A new survey says that the average cost for the internal controls provisions of the Sarbanes-Oxley Act is $3.8 million, down 16.3 percent from last year and about halfway to the drop anticipated for the second year of compliance.

Financial Executives International polled 274 public companies with average revenues of $6 billion, 238 of which are accelerated filers. It was the fourth SOX compliance survey FEI has conducted since 2004.

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