Sarbanes Oxley Matrix

Records and Information Management
SARBANES-OXLEY ACT
Review/Analysis as of 9-18-2002
Guide to Sarbanes-Oxley Act
NOTES Only the text that deals with the creation, maintenance, or retention of documents and information is included. The documents/records are identified as a study, report, rule (pol record documenting evidence of action. The text may or may not be exact text from the Act. Yellow highlight represents Corporate responsibilities Green highlight represents Registered Public Accounting firm responsibilities Orange highlight represents corporate responsibilities that may be outsourced. Responsibility designation codes include: Board or COMM=SEC Commission and/or Board; RPA=Registered Public Accounting Firm; Issuer=Public Corporation
SUMMARY STATEMENT
TITLE I PUBLIC COMPANY ACCOUNT OVERSIGHT BOARD Sec. 103 Rules required: Board will establish rules regarding: 1. Audit papers prepared and maintained 2. 7 yrs 3. sufficient detail to support conclusions 4. concurring/second partner review and approval 5. scope of testing of internal control structure and procedures 6. findings of the auditor 7. Evaluation: of maintenance of records accurately and fairly reflect the transactions and dispositions of the assets of the issuer; provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the issuer are being made only in accordance with authorizations of management and directors of the issuer; description of material weaknesses and material noncompliance on the basis of such testing Sec. 104 3/1/2013 (printed)
STUDY REPORTS RULES
RECORDS
RESPONSIBILITY
CREATION
MNTNC
RETENTION
X X
BOARD RPA RPA RPA RPA RPA RPA X X X X X X X 7 YRS
RPA
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STUDY REPORTS RULES RECORDS RESPONSIBILITY CREATION MNTNC RETENTION
SUMMARY STATEMENT
Board will conduct continuing program of inspections for registered public accounting firms that prepare audit reports for more than 100 issuers. 1. Once every 3 years 2. Identify any act or practice or omission to act 3. Report any such act, practice or omission 4. Formal investigation or take disciplinary action 5. Inspect and review selected audit and review engagements 6. Perform such other testing of the audit 7. Require retention of records not otherwise required by section 103 Board will prepare written report 1. Transmitted to Commission 2. Appropriate detail 3. Available in appropriate detail to the public Sec. 105 Board may require 1. Production of audit work papers and any other document or information in the possession of the registered public accounting firm or any associated person thereof; may inspect the books and records of such firms or associated persons 2. Production of any document in the possession of any other person, including any client of a registered public accounting firm that the board considers relevant or material to an investigation under this section. 3. Provide for procedures to seek issuance of subpoena to require testimony of and production of any document in the possession of any person . . relevant or material to an investigation under this section. All documents and information prepared for the Boards review shall be confidential and privileged as an evidentiary matter. Board will keep a record of the proceedings for any hearing. 3/1/2013 (printed)
BOARD BOARD BOARD X BOARD BOARD BOARD BOARD RPA X BOARD BOARD BOARD BOARD BOARD X X X X X X
RPA
RPA
X*
BOARD BOARD
BOARD
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STUDY REPORTS RULES RECORDS X RESPONSIBILITY BOARD CREATION X MNTNC RETENTION
SUMMARY STATEMENT
Board sanctions will be supported by a statement setting forth: part of such sanction
No associated person of a registered public accounting firm shall be deemed to have failed reasonably to supervise any other person for purposes of subparagraph A if: procedures, and a system for applying such procedures If the Board imposes a disciplinary sanction, the report shall include:
X BOARD X X
imposition Sec. 106 This act is applicable to foreign public accounting firms
X X
RPA
and furnishing of such reports Sec. 107 Commission shall approve a proposed rule if it is consistent with the requirements of this Act. The Board shall promptly file notice with the Commission of any final sanction on any registered public accounting firm or . . any associated person thereof. Sec. 108 The Commission may recognize any accounting principles established by a standard setting body
X COMM
X NOTICE
BOARD
X*
COMM
interest 3/1/2013 (printed) Page 3
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SUMMARY STATEMENT
consideration by majority vote of its members and of high quality
the public containing audited financial statements of that standard setting body Study on Principles-Based Accounting X 1 YR TITLE II AUDITOR INDEPENDENCE Sec. 201 Registered public accounting firm will not provide any non-audit service including:
X
STANDARDS ORG COMM
X X
RPA
implementation or contribution-in-kind reports
investment banking services the audit
Sec. 202 Audit committees must pre-approve any auditing and non-auditing services other than the exemptions approved by the Board in subparagraph B
AUDIT COMMITTEE
Preapproval is waived
AUDIT COMMITTEE
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SUMMARY STATEMENT
total revenues paid by the issuer during the fiscal year
X X
AUDIT COMMITTEE AUDIT COMMITTEE
the audit committee of the issuer and approved prior to the completion of the audit Sec. 203 A registered public accounting firm shall not provide audit services to an issuer primary responsibility or review responsibility has performed audit services for the issuer in each of the 5 previous fiscal years of that issuer Sec. 204 Registered public accounting firm shall provide a timely report to the audit committee used . . discussed with management and the management of the issuer Sec. 206 A registered public accounting firm cannot perform any audit service for an issuer if the CEO, controller, CFO, chief accounting officer, or any person serving in an equivalent position for the issuer, was employed by that registered independent public accounting firm; and participated in any capacity in the audit of that issuer during the 1 year period preceding the date of the initiation of the audit. Sec. 207 Study required regarding mandatory rotation of registered public accounting firms. 3/1/2013 (printed)
