On Wed, 2 Mar 2005 15:21:17 -0800, Laurie Gingrich
<[log in to unmask]> wrote:
> For those who work at publicly held companies, are you aware of any retention decisions that have been made concerning Sarbanes-Oxley section 404 documentation?  I have  heard this question being asked within companies, but so far no definitive decisions.

I am not aware of any federal regulations concerning documentation of
Section 404 compliance, but I look upon this like I did the Y2K
records retention discussions held here many years ago. That is if you
have created records that document your companies efforts to comply
with the various SOX requirements and desires than they should be
scheduled. The retention, if regulatory and statutory requirements are
absent, will be determined by the following values Operational,
administrative, fiscal, legal and historical. The retention period
decided upon will vary from company to company.

The records management program at my company is just one part of an
overall compliance program (privacy is another component). Records
mgmt offers such internal controls as records hold notices, records
destruction authorization etc. The biggest problem is educating the
umpteen thousand employees why it is being done.

Peterk

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