The Clock is Ticking!

Although the Sarbanes-Oxley, Section 404(b) reprieve failed in the Senate, it will definitely be interesting to see what happens with the vote on the Wall Street Reform Act.  Again, just because the reprieve failed, we are still uncertain on the outcome of 404(b) due this year.  The vote by the Senate as discussed in this great article from MSNBC.com helps shed some light on what may happen:

Here is the Sarbanes-Oxley non-accelerated filer reprieve reality for fiscal filers with yearend dates between June 15 and December 31.  Your auditors are going to expect you to provide them with at least two quarters worth of functioning controls data.  They will also expect to be able to go back in time to randomly test at least two quarters worth of data (so just because you give them your test work does not mean that is all they will ask you for. They will ask for other samples in an attempt to uncover any attempts by you to give them only clean examples and they will watch you pull the samples to ensure you do not have the opportunity to fix problems prior to handing over the documentation). 

There hasn't been any action yet in the Senate.

On Jan. 20th, the bill was: