What is Going to Happen With Section 404 of the Sarbanes Oxley Act

8/7/2019 What is Going to Happen With Section 404 of the Sarbanes Oxley Act

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_____________________________________________________________ International Association of Risk and Compliance Professionals (IARCP)

www.risk-compliance-association.com

International Association of Risk and ComplianceProfessionals (IARCP)

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- What is going to happen with Section 404 of the SarbanesOxley Act?

Dear Members,

What is going to happen with Section 404 of the Sarbanes Oxley Act?

What is next for Sarbanes Oxley experts? This is always one of the most

important issues we discuss in the association.Today we will study a really important opinion: A report by members of the Office of Economic Analysis, U.S. Securities and ExchangeCommission (SEC). The Commission has expressed no view regardingthe analysis, findings, or conclusions contained herein.

OFFICE OF ECONOMIC ANALYSIS - UNITED STATESSECURITIES AND EXCHANGE COMMISSION (SEC)Study of the Sarbanes-Oxley Act of 2002 Section 404 Internal Controlover Financial Reporting Requirements

Executive Summary

The Public Company Accounting Reform and Investor Protection Act,otherwise known as the Sarbanes- Oxley Act (the Act), was enacted inJuly 2002 after a series of high-profile corporate scandals involvingcompanies such as Enron and Worldcom.

Section 404(a) of the Act requires management to assess and report on the


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effectiveness of internal control over financial reporting (ICFR).

Section 404(b) requires that an independent auditor attest tomanagements assessment of the effectiveness of those inter nal controls.

Because the cost of complying with the requirements of Section 404 of theAct (Section 404) has been generally viewed as being unexpectedlyhigh, efforts to reduce the costs while retaining the effectiveness of compliance resulted in a series of reforms in 2007.

This report presents an analysis of data from publicly traded companiescollected from an SEC-sponsored Web survey of financial executives of companies with Section 404 experience conducted during December 2008and January 2009.

The analysis of the survey data is designed to inform the Commission andother interested parties as to whether changes occurring since 2007 arehaving the intended effect of facilitating more cost-effective internalcontrols evaluations and audits, especially as they may apply to smallerreporting companies.

The findings of the analysis relating to efficiency include evidence on thetotal and component compliance costs, the changes in costs over time,and the factors that help to explain why costs are lower or higher for some

companies than for others.

These findings include evidence of direct and indirect effects thatmanagement ascribes to Section 404 compliance, including evidence onintended benefits.

The 2007 reforms that are the focus of thi s inquiry include the SECs June2007 Management Guidance and its order approving the Public CompanyAccounting Oversight Boards (PCAOB) Accounting Standard No. 5(AS5) (collectively referred to as the 2007 reforms).


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We are primarily interested in wh ether and how companies experiencewith Section 404(b) compliance changed following the reforms, yet thisreport also presents evidence on the implementation of both Section404(a) and Section 404(b).

This reflects the interrelationship between the two requirements.

The survey was open to all reporting companies with relevant experiencein complying with Section 404, recognizing that only large acceleratedfilers and accelerated filers are currently required to comply with bothSection 404(a) and Section 404(b) and, thus, have information on theoverall cost of compliance with these sections.

These experienced filers that responded to the survey tend to have public

float in excess of $75 million, which is large compared to that of non-accelerated filers that are not yet required to comply with Section404(b).

The evidence on the experiences of larger companies may be useful inevaluating the extent to which additional improvements to theimplementation of Section 404(b) should be undertaken before itbecomes applicable to non-accelerated filers.

Notwithstanding, it is important to highlight that the analysis in this

report is not designed to provide compliance cost estimates forcompanies that have yet to comply with the relevant requirements of Section 404.

The general conclusion from the analysis of survey data is thatcompliance costs vary with company size (increasing with size),compliance history (decreasing with increased compliance experience),and compliance regime (lower after the 2007 reforms).

