Academic work suggests that the ambiguity of the term "cost-effective" in the FCPA weakened the rule considerably (Kinney et al. 1990). In fact, in the 1980s the existence of fraud and unexpected business failures led some members of Congress to question the adequacy of the financial reporting systems, and especially the internal controls, of public companies. This concern prompted the creation of the Treadway Commission and its call for additional internal control standards and guidance (Kinney et al. 1990). Specifically, the Commission recommended that all public companies should be required to include a report on internal control, written by management, in their annual reports a recommendation that has finally been realized under SOX Section 404.