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DESPITE SIGNIFICANT IMPROVEMENTS since the U.S. Sarbanes-Oxley Act of 2002 became effective, the continuing cost of compliance with the act's Section 404 requirements remains a concern for board members and management. A periodic operational audit of the Section 404 program can provide valuable information to executive management and the audit committee, and potentially identify areas where significant costsavings can be realized. Whether the Section 404 program is managed by the finance department, internal auditing, or another organization, it's an excellent candidate for this type of review, particularly if the focus remains on program efficiency. Several questions, based on The IIA's publication Sarbanes-Oxley Section 404: A Guide for Management by Internal Control Practitioners, can be used as the basis for the audit. The questions cover issues ranging from ensuring that operating management takes ownership of its processes, to achieving fewer and more effective key controls, to determining whether the external auditor's reliance on management testing has been optimized.