Larger companies tend to incur higher compliance costs in dollar terms(absolute cost), while smaller companies report higher costs as a


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among smaller companies toward evaluating the effectiveness of ICFR and away from the tasks of identifying risks to the companys financialreporting and identifying controls that address identified risks.

These respondents, however, had a less favorable response to a questionabout the SECs responsiveness to concerns about compliance costs.

The Web survey also included questions about respondents perceptionsof other potential effects of Section 404 compliance, including potentialbeneficial effects.

In particular, respondents were more likely to report direct benefits of compliance with Section 404 rules (i.e., improvements directly related to acompanys financial reporting process, such as the quality of the

companys ICFR), rather than indirect benefits of compliance (i.e.,improvements indirectly related to a companys financial reportingprocess, such as the companys ability to raise capital).

Respondents from larger companies and Section 404(b) companies tendto regard Section 404 compliance more favorably than those from theircounterparts in almost every respect.

Before turning to a more detailed outline of findings, it will be useful toprovide some background on the size and compliance categories of the

companies that are the subject of the study.

Throughout the analysis, respondents are partitioned based on the size of their company using the size thresholds that parallel the SECs reportingthresholds.

Under SEC regulations typically non-accelerated filers have publicfloat of less than $75 million; accelerated filers have public float between$75 million and $700 million; and large accelerated filers have public float of $700 million or more.


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The evidence on the costs and benefits of Section 404(b) compliance isalmost entirely from the last two g roups, which are termed large andmedium/mid -sized companies in this report, because smallcompanies (with public float less than $75 million) were typically not yetrequired to comply with Section 404(b) at the time of the survey.

Following previous research, in some instances, the analysis of smallercompanies focuses on those having a public float falling within a bandabove and below the $75 million threshold that distinguishesnon-accelerated from accelerated filers.

In addition, to separate the effects of Section 404(a) compliance fromthose of Section 404(b), when appropriate the analysis partitionscompanies that were compliant with both Sections 404(a) and 404(b) in

the relevant fiscal year (henceforth Section 404(b) companies) fromthos e that are compliant with Section 404(a) only (henceforth Section404(a)- only companies).

A more detailed presentation of findings as answers to the centralquestions of the report follows:

Q1. How does the cost of complying with Section 404 vary acrosscompanies, and what factors influence a companys compliancecost?

The total cost of complying with Section 404 varies across companiesdepending on

(1) The companys size,

(2) Whether the company is complying with Section 404(a) only or alsowith Section 404(b),

(3) The companys experience in complying with Section 404(b), and


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(4) Whether compliance occurred before or after the 2007 reforms.

Specifically, the absolute compliance cost in dollar terms tends toincrease with company size (measured by public float), but the costscaled by asset value tends to decline as company size increases.

As one would expect, total compliance costs are typically larger forcompanies complying with Section 404(b) in addition to Section 404(a).

Longer experience with Section 404(b) compliance, however, isassociated with a decrease in the typical reported costs (scaled bycompany assets).

The cost of compliance tends to be lower after the 2007 reforms than

before and this decrease is most pronounced among larger companies.

Q2. What is the observed trend in Section 404 compliance cost beforeand after the 2007 reforms?

The Web survey collected response data on audit fees, outside vendor fees,non-labor costs, and internal labor hours.

These cost components were aggregated using conservative assumptionsin order to obtain a dollar estimate of the total cost of compliance (seeSection IV.a).

The evidence generally indicates that the typical total compliance costshave decreased from the year prior compared to the one after the 2007reform and are expected to decrease further in the fiscal year in progressat the time of the survey.

Among Section 404(b) companies, the mean total Section 404 compliancecost drops significantly from $2.87 million pre-reform to $2.33 millionpost-reform, representing a 19 percent decline in the total compliancecost.


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The compliance cost is expected to be lower still, with a mean cost of $2.03 million, representing a combined decline of 29 percent.

When reporting compliance costs by size category, the mean totalcompliance cost decreases from $769,000 to $690,000 among filers withpublic float lower than $75 million, but this difference is not statisticallysignificant.

