No Shortcuts On Road To Compliance

As a fledgling sportswriter in the early 1980s, I had the opportunity to meet famed New York sports columnist Dick Young at a prizefight and asked the acerbic scribe -- who was credited with coining the famous moniker "Joe Baby" when sarcastically referring to quarterback Joe Namath -- if he could offer me any tips to become better at my craft.

Young, whose take-no-prisoners writing style won him legions of admirers but few friends, looked at me dourly and said, "Son, you'll get your stories by working, there's no shortcut. Period."

And with that he returned to watching the fight, turning his back to me -- an unmistakable sign that the day's lesson was over.

Since that time, I've often thought about how the late columnist's advice rang true with literally every avenue where it's tempting to take a shortcut -- save for driving.

The same theory obviously could be applied to ensuring adequate internal controls.

In past debates about costs in time, money and people to comply with Sarbanes-Oxley 404, it appeared that those most affected were looking for that elusive shortcut.

Especially small companies, which to be fair, were and are, at a disadvantage with respect to the capital costs associated with SOX 404. Those aforementioned filers defined as those with market caps under $75 million, adopted the "squeaky wheel" posture and were recently given until 2007 to come into 404 compliance. Meanwhile their larger siblings were mandated to be 404-ready in November 2004.

Last week, the wee folks got some more help.

The Committee of Sponsoring Organizations -- a 20-year-old private sector group -- issued a draft to help small filers comply with internal controls requirements on a more cost-effective basis.

Basically the proposal outlines some 26 elements of financial controls, how to ensure their adequacy, and also offer some ways to reduce costs for small filers.

The proposal is currently out for comment, and once those opinions begin coming it will serve as a barometer as to whether it will either quell, or prolong, 404 complaints from the smaller companies.

If not, then small cap filers may well be drawn into that uncomfortable if not dangerous temptation of asking where do they draw the line between adequate and inadequate internal controls?

The latter sounds disturbingly like the dreaded "s" word - shortcut. That brings me back to the lesson I was taught about veering in that direction.

Twenty years later I've never forgotten it.

Here's hoping small filers won't have to learn it.

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