Since we didn't have a lot of our policies, procedures and standards documented, we needed to come up with a basic framework that we could use to get started.
Once we adopted a framework for developing policies, standards and procedures, we made really good progress. The documentation process really started to fall into place.
We still have a lot more work to do, but as far as the documentation and general infrastructure of our processes, it's pretty much done.
We spent the first six to eight months of the SOX project figuring out how we were going to do this.