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July 29, 2007


Rick Julien


I only have time for a quick reply

You and I have discussed this before during some presentations.....I respectfully disagree with you and Fred on this. The effectiveness of SOx 404 if effectively implemented and audited will work in most cases. It is not about any specific requirement but the interrelated nature of the entity level controls that will created an environment that there will need to be substantial collusion for financial fraud to continue for any amount of time. An active, knowledgeable audit committee, an effective hot line , ethics training, sub certifications, qualified financial reporting staff, a thoughtful 302 disclosure committee, a strong internal audit function etc etc

This really requires a strong active audit committee that believes in good corporate governance .........

SOx has been a good thing for our capital markets

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