（2009）Auditor Attestation of Internal Control Over Financial Reporting：What You Can Expect-A Smaller Public Company Perspective.pdfVIP

Auditor Attestation of Internal Control Over Financial Reporting: What You Can Expect A Smaller Public Company Perspective Smaller public companies were required to comply with the management assertion requirement of Section 404 of the Sarbanes-Oxley Act for their annual report filings for fiscal years ended on or after December 15, 2007. These companies will be subject to the auditor attestation requirement of Section 404 for those annual reports filed for fiscal years ended on or after December 15, 2009. This paper explores considerations for smaller public companies as they prepare for their first auditor attestation of internal control over financial reporting. IntroductIon Many smaller public companies will soon be subject to their first auditor attestation. For those holding out hope that the U.S. Securities and Exchange Commission (SEC) might eliminate, or limit in some way, the attestation requirement for smaller public companies, insights as to the SEC’s likely future actions were suggested in writ- ten responses by SEC chairwoman, Mary Schapiro, to questions she received from Senator Carl Levin during her confirmation process. In her letter to Senator Levin, Ms. Schapiro provided insight into how she will differ from her predecessor, Christopher Cox. With respect to Sarbanes-Oxley compliance, she noted that “it’s time we bring uniformity to the system.” This point virtually assures the markets that the auditor attestation of management’s assertion on the effectiveness of internal control over financial reporting (ICFR) eventually will become a reality for smaller public companies. Many smaller public companies are already reporting on ICFR. AuditA released a report detailing its analysis of Year Four Sarbanes-Oxley filings. The analysis revealed that for filings through September 10, 2008, the SEC received 3,435 annual reports with an unattested management assertion on the effectiveness of IC