All this makes me glad I am in the uk

-----Original Message-----
From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED] Behalf Of Susan Joslyn
Sent: 06 August 2004 14:39
To: [EMAIL PROTECTED]
Subject: RE: [U2] [OT] Sarbanes-Oxley


Three more things about Sarbanes-Oxley ... most important, acronyms.  I
immediately latched onto SOX but the accounting world and the official sites
started calling it SOA.  So I used that for the article but I still like SOX
mainly because its unique and because you can say it.  :)

Tony, SOX doesn't have a whole lot of specifics in it.  Most of the
specifics are coming from COSO which was "endorsed" as an accounting frame
work by SOX.  Section 404 is the one that is driving a lot of the specific
requirements and as you can see here it is open to much interpretation (see
below).

Bill, I think you misunderstood me.  I didn't say auditors should drive it.
I said the problem is that we are allowing that to happen.  Everyone I know
in IT is responding to requests from auditors rather than saying "Okay, lets
study up a bit and see what we can bring to the table to meet the
requirement.  Cut 'em off at the pass, I say.

And Bill, I *love* this remark -- for this is exactly what has now occurred!
> My point is there are more powerful arguments for structural
ineffectiveness rather than some surreptitious human behavior.  Besides, one
controls human behavior by instituting institutional structural controls.
:-)


TITLE IV
Section 404 
Management Assessment Of Internal Controls 

(a) RULES REQUIRED- The Commission shall prescribe rules requiring each
annual report required by section 13 of the Securities Exchange Act of 1934
(15 U.S.C. 78m) to contain an internal control report, which shall--

(1) state the responsibility of management for establishing and maintaining
an adequate internal control structure and procedures for financial
reporting; and

(2) contain an assessment, as of the end of the most recent fiscal year of
the issuer, of the effectiveness of the internal control structure and
procedures of the issuer for financial reporting.

(b) INTERNAL CONTROL EVALUATION AND REPORTING- With respect to the internal
control assessment required by subsection (a), each registered public
accounting firm that prepares or issues the audit report for the issuer
shall attest to, and report on, the assessment made by the management of the
issuer. An attestation made under this subsection shall be made in
accordance with standards for attestation engagements issued or adopted by
the Board. Any such attestation shall not be the subject of a separate
engagement
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