The reduction in compliance costs is more pronounced among themedium and large companies that are already required to comply withSection 404(b).

The medians reveal similar patterns for the typical company in oursample.

The median total Section 404 compliance cost declines significantly from$1.19 million pre-reform to $1.04 million post-reform, a 13 percent decline.

The median expected cost for the fiscal year in progress is lower still, at$905,000, a combined decline of 24 percent relative to the pre-reformmedian cost.

For non-accelerated filers, the median total compliance cost decreasedfrom $579,000 to $439,000, but, as with the means, the difference for these

companies is not statistically significant.

When analyzing first-time compliance costs before and after the 2007reforms, the results are mixed and the mean decrease in total costs is notstatistically significant.

In contrast, for companies in their second year of compliance withSection 404(b), both the mean and median compliance costs aresignificantly lower after the 2007 reforms than before.

Meanwhile, among Section 404(a)-only companies, the mean total cost


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also decreased from $425,000 pre-reform to $336,000 post-reform, but thedifference is not statistically significant, and the median cost actuallyincreased from $111,000 to $162,000.

Both the mean and the median, however, are expected to decrease for thefiscal year in progress at the time of the survey.

Q3. How do the component costs of complying with Section 404compare, and how have they changed since the 2007 reforms?

For Section 404(b) compliant companies, the largest cost component isinternal labor costs which can comprise more than 50 percent of thetotal compliance cost followed by the estimated portion of total auditfees attributed to ICFR (404(b) audit fees), outside vendor fees, and

non-labor cost.

In general, every component cost declines after the reforms compared tothe year before, and is projected to decline further in the fiscal year inprogress.

The most notable changes in the cost components between pre-reformand post-reform are observed in the outside vendor fees and the percentof the total audit fees attributable to ICFR.

The mean outside vendor fee decreases by 29 percent from $438,000pre-reform to $311,000.

The median outside vendor fee decreases by 10 percent from $100,000 to$90,000.

Both differences are statistically significant, and the outside vendor feesare expected to decrease significantly to a mean cost of $222,000 andmedian cost of $55,000 in the fiscal year in progress at the time of thesurvey.


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financial reporting (49 percent), the companys ability to preven t anddetect fraud (48 percent), and the respondents confidence in the financialreports of other companies complying with Section 404 (40 percent).

The majority of respondents recognize no effect of Section 404compliance on: the companys ability to raise capital, investor confidencein the companys financial reports, the companys overall firm value, andthe liquidity of the companys common stock.

Finally, the perceived effect of Section 404 compliance on the efficiency of the operating and financial reporting processes and the timeliness of thecompanys financial statement audit varies widely: while a majority of respondents perceive no effect on these dimensions, non-trivial portionsof respondents recognize a negative effect that is, a reduction in the

efficiency of the operating and financial reporting processes and/or thetimeliness of financial statement audit.

In the cross-section, larger companies were more likely to ascribe positivedirect and indirect effects to Section 404 compliance than were smallercompanies.

Q5. What are the reported benefits of Section 404 compliance fromthe perspective of financial statement users?

In order to obtain a more complete picture of the effects of Section 404implementation, staff members from the SECs Office of the Chief Accountant conducted separate in-depth phone interviews of a sample of 30 users of financial statements including lenders, securities analysts,credit rating agencies, and other investors.

Although the sample is admittedly smaller than that of issuersparticipating in the survey, the evidence gathered is useful because itprovides the perspective of financial statement users on the effects of Section 404 compliance.


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In general, financial statement users regard ICFR disclosures to bebeneficial and indicated that Section 404(a) and Section 404(b) compliance has had a positive impact on their confidence in thecompanies financial reports.

The users generally indicate that Section 404 compliance leadsmanagement to better understand financial reporting risks, put in placeappropriate controls to address financial reporting risks, and addressinternal control deficiencies in a more timely fashion than in the absenceof the disclosure requirement.

