The Top Down Group has developed a  customized, efficient and repeatable approach to SOX 404 compliance for our clients, focusing on adding value and improving efficiency.

Our five step process begins with the preparation of a top down, qualitative and quantitative assessment of our client's financial statements in order to gauge the significant processes and locations that should be documented and assessed for purposes of Sarbanes Oxley compliance.

• It is during this step where we review any unnecessary procedures or processes which often reduce productivity and increase costs. A risk and control matrix describing the control activities of the key processes and locations is created.

An Executive Summary of the project is also prepared for management and the external auditors  to ensure aggreement with scope and deadlines.

• The Executive Summary includes a project plan and timeline with estimated completion dates, and also highlights the number of controls to be tested to accurately monitor the effectiveness of the controls and the status of the project.

We then develop automated test plans and perform the testing of the key controls to determine whether or not they are operating effectively.

• Testing is performed in a two-phased approach, and internal resources are utilized where practical per the standards of Auditing Standard 5 to further reduce the cost of compliance for our clients.

Control gaps or identified deficiencies are next evaluated individually and in the aggregate to determine significance and effect on internal control.

• Suggestions to remediate deficiencies are discussed with management and implemented prior to phase II testing.

Finally, we prepare a year end assessment which documents the approach and scope of the program, the results of testing, the significance of any remaining deficiencies and management's evaluation of its controls over financial reporting.

• This report forms the basis of management's asssessment of internal control over financial reporting which is filed annually.