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I also encourage management and Boards to incorporate 404 into a broader , longer-term , enterprise-wide risk management program , and not view it as a short-term , check-the-box exercise . Health Track works to identify possible at-risk employees and provide them with intervention programs , company-sponsored exercise opportunities , and general health education and disease management . [ 79 ] Traditionally , European exercise of jurisdiction has not been as encompassing of non-residents as the United States use of long arm statutes to establish jurisdiction . The Commission held a roundtable in April of this year to obtain feedback on the first year of 404 implementation from all interested parties , including directors and officers of public companies , both large and small , as well as investors and auditors.6 What I heard loud and clear at the roundtable was that the required assessment of internal controls has to a large extent shifted from management to the auditors in what has become a non-risk-based , check-the-box exercise with an apparent focus on controls for controls sake . Rather , the assessment became a mechanistic , check-the-box exercise . These include excessive levels of stress , elevated fat consumption , insufficient exercise , and excessive speed while driving . I have been concerned from the beginning that Section 404 would become an expensive , short-term , check-the-box exercise , taking focus away from management and moving it to internal and external auditors .