the effects of measures taken by both the SEC and the PCAOB in previous years, including whether the measures have helped companies reduce their compliance costs and whether the Commission should consider additional measures. These measures include SEC guidance for management’s Section 404 assessment, which was issued in 2007, and the PCAOB’s effort to make the Section 404(b) auditor attestation process more efficient.


More information about the 404 survey project can be found at



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