Study on the Impact of Companies' Compliance with the Requirements Implementing Section 404 of the Sarbanes-Oxley Act of 2002

Forms and Documents

Document Name	Status
404appA_revised_at_OMB_request_061708_ (2).doc Supplementary Document	2008-06-19
404exhibit B_040808 943pEM041008_caEdits_.doc Supporting Statement B	2008-04-15
PRAsuppstmt4040410_revised_at_OMB_request_061808438p_.doc Supporting Statement A	2008-06-19
404appBem041008cafinal_.doc Supplementary Document	2008-04-10
404appA (2).doc Supplementary Document	2008-04-10

IC Document Collections

IC ID	Document Title	Status
184430	Study on the Impact of Companies' Compliance with the Requirements Implementing Section 404 of the Sarbanes-Oxley Act of 2002 Other-APPENDIX A - Draft Questions for Survey	New

ICR Details

OMB Control No: 3235-0641	ICR Reference No: 200804-3235-008
Status: Historical Active	Previous ICR Reference No:
Agency/Subagency: SEC	Agency Tracking No: 270-575
Title: Study on the Impact of Companies' Compliance with the Requirements Implementing Section 404 of the Sarbanes-Oxley Act of 2002
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Regular
OIRA Conclusion Action: Approved with change	Conclusion Date: 06/19/2008
	Date Received in OIRA: 04/16/2008
Terms of Clearance: This survey project is approved for one year, resived as indicated in the cleared versions of the survey instrument and supporting statement. OMB requests that the agency provide a report on the results of this survey research, including information regarding response rates and measures to address potential non-response bias.

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	06/30/2009	36 Months From Approved
Responses	11,000	0	0
Time Burden (Hours)	11,000	0	0
Cost Burden (Dollars)	0	0	0

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Abstract: We plan to undertake a study to determine whether the Section 404(b) auditor attestation requirement is being implemented in a manner that will be cost-effective for smaller reporting companies.

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Authorizing Statute(s): None

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments
60-day Notice:	Federal Register Citation:	Citation Date:
	73 FR 7614	01/23/2006
30-day Notice:	Federal Register Citation:	Citation Date:
	73 FR 20073	04/14/2008
Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Study on the Impact of Companies' Compliance with the Requirements Implementing Section 404 of the Sarbanes-Oxley Act of 2002

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	11,000	0	0	11,000	0	0
Annual Time Burden (Hours)	11,000	0	0	11,000	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The Commission is undertaking a study to inform its evaluation of the effectiveness and efficiency of rules implementing Section 404 of the Sarbanes-Oxley Act of 2002.

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Annual Cost to Federal Government: $700,000

Does this IC contain surveys, censuses, or employ statistical methods? Yes Part B of Supporting Statement

Is the Supporting Statement intended to be a Privacy Impact Assessment required by the E-Government Act of 2002? No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? Uncollected

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? Uncollected

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? Uncollected

Is this ICR related to the Pandemic Response? Uncollected

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 04/16/2008

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