AUDIT COMMITTEE
RPA
RPA
X X
X X
RPA
X 1 YR
COMPTROLLER GENERAL US
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SUMMARY STATEMENT
Not later than 1 year after date of enactment of this Act. TITLE III CORPORATE RESPONSIBILITY Sec. 301 Commission shall by rule prohibit the listing of any security of an issuer that is not in compliance with the requirements of any portion of paragraphs 2 through6 Audit committee of each issuer shall be directly responsible for the appointment, compensation, and oversight of the work of any registered public accounting firm employed by that issuer for the purpose of preparing or issuing an audit report or related work, and each such registered public accounting firm shall report directly to the audit committee. Audit committee members: issuer
X 230 DAYS
COMM
X 230 DAYS X 230 DAYS
AUDIT COMMITTEE
ISSUER BD
compensatory fee from the issuer subsidiary thereof Audit Committee shall establish procedures received by the issuer regarding accounting, internal accounting controls, or auditing matters employees of the issuer of concerns regarding questionable accounting or auditing matters Audit committee shall have the authority to engage independent counsel and other advisers, as it determines necessary to carry out its duties
X AUDIT COMMITTEE X
ISSUER
ISSUER
AUDIT COMMITTEE
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STUDY REPORTS RULES X FUNDIN G RECORDS RESPONSIBILITY CREATION MNTNC RETENTION
SUMMARY STATEMENT Each issuer shall provide for appropriate funding, as determined by the audit committee, in its capacity as a committee of the board of directors, for payment of compensation
ISSUER
Sec. 302 Each company filing periodic reports is required
the principal financial officer or officers, or persons performing similar functions, certify in each annual or quarterly report filed or submitted that:
X ISSUER
contain any untrue statement of a material fact financial condition and results of operation The signing officers
ISSUER/ CEO
internal controls that material information relating to the issuer and its consolidated subsidiaries is made known to such officers by others within those entities controls with 90 days effectiveness of their internal controls audit committee operation of internal controls
ISSUER/ CEO
ISSUER/ CEO ISSUER/ CEO ISSUER/ CEO ISSUER/ CEO
X X X
X X X
ISSUER/ CEO
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SUMMARY STATEMENT
management or other employees who have a significant role in the issuers internal controls were significant changes in internal controls or any corrective actions with regard to significant deficiencies and material weaknesses Issuer cannot lessen the legal force of the statement by having reincorporated or having engaged in any other transaction that resulted in the transfer of the corporate domicile or offices of the issuer from inside the United States to outside of the United States. Sec. 303 Any officer or director of an issuer is prohibited from any action to fraudulently influence, coerce, manipulate, or mislead any independent public or certified accountant engaged in the performance of an audit of the financial statements of that issuer. Sec. 304 When an issuer is required to prepare an accounting restatement due to material noncompliance, the CEO and CFO shall reimburse the issuer for based compensation received during the 12-month period following the first public issuance or filing with the Commission the issuer during that 12-month period Sec. 306 Any director or executive officer of an issuer cannot
ISSUER/ CEO
ISSUER/ CEO
ISSUER
ISSUER
ISSUER
X X
ISSUER ISSUER
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SUMMARY STATEMENT
acquire or transfer any equity security of the issuer (other than an exempted security) during any blackout period if the director or officer acquires such equity security in connection with his or her service or employment as a director or executive officer. issuer
ISSUER
ISSUER
Plan Administrator shall notify in writing (electronic or other form that is reasonably accessible to the recipient
X X
X X
PLAN ADMINISTRATOR PA
X X
rights affected blackout period evaluate the appropriateness of their current investment decisions in light of their inability to direct or diversity assets credited during the blackout Sec. 307 Rules required (within 180 days) for minimum standards of professional conduct for attorneys appearing and practicing before the Commission in any way in the representation of issuers including:
PA
PA
PA
X 180 DAYS
COMM
violation of securities law or breach of fiduciary duty
LEGAL
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SUMMARY STATEMENT
committee of the board of directors of the issuer or to another committee Sec. 308 Study required: 5 years to identify areas were such proceedings may be utilized to efficiently, effectively, and fairly provide restitution for injured investors penalties and disgorgements House and Committee on Banking, Housing, and Urban Affairs of the Senate within 180 days TITLE IV ENHANCED FINANCIAL DISCLOSURES Sec. 401 Financial reports submitted to the commission shall reflect all material correcting adjustments. Rules required: not later than 180 days
X X
LEGAL COMM
X 180 DAYS
COMM
X 180 DAYS
COMM
balance sheet transactions, arrangements, obligations etc. presented in a manner that material fact or omit to state a material fact
X X X X
ISSUER ISSUER ISSUER ISSUER ISSUER COMM
results of operations of the issuer under GAAP Study required: not later than 1 year Study of filings to determine
X X 1 YR
reflecting the economics of such transactions 3/1/2013 (printed) Page 10
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SUMMARY STATEMENT
