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sox section 404: assessment of internal control

the most contentious aspect of sox is section 404, which requires management and the external auditor to report on the adequacy of the company's internal control over financial reporting (icfr). this is the most costly aspect of the legislation for companies to implement, as documenting and testing important financial manual and automated controls requires enormous effort. under section 404 of the act, management is required to produce an �internal control report� as part of each annual exchange act report. see 15 u.s.c. � 7262. the report must affirm �the responsibility of management for establishing and maintaining an adequate internal control structure and procedures for financial reporting.� 15 u.s.c. � 7262(a). the report must also �contain an assessment, as of the end of the most recent fiscal year of the company, of the effectiveness of the internal control structure and procedures of the issuer for financial reporting.� to do this, managers are generally adopting an internal control framework such as that described in coso.
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