One overriding and consistent theme that is emerging is that time is running out to achieve compliance. Many corporations are in fact hoping there will be further extensions to the June 2004 deadline. In conversation with SEC staff, it was suggested that the political environment was not conducive to further slippage, and the June 2004 target date has been passed into law. For those undecided about a course of action and those assessing the feasibility of their current action plans, the following is a suggested timeline:
|
Early Fall (2003) |
Mid November |
Mid January (2004) |
Mid March |
Mid May |
|
|
|
|||
|
Selected Strategy |
Implementation |
Build & Test |
Implement & Educate |
Execute |
|
- Assessment completed of which pattern to follow |
- Processes Mapped - Application and Providers selected |
- Applications Integrated |
- Transition & migration - Staff education - Documentation |
|
After reviewing the SOX requirements and beginning the process towards attaining compliance, CFOs are quickly realizing the enormity of the project. According to the Wharton School of Business, a new PricewaterhouseCoopers survey of 136 CFOs and managing directors of U.S. multinationals shows that executives today view Sarbanes-Oxley less favorably than they did last year. The percentage with a favorable opinion of the legislation stood at 30% in June, down from 42% in October. This downward spiral is expected to continue.
Sarbanes-Oxley will change the landscape of corporate America. For companies that have not invested in risk management and quality programs the journey will be time consuming and expensive. It is even reasonable that by the spring of 2004, the financial markets will set valuation premiums for corporations that are on target for compliance with the new regulations. Stated differently, Sarbanes-Oxley compliance may well be viewed as a capability that will separate and differentiate the well-managed corporation.