Survey Results: Location of 404 Management Report

1. In the SEC's June 2003 adopting release, the SEC expressed an expectation that companies would place their 404 management report in close proximity to the auditor's attestation report - near MD&A or immediately preceding the financial statements - and appropriately cross-referenced in Item 9A. In your Form10-K, where will you place the internal controls report (not including cross references)? (Total responses: n=194)
(select only one)
n=66 (34.02%) Immediately preceding the financial statements
n=16 (8.25%) Immediately after the financial statements
n=0 (0.00%) Immediately preceding MD&A
n=10 (5.15%) Immediately after MD&A
n=93 (47.94%) In Item 9A
n=9 (4.64%) Somewhere else

2. In addition to your Form 10-K, please indicate anywhere else that you will place your 404 management report: (Total responses: n=177)
(select all that apply, may total more than 100%)
n=71 (40.11%) Place it in the glossy annual report
n=3 (1.69%) Cross-reference it in the glossy annual report
n=2 (1.13%) Place it in the proxy statement
n=5 (2.82%) Cross-reference it in the proxy statement
n=4 (2.26%) Post it as a stand-alone document on the company's website
n=102 (57.63%) Haven't decided yet

3. For those that intend to place the 404 management report in the glossy annual report, do you intend to place it:(Total responses: n=150)
(select only one)
n=2 (1.33%) Near the front cover
n=14 (9.33%) Near the back cover
n=64 (42.67%) In the same location as it is in the Form10-K
n=10 (6.67%) Somewhere else besides the three choices above
n=60 (40.00%) Haven't decided yet

4. Even though CEO and CFO signatures are not required on the 404 management report, we hear that some intend to sign it. What are the intentions for your company? (Total responses: n=198)
(select only one)
n=34 (17.17%) Yes, our CEO and CFO intend to sign the 404 management report
n=111 (56.06%) No, no one will sign the 404 management report
n=0 (0.00%) Someone else besides the CEO and CFO will sign the 404 management report
n=53 (26.77%) Haven't decided yet

5. In the past, some companies have historically put in a statement about management's statement of responsibility for the financial statements (typically in the glossy annual report, right after MD&A and signed by the CEO and CFO). For those companies that have included such statements in the past: (Total responses: n=150)
(select only one)
n=38 (25.33%) Yes, we will continue to include a statement about management's responsibility for the financial statements
n=38 (25.33%) No, we will no longer include a statement about management's responsibility for the financial statements
n=74 (49.33%) Haven't decided yet