Why Spreadsheets can send the Pillars of Solvency II Crashing Down
Solvency II is now fast approaching and while it may provide added protection to policy holders, its impact on the insurance industry is not all a bed of roses. Expect insurance companies to restructure, increase manpower, and raise spending on actuarial operations and risk management initiatives. Those that cannot, will have to go. But what have spreadsheets got to do with all these?
Well, spreadsheets aren’t really the main casts in this blockbuster of a regulatory exercise but they certainly have a significant supporting role to play. Pillar I of Solvency II, which calls for improved supervision on internal control, risk management, and corporate governance, and Pillar II, which tackles supervisory reporting and public disclosure of financial and other relevant information, both affect systems that have high-reliance on spreadsheets.
A little background about spreadsheets might help.
Who needs an IT solution when you can have spreadsheets?
Everyone in any organisation just love spreadsheets; from the office clerk to the CEO. Because they’re so easy to use (not to mention they’re a staple in office computers), people employ them for processing numbers and as an all-around tool for planning, forecasting, reporting, complex modelling, market data analysis, and so on. They make such tasks faster and easier. Really?
You probably haven’t heard of spreadsheet hell
Unfortunately, spreadsheets do have certain shortcomings. Due to their inherent structure and lack of controls, it is so easy to commit simple errors like an accidental copy paste, an omission of a negative sign, an incorrect data input, or an unintentional deletion. Such shortcomings may seem harmless until your shareholders discover a multi-million discrepancy in your financial report.
And because spreadsheet errors can go undetected for a long time, they are constant targets of fraudsters. In other words, spreadsheets are high risk applications.
Solvency II Impact on Spreadsheet-based Financial and IT Systems
Regulations like Solvency II, are aimed at reducing risks to manageable levels. Basically, Solvency II is a risk-based system wherein a company?s capital requirements will depend on its measured riskiness. If companies want to avoid facing onerous capital requirements, they have to comply.
The three pillars of Solvency II have to be in place. Now, since spreadsheets (also known as User Developed Applications or UDAs) are high-risk applications with weak control features and prone to produce inaccurate reports, companies will have a lot of work to do to establish Pillars II and III.
There are at least 8 articles that impact spreadsheets in the directive. Article 82, for example, which requires firms to ensure a high level of data quality and accuracy, strikes at the very core of spreadsheets? weakness.
A whitepaper by Raymond Panko entitled ?Spreadsheets and Sarbanes-Oxley: Regulations, Risks, and Control Frameworks? mentioned that 94% of audited real world operational spreadsheets that were included in his study were found to have errors and that an average of 5.2% of all cells in the audited spreadsheets had errors.
Furthermore, many articles in the directive call for the enforcement of better documentation. This is one thing that’s very tedious and almost unrealistic to do with spreadsheets because just about anyone uses them. Besides, with different ‘versions? of the same data existing in different workstations throughout the organisation, it would be extremely difficult to keep track of them all.
Because of spreadsheets you now need an IT solution
It is clear that, with the growing number of regulations and the mounting complexity of tasks needed for compliance, spreadsheets no longer belong in this era. What you need is a server-based solution that allows for seamless collaboration, data reliability, data consistency, increased security, automatic consolidation, and all the other features that make regulation compliance more doable.
One important ingredient for achieving Solvency II compliance is sound data risk management. Sad to say, the ubiquitous spreadsheet will only expose your data to more risks.
For many people within the UK, water is not really something to worry about. Surely enough of it falls out the sky throughout the year that it does feel highly unlikely that we?ll ever run out of it. There certainly does seem to be an abundance of Branded Water available in plastic bottles on our supermarket shelves.
Water, water, every where, And all the boards did shrink; Water, water, every where, Nor any drop to drink.
Despite this, Once-unthinkable water crises are becoming commonplace. If you consider that In England and Wales, we use 16 billion litres of clean drinking water every day ? that’s equivalent to 6,400 Olympic sized swimming pools.
Currently, water companies can provide slightly more than we need ? 2 billion litres are available above and beyond what we’re using. In some areas, though, such as south east England, there is no surplus and, as such, these regions are more likely to face supply restrictions in a dry year.
If we take little moment to reflect on some of the most notable water related stories over the past few years, we’ll start to get a picture of just how real the potential and the threat of water shortages can be.
Reservoirs in Chennai, India?s sixth-largest city, are nearly dry right now. Last year, residents of Cape Town, South Africa narrowly avoided their own Day Zero water shut-off.
It was only year before that, Rome rationed water to conserve scarce resources.
Climate change is likely to mean higher temperatures which may drive up the demand for water (alongside population growth) and increase evaporation from reservoirs and water courses during spring and summer.
