Section 409 of the Sarbanes Oxley Act complements Section 404. The Section 409 states that all issuers complying with SOX, shall disclose to the public on a rapid and current basis such additional information concerning material changes in the financial condition or operations of the issuer in plain english which may include trend and qualitative information and graphic presentations, as the SEC determines, by rule, is necessary or useful for the protection of investors and in the public interest.

For my clients, my adivse is that the key to understanding Section 409 is that real time disclosures depend more on early warnings, which depend more often on operating information rather than on financial information. Section 409 thus in ways complements Section 404 of the Sarbanes Oxley Act.

I will discuss more on Real time disclosures in my coming posts for the readers benefits here.

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SAS 70 Audits , Control Deficiency , Designing Internal Controls