March 21, 2006
Macatawa Bank Corporation is $1.8 billion community bank organization located in Western Michigan. Our market capitalization is approximately $375 million, which puts us in the small-cap category, and we have now been subject to the requirements of Sarbanes Oxley section 404 for two years. We are a state chartered bank so we are regulated both by the state and by the FDIC.
Because of the significant regulation that banks face, even before Sarbanes Oxley, I found little to no value in complying with the requirements of section 404. Our internal control systems had already been very well established. 404 merely required us to document our controls in a different way, which proved to be incredibly time-consuming and costly. In addition, our external auditors chose to set very high standards for how to comply with 404 which created additional effort on our part and significant additional fees to them. Our external audit fees increased by 192% from 2003 to 2004 and remained high for 2005 despite receiving unqualified opinions on our controls in both years.
Due to the unnecessary extra effort and significant additional cost in complying with 404, I strongly support the proposal to eliminate the requirement for external auditor attestation of the effectiveness of our internal control system.