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Section 404- Management Assessment of Internal Controls
The Commission shall require, for each issuer filing periodic reports under section 13(a) or 15(d) of the Securities
Exchange Act of 1934, to contain a report on internal controls, containing:
(1) the responsibility of management for establishing and maintaining an adequate internal control structure and
B.
procedures for financial reporting; and
(2) an assessment, as of the end of the fiscal year of the issuer, of the effectiveness of the internal control structure
and procedures of the issuer for financial reporting.

The public accounting firm that prepares or issues the audit report for the issuer shall attest to, and report on, the
assessment made by the management of the issuer. An attestation made under this subsection shall be made in
accordance with standards for attestation engagements issued or adopted by the Board.

Section 409- Real Time Issuer Disclosures
Each issuer reporting under section 13(a) or 15(d) shall disclose any additional information to the public on a real time
basis concerning material changes in the financial condition or operations of the company, including trend and
qualitative information and graphic presentations necessary or useful for the protection of investors and in the public
interest.

Section 802- Criminal Penalties for Altering Documents
Any person knowingly altering, destroying, mutilating, concealing or falsifying, records/documents related to legal
investigation, shall be fined under this title/imprisoned not more than 20 years, or both.
Any accountant who conducts an audit of the entity to which section 10A(a) of the Securities Exchange Act of 1934
applies, 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 or review was concluded. Any person wilfully violating the requirement to maintain records for 5 years will
be fined/imprisoned not more than 10 years, or both.

Section 902-Attempts & Conspiracies to Commit Fraud Offenses
Any person who attempts or conspires to commit any offense under this chapter shall be subject to the same
penalties as those prescribed for the offense, the commission of which was the object of the attempt or conspiracy.

Section 906 - Corporate Responsibility for Financial Reports
Each periodic report containing financial statements filed by an issuer with the Securities Exchange Commission
pursuant to section 13(a) or 15(d) of the Securities Exchange Act of 1934 shall be accompanied by a written statement
by the chief executive officer and chief financial officer (or equivalent thereof) of the issuer certifying that the periodic
report containing the financial statements fully complies with the requirements of section 13(a) or 15(d) of the
Securities Exchange Act of 1934 (15 U.S.C. 78m or 78o(d)) and that information contained in the periodic report fairly
presents, in all material respects, the financial condition and results of operations of the issuer. Wilful false/misleading
certification may result in penalties up to USD 5 million and a jail term up to 20 years.

Section 1107: Criminal penalties for retaliation against whistleblowers

Whoever knowingly, with the intent to retaliate, takes any action harmful to any person, including interference with
the lawful employment or livelihood of any person, for providing to a law enforcement officer any truthful information
relating to the commission or possible commission of any federal offense, shall be fined under this title, imprisoned
not more than 10 years, or both.

Sarbanes Oxley Compliance- Cost vs. Benefits
One of the key concerns during the implementation of provisions of Sarbanes Oxley Act was the compliance cost
associated with it vis-à-vis the benefits derived from the stricter provisions, specially compliance cost of Section 404 as
it required companies/entities to set up robust internal control framework along with resource cost of review of the
framework for operating effectiveness. Congressman Ron Paul and others such as former Arkansas governor Mike
Huckabee have opined that SOX unnecessarily pushed up costs and rendered U.S. corporations at a competitive
disadvantage with foreign firms, driving businesses out of the United States. A research study published by Joseph
Piotroski of Stanford University and Suraj Srinivasan of Harvard Business School titled "Regulation and Bonding:
Sarbanes Oxley Act and the Flow of International Listings" in the Journal of Accounting Research in 2008 found that
following the act's passage, smaller international companies were more likely to list in stock exchanges in the U.K.
rather than U.S. stock exchanges.
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However, throughout the years the cost associated with Sarbanes Oxley compliance continue to show a decreasing
trend.
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