Report: not later than 6 months after the study to the President, Committee on Banking, Housing and Urban Affairs of the Senate, and the Committee on Financial Services
X 6 MOS
COMM
transactions including assets, liabilities, leases, and losses of , and the use of special purpose entities to facilitate off-balance sheet transactions issuers reflecting the economics of such transactions to investors special purpose entities sponsored by an issuer where issuer has the majority of the risks and rewards and quality of reporting off-balance sheet transactions Sec. 402 It is unlawful to directly or indirectly extend or maintain credit, to arrange for credit or to renew an extension of credit in the form of a personal loan to or for any director or executive officer of that issuer. Limitations include various vehicles to allow the employee to transact business that is in the ordinary course of business, generally made available to the public, or made on market terms. Sec. 403 Any beneficial owner of more than 10 percent of any class of any equity security shall file the statements required by this subsection:
COMM
COMM
COMM
COMM
COMM
ISSUER
X 10 DAYS
BENEFICIAL OWNER
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SUMMARY STATEMENT
securities date commission will provide the statements on a publicly accessible internet site not later than the end of the business day following the filing.
corporate website not later than the end of the business day following that filing. Sec. 404 Rules required: of management for establishing and maintaining an adequate internal control structure and procedures for reporting of the internal control structure and procedures of the issuer for financial reporting made by the management of the issuer. Internal controls assessment: each RPA shall attest to, report on the assessment made by the management of the issuer. Sec. 405 Exemptions to investment companies registered under Section 8 of the Investment Company Act of 1940 Sec. 406 Rules required: Each issuer to disclose whether or not and the reason such issuer has adopted a code of ethics for senior financial officers
X X180 days
ISSUER
CORP WEB SITE
COMM
ISSUER
RPA
X X90/180 days
INVESTMENT COMPANIES
COMM
ISSUER
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SUMMARY STATEMENT
Revise regulations concerning prompt disclosure on Form 8-K any change in or waiver of the code of ethics for senior financial officers To promote
X90/180 days
COMM
disclosure in the periodic reports and regulations Sec. 407 Rules required: to require each issuer to disclose whether or not, and the reasons therefore, the audit committee of that issuer is comprised of at least 1 member who is a financial expert accountant, auditor, principal financial officer, comptroller, principal accounting officer of an issuer or a position involving the performance of similar functions including
X90/180 days
COMM
Sec. 408 Commission shall review these disclosures including a review of an issuers financial statement and considering
COMM
price compared to others
sector of the economy Sec. 409 Issuer shall disclose to public information concerning material changes in the financial condition or operations of an issuer on a rapid and current basis as is necessary for the protection of investors and in the public interest 3/1/2013 (printed)
ISSUER
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SUMMARY STATEMENT
TITLE V ANALYST CONFLICTS OF INTEREST Sec. 501 Rules required: not more than 1 year To address conflicts of interest when analysts recommend securities
x 1yr
COMM
of research reports evaluation of securities analysts to officials employed by the broker/dealer who are not engaged in investment banking activities banking activities may not directly or indirectly retaliate against or threaten to retaliate against any securities analyst as a result of any negative research report that may adversely affect the present or prospective relationship participate/have participated in public offerings should not publish/distribute research reports related to such to assure that securities analysts are separated by informational partitions from the review, pressure, oversight of those involved in investment banking activities. research report known or obvious conflicts of interest including in the investment
ANALYSTS
ANALYSTS
ANALYSTS
ANALYSTS
ANALYSTS
X X X
X X X
ANALYSTS/ BROKERS ANALYSTS/ BROKERS ANALYSTS/ BROKERS
X X X
broker/dealer
ANALYSTS/ BROKERS
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SUMMARY STATEMENT
research report based upon the investment banking revenues TITLE VI COMMISSION RESOURCES AND AUTHORITY Sec. 601 Funds are authorized to carry out functions, powers, and duties Sec. 602 Commission may censure, deny any person from practicing before the Commission
ANALYSTS/ BROKERS
x Funding
COMM
COMM
of securities laws
Authority to prohibit persons who have participated in an offering of penny stock. TITLE VII STUDIES AND REPORTS SEC. 701 Comptroller of the US will conduct a study to identify the factors that led to consolidation of public accounting firms since 1989; present and future impact; solutions to any problems identified. SEC. 702 Commission to study the role and function of credit rating agencies in the operation of securities market Sec. 703 Commission to determine number of securities professionals who have been found to have aided and abetted or been primary violators of a violation of the federal securities laws; including a description of the laws violations committed by them including: 3/1/2013 (printed)
COMM
COMPTROLLER U.S.
COMM
COMM
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SUMMARY STATEMENT
imposed
