Sarbanes Oxley Public Policy Essay

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Harrington 1 Sarbanes- Oxley Act of 2002: A Comprehensive Review By Hennessey T. Harrington For Business 102 Ethics & Public Policy Dr. Jasso TA Josh December 7, 2010 Harrington 2 TABLE OF CONTENTS 1. 0 Sarbanes- Oxley Act of 2002: Spectrum of Objectives 1. 1 On History 1. 2 On Accountability 1. 3 On Corporate Social Responsibility 2. 0 Sarbanes- Oxley Act of 2002: A Historical Account 2. 1 On Necessity 2. 2 On Defective Oversight 2. 3 On Corruption 2. On Conflict of Interest 2. 5 On Imperfect Disclosure 3. 0 Sarbanes- Oxley Act of 2002: Implementation & Context 4. 0 Sarbanes- Oxley Act of 2002: Significance With Respect to Business & Society 4. 1 On Business 4. 2 On Society 5. 0 Sarbanes- Oxley Act of 2002: A Political Analysis of Strengths & Weaknesses 5. 1 On Weakness: Cost of Compliance 5. 2 On Strengths: Moving Forth 5. 3 Recommendation for Policy Makers 6. 0 Conclusion 7. 0 Appendix Harrington 3 8. 0 References

Abstract [Although critics claim that the Sarbanes- Oxley Act of 2002 has been costly to the private sector and contributed to national deficit; SOX has however, drastically improved corporate transparency, restored investor confidence and proven impactful with regards to the Social Responsibility Movement. This comprehensive analysis will validate the imperative ethical purpose of SOX, while also demonstrating its positive impact on national business markets. ] Hennessey T. Harrington 1. 0 Sarbanes-Oxley Act of 2002: Spectrum of Objectives To protect investors by improving the accuracy and reliability of cooperate disclosures made pursuant to the securities laws, and for other purposes” (Sarbanes-Oxley Act of 2002) The Sarbanes- Oxley Act of 2002 set out (1) to ensure corporate honesty with respect to finance, (2) to enhance accountability among corporate decisions makers, and (3) make an impactful and legal stride towards national Corporate Social Responsibility. Overall the SOX Act implements governance measures that legally ensure the transparency and authenticity of corporate financial reports and procedures.

Written with a motif of quality assurance, the SOX act aims to rebuild investor confidence that has been eroded by major scandals such as the Enron and WorldCom cases. Sarbanes- Oxley implements specific procedures that are backed by specific government punishments, meanwhile introducing private oversight for accounting services. The SOX act is a significant step towards U. S. government assurance of Corporate Responsibility. 1. 1 On Honesty Sarbanes- Oxley act of 2002 begins with the establishment of the Public Company Harrington 4 Accounting Oversight Board or PCAOB.

Found in Title I, the PCAOB was formed to, “oversee the audit of public companies that are subject to securities laws
 to protect the interests of investors and further the public interest of investors” (SOX SEC. 101. A). This is a board independent of the United States government that will register public accounting firms, provide quality control, conduct inspections, hold investigations, provide operations standards and manage major accounting practices. It consists of 5 members that are replaced every 5 years and are required to remain independent from any accounting firm.

The PCAOB provides a governing body that has discretion towards national standards and regulates practice; both vestiges that have never been implemented in corporate accounting. By utilizing a board of members, investors now have a tangible source to contact for discrepancies and unsure safety from fraudulent firms. SOX also strives to reinforce financial honesty with Title IV “Enhanced Financial Disclosure” (SOX SEC. 401-409). This clause addresses financial honesty by making the financial ongoing of a corporation more transparent to its investors.

Ideally, firms will no longer be able to hide their numbers from investors, as seen with Enron and so forth. Most importantly from this clause is the call for “ Off Balance Sheet Transactions” (SOX SEC. 401. J). These transactions were previously not required to be displayed on the balance sheet, yet with SOX, firms need to be fully transparent. This eliminates the ability for crafty financial officers to hide expenses, assets and liabilities formerly used to shape company productivity and thus ultimately affects investor decisions.

Through off “off balance sheet transactions”, auditors from Enron, “were able to hide billions of dollars of debt from failed deals and projects” (Wikipedia Enron). These hidden transactions translated into $11 billion lost in year 2000 alone and stock prices to drop by Harrington 5 90%. 1. 2 On Accountability SOX takes the initiative towards providing investors with protection under law. By proving rights, voice, and security, SOX intends to reassure sanctity in the market meanwhile promoting investor friendly practices. Title VI dictates the allocation of government funds towards investor friendly advancements under SOX.

