SOX Compliance Under COVID-19: Considerations for Completing Quarterly Assessments

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By
Terry Hartzog, Protiviti Managing Director, and Kristen Kelly, Protiviti Associate Director

A question receiving heightened attention recently is the quarterly evaluation of deficiencies identified in companies’ Sarbanes-Oxley (SOX) programs. Many organizations are considering whether a formal quarterly control deficiency analysis needs to be performed and documented to the same extent as the annual control deficiency analysis.

In this article, we provide a brief reminder on guidance and disclosure requirements, highlight current U.S. Securities and Exchange Commission (SEC) insights and trends, and provide practical considerations that organizations can apply today.

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