The Center for Audit Quality

June 26, 2008	Internal Control Over Financial Reporting in Exchange Act Periodic Reports of Non-Accelerated Filers
August 3, 2007	Definition of the Term Significant Deficiency
June 20, 2007	Amendments to Rules Regarding Management's Report on Internal Control Over Financial Reporting
December 15, 2006	Internal Control Over Financial Reporting in Exchange Act Periodic Reports of Non-Accelerated Filers and Newly Public Companies
June 5, 2003	Management's Report on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports

FAQs for Management on ICFR	Management's Report on Internal Control Over Financial Reporting and Certification of Disclosure in Exchange Act Periodic Reports Frequently Asked Questions, September 24, 2007
ICFR Guidance for Management	Commission Guidance Regarding Management’s Report on Internal Control Over Financial Reporting Under Section 13(a) or 15(d) of the Securities Exchange Act of 1934, June 20, 2007
404 Brochure for Small Business	Sarbanes-Oxley Section 404: A Guide for Small Business

Filer Status
Filer Status		Management Report on ICFR	Auditor Attestation on Management's Report on ICFR
U.S. Issuer	Non-accelerated filer (public float under $75 million)	Annual reports for fiscal years ending on or after December 15, 2007	Annual reports for fiscal years ending on or after June 15, 2010
U.S. Issuer	Large accelerated filer and accelerated filer (public float above $75 million)	Annual reports for fiscal years ending on or after November 15, 2004	Annual reports for fiscal years ending on or after November 15, 2004
Foreign private issuer	Non-accelerated filer (public float under $75 million)	Annual reports for fiscal years ending on or after December 15, 2007	Annual reports for fiscal years ending on or after June 15, 2010
Foreign private issuer	Accelerated filer (public float above $75 million and below $700 million)	Annual reports for fiscal years ending on or after July 15, 2006	Annual reports for fiscal years ending on or after July 15, 2007
Foreign private issuer	Large accelerated filer (public float above $700 million)	Annual reports for fiscal years ending on or after July 15, 2006	Annual reports for fiscal years ending on or after July 15, 2006
U.S. or Foreign private issuer	Newly public company	Second annual report	Second annual report

Source: Internal Control Over Financial Reporting in Exchange Act Periodic Reports of Non-Accelerated Filers *

* On October 2, 2009 the SEC announced an additional six month deferral for non-accelerated filers from complying with the provisions of Section 404(b) of the Sarbanes-Oxley Act of 2002. Under this extension, non-accelerated filers will now be required to provide the auditor attestation reports in their annual reports for fiscal years on or after June 15, 2010. This deferral is not currently reflected in the SEC’s compliance date table within Release No. 33-8934, Internal Control Over Financial Reporting In Exchange Act Periodic Reports of Non-Accelerated Filers.

CAQ Alert #2009-88	SEC Announces Final Deferral of 404(b) Requirement for Smaller Public Companies, October 5, 2009
CAQ Alert #2008-94	SEC's Findings of Section 404(a) Deficiencies for First Time Filers, December 31, 2008
CAQ Alert #2008-81	Section 404(b) Reporting by Non-Accelerated Filers After Exiting Accelerated Filer Status, November 25, 2008
CAQ Alert #2007-66	Items to Consider Regarding Management's Report on Internal Control for Audits of Non-Accelerated Filers, December 19, 2007
CPCAF Alert #146	SEC Provides Further Relief from Section 404 Requirements for Smaller and Newly Public Companies, December 18, 2006
CPCAF Alert #46	Reporting Considerations for Non-Accelerated Filer Audit Reports, March 22, 2005

SEC Spotlight

Spotlight On: Internal Control Reporting Provisions