Although, users offer divergent opinions regarding the extent to whichdisclosures of material weakness affect their decision-making process,most agree that severe weaknesses that could take years to remediate are

likely to negatively affect their decision-making.Users tend not to perceive the benefits of Section 404 compliance to varywith the size of the reporting company.

Instead, many indicate that these benefits depend on a companyscomplexity and industry affiliation. At the same time, the users agree thatvariations in compliance requirements based on complexity and/orindustry would likely be impractical.

Finally, most users indicate that the benefits they perceive from Section404 compliance have not changed substantially over time.

This is an important finding since it indicates that the 2007 reforms, whileintended to reduce certain duplicative efforts in conducting theevaluation of ICFR, did not at the same time change financial statementusers perception of the effectiveness of Sect ion 404.

Regarding the Section 404(b) requirement, the general consensus is thatthe auditors report on ICFR required under Section 404(b) provides anincremental benefit beyond the managements report because many


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respondents perceive the audit requirement to provide necessarydiscipline to the reporting process.

Although some users express the concern that ICFR evaluation maydivert managements attention from other important areas of theirbusinesses, these respondents continued to believe that strong ICFR isnecessary and that financial statements need to be of high quality andreliable.

Most users interviewed indicate that the process of compliance withSection 404 has become more efficient since the initial implementation in2004 due to:

(i) reduction in the level of documentation,

(ii) improved communications between auditors and management,

(iii) increased use of professional judgment in scoping and testing,

(iv) more focus on higher risk areas, and

(v) streamlining of audits subsequent to the first-time effort required bySection 404 compliance.

Q6. In what ways have the Commissions 2007 reforms affected thecompanies procedures of complying with Section 404?

Nearly all respondents who completed an optional section of the surveyrequesting feedback on managements Section 404(a) experienceresponded that they used Management Guidance and found it to beuseful.

Those who responded indicate that both Management Guidance andAuditing Standard No. 5 have helped reduce the total cost of compliance,for companies in every size category.


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The respondents also indicate on average that Auditing Standard No. 5resulted in a small decrease in the time it takes to complete theindependent audit of ICFR.

The perceived impact of AS5, however, varies with the size of thecompany and its experience with Section 404(b) compliance.

Specifically, the perceived impact of AS5 on the time it takes to completethe independent audit of ICFR is significantly smaller among small filersand among companies with no previous experience with Section 404(b)compliance.

When asked to compare the changes in activities associated withmanagements evaluation of ICFR, the respondents in dicate a slight

decrease on average from pre-reform to post-reform in the number of risks subject to testing, the number of controls tested, but a slightincrease in the level of documentation, the use of managementsinteraction with controls as evidence, reliance on evidence gained fromself-assessment, and reliance on evidence from direct testing.

Like much of the previous results, the responses varied significantlydepending on the respondents size.

While smaller companies typically report an increase in every component,

the changes reported by medium and large filers are not homogenous.

Interestingly, however, the evidence suggests that the complianceprocess across companies of different size has become more homogenousfollowing the 2007 reforms.

Finally, the survey evidence indicates that companies are increasinglystructuring their evaluations of ICFR with the intent of allowing theindependent auditor to rely on their internal work, which is consistentwith one of the goals of the 2007 reforms through Auditing Standard No.5.


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Some caveats about the analysis of Web survey data on Section 404implementation

There are a number of caveats to consider when interpreting the evidencepresented in this study, some of which are due to the inherent nature of survey data, while others are the result of the particular context in whichthe Section 404 survey takes place.

First, most, if not all, analyses of survey data are affected to variousdegrees by the following potential difficulties:

Self -Selection Bias (i.e., Non-response Bias):Participation in survey research is generally voluntary.

The process by which survey participants select to participate in asurvey can bias the inference based on survey data, if the participants(self-) selection process is such that particular segments of the populationare systematically over- or under-represented.

