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Sarbanes-Oxley Act: Section 404 Practical Guidance for ...

Sarbanes-Oxley Act: Section 404 Practical Guidance for Management* July 2004 *connectedthinking This monograph is designed to assist management in its efforts to satisfy its responsibilities established by the Public Company Accounting Reform and Investor Protection Act of 2002. The monograph is based on rule-making and Guidance available as of July 2, 2004; accordingly, as new rules or modifications or interpretations to existing rules emerge, certain aspects of this monograph may become obsolete. Because interpreting this Guidance is proving to be an evolutionary process, preparers and users are cautioned to carefully evaluate and monitor further implementation Guidance from the Securities and Exchange Commission (SEC) and the Public Company Accounting Oversight Board (PCAOB).

process, this monograph should provide useful information in developing their overall strategy for implementing Section 404. It is worth noting that interpreting these new rules has proven to be an evolutionary process. Additional future interpretative guidance may be issued by the SEC for registrants and by the PCAOB for external auditors.

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