SOX for non-accelerated filers

SOX 404 has two key components: Section (a) requires management to conduct an assessment of its internal controls over financial reporting (ICFR) and disclose in its MD&A its findings. Companies have had to comply with this for some time. Section (b) requires a company’s external auditors to assess and attest as to the effectiveness of management’s ICFR. It is generally accepted that the auditor’s attestation makes complying much more onerous.

Non-accelerated filers (companies with a market float under $75m) have been provided a permanent exemption from Sarbanes-Oxley 404(b). However, management must still complete its own assessment of internal controls over financial reporting as they have been required to do so for the past few years.

Efficiently meeting the requirements can still be a challenge. Success projects leverage the lessons learned over the past several years by larger companies combined with focusing on changes by the regulators, new guidance from the SEC and tailored guidance for smaller companies from the Committee of Sponsoring Organisations (COSO).

At Breakwater, we have been working with companies to help achieve compliance in the most efficient and effective manner while still meeting the rigorous standards of the external auditors, including the Big 4. Our proven methodology and experience has helped our clients benefit by achieving compliance without breaking the bank or creating unnecessary complexity.

For information on how Breakwater can assist in ensuring you meet your internal control compliance requirements please go to our SOX / 52-109 information page or contact Steven Figner, Incorporated Partner, at sfigner@breakwateradvisors.ca or 778 331 2230.