We conduct extensive analyses to test for the presence and the potentialseverity of the problem, particularly by investigating the extent to whichkey characteristics of the sample of respondents to the survey coincide ordiverge from those of the list of companies identified as the targetpopulation.

We find that respondent companies are representative of the initial list of public companies identified for this study, particularly among Section404(b) companies or within company size groups.

We also find that the typical responses of voluntary participants in thesurvey are not significantly different from those of a randomly selected,stratified sample of companies that were the target of follow-up efforts toinduce their participation.

Overall, the evidence is consistent with the notion that the voluntary


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nature of the participation introduces no bias in the responses, at leastrelative to the separate treatment group where part of the decision toparticipate is a result of the follow-up effort.

Response Bias:If there are no penalties for misrepresentation and survey participantshave systematic incentives to be less than fully truthful, inference basedon survey data (or any other self-reported information that meets thosecriteria) may not be accurate.

A similar problem arises when survey questions are designed to elicit theparticipants subjective perceptions on a particular subject and theparticipants views are systematically biased.

The portion of survey data that we could independently verify (i.e., auditfees) indicates that the participants representations do not deviatesubstantially from what is reported in official SEC filings.

Aside from this exercise, it is virtually impossible to assess the extent towhich the remaining survey data may not be accurate.

The nature of the survey questions varies, with some questions focusingon quantifiable items (e.g., internal labor hours) and others on directionalperceptions (e.g., assessment of the effect of Section 404 on the quality of

ICFR) and others still on directional/ordinal perceptions (e.g.,assessment of the effect of AS5 on the amount of time it takes to completethe independent audit under Section 404(b)).

The common element, however, is that these data cannot beindependently verified, either because companies are do not keep aseparate record of the figures provided (e.g., costs) or because theinformation provided is based on the respondents perceptions which bytheir very nature are not verifiable.

The analysi s in this report provides a characterization of companies


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experiences with Section 404 compliance that is based on surveyparticipants representations of their experiences.

Other caveats are specific to the analysis presented in this report, as theydepend on the nature and timing of the survey.

In particular:

1. The number of respondents from Section 404(b) companies that arenon-accelerated filers and have usable data is relatively small approximately 100 companies versus over 1,600 accelerated filers in themost recently completed fiscal year (see Table 9) and there are reasonsto believe the experience of these companies may not extend to othernon-accelerated filers that are yet to comply with Section 404(b).

Specifically, non-accelerated Section 404(b) companies that participatedin the survey are either voluntary compliers or have been required tocomply in the past as accelerated filers and must continue to do sobecause their float has not dropped below $50 million since.

To the extent that these factors affect companies experience with Section404(b) compliance, one should be careful when extrapolating the resultsto non-accelerated filers that are yet to comply.

2. Non-accelerated filers were required to start complying with Section404(a) at the end of 2007 after the reforms.

Yet, a number of non-accelerated filers responding to the survey reportedbearing Section 404 compliance costs prior to the reform.

These respondents were contacted after the survey was closed to inquireabout the nature of the information provided.

These respondents indicated that their company began complying withSection 404 requirements prior to the Commissions public


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announcement that the compliance deadline had been extended and,thus, they viewed the resulting pre-reform costs reported in the survey asappropriately ascribed to Section 404(a) compliance.

The analysis of non- accelerated filers experience prior to the reformsshould be interpreted with the caveat in mind that it may not berepresentative of what the typical non-accelerated filer would haveexperienced.

3. The characteristics of the internal governance structure and financialreporting process are likely to be important determinants of thecompanie s compliance experiences, including costs and benefits and thenature of the audit services they obtain under Section 404(b).

To the extent that accelerated and non-accelerated filers displaysignificant differences in these dimensions, it may not be appropriate toextrapolate the analysis of accelerated filers to non-accelerated filers.

4. All the cost figures presented in this analysis are based on surveyrespondents characterization of the resources devoted to Section 404compliance.

