March 30, 2005
I appreciate the opportunity to submit my comments on the Sarbanes-Oxley 404 process and our experience during 2004.
Overall, the process took approximately 18 months to complete, with out-of-pocket expenditures of approximately 900,000 and approximately 40,000 hours of staff time, which was a significant time commitment for a company with approximately 1900 employees during 2004.
There were benefits from this experience as you would expect from a detailed review of any control environment. But the banking industry is heavily regulated with ongoing examinations from the Federal Reserve, OCC, external and internal auditors, and the FDIC as well as the existing FDICIA legislation. We estimate that our overall expenditures were in the 2,000,000 range when you include an estimate of the staffs salaries and benefits. Given that banking, by its very nature, has to have a strong control environment, I am not sure the benefits were equal to the level of expenditure or the commitment of the staffs time from other projects.