The glass is half full, but that's debatable*.

• Position: Sarbanes-Oxley Act of 2002, Section 404, financial reporting of public companies

Sarbanes-Oxley Section 404 requires public companies to attest to the effectiveness of their internal controls over financial reporting.

As we await the first 404 reports, the debate has heated up a notch about whether these reports will have any impact on the level of confidence investors have in the financial reporting from public companies.

Possibly the greatest concern about Section 404 coming from those deep in the compliance process is the cost of the work in both time and money. Many companies are looking at this cost and are candidly questioning whether there's a corresponding benefit.

And that really cuts to the core of the 404 debate: will all this be worth the effort? Part of the answer will come when the reports are released and investors respond. Will they see value in this new information? Will these reports help rebuild investor confidence?

We are hopeful that investors will spend the time to understand the relevance and benefits of these reports. We have attempted in past communications to frame how this information may contribute to better decisions. In addition, the Big 4 firms have co-authored two investor guides to 404 that help explain what much of this means. (Both investor guides can be accessed at www.s-oxinternalcontrolinfo.com)

Two things that investors should take great comfort in are the significant attention and effort being given to internal controls by companies and auditors.

Never across corporate America has there been such an intense focus on examining whether the appropriate internal controls over financial reporting are in place and are functioning. 404 is an opportunity for a company to document and test its internal controls over financial reporting before problems happen. This is the chance to find weaknesses and correct them. Our experience in the marketplace is that this is happening. Many issues have been identified and have been or will be remediated.

This should be good news to investors and corporate...