The funds totaling to $776 million for 2003 alone, are used to provide salaries for SOX employees, appropriate information technology (i. e. computers, communication services etc. ), professional oversight, and disciplinary efforts. Title VII of SOX fleshes out the updated and more severe punishments for cooperate fraudulency and criminal activity. Title VII states the penalties for destruction of records, hiding called upon information, and violating abridged terms in “Corporate and Criminal Fraud Accountability” (SOX. SEC. 801-807).

All of which ensure that if a firm violates the granted parameters of SOX, it shall be accountable for fines and jail time. 1. 3 On Corporate Social Responsibility Self entitled clause “TITLE III: Corporate Responsibility”(SOX. SEC. 301-308) articulates its plight towards an increasingly socially responsible market for investors and consumers to experience. This clause mandates that in effort to achieve an ethical and responsible corporate culture, firms must have a definitive relationship with their auditors (both private and public) as well as put the majority of decision-making responsibility on

Harrington 6 the Chief Executive Officer and the Chief Financial Officer. Both the CEO and CFO must “certify” (SOC. SEC. 306) the validity of their financial statements before releasing them to the public or submitting them for board review. This registration clause allows for investors to have faith granted the CEO and CFO are held legally responsible for their actions. Dennis Chookaszain, Chairman of Chicago Mercantile Exchange Holdings Inc. audit committee explains, “when I was CEO, I had two jobs: strategic direction and deployment of resources.

I decided what businesses we were going to be in and how many people and how much money we were going to use. Now the CEO’s got a third job: compliance oversight. In the past, the CEO would say, “Everybody should behave ethically. ” That, and having a corporate ethics statement, was all you had to do. Now the CEO is being forced to get in touch with the details of how the organization functions. But I don’t think that’s bad. The CEO’s job is to make sure things run right. ” (Crain’s Chicago Business)

Furthermore SOX Act is a significant steppingstone towards complete Social Responsibility. As we look to Archie Carroll’s pyramid of CSR (Figure 1) we see that firms must maintain stable economic, legal, ethical and philanthropic citizenship in order to maintain profitability and serve stakeholders. Firms must first fulfill their Economic and Legal responsibilities. Although the SOX act is fairly costly, by following it legally firms will collectively rebuild their markets by regaining the trust of investors. Ideally when investors have legal backing they will have the confidence to invest.

SOX also forces firms to behave ethically granted it calls specifically for fair practices. SOX reinforces corporate core values; respect integrity communication and excellence. These Core Values maintain efficiency in the relationship between supplier and consumer. 2. 0 Sarbanes- Oxley Act 2002: A Historical Account “Outrageous financial malfeasance and voracious fraud are now seen to have been endemic during recent years within many celebrity corporations of the Fortune 500¼. Public opinion throughout the world as Harrington 7 ell as corporate and government leaders have been shocked. The past 65 years have not witnessed a more important or comprehensive law addressing the processes of corporate governance”-Jack Friedman, Chairman of Directors Roundtable The SOX Act was a direct response to market failure via information asymmetry. Market Failure is, according to Weirmer and Vinning’s Policy Analysis: Concepts and Practice, 3rd Ed. , “
 as circumstance in which the pursuit of private interest does not lead to and efficient use of society’s resources of a fair distribution of society’s goods” (1999, pg. 74).

In other words, a market failure is the inefficiency between resources between supplier and consumers. Information asymmetry thus became the catalyst for inefficiency in the distribution of stakeholder (Figure 2) goods such as jobs and accounts worth billions. SOX became the nucleus for market failure prevention, specifically in auditing scandals such as Enron and WorldCom. 2. 1 On Necessity Before Sarbanes- Oxley was enacted in 2002, the only previous significant form of accounting governance was the establishment of the Securities and Exchange Commission in 1933 and the Securities Exchange Act of 1934.

