Spreadsheet Woes – Burden in SOX Compliance and Other Regulations

End User Computing (EUC) or end User Developed Application (UDA) systems like spreadsheets used to be ideal ad-hoc solutions for data processing and financial reporting. But those days are long gone.

Today, due to regulations like the:

  • Sarbanes-Oxley (SOX) Act,
  • Dodd-Frank Act,
  • IFRS (International Financial Reporting Standards),
  • E.U. Data Protection Directive,
  • Basel II,
  • NAIC Model Audit Rules,
  • FAS 157,
  • yes, there?s more ? and counting

a company can be bogged down when it tries to comply with such regulations while maintaining spreadsheet-reliant financial and information systems.

In an age where regulatory compliance have become part of the norm, companies need to enforce more stringent control measures like version control, access control, testing, reconciliation, and many others, in order to pass audits and to ensure that their spreadsheets are giving them only accurate and reliable information.

Now, the problem is, these control measures aren’t exactly tailor-made for a spreadsheet environment. While yes, it is possible to set up a spreadsheet and EUC control environment that utilises best practices, this is a potentially expensive, laborious, and time-consuming exercise, and even then, the system will still not be as foolproof or efficient as the regulations call for.

Testing and reconciliation alone can cost a significant amount of time and money to be effective:

  1. It requires multiple testers who need to test spreadsheets down to the cell level.
  2. Testers will have to deal with terribly disorganized and complicated spreadsheet systems that typically involve single cells being fed information by other cells in other sheets, which in turn may be found in other workbooks, or in another folder.
  3. Each month, an organisation may have new spreadsheets with new links, new macros, new formulas, new locations, and hence new objects to test.
  4. Spreadsheets rarely come with any kind of supporting documentation and version control, further hampering the verification process.
  5. Because Windows won’t allow you to open two Excel files with the same name simultaneously and because a succession of monthly-revised spreadsheets separated by mere folders but still bearing the same name is common in spreadsheet systems, it would be difficult to compare one spreadsheet with any of its older versions.

But testing and reconciliation are just two of the many activities that make regulatory compliance terribly tedious for a spreadsheet-reliant organisation. Therefore, the sheer intricacy of spreadsheet systems make examining and maintaining them next to impossible.

On the other hand, you can’t afford not to take these regulations seriously. Non-compliance with regulatory mandates can have dire consequences, not the least of which is the loss of investor confidence. And when investors start to doubt the management’s capability, customers will start to walk away too. Now that is a loss your competitors will only be too happy to gain.

Learn more about our server application solutions and discover a better way to comply with regulations.

More Spreadsheet Blogs


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Top 10 Disadvantages of Spreadsheets


Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry


How Internal Auditors can win the War against Spreadsheet Fraud


Spreadsheet Reporting – No Room in your company in an age of Business Intelligence


Still looking for a Way to Consolidate Excel Spreadsheets?


Disadvantages of Spreadsheets


Spreadsheet woes – ill equipped for an Agile Business Environment


Spreadsheet Fraud


Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


Server Application Solutions – Don’t let Spreadsheets hold your Business back


Why Spreadsheets can send the pillars of Solvency II crashing down

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What Sub-Metering did for Nissan in Tennessee

When Nissan built its motor manufacturing plant in Smyrna 30 years ago, the 5.9 million square-foot factory employing over 8,000 people was state of art. After the 2005 hurricane season sky-rocketed energy prices, the energy team looked beyond efficient lighting at the more important aspect of utility usage in the plant itself. Let’s examine how they went about sub-metering and what it gained for them.

The Nissan energy team faced three challenges as they began their study. They had a rudimentary high-level data collection system (NEMAC) that was so primitive they had to transfer the data to spread-sheets to analyse it. To compound this, the engineering staff were focused on the priority of getting cars faster through the line. Finally, they faced the daunting task of making modifications to reticulation systems without affecting manufacturing throughput. But where to start?

The energy team chose the route of collaboration with assembly and maintenance people as they began the initial phase of tracking down existing meters and detecting gaps. They installed most additional equipment during normal service outages. Exceptions were treated as minor jobs to be done when convenient. Their next step was to connect the additional meters to their ageing NEMAC, and learn how to use it properly for the first time.

Although this was a cranky solution, it had the advantage of not calling for additional funding which would have caused delays. However operations personnel were concerned that energy-saving shutdowns between shifts and over weekends could cause false starts. ?We’ve already squeezed the lemon dry,? they seemed to say. ?What makes you think there?s more to come??