Sec. 704 Study required to review and analyze all enforcement actions by the Commission involving violations of reporting requirements Sec. 705 GAO study required to determine whether investment banks and financial advisers assisted in manipulating their earnings and obfuscating their true financial condition. TITLE VIII CORPORATE AND CRIMINAL FRAUD ACCOUNTABILITY Sec. 802 Whoever knowingly alters, destroys, mutilates, conceals, covers up, falsifies or makes false entry in any record, document or tangible object with the intent . . . shall be fined, imprisoned or both. Any accountant who conducts an audit of an issuer shall maintain all audit or review work papers for a period of 5 years from the end of the fiscal period in which the audit was conducted. Rules required: Commission shall promulgate such rules and regulations relating to retention of relevant records such as:
COMM
GAO
ISSUER/ EXEC
ACCOUNT ANT/ RPA
X 5YRS
X 180 DAYS
COMM
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SUMMARY STATEMENT
received in connection with an audit, review and contain conclusions, opinions, analyses, or financial data relating to such an audit or review conducted by an accountant for the issuer of securities under the SEA of 1934 Anyone who knowingly and willfully violates shall be fined, imprisoned or both Sec. 804 Statue of Limitations for securities fraud is
ISSUER/ RPA ETC
X X X
ISSUER/ RPA ETC
Sec. 805 Whistleblower protection to prohibit discriminate behavior against an employee for assisting an investigation regarding a violation of the SEC regulations TITLE IX WHITE-COLLAR CRIME PENALTY ENHANCEMENTS Sec. 905 United States Sentencing Commission shall amend the federal guidelines to ensure that sentencing reflects the serious nature of the offenses and penalties set forth in this ACT, and the growing incidences of serious fraud offenses which are defined above. Sec. 906 Each periodic report containing financial statements filed by an issuer shall include a written statement by the CEO, CFO or equivalent of the issuer stating that:
ISSUER/ RPA ETC
US SENTENCING COMMISSION
ISSUER/ CEO,CFO
material respects, the financial condition and results of operations of the issuer TITLE X CORPORATE TAX RETURNS Sec. 1001 3/1/2013 (printed) Page 17
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SUMMARY STATEMENT
Federal income tax return should be signed by the CEO of such corporation TITLE XI CORPORATE FRAUD ACCOUNTABILITY Sec. 1103 A temporary freeze on assets during an investigation an escrow subject to court supervision in an interest bearing account for 45 days. Sec. 1105 Commission may issue an order to prohibit any person who has violated the rules, from acting as an officer or director of any issuer of a class of securities Sec. 1106 Penalties increased for fines and imprisonment Sec. 1107 Any person who retaliates against a person for providing truthful information relating to the commission or federal offense shall be fined, imprisoned or both.
ISSUER/ CEO
COMM/ ISSUER/ RPA
COMM
COMM
COMM
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e identified as a study, report, rule (policy), or
uer=Public Corporation
Documents/Records Series Suggestions
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Board Policy/Procedures
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Documents/Records Series Suggestions Purchase/contract file for each service to document approval or exemption class, created/retained by Audit Committee
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Board Policy/Procedure/Compliance Statement
Board Policy/Procedures; Complaint File to document complaints received; created/retained by Audit Committee
Board Policy/Procedure; budget allocation for Audit Committee; Purchase/Payment File for Services; created/retained by Audit Committee
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Company Policy/Procedure; Signature and affidavit on all periodic reports, created/retained by issuing officer
Company Policy/Procedure on Internal Controls; Periodic Reports to include affidavit, created/retained by issuing officer
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Company Policy/Procedure/Compliance Statement
Company Policy/Procedure/Compliance Statement; Restatement File to document compliance, created/retained by issuing officer
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Company Policy/Procedures/Compliance Statement;
Company Policy/Procedure; Compliance Statement; Black Out File to document each occurrence, created/retained by Plan Administrator (must be included in a contract for 3rd party services)
Compliance Statement for attorneys practicing before SEC (including 3rd party services); report to the audit committee.
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Company Policy/Procedure/Compliance Statement; File on Off-balance sheet transactions including reconciliations, created/retained by issuing officer
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Company Policy/Procedure/Compliance Statement.
Company Policy/Procedure; Compliance Statement; Beneficial Owner File with statement and date issued, created/retained by issuing office
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Company Policy/Procedure; Internet Publishing, created/retained by Corporate Communications in hard copy
Company Policy/Procedure; Annual Report Affidavit, created/retained by issuing office
Code of Ethics, created/retained by issuing office
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Company Policy/Procedure/Compliance Statement; Public Information Statement created/retained by Corporate Communications
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Grainger currently retains all internal audit reports and work papers, and external audit reports
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Company Policy/Procedures/Compliance Statement; This documentation will be found in a Litigation Case file.
Company Policy/Procedure/Compliance Statement; Report with Signature and Statement, created/retained by issuing office
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Documents/Records Series Suggestions Company Policy/Procedure; Compliance Statement; Tax Return with CEO signature, created/retained by issuing office
Compliance requirement; document any occurrence in Legal Case File
Order to be issued as necessary Penalties increased as necessary
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Sarbanes Oxley Matrix

