SOX Section 404

The implementation of ' 404 of the Sarbanes-Oxley Act (SOX) is essentially complete for large public companies. Most agree it was expensive and proved an immense corporate distraction. According to Financial Executives International (FEI) 94% of executives polled reported that the cost of compliance with ' 404 far outweighed the benefits. Nevertheless, large companies were able to fund the documentation of their control structure and get on with business. Some companies even reported customer service improvements, cost-saving consolidations and streamlined operational benefits stemming from the exercise. But lost in this post-mortem is that the implementation of ' 404 is not finished. Overlooked by many is that ' 404 has yet to be implemented in one of our most important pillars of the U.S. economy, our small public companies defined as those with a market capitalization of less than $75 million.