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October 2004 |
AeA establishes 18 SOX 404 working groups in
each of AeA’s regional councils |
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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 |
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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. |
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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 |
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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 |
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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 |
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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. |
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June 2005 |
PCAOB Chairman McDonough addresses AeA Board
of Directors |
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Summer 2005 |
AeA provides regulators with preliminary
company feedback on year-two SOX 404 compliance |
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August 2005 |
AeA and NASDAQ conduct year-two cost survey |
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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 |
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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 |
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January 2006 |
AeA Bay Area member company lunch with SEC
Commissioner Cynthia Glassman in San Jose, CA to discuss Sarbanes-Oxley |
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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 |
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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 |
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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 |