As such, the general caveats above apply. Moreover, there are someaspects specific to our analysis:

a. All estimates presented in this report are based on non-auditednumbers based on the respondents perception provided in the survey.

Moreover, the nature of the estimates is limited by the scope of the survey.

b. There are reasons to question the ability of respondents to provide anaccurate breakdown of audit fees into Section 404(b) fees versus financialstatement audit fees.

Auditors interviewed by the SECs OCA staff highlight this difficulty on


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the basis that, for Section 404(b) companies, the two audits are integratedand audit firms do not typically provide a breakdown of the fees.

Based on conversations with issuers, however, it seems routine for themto request and obtain audit fee quotes that account for the incrementalauditors work under Section 404(b) requirements before the companybegins complying with this section of the Act.

Thus, it is possible that respondents attribution of audit fees to Section404(b) may be inaccurate, to the extent that they are based on quotesprovided by auditors upon first-time compliance with this section andthat such a breakdown does not apply in subsequent years of compliance

c. It is important to note that the estimates of internal labor costs

presented in this report are based on an assumption about a reasonablehourly rate.

The rate adopted for internal labor is $121 per hour, consistent with therate quoted as of September, 2008 for a junior accountant cited in a reporton salaries prepared by the Securities Industry and Financial MarketsAssociation (SIFMA), to which the Commission frequently refers in itsrulemakings.

This is at the low end of cost estimates that are provided in the SIFMA

report for accounting and related services, and above the rate of $50/hour(or $100,000 for 2000 hours) that is assumed in a series of FinancialExecutives International (FEI) reports of survey findin gs relating to thecosts of compliance with Section 404 that date back to 2005.

Although our assumed rate is within the range of reasonable estimates forevaluating the overall costs of compliance, it is not intended for use inestimating the cost to an individual company.

We have provided information sufficient for determining how the internallabor costs are affected by changes in the hourly rate e.g., doubling


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companies systematically shirk in complying with the Exchange Actrequirements absent SOX, then the incremental economic cost of Section404 compliance should include the aforementioned maintenanceexpenses that would not be borne absent Section 404.

Similarly, it is worth noting that a parallel logic applies to the benefits of Section 404 compliance.

That is, from an economic perspective, the incremental benefits of Section 404 include the improvements in ICFR resulting from thedeferred maintenance that would not have occurred absent the new disclosure requirements of Section 404.

5. Participants in the survey provided their perceptions of the effects of

Section 404 compliance, both on the financial reporting process and theircompanys interaction with capital market participants. The followingcaveats should be kept in mind for this part of the analysis:

a. The assessment of the benefits is qualitative in nature, given theintrinsic difficulty of quantifying the benefits of Section 404 compliance inmonetary terms, and not directly comparable to the cost estimatesprovided by the same respondents.

b. In addition to lack of comparability with cost estimates, the analysis of

the survey responses about the benefits of compliance may be subject toresponse bias.

In particular, the response bias would seem to be especially relevant whenparticipants provide their assessment of how Section 404 complianceaffects subjects outside the corporation (e.g., investors confidence in thecompanys reports).

The resulting analysis may be biased if the respondents perception ortheir representation of those perceptions is biased.


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With this caveat in mind, the staff of the SECs Office of the Chief Accountant (OCA) conducted in-depth interviews with individualsrepresenting a variety of external users of financial statements to gathertheir views on the effects of Section 404.

This effort complements the analysis of the views expressed by thecompanies participating in the survey, in combination providing abroader and more complete assessment of the effects of Section 404 oncapital market participants.

6. In various parts of the survey, the participants provided informationabout their experience with Section 404 compliance over several years: themost recently completed fiscal year; the fiscal year prior to that, and thefiscal year in progress at the time of the survey.

While responses referring to the participants past experience reflectevents that are certain, responses for the fiscal year in progress at the timeof the survey result in estimates and perceptions that are intrinsically lessprecise, due to the inherent uncertainty about future events.


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What is Going to Happen With Section 404 of the Sarbanes Oxley Act

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