The Public Company Accounting Reform and Investor Protection Act, otherwise known as the Sarbanes-Oxley Act (the "Act"), was enacted in July 2002 after a series of high-profile corporate scandals involving companies such as Enron and Worldcom. Section 404(a) of the Act requires management to assess and report on the effectiveness of internal control over financial reporting ("ICFR"). Section 404(b) requires that an independent auditor attest to management's assessment of the effectiveness of those internal controls. Because the cost of complying with the requirements of Section 404 of the Act ("Section 404") has been generally viewed as being unexpectedly high,1 efforts to reduce the costs while retaining the effectiveness of compliance resulted in a series of reforms in 2007. This report presents an analysis of data from publicly traded companies collected from an SEC-sponsored Web survey of financial executives of companies with Section 404 experience conducted during December 2008 and January 2009. The analysis of the survey data is designed to inform the Commission and other interested parties as to whether changes occurring since 2007 are having the intended effect of facilitating more cost-effective internal controls evaluations and audits, especially as they may apply to smaller reporting companies. The findings of the analysis relating to efficiency include evidence on the total and component compliance costs, the changes in costs over time, and the factors that help to explain why costs are lower or higher for some companies than for others. These findings include evidence of direct and indirect effects that management ascribes to Section 404 compliance, including evidence on intended benefits. The 2007 reforms that are the focus of this inquiry include the SEC's June 2007 Management Guidance and its order approving the Public Company Accounting Oversight Board's (PCAOB) Accounting Standard No. 5 (AS5) (collectively referred to as the "2007 reforms"). We are primarily interested in whether and how companies' experience with Section 404(b) compliance changed following the reforms, yet this report also presents evidence on the implementation of both Section 404(a) and Section 404(b). This reflects the interrelationship between the two requirements.