The energy team had a lucky break when they stumbled into an opportunity to prove their point early into implementation. They spotted a four-hourly power consumption spike they knew was worth examining. They traced this to an air dryer that was set to cyclical operation because it lacked a dew-point sensor. The company recovered the $1,500 this cost to fix, in an amazing 6 weeks.

Suitably encouraged and now supported by the operating and maintenance departments, the Smyrna energy team expanded their project to empower operating staff to adjust production schedules to optimise energy use, and maintenance staff to detect machines that were running without output value. The ongoing savings are significant and levels of shop floor staff motivation are higher.

Let’s leave the final word to the energy team facilitator who says, ?The only disadvantage of sub-metering is that now we can’t imagine doing without it.?

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Renewable energy – Is it a common man’s cup of tea?
I came across an article on a young graduate in renewable energy engineering. The fellow was doing technical sales and marketing jobs for renewable energy products though he felt that as a graduate, he ought to be doing more than just sales. His, sentiments, I can relate with but again thinking about the field of renewable energy, how many people understand what it is, its importance/ benefits, how to acquire it, its installation, costs etc.? Renewable energy is energy generated from natural resources. The renewable energy sources include sunlight, wind, rain, tides, geothermal heat and various forms of biomass. These sources are renewable naturally and continuously replenished, therefore this energy cannot be exhausted. Renewable energy technologies range from solar power, wind power, hydroelectricity/micro hydro, biomass and bio-fuels for transportation. Back to the aspiring young professional who felt that his place in the renewable energy sector lies in doing strategies and coming up with new products-the advice fronted to him was that doing technical sales is the best job for engineers, as it helps them impact on users of their products. Sales entail interacting with customers and knowing their needs so that the product features can be enhanced to suit the customer?s needs. Now, that is brilliant and accurate advice. It is however important to take into consideration that renewable energy is not a common man?s cup of tea and right now the focus all over the world is to build green economies. To me the need for more and more people to understand the benefits, savings and cost of renewable energy cannot be overemphasised. Effort should be made to keep marketing of renewable energy products/ services simple and conversational by avoiding use of acronyms or jargon explaining about operational details. More impact can be made if a marketing rather than technical sales approach is used. Technical sales have been described as boring (can be used as a sleeping aid), tends to use extensive vocabulary, jargon and acronyms that product users cannot relate with and tends to discuss the products technical aspects as opposed to the benefits to the customer. Fun should be created out of all this by making things simple and demonstrating cost savings and benefits of renewable energy.
2015 ESOS Guidelines Chapter 1 ? Who Qualifies

The base criteria are any UK undertaking that employs more than 250 people and/or has a turnover in excess of ?50 million and/or has a balance sheet total greater than ?43 million. There is little point in attempting to separate off high polluting areas. If one corporate group qualifies for ESOS, then all the others are obligated to take part too. The sterling equivalents of ?38,937,777 and ?33,486,489 were set on 31 December 2014 and apply to the first compliance period.

Representatives of Overseas Entities

UK registered branches of foreign entities are treated as if fully UK owned. They also have to sign up if any overseas corporate element meets the threshold no matter where in the world. The deciding factor is common ownership throughout the ESOS system. ecoVaro appreciates this. We have seen European companies dumping pollution in under-regulated countries for far too long.

Generic Undertakings that Could Comply

The common factor is energy consumption and the organisation’s type of work is irrelevant. The Environmental Agency has provided the following generic checklist of undertakings that could qualify:

Limited Companies Public Companies Trusts
Partnerships Private Equity Companies Limited Liability Partnerships
Unincorporated Associations Not-for-Profit Bodies Universities (Per Funding)

Organisations Close to Thresholds

Organisations that come close to, but do not quite meet the qualification threshold should cast their minds back to previous accounting periods, because ESOS considers current and previous years. The exact wording in the regulations states:

?Where, in any accounting period, an undertaking is a large undertaking (or a small or medium undertaking, as the case may be), it retains that status until it falls within the definition of a small or medium undertaking (or a large undertaking, as the case may be) for two consecutive accounting periods.?

Considering the ?50,000 penalty for not completing an assessment or making a false or misleading statement, it makes good sense for close misses to comply.

Joint Ventures and Participative Undertakings

If one element of a UK group qualifies for ESOS, then the others must follow suit with the highest one carrying responsibility. Franchisees are independent undertakings although they may collectively agree to participate. If trusts receive energy from a third party that must do an ESOS, then so must they. Private equity firms and private finance initiatives receive the same treatment as other enterprises. De-aggregations must be in writing following which separated ESOS accountability applies.

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