Compliance: Thinking outside the Sarbox

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Plans to standardize on a PeopleSoft platform and improve integration among the different modules were in the works, but SOX gave the project some urgency, Haggerty says. "It helps to have that sort of stick to carry," he says.

With so much of the legislation in flux, having a solid relationship between IT and financial staff is also helpful, Blank says. "We've got to be at the table as a partners. If we didn't have that kind of relationship, we'd all be in therapy."

SOX saga

Here are some key milestones of the Sarbanes-Oxley Act.

July 30, 2002: President Bush signs into law the Sarbanes-Oxley Act of 2002.

Aug. 29, 2002: Section 302 goes into effect, requiring CEOs and CFOs of all public companies to personally certify that the reports that their companies file with the Securities and Exhange Commission (SEC) are accurate and complete.


Jan. 15, 2003: SEC adopts Section 406 rules requiring companies to disclose whether they have a code of ethics for their CEO, CFO and senior accounting personnel.

May 27, 2003: SEC adopts Section 404 rules requiring an annual management report on and auditor attestation of a company’s internal controls over financial reporting.

June 18, 2003: SEC sets effective date for Section 404 and initial compliance dates for public companies.

Dec. 15, 2003: Effective date for large companies with fiscal years ending on or after this date to begin filing annual reports within 75 days (down from 90 days) after year-end and quarterly reports.


Jan. 23, 2004: Five companies ask SEC to extend the June 15, 2004, Section 404 compliance date for large companies.

Feb. 24, 2004: SEC announces extension to Section 404 compliance deadlines.

March 11, 2004: SEC votes to adopt additional 8-K disclosure requirements, in accordance with Section 409.

Aug. 23, 2004: Effective date for first provisions of Section 409, expanding the number and type of financial events companies must disclose in 8-K forms.

Dec. 16, 2004: SEC establishes advi- sory committee to examine the impact on smaller public companies.

Nov. 15, 2004: Deadline for large companies to begin complying with Section 404.

Nov. 30, 2004: SEC postpones certain Section 404 compliance deadlines.


July 15, 2005: Current deadline for small companies to begin to complying with the requirements of Section 404.

Dec. 15, 2005: Revised deadline for large companies to begin filing ann- ual reports within 60 days after year-end and quarterly reports within 35 days after quarter-end.

Copyright © 2005 IDG Communications, Inc.

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