Sarbanes-Oxley 404(b) Reprieve Update: Listen and watch these great video interviews by Meet the Press with Senator Dodd and Senator Shelby about the H.R.4173 - Wall Street Reform and Consumer Protection Act of 2009 via this link: 

I hear stories daily about people who are paying incredible amounts of money to have a third-party implement their internal control infrastructure and then test their internal controls on an annual basis.

The requirement for non-accelerated filers to comply with Section 404(b) may in fact kick in this year after all. It is currently scheduled to become effective for non-accelerated filers on June 15, 2010.

The Senate is meeting right now that could cause the inclusion or exclusion of Section 404(b) from the omnibus financial reform bill (H.R. 4173) or the "Wall Street Reform and Consumer Protection Act of 2009."  

The omnibus financial reform bill (H.R. 4173) or the "Wall Street Reform and Consumer Protection Act of 2009" was passed by the House of Representatives via a vote of 223-202 on December 11, 2009.  This bill would seek to permanently grant a 404(b) reprieve for non-accelerated filers (those with a market capitalization below $75 million).  The bill must now be passed by the Senate to be put into law and their vote has yet to be scheduled.  As it stands now, non-accelerated filers must comply with 404(b) by June 15, 2010; 404(a) has been in effect since 2007 and is not in debate.