The requirements of the Sarbanes-Oxley Act of 2002, passed by Congress in the wake of the Enron and WorldCom scandals, apply only to companies that file reports with the Securities and Exchange Commission. However, some of the principles that are contained in the act (commonly known as “SOX”) provide good guidance on how nonpublic companies and independent planners should conduct their businesses.

Section 404 of SOX requires management of public companies to annually assess the effect

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