How To Get Started with your IT Compliance Efforts for SOX

There’s no question about it. For many of you top executives in the corporate world, all roads leading to a brighter future have to go through SOX compliance. And because the business processes that contribute to financial reporting (the crux of the Sarbanes-Oxley Act) are now highly reliant on IT systems, it is important to focus a good part of your attention there.

It is a long and arduous path to IT compliance, so if you don’t want your company to fall by the wayside due to inefficient utilisation of resources, it is important to set out with a plan on hand. What we have here are some vital information that will guide you in putting together a sound plan for SOX compliance of your company?s IT systems.

Why focus on IT systems for SOX compliance?

We’ll get to that. But first, let’s take up the specific portions of the Sarbanes-Oxley Act that affect information technology. These portions can be found in Section 302 and Section 404 of the act.

In simplified form, Section 302 grants the SEC (Securities and Exchange Commission) authority to come up with rules requiring you, CEOs and CFOs, to certify in each annual or quarterly financial report the following:

  • that you have reviewed the report;
  • that based on your knowledge, the report does not contain anything or leave out anything that would render it misleading;
  • that based on your knowledge, all financial information in the report fairly represent the financial conditions of the company;
  • that you are responsible for establishing internal controls over financial reporting; and
  • that you have assessed the effectiveness of the internal controls.

Similarly, Section 404, stated in simplified form, allows the SEC to come up with rules requiring you, CEOs and CFOs, to add an internal control report to each annual financial report stating that you are responsible for establishing internal controls over financial reporting.

You are also required to assess the effectiveness of those controls and to have a public accounting firm to attest to your assessment based upon standards adopted by the Public Company Accounting Oversight Board (PCAOB).

While there is no mention of IT systems, IT systems now play a significant role in financial reporting. Practically all of the data you need for your financial reports are stored, retrieved and processed on IT systems, so you really have to include them in your SOX compliance initiatives and establish controls on them.

Now that that’s settled, your next question could very well be: How do you know what controls to install and whether those controls are already sufficient to achieve compliance?

Finding a suitable guide for IT compliance

The two bodies responsible for setting rules and standards dealing with SOX, SEC and PCAOB, point to a well-established control framework for guidance – COSO. This framework was drafted by the Committee of Sponsoring Organisations of the Treadway Commission (COSO) and is the most widely accepted control framework in the business world.

However, while COSO is a tested and proven framework, it is more suitable for general controls. What we recommend is a widely-used control framework that aligns well with COSO but also caters to the more technical features and issues that come with IT systems.

Taking into consideration those qualifiers, we recommend COBIT. COBIT features a well thought out collection of IT-related control objectives grouped into four domains: Plan and Organise (PO), Acquire and Implement (AI), Deliver and Support (DS), and Monitor and Evaluate (ME). The document also includes maturity models, performance goals and metrics, and activity goals.

A few examples of COBIt’s detailed control objectives are:

DS4.2 – IT Continuity Plans
DS4.9 – Offsite Backup Storage
DS5.4 – User Account Management
DS5.8 – Cryptographic Key Management
DS5.10 – Network Security
DS5.11 – Exchange of Sensitive Data

By those titles alone, you can see that the framework is specifically designed for IT. But the document is quite extensive and, chances are, you won’t need all of the items detailed there. Furthermore, don’t expect COBIT to specify a control solution controls for every control objective. For example, throughout the control objective DS4 (Ensure Continuous Service), you won’t find any mention of virtualisation, which is common in any modern business continuity solution.

Basically, COBIT will tell you what you need to attain in order to achieve effective governance, management and control, but you’ll have to pick the solution best suited to reach that level of attainment.

Articles highly relevant to the one you just read:

Month End Accounting The Way It Should Be Today
Spreadsheet Woes ? Burden in SOX Compliance and Other Regulations
Spreadsheet Woes ? Limited Features For Easy Adoption of a Control Framework
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Spreadsheet Risks in Banks

No other industry perhaps handles such large volumes of critical financial data more than the banking industry. For decades now, spreadsheets have become permanent fixtures in the front-line reporting tool sets of banks, providing organised information when and where needed.

But as banks enter into a period of heightened credit risks, elevated levels of fraud, and greater regulatory scrutiny, many are wondering if continued reliance on spreadsheets is a wise decision for banks today.

The downfall of Lehman Brothers which eventually led to its filing for Chapter 11 bankruptcy protection on September 15, 2008, served as a wake up call for many institutions across the globe to make a serious examination of their own risk management practices. But would these reforms include evaluating the security of user developed applications (UDAs), the most common of which are spreadsheets, and putting specific guidelines as to when they can – or cannot be – used?

