October 16, 2006
In the proposed extension for Newly Public companies, there does not seem to be any difference between when management needs to perform their assessment of ICFR and when the auditor needs to perform their assessment (which exists for accelerated and non-accelerated files). I recommend that newly public companies also be granted the one year deferral for auditor assessment. This will give them also the opportunity deal with SOX by themselves, before they need to prepare for the auditor. As experience has shown with US companies, there are many learning opportunities between year one and year two and the additional year to prepare for the auditor will both reduce the burden on companies as well as allow the company to perform a more effective and efficient assessment in their 2nd year of compliance