As the nation approaches the end of 2004, we also approach the moment of truth for the Sarbanes-Oxley Act's most onerous provision, Section 404. Will its demanding requirements produce myriad revelations about wholesale corporate wrongdoing–and the market tumult that would inevitably follow? Or will we merely be privy to a series of company failures to dot their i's or cross their t's–and the market tumult that could unfortunately follow? Regulators have left large patches of gray when it comes to some key definitions, so it's almost inevitable that there will be some differences of opinion on how the law's various tests should be applied. We are already seeing some similar debate involving derivative accounting rule FAS 133 (see page 30), and accounting problems with FAS 133 should logically lead to problems–or at least uncertainty–with Section 404. Given the rigors of the project and the cloudiness about how the review process will play out, rather than wish you all a Happy New Year, I'll simply say, "Good luck."