Section 404 has two parts. Under 404(a), management of a US public company must document its internal controls over financial reporting and assess their effectiveness annually. Under 404(b), accelerated and large accelerated filers must also have their external auditor attest to that assessment. Typical controls include account reconciliations, journal entry approvals, access restrictions and management review controls.
In practice teams maintain a risk and control matrix, test controls through the year and fix deficiencies before year end. A deficiency that could allow a material misstatement is a material weakness and must be disclosed.
In software: Workiva offers SOX documentation and testing alongside its filing tools, AuditBoard focuses on SOX and internal audit workflows and FloQast added compliance management so close tasks double as control evidence.
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