For almost 70 years auditing procedures have gone virtually unchanged with respect to the exponential grow of corporate America and the stock markets. Through a lack of maintenance corporate auditing saw these major problems; (1) inadequate defective oversight, (2) in house auditing and corruption, (3) conflict of interests among auditors and (4) imperfect disclosure to stakeholders. These problems became the lead to losses in the trillions between 2000 and 2002 alone. 2. 2 On Defective Oversight The Pre-SOX Era operated with little audit oversight thus allowed for

Harrington 8 experienced auditors to exploit balance sheet loopholes. These loopholes have proven costly to stakeholders granted several firms have gone bankrupt by using them. Thus oversight among auditors became essential to maintaining honest practices. 2. 3 On Corruption The SOX Act has cracked down on corruptive accounting and bribery by monitoring set provisions by the PCAOB. As a result some of the largest firms have been exposed for questionable methods such as allegations of Halliburton’s bribe to Nigerian officials or Bristol-Meyers Squibb’s bribes to German derivative market shareholders [Corruption’s New Nemesis, A21].

These are just a few of many companies that have been found making corrupt and illegal trades since the enactment of SOX, thus proving that SOX has not only been necessary but also effective in enforcing national standards of tenure. As firms like Tyco and Bristol- Squib are penalized for their illegitimate trades investors will gain confidence in the PCAOB and eventually in their investments. 2. 4 On Conflict of Interest Until the SOX was enacted in 2002, investors relied on self-regulated auditors to carry out accounting matter.

Many firms abused this in-house liberty in order to make personal profits while depicting a thriving corporation to investors. Also upper management had little to none information on auditing procedures. CEOs had only been required to maintain the firm on a strategic level while the CFO and accountants played roles in taking procedural short cuts, hence a multi-billion dollar conflict of interest. 2. 5 On Imperfect Disclosure Again we see the importance of transparency and the dangers of information asymmetry. Investors lost billions to the market granted they were withheld from vital

Harrington 9 information on the progression of their firms. Firm using “off balance sheet” techniques were often able to hide losses inevitable lead to many cases of bankruptcy. SOX provides provisions that grantee investor safety via full disclosure. Now the CEO and the CFO must register and sign all major financial statements. In effect this provisions allows for disclosure and confidence among investors. According to Justin Clein, SEC official, “clients with disclosure committees are keeping better minutes” (Porus. pg. C01). Thus better minutes make for more informed stakeholders. 3. Sarbanes- Oxley Act of 2002: Implementation & Context Sarbanes-Oxley Act of 2002, PL 107-204, 116 Stat 745 Formerly known as the Corporate and Auditing Accountability, Responsibility and Transparency Act of 2002, Sarbanes- Oxley is codified under United States Law. The codification process begins with voting and then is certified by the President to be an official Act of Congress. The U. S. code provides an efficient way for politicians and citizens to track and utilize every bill in the U. S. Federal Register. The U. S. Code also is updated every five years to ensure upkeep and removal of outdated references.

SOX references the Securities Exchange Act of 1934 throughout its titles thus we look to the SEC of 1934 to implement the law. References are cited as the following example, “The provisions of section 17(a)(1) of the Securities Exchange Act of 1934 (15 U. S. C. 78q(a) (1)). ” To research the specific parts of the code, we begin with the title number, then to chapter and finally the short title that is signified with the symbol, “§”. Federal Agencies are responsible for managing the regulations each law puts into place. Federal Agencies serve as administrators of the policy and deal with all clerical duties.

Harrington 10 4. 0 Sarbanes- Oxley Act of 2002: Significance with Respect to Business & Society “I predict that in the years to come Sarbanes-Oxley will be worth its weight in more than gold. SarbanesOxley will have almost single handedly rescued American business from self-destruction” (Maxine Waters Representative of the United States; Committee on House Financial Services) 4. 1 On Business Although critics argue that the Sarbanes- Oxley Act of 2002 has been costly to all sectors, one cannot ignore SOX’s positive impact on investors and massive push for ethical behavior among some of the nations most powerful firms.

SOX bares against fraud, scandals and bribery all unethical behaviors that can ultimately lead to the most costly demise of corporate giants such as we saw between 2000-2002. As Archie Carroll argues, profitability is heavily based on corporate image and trust, thus as firms regain confidence from investors, profits will follow. Ultimately the SOX act is costly yet ethically effective. Although the law will take years to pay for itself, it will slowly but surely earn its due by minimizing corporate bankruptcies and increasing investors support.

