From: Bill Ulland
As CEO of IKONICS Corporation, a small NSADAQ (IKNX) company, I would like to register our strong support for the recommendations of the Advisory Committee on Smaller Public Companies to exempt companies of our size from Rule 404.
We are a small ($14,000,000 in sales) and profitable ($900,000) company which has been public since 1952, without a hint of accounting irregularity. We were recently named as one of the 100 fastest growing American public companies. Our stockholders have done well and our employees and community have also benefited from our success.
The cost impact of Rule 404 on a company our size is potentially devastating (even without Rule 404 our audit fees have increased by 250% since 2002) and creates a strong incentive for us to either delist or sell the company. I donít believe either is in the best interest of our stockholders or our employees.
An further irony in this is that the rush of new business created by SOX to the Big Four accounting firms has caused them to either jettison less lucrative small customers like IKONICS or raise their fees to excessive levels (fortunately for us Mc Gladrey and Pullen has an office in our city and took our business, after Deloitte declined to continue with us because of our size). Rule 404 will only accelerate that trend.
I donít believe it is reasonable to argue that the incremental confidence that Rule 404 might bring to investors will in any way significantly offset the reduced earning and share value caused by the cost of compliance. Relief from Rule 404 will be good for IKONICS, stockholders and our employees.