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Government Affairs >>
SOX 404: How AeA Sought Relief

This timeline does not include numerous AeA council events and meetings on SOX 404 or AeA staff meetings on Capitol Hill.

 
October 2004 AeA establishes 18 SOX 404 working groups in each of AeA’s regional councils
November 2004 AeA establishes National SOX 404 Committee made up of representatives from each council’s local working group

AeA Board of Directors meeting with SEC Chief Accountant Don Nicolaisen to discuss problems with Section 404

December 2004 AeA drafts report on impact of SOX 404 on smaller companies from feedback provided by local working groups and national committee. This is the first report of its kind detailing the problems of SOX 404 and providing recommendations as to how implementation can be improved.
January 2005 AeA National SOX 404 Committee meeting with SEC Chief Accountant and his staff to deliver preliminary AeA report to SEC

AeA CEO meeting with PCAOB Chairman Bill McDonough to convey the problems cited in AeA SOX 404 report

February 2005 Release of AeA report, "Sarbanes-Oxley Section 404: The 'Section' of Unintended Consequences and its Impact on Small Business"

AeA meeting with Government Accountability Office (GAO) to discuss AeA report and GAO SOX study

March 2005 AeA National SOX 404 Committee meetings in DC with:
  • PCAOB Chairman and other board members to discuss AeA report
  • Senator Paul Sarbanes’ Banking Committee Staff Director to discuss SOX 404
  • GAO to discuss SOX 404 costs

SEC announces AeA National SOX 404 Committee chairman, Alex Davern, selected to serve on its newly-created Advisory Committee on Smaller Public Companies

April 2005 AeA National SOX 404 Committee meeting in DC with the “Big Four” accounting firms to discuss AeA report and company concerns relating to SOX 404

AeA National SOX 404 Committee chair participates in SEC’s Advisory Committee on Smaller Public Companies

AeA National SOX 404 Committee chair participates in SEC roundtable on internal controls. During roundtable, PCAOB Chairman McDonough references AeA meeting.

June 2005 PCAOB Chairman McDonough addresses AeA Board of Directors
Summer 2005 AeA provides regulators with preliminary company feedback on year-two SOX 404 compliance
August 2005 AeA and NASDAQ conduct year-two cost survey
September 2005 AeA member company dinner with PCAOB member Dan Goelzer in San Francisco, CA to discuss SOX 404 compliance

Meetings to discuss AeA/NASDAQ survey with SEC Commissioners Glassman and Campos, PCAOB, Representative Mike Oxley, and White House staff

October 2005 AeA and NASDAQ release survey results on SOX 404. Survey showed almost no decrease in costs expected for smaller companies and an overall average decrease of 7.4 percent expected in year two.

AeA member company lunch with PCAOB Chairman McDonough in New York City to discuss SOX 404 compliance

PCAOB announces that AeA Board member and National SOX 404 Committee member, Marty Singer, selected to serve on its 2006 Standing Advisory Group

AeA staff led a panel discussion during House Small Business Committee roundtable on SOX 404

January 2006 AeA Bay Area member company lunch with SEC Commissioner Cynthia Glassman in San Jose, CA to discuss Sarbanes-Oxley
March 2006 AeA National SOX 404 Committee meetings with SEC Commissioners Atkins and Campos, advisors to SEC Chairman Cox and Commissioner Nazareth, PCAOB member Dan Goelzer, Rep. Oxley, and other congressional staff, to discuss AeA support of proposed recommendations to exempt many smaller companies from SOX 404 compliance
April 2006 AeA comments in support of SEC Advisory Committee on Smaller Public Companies’ proposed recommendations which would provide many smaller companies with SOX 404 relief

AeA seeks company feedback for May SEC and PCAOB roundtable on internal controls

May 2006 AeA National SOX 404 Committee chair to participate in SEC and PCAOB roundtable on internal controls

AeA submits comments for House Small Business Committee hearing on impact of SOX 404 on smaller companies


For more information on Sarbanes-Oxley contact Marie Lee, Tax Counsel/Director, Tax Policy, AeA at 202.682.4448.

This page was last updated on 05/05/06.  
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