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Thomas Brandt Jr., CFO of Telecommunication Systems Inc., a $143 million producer of wireless software, keeps in his office a paper-based reminder of his first-year compliance under Section 404 of Sarbanes-Oxley, even though everything is also stored on computer systems. Despite the Annapolis, Md.-based company’s relatively small size, the 404-compliance project fills 18 ringed binders with all the process documentation, records of testing, interim testing and follow-up testing. “It was documented to an extreme, which is not to fault our auditing group that made the judgments,” says Brandt. “They had to cover their exposures and err on the safe side.”

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