Investor confidence is on the rise due to specific clauses in SOX that protect them not only from future fraud but also assert them higher levels of transparency; or in other words allows them to see more clearly in mechanics of their financial investments. As Michael G. Oxley states, “During my first term as Chairman of the Financial Services Committee, our work was consumed with responding to the corporate accounting scandals and formulating legislative solutions aimed at assuring market participants, particularly investors, that America’s capital markets were the most vibrant and Harrington 11 transparent in the world” (U.

S. Fed News Service 2006). Hence we see that SOX is not only active in identifying illegal practices but also setting standards that move towards a cleaner and safer investor environment. As investors regain confidence with the market, we will see an increase in cash flow. SOX also affects the business sector by minimizing the risk for costly clerical errors. With stricter procedures and the CEO/CFO registration policy, businesses are going to catch any errors in their statements. These errors often lead to the misperception of financial status and accordingly open business to lawsuits by stakeholders.

The SOX Act bars against these errors, as Chris McWilton says, “A post-mortem of its SarbanesOxley compliance effort, looking at what worked and didn’t work, found poor documentation of financial controls that could have been automated, but weren’t. Among the lessons learned is that standardization of processes minimizes the risk of misstatements on financial reports,” (Info Week, 2005). As follows we see that SOX benefits businesses by minimizing misstatements thus increasing productivity and consequently profitability. 4. 2 On Society SOX provides society with a sense of corporate citizenship.

Now that firms are being held responsible for their actions we can rest a little bit easier with our current and future investments. SOX provides specific virtues for firms to follow thus leveling the once corrupt playing field between consumers and upper management. SOX gives voice to the public and allows us to take out transgressions to the PCAOB. 5. 0 Sarbanes- Oxley Act of 2002: A Political Analysis of Strengths & Weaknesses “Five years from now,” Steve Hill predicts, “people will look back at their compliance initiatives as a catalyst for business improvement. (Info Week, 2005) Harrington 12 On Weaknesses: Cost of Compliance They key weakness of SOX is that it has been costly both financially and timely. SOX imposes procedures that require more attention to detail on financial statements. This means that individual firms must pay employees and auditing firms for extra work, thus taking a proportional chunk from their in house expenses. The cost of compliance has been seen as controversial and typically unwanted my most firms yet this is natural considering it takes away from profits in the short run.

For example, “According to an event-analysis conducted by Ivy Xiying Zhang, now a professor at the University of Minnesota, the key legislative events leading to the passage of Sarbanes-Oxley coincided with the loss of $1. 4 trillion of shareholder wealth”(CQ Congressional Testimony, 2006). Unfortunately the short run cost of SOX has taken a sizable portion of most firms profits yet in the long run the profits will return through an increase in investments. As people regain their confidence in the market, they will buy shares and the cash flow will be returned. . 2 On Strengths: Moving Forth Sarbanes- Oxley has been criticized for its financial costs, yet insiders admit that it is the right thing to do. By providing investors with transparency and real time disclosure, firms are required to mature into liable and socially responsible vestiges of commerce. SOX calls for rigorous insider information and transactions thus allowing us to see the inner workings of any given firm. SOX eliminates the possibility for crafty accountants to execute information asymmetry thus preventing market failures.

With a buffer to market failure both the corporation and the consumer are granted market efficiency, which in turn will lead to profitability. Harrington 13 Take for example the Winner Medical Group, a large player in medical products, and their optimism towards the benefits that Sarbanes- Oxley compliance provides. “We are very confident that our Project to comply with Sarbanes-Oxley Section 404 within the time required will be successfully executed,” said Jianquan Li, Chief Executive Officer. “However, our goal is far beyond compliance with the rules.

The ultimate goal of our Project is to build sound and self-improving internal controls over our financial reporting processes. I am confident that our board of directors, management and all other personnel are dedicated to maintaining an effective system of internal controls as one of the cornerstones necessary to build and improve shareholder value. “(Obesity, Fitness & Wellness Weekly, 2006) We see that firms like Winner Medical Group view SOX as a call to honor the ethics of corporate citizenship and the rights of their stakeholders. Furthermore Winner has seen “Rewarding responses from shareholders”(OF&W,2006) for their stance on SOX.