The impact of climate change on total rainfall is uncertain, but the rain that does fall is likely to arrive in heavier bursts in winter and summer. Heavier rain tends to flow off land more quickly into rivers and out to sea, rather than recharging groundwater aquifers.
A greater chance of prolonged dry periods is also conceivable. This combined with the harsh reality that no human population can sustain itself without sufficient access to fresh water.
If present conditions continue, 2 out of 3 people on Earth will live within a water-stressed zone by 2025
What is water stress?
Water stress is a term used to describe situation when demand for water is greater than the amount of water available at a certain period in time, and also when water is of poor quality and this restricts its usage. Water stress means deterioration in both the quantity of available water and the quality of available water due to factors affecting available water.
Water stress refers to the ability, or lack thereof, to meet human and ecological demand for water. Compared to scarcity, water stress is a more inclusive and broader concept.
Water Stress considers several physical aspects related to water resources, including water scarcity, but also water quality, environmental flows, and the accessibility of water.
Supply and Demand
Major factors involved when water scarcity strikes is when a growing populations demand for water exceeds the areas ability to service that need.
Increased food production and development programs also lead to increased demand for water, which ultimately leads to water stress.
Increased need for agricultural irrigation in order to produce more crops or sustain livestock are major contributors to localised water stress.
Overconsumption
The demand for water in a given population is fairly unpredictable. Primarily, based on the fact that you can never accurately predict human behaviour and changes in climate.
If too many people are consuming more water than they need because they mistakenly believe that water is freely available and plentiful, then water stress could eventually occur.
This is also linked to perceived economic prosperity of a give region. Manufacturing demand for water can have huge impact regardless whether water is actively used within the manufacturing process or not.
Water Quality
Water quality in any given area is never static. Water stress could happen as a result of rising pollution levels having a direct impact on water quality.
Water contamination happens when new industries either knowingly or unknowingly contaminate water with their industrial practices.
Largely, this can happen and frequently does so because these industries do not take effective control of monitoring and managing their impact on communal water supplies. Incorrectly assuming this is the responsibility of an additional third party like the regional water company.
The truth is, water quality and careful monitoring of it is all of our responsibility.
Water Scarcity
Simple increases in demand for water can in itself contribute to water scarcity. However, these are often preceded by other factors like poverty or just the natural scarcity of water in the area.
In many instances, the initial locations of towns or cities were not influenced by the close proximity of natural resources like water, but rather in pursuit of the extraction of other resources like Gold, Coal or Diamonds.
For Instance, Johannesburg, South Africa is the largest City in South Africa and is one of the 50 largest urban areas in the world. It is also located in the mineral rich Witwatersrand range of hills and is the centre of large-scale gold and diamond trade.
Johannesburg is also one of the only major cities of the world that was not built on a river or harbour. However, it does have streams that contribute to two of Southern Africas mightiest rivers – Limpopo and the Orange rivers. However, most of the springs from which many of these streams emanate are now covered in concrete!
Water Stress and Agriculture
Peter Buss, co-founder of Sentek Technology calls ground moisture a water bank and manufactures ground sensors to interrogate it. His hometown of Adelaide is in one of the driest states in Australia. This makes monitoring soil water even more critical, if agriculture is to continue. Sentek has been helping farmers deliver optimum amounts of water since 1992.
The analogy of a water bank is interesting. Agriculturists must ?bank? water for less-than-rainy days instead of squeezing the last drop. They need a stream of real-time data and utilize cloud-based storage and processing power to curate it.
Sentek?s technology can be found in remote places like Peru?s Atacamba desert and the mountains of Mongolia, where it supports sustainable floriculture, forestry, horticulture, pastures, row crops and viticulture through precise delivery of scarce water.
This relies on precision measurement using a variety of drill and drop probes with sensors fixed at 4? / 10cm increments along multiples of 12? / 30cm up to 4 times. These probe soil moisture, soil temperature and soil salinity, and are readily repositioned to other locations as crops rotate.
Peter Buss is convinced that measurement is a means to an end and only the beginning. ?Too often, growers start watering when plants don’t really need it, wasting water, energy, and labour. By accurately monitoring water can be saved until when the plant really needs it.
Peter also emphasises that crop is the ultimate sensor, and that ?we should ask the plant what it needs?.
This takes the debate a stage further. Water wise farmers should plant water-wise crops, not try to close the stable door after the horse has bolted and dry years return.
The South Australia government thinks the answer also lies in correct farm dam management. It wants farmers to build ones that allow sufficient water to bypass in order to sustain the natural environment too.
