The Merc Masters Certification

March 1, 2007

by Eric Krell

Leave it to a straight-talking Finance-IT expert to debug a long-standing problem nestled in the dense language of the Sarbanes-Oxley Act.

CEOs and CFOs are required, under Sarbanes Section 302, to scrutinize their publicly listed company's numerous financial reporting controls, identify any deficiencies within those controls, understand how changes to the business might affect internal controls, and then -- based on those assessments -- certify the accuracy of financial reports on a quarterly basis.

The problem is that the process for generating the knowledge required to conduct that scrutiny, as laid out in Section 404 of the act, in most cases occurs on an annual basis. In fact, Section 302 took effect well before the much-delayed Section 404 took effect in December 2004. Many top executives signed their names and then crossed their fingers.

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