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Records and Information Management

Guide to Sarbanes-Oxley Act

STUDY REPORTS RULES

BOARD RPA RPA RPA RPA RPA RPA X X X X X X X 7 YRS

Records and Information Management

Records and Information Management

interest 3/1/2013 (printed) Page 3

Records and Information Management

STANDARDS ORG COMM

implementation or contribution-in-kind reports

investment banking services the audit

Records and Information Management

total revenues paid by the issuer during the fiscal year

AUDIT COMMITTEE AUDIT COMMITTEE

Records and Information Management

X 230 DAYS X 230 DAYS

Records and Information Management

Sec. 302 Each company filing periodic reports is required

ISSUER/ CEO ISSUER/ CEO ISSUER/ CEO ISSUER/ CEO

Records and Information Management

Records and Information Management

violation of securities law or breach of fiduciary duty

Records and Information Management

ISSUER ISSUER ISSUER ISSUER ISSUER COMM

reflecting the economics of such transactions 3/1/2013 (printed) Page 10

Records and Information Management

Records and Information Management

CORP WEB SITE

Records and Information Management

price compared to others

Records and Information Management

ANALYSTS/ BROKERS ANALYSTS/ BROKERS ANALYSTS/ BROKERS

Records and Information Management

Records and Information Management

ACCOUNT ANT/ RPA

Records and Information Management

ISSUER/ RPA ETC

ISSUER/ RPA ETC

ISSUER/ RPA ETC

Records and Information Management

COMM/ ISSUER/ RPA

Records and Information Management

e identified as a study, report, rule (policy), or

Records and Information Management

Documents/Records Series Suggestions

Records and Information Management

Documents/Records Series Suggestions

Records and Information Management

Documents/Records Series Suggestions

Records and Information Management

Records and Information Management

Documents/Records Series Suggestions

Board Policy/Procedure/Compliance Statement

Records and Information Management

Documents/Records Series Suggestions

Records and Information Management

Documents/Records Series Suggestions

Company Policy/Procedure/Compliance Statement

Records and Information Management

Documents/Records Series Suggestions

Company Policy/Procedures/Compliance Statement;

Records and Information Management

Documents/Records Series Suggestions

Records and Information Management