There is more to water management than squeezing the last drop. Soil moisture goes beyond measuring for profit. It is about farming sustainably using data from sensors to guide us.
Ecovaro is ahead of the curve as we explore imaginative ways to exploit the data these provide for the common good of all.
A Quarter of the World?s Population, Face High Water Stress
Data from WRI?s Aqueduct tools reveal that 17 countries? home to one-quarter of the world?s population?face ?extremely high? levels of baseline water stress, where irrigated agriculture, industries and municipalities withdraw more than 80% of their available supply on average every year.
Water stress poses serious threats to human lives, livelihoods and business stability. It’s poised to worsen unless countries act: Population growth, socioeconomic development and urbanization are increasing water demands, while climate change can make precipitation and demand more variable.
How to manage water stress
Water stress is just one dimension of water security. However, like any challenge, its outlook depends on adequate monitoring and management of environmental data.
Even countries with relatively high water stress have effectively secured their water supplies through proper management by leveraging the knowledge they have garnered by learning from the data they gathered.
3 ways to help reduce water stress
In any geography, water stress can be reduced by measures ranging from common sense to innovative technology solutions.
There are countless solutions, but here are three of the most straightforward:
1. Increase agricultural efficiency: The world needs to make every drop of water go further in its food systems. Farmers can use seeds that require less water and improve their irrigation techniques by using precision watering rather than flooding their fields.
Businesses need to increase investments to improve water productivity, while engineers develop technologies that improve efficiency in agriculture.
2. Invest in grey and green infrastructure: D Data produced by Aqueduct Alliance – shows that water stress can vary tremendously over the year. WRI and the World Bank?s researchshows that built infrastructure (like pipes and treatment plants) and green infrastructure (like wetlands and healthy watersheds) can work in tandem to tackle issues of both water supply and water quality.
3. Treat, reuse and recycle: We need to stop thinking of wastewater as waste.
Treating and reusing it creates a ?new? water source.
There are also useful resources in wastewater that can be harvested to help lower water treatment costs. For example, plants in Xiangyang, China and Washington, D.C. reuse or sell the energy- and nutrient-rich byproducts captured during wastewater treatment.
Summary
The data is undeniably clear, there are very worrying trends in water.
Businesses and other other organisations need to start taking action now and investing in better monitoring and management, we can solve water issues for the good of people, economies and the planet. We collectively cannot kick this can down the road any further, or assume that this problem will be solved by others.
It is time, for a collective sense of responsibility and for everyone to invest in future prosperity of our Planet as a collective whole. Ecological preservation should be at the forefront of all business plans because at the end of the day profit is meaningless without an environment to enjoy it in!
Section 404 contains the most onerous and most costly requirements you’ll ever encounter in the Sarbanes-Oxley Act (SOX). In this article, we?ll take a closer look at the salient points of this contentious piece of legislation as it relates to IT. We?ll also explain why companies are encountering difficulties in complying with it.
Then as soon as we’ve tackled the main issues of this section and identify the pitfalls of compliance, we can then proceed with a discussion of what successful CIOs have done to eliminate those difficulties and consequently bring down their organisation’s IT compliance costs. From this post, you can glean insights that can help you plan a cost-effective way of achieving IT compliance with SOX.
SOX 404 in a nutshell
Section 404 of the Sarbanes-Oxley Act, entitled Management Assessment of Internal Controls, requires public companies covered by the Act to submit an annual report featuring an assessment of their company?s internal controls.
This ?internal control report? should state management’s responsibility in establishing/maintaining an adequate structure and a set of procedures for internal control over your company?s financial reporting processes. It should also contain an assessment of the effectiveness of those controls as of the end of your most recent fiscal year.
Because SOX also requires the public accounting firm that conducts your audit reports to attest to and report on your assessments, you can’t just make baseless claims regarding the effectiveness of your internal controls. As a matter of fact, you are mandated by both SEC and PCAOB to follow widely accepted control frameworks like COSO and COBIT. This framework will serve as a uniform guide for the internal controls you set up, the assessments you arrive at, and the attestation your external auditor reports on.
Why compliance of Section 404 is costly
Regardless which of the widely acceptable control frameworks you end up using, you will always be asked to document and test your controls. These activities can consume a considerable amount of man-hours and bring about additional expenses. Even the mere act of studying the control framework and figuring out how to align your current practices with it can be very tricky and can consume precious time; time that can be used for more productive endeavours.
Of course, there are exceptions. An organisation with highly centralised operations can experience relative ease and low costs while implementing SOX 404. But if your organisation follows a largely decentralised operation model, e.g. if you still make extensive use of spreadsheets in all your offices, then you’ll surely encounter many obstacles.
