SARBANES-OXLEY IMPLEMENTATION: A CASE STUDY Melanie R. Stiggers, PricewaterhouseCoopers Jeffrey E. Michelman & Bobby E. Waldrup, University of North Florida Case Objectives and Use The case exposes students to the impact of Section 404 of the Sarbanes-Oxley Act of 2002. Moreover, this objective should help students to gain a better understanding of the impact of change on the profession of accounting/auditing and on the organizations that these functions operate within. These concepts are extended by examining the importance of audit documentation. This includes the overall concept of re-performance in audit work, as well as the newly established requirements of PCAOB AS 3: Audit Documentation. Further, the case deals with the role of mentors in a organization. This deals more specifically with a mentor’s role in the efficient acclimation of new staff in an organization. Finally, the case addresses several organizational behaviour issues. In particular, the need and ability to enact change in an organization; written vs. oral Communication; management’s role in facilitating organizational change and communication. In addition, this would be a important time to discuss the impact of SOX on non-covered organizations and the impact of rating agencies, state regulators and boards of directors on internal control system development and compliance. This case can be used to facilitate learning as well as supplement a test and in class discussions in an undergraduate or graduate auditing or internal audit class. Case Synopsis Since its passing, no legislation has had a more profound impact on the business community in the past seventy years than the Sarbanes-Oxley Act of 2002. Criticized tremendously for its significant requirements on an organization, this paper explores those requirements from the trenches of an implementation effort. Additionally, it takes the perspective of an intern newly inducted into an organization, and her efforts to navigate her matriculation through a 404 implementation. The authors developed the case for class discussion rather than to illustrate either effective or ineffective handling of the situation. The case, instructor’s manual, and synopsis were anonymously peer reviewed and accepted by the North American Case Research Association (NACRA) for its annual meeting, October 27-29, 2005, North Falmouth, MA. All rights are reserved to the authors and NACRA. © 2005 Melanie R. Stiggers, Jeffrey E. Michelman and Bobby E. Waldrup. Contact person: Jeffrey E. Michelman, Coggin College of Business, University of North Florida, 4567 St. Johns Bluff Rd., Jacksonville, FL, 32224, 904-620-1541, jmichelm@unf.edu