The following links may be of interest to you as you proceed down the path to Sarbanes-Oxley 404 Compliance. Some contain official and legal opinions, others are public forums where some who are "in-the-trenches" gather to pool their information and "lessons learned":
AICPA The American Institute of Certified Public Accountants is the national, professional organization for all Certified Public Accountants. Its mission is to provide members with the resources, information, and leadership that enable them to provide valuable services in the highest professional manner to benefit the public as well as employers and clients.
U.S. Securities & Exchange Spotlight on Sarbanes-Oxley
U.S. Securities & Exchange Sarbanes-Oxley FAQ's
Additional Public Forums on Sarbanes-Oxley:
www.sarbanes-oxley.com
www.sarbanes-oxley-forum.com