As we see in many cases SOX is a dynamic policy that came at a most crucial time. The majority of its strength comes from its specificity and assertiveness to solve the direct problems of the past. Firms are now considerate of stakeholder voice. By being more aware of the fiduciary needs of consumers, firms are moving in a direction that takes ethical initiative for compliance. Many firms are reassuring their stakeholders by revamping their codes of ethics with a focus on the ethical nature of business and its relationship with common sense. . 3 Recommendation for Policy Makers No policy is perfect. Yet as a modern society it is our duty to create laws that strive for perfection. We need to keep laws liquid and allow future generations to amend or eliminate outdated regulations. I argue that policy makers should remain tentative, and should update policies with the changes of our nation. I feel that transparency is key to keeping people honest. Policy makers should strive to keep firms honest by forcing them Harrington 14 to expose their methods to their stakeholders.

For example with SOX we see that firms are forced to ethical practice yet it comes with a major price tag, thus in the future policy makers can amend SOX lowering costs while remaining effective. 6. 0 In Conclusion This paper set out to discuss the nature of Sarbanes-Oxley in politics, business, society and the corresponding effects it has taken on them. I have addressed the mechanical specifics of SOX and its effects on various aspects of our economy. I also have argued the point Sarbanes- Oxley is, and will continue to, make a positive impact on our society and will set the standard for the way we do business in the future.

Base on my research, I have found that Sarbanes- Oxley is a good policy and will reap benefits for many years to come. Parameters originally set for the stakeholder and shareholder safety will transgress into benefits for the entire market. As firms comply with SOX they will eventually run cleaner and viable business that will gain moral and financial support of the public. We must remember that SOX is in response to major scandals thus a it has the duty to keep the abuse of finance at minimum in the future.

Again I feel that SOX will be a policy that benefits both the stakeholder and the corperation by creating a market that is efficient, honest and most importantly ethical. Harrington 15 7. 0 APPENDIX FIGURE 1 FIGURE 2 Harrington 16 APPENDIX H. R. 3763 One Hundred Seventh Congress of the United States of America AT THE SECOND SESSION Begun and held at the City of Washington on Wednesday, the twenty-third day of January, two thousand and two An Act To protect investors by improving the accuracy and reliability of corporate disclosures made pursuant to the securities laws, and for other purposes.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled, SECTION 1. SHORT TITLE; TABLE OF CONTENTS. (a) SHORT TITLE. —This Act may be cited as the ‘‘SarbanesOxley Act of 2002’’. (b) TABLE OF CONTENTS. —The table of contents for this Act is as follows: Sec. 1. Short title; table of contents. Sec. 2. Definitions. Sec. 3. Commission rules and enforcement. TITLE I—PUBLIC COMPANY ACCOUNTING OVERSIGHT BOARD Sec. 101. Establishment; administrative provisions. Sec. 102. Registration with the Board. Sec. 103. Auditing, quality control, and independence standards and rules.

Sec. 104. Inspections of registered public accounting firms. Sec. 105. Investigations and disciplinary proceedings. Sec. 106. Foreign public accounting firms. Sec. 107. Commission oversight of the Board. Sec. 108. Accounting standards. Sec. 109. Funding. TITLE II—AUDITOR INDEPENDENCE Sec. 201. Services outside the scope of practice of auditors. Sec. 202. Preapproval requirements. Sec. 203. Audit partner rotation. Sec. 204. Auditor reports to audit committees. Sec. 205. Conforming amendments. Sec. 206. Conflicts of interest. Sec. 207. Study of mandatory rotation of registered public accounting firms. Sec. 08. Commission authority. Sec. 209. Considerations by appropriate State regulatory authorities. TITLE III—CORPORATE RESPONSIBILITY Sec. 301. Public company audit committees. Sec. 302. Corporate responsibility for financial reports. Sec. 303. Improper influence on conduct of audits. Sec. 304. Forfeiture of certain bonuses and profits. Sec. 305. Officer and director bars and penalties. Sec. 306. Insider trades during pension fund blackout periods. Sec. 307. Rules of professional responsibility for attorneys. Sec. 308. Fair funds for investors. Harrington 17 TITLE IV—ENHANCED FINANCIAL DISCLOSURES Sec. 401.

