The only portion of the law that is withheld in application to smaller issuers, is 404b. That is, the section defining the requirement for auditor reporting on internal controls.
That section is the major "cost" component in making SOX compliance expensive...
But, 404b being withheld from application... doesn't alter any of the other requirements of the law... it just means small companies don't have to pay to have their internal controls be audited.
Obviously, CLYW is a LONG way from having "the problem" being the cost of auditing internal controls over continuous reporting of inventory, etc. It wouldn't be expensive for CLYW to comply, either, given they don't HAVE anything else to audit other than finance... and that has to be audited already anyway. Auditing control over the checkbook... wouldn't be a big deal...
SOX changed rules in GOVERNANCE... and that law applies to CLYW... and THAT is the law that CLYW is running over roughshod right now...
Most SOX critics agree that the governance changes the law imposed were long past being made necessary...
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