Background
The Wall Street Reform and Consumer Protection Act of 2010 – passed in July 2010 -- permanently exempted non-accelerated filers (public companies with a market cap <$75M) from Sarbanes-Oxley, Section 404(b), which requires an external audit review of a company’s internal controls over financial reporting. Instead, non-accelerated filers can continue to “self-certify” the adequacy of their internal controls under the requirements of Sarbanes-Oxley, section 404(a).