Disclosures in periodic reports. Sec. 402. Enhanced conflict of interest provisions. Sec. 403. Disclosures of transactions involving management and principal stockholders. H. R. 3763—2 Sec. 404. Management assessment of internal controls. Sec. 405. Exemption. Sec. 406. Code of ethics for senior financial officers. Sec. 407. Disclosure of audit committee financial expert. Sec. 408. Enhanced review of periodic disclosures by issuers. Sec. 409. Real time issuer disclosures. TITLE V—ANALYST CONFLICTS OF INTEREST Sec. 501. Treatment of securities analysts by registered securities associations and national securities exchanges.

TITLE VI—COMMISSION RESOURCES AND AUTHORITY Sec. 601. Authorization of appropriations. Sec. 602. Appearance and practice before the Commission. Sec. 603. Federal court authority to impose penny stock bars. Sec. 604. Qualifications of associated persons of brokers and dealers. TITLE VII—STUDIES AND REPORTS Sec. 701. GAO study and report regarding consolidation of public accounting firms. Sec. 702. Commission study and report regarding credit rating agencies. Sec. 703. Study and report on violators and violations Sec. 704. Study of enforcement actions. Sec. 705. Study of investment banks.

TITLE VIII—CORPORATE AND CRIMINAL FRAUD ACCOUNTABILITY Sec. 801. Short title. Sec. 802. Criminal penalties for altering documents. Sec. 803. Debts nondischargeable if incurred in violation of securities fraud laws. Sec. 804. Statute of limitations for securities fraud. Sec. 805. Review of Federal Sentencing Guidelines for obstruction of justice and extensive criminal fraud. Sec. 806. Protection for employees of publicly traded companies who provide evidence of fraud. Sec. 807. Criminal penalties for defrauding shareholders of publicly traded companies. TITLE IX—WHITE-COLLAR CRIME PENALTY ENHANCEMENTS Sec. 01. Short title. Sec. 902. Attempts and conspiracies to commit criminal fraud offenses. Sec. 903. Criminal penalties for mail and wire fraud. Sec. 904. Criminal penalties for violations of the Employee Retirement Income Security Act of 1974. Sec. 905. Amendment to sentencing guidelines relating to certain white-collar offenses. Sec. 906. Corporate responsibility for financial reports. TITLE X—CORPORATE TAX RETURNS Sec. 1001. Sense of the Senate regarding the signing of corporate tax returns by chief executive officers. TITLE XI—CORPORATE FRAUD AND ACCOUNTABILITY Sec. 1101.

Short title. Sec. 1102. Tampering with a record or otherwise impeding an official proceeding. Sec. 1103. Temporary freeze authority for the Securities and Exchange Commission. Sec. 1104. Amendment to the Federal Sentencing Guidelines. Sec. 1105. Authority of the Commission to prohibit persons from serving as officers or directors. Sec. 1106. Increased criminal penalties under 8. 0 REFERENCES Harrington 18 Cooper, P. P. (2002, August 14). Tope Executives now must certify firms financial results. The Philadelphia Inquirer, p. C01 Emerging Company and the SEC [Sarbanes- Oxley]. (n. . ). Retrieved from http://www. businessforum. com/ SEC01. html Enron Scandal [Wiki]. (n. d. ). Retrieved from http://en. wikipedia. org/wiki/Enron_scandal Factor, M. (2006, June 19). COst of Compliance with Sarbanes Oxley Financial Regulation Act. CQ COngressional Testimony. Marlin, S. (2005, March 21). Gaining Strength From SarBox. Information Week. Oxley, M. (2006, July 28). Oxley Statement on SarbanesOxley. CQ Congressional Press Release, House of Rep. Sarbanes- Oxley Guideline. (n. d. ). [Brochure]. Sarbanes- Oxley [Wiki]. (n. d. ). Retrieved from http:// en. wikipedia. rg/wiki/ Sarbanes%E2%80%93Oxley_Act#History_and_context:_events _contributing_to_the_adoption_of_Sarbanes. E2. 80 . 93Oxley Schrage, E. J. (2005, November 15). Corruptions New Nemesis. Washington Post, p. A21 U. S. Code [Codification ]. (n. d. ). Retrieved December 1, 2010, from Cornell University website: http://www. law. cornell. edu/uscode/ Water, M. (2006, September 19). Review of SarbanesOxley Banking Overhaul. CQ Congressional Harrington 19 Textimony, p. 1 Winner Medical Group Inc; Implements Sarbanes-Oxley Compliance Project. (n. d. ). Obesity, Fitness & Wellness Week. Harrington 20

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