Since its enactment in 2002 in response to notorious financial scandals at Enron, WorldCom, and other corporate behemoths, the Sarbanes-Oxley Act, or SOX, has been a continuing target of criticism. And probably no provision of the law has provoked more animus than Section 404(b), which requires public companies to have external auditors annually assess the adequacy of their internal controls over financial reporting. Scorned recently by one prominent economist as “one of the most costly and counterproductive regulations ever introduced,” SOX