According to one survey conducted by FEI (Financial Executives International), an organisation that carried out a series of SOX-compliance-related surveys since the first year of SOX adoption, respondents with centralised operations enjoyed lower costs of compliance compared to those with decentralised operations. For example, in 2007, those with decentralised operations spent 30.1 % more for compliance than those with centralised operations.
The main reason for this disparity lies in the disorganised and complicated nature of spreadsheet systems.
Unfortunately, a large number of companies still rely heavily on spreadsheets. Even those with expensive BI (Business Intelligence) systems still use spreadsheets as an ad-hoc tool for data processing and reporting.
Because compliance with Section 404 involves a significant amount of fixed costs, smaller companies tend to feel the impact more. This has been highlighted in the ?Final Report of the Advisory Committee on Smaller Public Companies? published on April 23, 2006. In that report, which can be downloaded from the official website of the US Securities and Exchange Commission, it was shown that:
Companies with over $5 Billion revenues spent only about 0.06% of revenues on Section 404 implementation
Companies with revenues between $1B – $4.9B spent about 0.16%
Companies with revenues between $500M – $999M spent about 0.27%
Companies with revenues between $100M – $499M spent about 0.53%
Companies with revenues less than $100M spent a whopping 2.55% on Section 404
Therefore, not only can you discern a relationship between the size of a company and the amount that the company ends up spending for SOX 404 relative to its revenues, but you can also clearly see that the unfavourable impact of Section 404 spending is considerably more pronounced in the smallest companies. Hence, the smaller the company is, the more crucial it is for that company to find ways that can bring down the costs of Section 404 implementation.
How to alleviate costs of section 404
If you recall the FEI survey mentioned earlier, it was shown that organisations with decentralised operations usually ended up spending more for SOX 404 implementation than those that had a more centralized model. Then in the ?Final Report of the Advisory Committee on Smaller Public Companies?, it was also shown that public companies with the smallest revenues suffered a similar fate.
Can we draw a line connecting those two? Does it simply mean that large spending on SOX affects two sets of companies, i.e., those that have decentralised operations and those that are small? Or can there be an even deeper implication? Might it not be possible that these two sets are actually one and the same?
From our experience, small companies are less inclined to spend on server based solutions compared to the big ones. As a result, it is within this group of small companies where you can find a proliferation of spreadsheet systems. In other words, small companies are more likely to follow a decentralised model. Spreadsheets were not designed to implement strict control features, so if you want to apply a control framework on a spreadsheet-based system, it won’t be easy.
For example, how are you going to conduct testing on every single spreadsheet cell that plays a role in financial reporting when the spreadsheets involved in the financial reporting process are distributed across different workstations in different offices in an organisation with a countrywide operation?
It’s really not a trivial problem.
Based on the FEI survey however, the big companies have already found a solution – employing a server-based system.
Typical server based systems, which of course espouse a centralised model, already come with built-in controls. If you need to modify or add more controls, then you can do so with relative ease because practically everything you need to do can be carried out in just one place.
For instance, if you need to implement high availability or perform backups, you can easily apply redundancy in a cost-effective way – e.g. through virtualisation – if you already have a server-based system. Aside from cost-savings in SOX 404 implementation, server-based systems also offer a host of other benefits. Click that link to learn more.
While some organisation leaders loathe spending on IT, a growing number are already convinced of the necessity of investing in it. Unfortunately, a substantial fraction of those convinced to pursue IT investments are misguided as to which initiatives are really contributory to reaching their organisation’s goals.
In the end, many of their purchases either end up underutilised or become white elephants altogether. There are also those difficult to spot – IT purchases that do become integrated into daily operations but have little effect on the organisation’s growth, positioning, profitability, or efficiency.
If a purchase is to cost your company a fortune, then its positive impact on established company objectives should reflect accordingly. But how would you know it would? You can’t hope to foresee all its benefits especially if the IT solution is still quite new to you.
Our job is not only to identify the strengths of an IT system but also to determine whether these strengths are at all useful to your organisation’s thrusts.
Basically, here’s what we’ll do:
Conduct a rigorous analysis of your organisation to determine the specific and overall impact of certain IT solutions. We’ll be looking for areas where the effects of IT can result in the most rapid reduction of costs and, at the same time, drive the organisation in the direction of its established goals.
Propose cohesive best-of-breed solutions in line with the results of our analysis. Our familiarity with the IT landscape and our extensive selection of contacts in the industry will allow us to conduct insightful picks from a vast field of choices.
Establish best practices to make sure IT investments are optimally utilised.
Perform periodic reviews to ensure practices and processes are still in line with the established goals.
Find out how we can increase your efficiency even more:
