If the Committee of Sponsoring Organizations of the Treadway Commission has succeeded in doing what it set out to do, small public companies may soon have an easier time of documenting their internal controls.Back in 1992, COSO issued a set of recommendations, "Internal Control - Integrated Framework." Ten years later, the Sarbanes-Oxley Act of 2002 required companies to certify the adequacy of their internal controls, and the COSO framework became a de facto standard.

SOX Section 404, on internal controls, went into effect for large companies effective November 2004. Overwhelmed with the task of compliance, they objected, but generally managed to meet the requirements. Smaller companies - those with market caps under $75 million - balked at the prospect. Meeting SOX would be unbearably complicated and expensive in both money and manpower. The SEC extended the deadline for compliance until 2007, but they would still have to comply.

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