Greetings Clients and Friends,

The Public Company Accounting Reform and Investor Act or Sarbanes-Oxley (SOX) Act of 2002 represents one of the most significant pieces of business legislation enacted in the past 25 years. Section 404 of this Act requires that management of publicly traded companies report on the effectiveness of the entity’s internal control and this report must be audited by the entity’s external auditors. Compliance with these reporting requirements will be a time-consuming and complex process for both management and the external auditors.

While compliance with the Act is the responsibility of the company, our firm is committed to helping our clients meet the requirements and obligations of SOX 404. This update is the first of our planned bi-weekly update memos which will be distributed by email. In addition, we plan to distribute literature, provide web links and other resources and hold both in-house and client-based training sessions. This information is intended to supplement the additional research performed by your staff.

In connection with assisting our firm and its clients to meet the responsibilities under the SOX 404 directives, we are pleased to announce the addition of Holly Holt to our team. Holly joins us at the Manager level and brings experience in both public accounting and industry to the firm. After graduating from Southwestern University in Georgetown Texas in 1983 with a BBA in Accounting (Cum Laude), Holly joined the Waco office of a Texas regional public accounting firm. She received her CPA in 1985 from the State of Texas (her reciprocal Colorado license is pending). After leaving public accounting, she became the Assistant Controller for the Dwyer Group Inc., a publicly traded company located in Waco Texas. She moved to Colorado in 1997 where she most recently worked as the Assistant Controller and Internal Auditor for National PetCare Centers, Inc. Holly joined The GHP Financial Group in September 2004 and will be focusing on SOX 404 training and compliance. She can be contacted at HHolt@ghpcpa.com. Her direct telephone extension is (303) 831-5080.

One of the first steps in the SOX 404 process will be for the company to document its internal control system. PCAOB Auditing Standard No. 2 An Audit of Internal Control Over Financial Reporting Performed in Conjunction with an Audit of Financial Statements provides the professional standards and related performance guidance to management on how to prepare and document compliance with the Act. A copy of this standard is located on the PCAOB website located at www.pcaobus.org. Another highly recommended reading is a publication from PricewaterhouseCoopers, Practical Guidance for Management, located at www.pwcglobal.com. Both these publications will provide valuable insight in the documentation process. If you are unable to access these items, please email Holly Holt will provide you with a copy of the information.

This e-mail contains only a brief summary of selected provision of the SOX 404 requirements and is provided by The GHP Financial Group as a service to clients and other interested individuals. Any action based on this information should be taken only after consulting with your GHP Financial Group advisor or legal council. For more information, please contact us at (303) 831-5000.

Regards,

Don Pangburn, CPA

Director
Gelfond Hochstadt Pangburn P.C.
Direct Phone and fax (303) 831-5064