By:  Cydney Posner

The NYSE continues to be active on the SOX 404 front. Below is a letter from the NYSE discussing its observations and recommendations for improving SOX 404, reflecting the efforts of an NYSE working group. The recommendations may be viewed here. While a number of the recommendations echo those of the SEC Advisory Committee on Smaller Public Companies (see my postine of 4/25/06), several of the concepts are novel, such as recommendations for a three-year rotational audit on internal control, with only negative assurances provided annually, and integration of the financial statement audit and all internal control procedures with the result that only one audit is performed with one audit opinion issued.

This content is provided for general informational purposes only, and your access or use of the content does not create an attorney-client relationship between you or your organization and Cooley LLP, Cooley (UK) LLP, or any other affiliated practice or entity (collectively referred to as "Cooley"). By accessing this content, you agree that the information provided does not constitute legal or other professional advice. This content is not a substitute for obtaining legal advice from a qualified attorney licensed in your jurisdiction, and you should not act or refrain from acting based on this content. This content may be changed without notice. It is not guaranteed to be complete, correct or up to date, and it may not reflect the most current legal developments. Prior results do not guarantee a similar outcome. Do not send any confidential information to Cooley, as we do not have any duty to keep any information you provide to us confidential. When advising companies, our attorney-client relationship is with the company, not with any individual. This content may have been generated with the assistance of artificial intelligence (Al) in accordance with our Al Principles, may be considered Attorney Advertising and is subject to our legal notices.