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Reference: File Number 4-497

Reference: File Number 4-497 2025

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The document is a letter from the Committee on Corporate Reporting of Financial Executives International to the Securities and Exchange Commission, providing feedback on the implementation of Section 404 of the Sarbanes-Oxley Act. It discusses the high costs and burdens associated with compliance, particularly for smaller companies, while emphasizing that the intent of the Act has not been fully realized in preventing fraud. The letter suggests several recommendations for refining guidance and practices to reduce compliance burdens without compromising effectiveness, including adopting a risk-based approach, allowing greater reliance on internal audits, and improving communication between auditors and management.

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