The SEC conducted a comprehensive survey on the economic effects of section 404 between
December 2008 and January 2009, which received responses from 2,901 companies representing
over half the companies filing Sec 404 (b) reports at that time. Based on this sample, Alexander,
Bauguess, Bernile, Lee, and Marietta-Westberg (2013) report a causal link between section 404
compliance and improvements in quality of the firms’ information environment, such as a positive
impact on IC structures, quality of financial reporting, and firm’s ability to prevent and detect fraud.
Despite respondents’ recognition of specific benefits, only 19 percent perceived a net benefit for
fiscal years completed after the 2007 reforms, with another 20 percent saying the costs and benefits
were equivalent.