The provision, which goes into effect Nov. 15, will cost public companies 63 percent on average more than they had previously thought, according to a new survey by Financial Executives International (FEI).
The increase in Section 404 compliance costs stems from unexpected burdens experienced in connection with the two major requirements of the provisions.
First, each company’s annual report must contain a statement of management’s responsibility for an adequate internal-controls structure and procedures for financial reporting and management’s assessment of the effectiveness of those procedures. Second, the provision requires the company’s auditor to report and sign off on that assessment of the effectiveness, in accordance with standards set up by the Public Company Accounting Oversight Board (PCAOB).
For the first requirement, many companies are documenting internal controls for 92 percent of total revenue, the survey showed.
In January, survey respondents estimated an average $590,100 in fees to their auditors to attest their internal controls. In July, the average projection for attestation fees was $823,200 — on top of annual audit fees.
Another reason for the revised compliance costs is a 42-percent jump in other external costs, such as an average added $1.037 million for software and IT consulting.
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