Case 3

A small biomedical company has had great success in the last four years and is now generating $75 million per year in sales. The company has only three employees, all siblings. Their strategy for success has involved leveraging a few valuable patents and outsourcing almost all business functions. The siblings are planning to take their company public with the hope of generating capital for expansion. Launching an IPO, however, will require them to become SOX 404 compliant. At present, the siblings are the only members of the board of directors and are the only officers of the company.

1. Analyze whether it is possible for a three-person company to become SOX 404 compliant?
2. What general steps should the siblings take to do so?