Banks and Spreadsheet Use

Banks have been known to utilise spreadsheets systems for many critical functions because most personnel are well-acquainted with them, and the freedom of being able to develop customised reports without needing to consult with the IT department offers flexibility and convenience. In fact, more than having a way to do financial budgeting and analysing customer profitability, even loan officers and trade managers have become reliant on spreadsheets for risk management reporting and for making underwriting decisions.

But there are more than a few drawbacks to using spreadsheets for these tasks, and the sooner bank executives realise these, the sooner they can adopt better solutions.

General Limitations

Spreadsheets are far from being data base systems and yet more often than not, they are expected to act as such, with figures constantly added and formulas edited to produce the presumably right set of reports.

In addition, data integrity is always a cause for concern as most values in spreadsheets are entered as manual inputs. Even the mere misplacement of a comma or a negative sign, or an inadvertent ?edit? to a formula can also be a source of significant changes in the outcome.

Confidentiality risk is also another drawback of the use of spreadsheets in banks as these tools do not have adequate?access controls to limit access to only authorised individuals. Pertinent financial information that fall into the wrong hands can lead to a whole new set of problems including the possibility of fraud.

Risks in Trading

For trading transactions, spreadsheets can prove to be of immense use – but only for small market volumes. As trade volumes increase and the types vary, spreadsheets are no longer a viable solution and may likely become more of a hindrance, with calculations taking longer in the face of bigger transaction amounts and growing transaction data.

And in trading, there is always the need for rigorous computational functions. Computing for the Value at Risk (VaR) for large portfolios for instance, is simply way beyond the capabilities of spreadsheets. Banks that persist in using them are increasing the risk of loss on those portfolios. Or, they can be opening up?opportunities for fraud?as Allied Irish Bank (in the case of John Rusnak – $690 million) learned the hard way.

Risks in Underwriting

Bankers who use spreadsheets as their main source of information for underwriting procedures also face certain limitations. Loan transactions require that borrowers? financial data be centralised and easily accessible to risk officers and lending officers involved in making decisions. With spreadsheets, there is no simple and secure way of doing that. Information can be pulled from different sources – individual tax returns, corporate tax documents, partnership documents, audited financial statements – hence there is difficulty in verifying that these reports adhere to underwriting policies.

Spreadsheet control and monitoring

Financial institutions which are having difficulty weaning themselves from the convenience and simplicity that spreadsheets offer are looking for possible control solutions. Essentially, they want to find ways that allow them to continue using these UDAs and yet somehow eliminate the?spreadsheet risks?and limitations involved.

Still, the debate goes back and forth on whether adequate control measures can be implemented on spreadsheets so that that the risks are mitigated. Many services have come forward to herald innovative solutions for better spreadsheet management. But at the end of the day, there really is no guarantee that such solutions would suffice.

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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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Field service and improved visibility

A manager is someone who has control over a company. They are given the responsibility of overseeing what the company does and making important decisions. The manager is the most important person in the empire and needs to be in the know at all times. Not what happened a day ago but in real-time and from any place.

Information is necessary for this to happen. It needs to be concise, brief and straightforward. Ideally, access to job status, location information, customer information, notifications and location information should be on the palms of their hands.

To sum it all up, there should be fluid communication among personnel in the field. Information should be accessed easily from one place as it flows to another to maintain steady two-way communication. This is possible with automation meaning that no amount of data will be left unseen or unused because of paperwork that was never handed over or looked into, reducing the chance of misinformation or missing information to a minimum.

Ways improved visibility will help your business through Field Service

Organisations using field services will agree that improved visibility has more business benefits and the real question is what aspect needs improving rather than discussing the benefits.

Real-time visibility

Managers need to be in the know from anywhere at any time. The manager needs information about the company. The need not to be physically present to have an idea of what’s going on. They should know everything at all times, from what was planned for the day to real-time events.

All this information should be easily accessed from one central point and should contain everything about the company and other relevant information.

Extending the back office into the field

This two-way communication is virtually irreplaceable. At any time, the information should flow among technicians in the field and those in the back office. This will help to have a better idea of how to manage the workload and come up with solutions to some work-related issues.

Everyone in the team should be informed and be up to speed about real-time events. Keeping everyone updated improves visibility because they can make updates and decisions based on the kind of information they get.

No more lost paperwork

Managing paper trail can be quite a hassle for organisations. With tons of workload, there can be many delays meaning that some information might be missed or forgotten. People might also choose not to turn up for work for days on end and can affect how much info is processed. Some work can be left undone, and work not invoiced.

When organisations use field service management services, information is fed only once and everything else is done automatically. Say goodbye to lags or relying on last month?s data. Work will move faster because people will have more time to focus on important things rather than chasing an endless paper trail.

Business intelligence

Field service management technology will let you know what is being done in the field and with such an abundance of data, will make sound decisions for the business.

