From: Lynn Mottram, CIA, CFE |
Your exposure draft takes into consideration the onerous effect of Sarbanes-Oxley 404 compliance for small companies, specifically micro-cap, and companies with revenues under $250M. However, it does not consider industries such as distribution companies, in which the revenues may be over $250M, but low net profit. Our company is a small cap accelerated filer in which our Sarbanes- Oxley compliance costs are almost 9% of of net profit. It would be a huge relief for low margin, low profit companies to receive relief from the external audit testing of management’ internal control testing and assertions. Respectfully submitted, Lynn Mottram, CIA, CFE |