Sticker Shock
(continued)
Not Adding Up How realistic are the following cost assumptions made by the SEC? Note: Numbers may not add up to 100%, due to rounding.
| 1) External legal and audit fees run an average of $300 per hour. | | Very low | | 3% | | Low | | 24% | | Accurate | | 56% | | High | | 16% | | Very high | | 1% |
| | 2) Internal professional staff costs are $125 per hour. | | Very low | | 2% | | Low | | 13% | | Accurate | | 47% | | High | | 33% | | Very high | | 5% |
| | 3) Complying with Reg G (reconciling pro forma to reported earnings) can be accomplished by an in-house junior accountant in about 30 minutes per filing, at a cost of $13 including overhead. | | Very low | | 50% | | Low | | 39% | | Accurate | | 11% | | High | | 0% | | Very high | | 0% |
| | 4) Disclosure associated with off-balance sheet arrangements costs $10,000, including in-house staff time and outside professional fees. | | Very low | | 15% | | Low | | 45% | | Accurate | | 33% | | High | | 5% | | Very high | | 2% |
| | 5) Additional disclosure associated with nonaudit fees and changes in practices to promote auditor independence takes about two hours, half a page of a proxy and/or 10-K, and costs about $418 per filing, including internal and external staff fees. | | Very low | | 23% | | Low | | 53% | | Accurate | | 23% | | High | | 2% | | Very high | | 0% |
| | 6) The average annual cost of implementing Section 404 is around $91,000 per company. | | Very low | | 23% | | Low | | 53% | | Accurate | | 13% | | High | | 6% | | Very high | | 0% |
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