Every decision is hinged on cold facts. Information needs to be easily accessed and filtered into the right categories so that sound business decisions are made from the collected data.

Growing revenue

The abundance of real-time information and improved visibility can determine whether a business will grow or not. Each piece of information can show trends that are critical for any business to improve. Trends show how each sector is doing and sheds more light into specific areas that need a total overhaul. This may include improving customer service, products on retail or hiring more technicians.

Without information, a company is one step closer to going out of business. Every action should be geared to increase the revenue and this starts by making the right choices.

Visibility when working offline

Working offline is an issue that can affect visibility. Sometimes agents will need to work in areas that have little network coverage or are deep down working in tunnels or are around heavy machines and turbines. Field service solutions are built for the mobile environment and for workers who may find themselves in non-connected areas so that they can still use their device while offline. This makes sure that there is no loss of information while working in-field

Time-saving

Certainly, business is constrained to its environments and if the demand changes it should prove to be flexible enough to adjust to changes as they happen. Field service solutions operations like schedule need to update instantly. Once activities start rolling, nothing should create lags in the schedule so that operations flow seamlessly at all time.

Field workers can then make updates and document changes easily on the job site directly on their device by using responsive site menus, drastically saving time while feeding data and complete orders.

Improved customer service

It is not a clich? to say that the customer is always right. With real-time information, both field service and back-office technicians can improve customer relations and satisfaction. With a unified system of sharing information like the ERPs and CRMs, the field officer can know more about specific clients, their history and other data to know more about what should be done in current and future orders. This means that better decisions will be made for each customer.

How improved visibility benefits different parts of the organisation

Improved visibility in all areas of the business makes information more accessible. Here are some of the benefits that various sects of a business can get from improved visibility.

? The business owner
The manager owns the company and can access all information with just a single tap. A lot of data can be used to analyse the health of the venture. This includes revenue, inventory, customer surveys, employee hours, invoices and customer data.
Profitability is increased by putting more emphasis on customer satisfaction and improving the quality of end products and services.

? The service manager
The service manager can see what is going on in the field in real-time, and look into measures that can improve the productivity of staff members in various departments.
And with workflow automation, time-saving is at the maximum because there is less paperwork consequently improving scheduling and job completion rates.

? Service administrator/ dispatcher
For the team in the office, they can assign tasks faster. Scheduling is automatically done and updated in real-time. It eliminates the need for paperwork and leaves more time to be productive on other errands.

? The field technician
Improved visibility for a field worker means that they can do their best in any task. They can share or get critical information about orders and customers. This drastically improves job completion rates and customer satisfaction.

? HR
Live information can be used to track certain orders, the time it takes to complete orders, and the number of staff required in the organisation. Such data can be used in HR to reduce payroll errors and erroneous overtime costs.

? Finance
Field service management software can also benefit the finance team by automation of invoices. A work order can be tracked from start to the end and invoiced immediately to retain faster payments. Relevant data can be used to track revenue and expenditures, and costs.

Real-time visibility gives a company many solutions to manage the workload. In the end, visibility is also useful in increasing revenue and a smooth transition of information for the company.

Month End Accounting the way it should Be Today

Month end accounting has always been a business critical exercise. Without the balance sheet, income statement, and other financial reports this exercise ultimately produces, management could not make informed decisions to keep the company in the right direction and at the ideal operational speed.

Now, in order to maintain optimal business velocity, month end activities have to be carried out as swiftly and as accurately as possible. Delays will only inhibit managers from reacting and effecting necessary adjustments in time. Inaccurate information, on the other hand, obviously lead to bad decisions.

But that’s not all. Never has the month end close been as demanding as it is today. Regulations like the Sarbanes-Oxley Act, Solvency II, Dodd-Frank Act, and others, which call for more stringent controls and more robust risk management practices, are now forcing companies to find better ways to face the end of the month.

Sticking to old month-end practices while striving to achieve regulation compliance can either cost a company more (if they add manpower) or simply bog it down (if they don’t). Among the worst of these practices is the use of spreadsheets.

These User Developed Applications (UDAs) are very susceptible to errors. (See spreadsheet risks)

What’s more, consolidating data from spreadsheets as well as carrying out reconciliations on them is very time consuming. These activities usually require data from outside sources – i.e. a workstation in a different department, building, or (in the case of really large corporations) geographical locations.

Furthermore, if one of these sources fail, the financial reports won’t be complete. This is not a far-fetched scenario, considering that spreadsheet storage and backup is typically carried out by the average end user. This leaves the spreadsheet data vulnerable to hard disk crashes, virus attacks, and unexpected disasters.

Thus, in order to produce accurate financial reports on time all the time, you need a financial/IT solution that offers optimal provisions for risk management, collaboration, backup, and business continuity. Learn about server-based solutions and discover a better way to carry out month end accounting.

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