How to Reduce Costs when Complying with SOX 404

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.

Read why spreadsheets post a burden when complying with SOX and other regulations.

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.

Not sure how to get started on a cost-effective IT compliance initiative for SOX? You might want to read our post How To Get Started With Your IT Compliance Efforts for SOX.?

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Matrix Management: Benefits and Pitfalls

Matrix management brings together managers and employees from different departments to collaborate with each other towards the accomplishment of the organizational goals. As much as it is beneficial, matrix management also has limitations. Hence, companies should understand its benefits and pitfalls before implementing this management technique.

Benefits

The following are some of the advantages of matrix management:

Effective Communication of Information

Because of the hybrid nature of the matrix structure, it enables different departments to closely work together and communicate frequently in order to solve project issues. This leads to a proficient information exchange among leaders and subordinates. Consequently, it results to developed strategies, enhanced performance and quick productivity.

Efficient Use of Resources

Resources can be used efficiently in the organisation since it can be shared among functions and projects. As the communication line is more open, the valuable knowledge and highly skilled resources are easily distributed within the organisation.

Increased Motivation

The matrix structure promotes democracy. And with the employees working on a team, they are motivated to perform their duties better. The opinions and expertise of the employees are brought to the table and considered by the managers before they make decisions. This leads to employee satisfaction, empowerment and improved performance.

Flexibility

Since the employees communicate with each other more frequently, decision making becomes speedy and response is adaptive. They can easily adjust with diverse situations that the company encounters.

Skills Development

Matrix employees are pooled out for work assignments, even to projects that are not necessarily in line with their skill background. With this approach to management, employees have the chance to widen their skills and expertise.

Discipline Retention

One significant advantage of matrix management is that it enables the employees to maintain their skills in functional areas while working with multidisciplinary projects. Once the project is completed and the team wraps up, the members remain sharp in their discipline technically and return to their home functions.

Pitfalls

Here are some disadvantages of matrix management:

Power Struggle

In the matrix structure, there is always tension between the functional and project manager. Although their intent is polite, their conflicting demands and competition for control over the same resources make it more difficult.

Internal Complexity

Having more than one manager, the employees might become confused to who their immediate leader is. The dual authority can lead to internal complexity and possible communication problems. Worst, employee dissatisfaction and high employee turnover.

Heightened Conflict

In any given situation where people and resources are shared across projects, there would always be competition and conflict. When these issues are prolonged, conflicts will heightened and will lead to more internal problems.

Increased Stress

For the employees, being part of a matrix structure can be stressful. Their commitment is divided among the projects and their relationship with multiple managers requires various adjustments. Increased stress can negatively affect their performance in the long run.

Excessive Overhead Expenses

Overhead administrative costs, such as salaries, increase in a matrix structure. More expenses, more burden to the organisation. This is a challenge to matrix management that leaders should consider carefully.

These are just some of the advantages and disadvantages of matrix management. The list could go on, depending on the unique circumstances that organisations have. The key is that when you decide to implement matrix management, you should recognise how to take full advantage of its benefits and understand how to lessen, if not eradicate, the pitfalls of this approach to management.

Data Leakage Prevention – Protecting Sensitive Information

When DuPont lost $400 million in intellectual property, it wasn’t because a hacker from the other side of the world infiltrated their system. The information was simply stolen by a former employee. Alarmingly, data loss incidents are not always caused by deliberate actions.

A file containing personal information accidentally attached to an email and sent to multiple recipients; financial data stored in a USB pen drive, accidentally left in a restaurant; or bank account data of colleagues, inadvertently posted on a company website – these are also some of the everyday causes of data loss.

A report done by research company Infowatch regarding global data leaks in 2010 showed that there were actually more accidental data leaks in that year compared to intentional ones. Accidental leaks comprised 53%, while intentional leaks comprised 42% (the rest were unidentified).

But even if they ?only? happened accidentally, breach incidents like these can still be very costly. The tens of thousands of dollars that you could sometimes end up paying in civil penalties (as in the case when you lose other people?s personal information) can just be the beginning. More costly than this is the loss of customer and investor confidence. Once you lose those, you could consequently lose a considerable portion of your business.

Confidential information that may already be leaking out right under your nose

With all the data you collect, process, exchange, and store electronically every day, your IT system has surely now become a storehouse of sensitive information. Some of them, you may be even taking for granted.

But imagine what would happen if any of the following trade secrets fell into the wrong hands: marketing plans, confidential customer information, pricing data, product development strategies, business plans, supplier information, source codes, and employee salaries.

These are not the only kind of data that you should be worried about. You could also get into trouble if your sloppy IT security fails to protect employee or client personal information such as their names; social security numbers; drivers license numbers; or bank account numbers and credit/debit card numbers along with their corresponding PINs.

In some countries, you could face onerous data breach notification requirements and heavy fines when these kind of data are involved.

There are now more holes to plug

It’s not just the different varieties of sensitive electronic information that you have to worry about. Because these data can take on different forms, i.e. data-at-rest, data-in-motion, and data-at-the-endpoints, you also need to take aim at different areas in your IT system.

Sensitive information can be found ?at rest? in each of your employees? hard disks, in your servers, storage disks, and in off-site backup disks. They can also be found ?in motion? in email, instant messaging, social networking messaging, P2P file sharing, ftp, http, and so on.

That’s not all. Your highly mobile workforce may have already introduced yet another high-risk area into your system: data-at-the-endpoints. This includes USB flash-disks, laptops, portable hard disks, CDs, and even smartphones.

The main challenge of data leak prevention

Having been made aware of the various aspects of data leakage, have you already come to grips with the extent of the task at hand?

There are two major things you need to do here to prevent data leakage.

One, you need to identify what data you have that can be considered as sensitive/confidential information. Of course you have financial information and employee salaries in your files. But do you also store personally identifiable information? Do you have trade secrets that are stored in electronic form?

Two, you need to pinpoint their locations. Are they only on your hard disks and laptops? Or have they made their way to flash drives, CDs/DVDs, or portable HDDs? Are they being transmitted through email or any other file transfer media?

The reason why you need to know what your sensitive data are as well as where they are is because you would like all efforts of securing them to be as efficient and unobtrusive as possible.

Let’s say, as a way of protecting your data, you decide to implement encryption. Since encryption can consume a lot of storage space and significantly reduce performance, it may be impractical to encrypt your entire database or all your files. For the same reason, you wouldn’t want to encrypt every single email that you send.

Thus, the best way would be to encrypt only the data that really need encryption. But again, you need to know what data needs to be encrypted and where those data can be found. That alone is no simple task.

Not only will you need to deal with the data you already have, you will also have to worry about the data that will go through your systems during the course of your day-to-day transactions.

Identifying sensitive data as it enters or leaves your system, goes through your network, or gets stored in your file system or database, and then applying the necessary security actions should be done automatically and intelligently. Otherwise, you could end up spending on a lot of man-hours or, worse, wasting them on a lot of false positives and negatives.

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Integrated eCommerce – The right way to do extend your business online

With more people spending more time on the Web, now is the perfect time to start selling your products and services online. And if you think those people are only busy posting status updates on Facebook and Twitter but avoid all other websites, think again. Many are actually buying stuff online. E-commerce has never been bigger. In the UK, it was already worth 100 Billion two years ago.

Buyers are finding it more convenient to buy products and services online because they can do so from practically anywhere; even in the comfort of their homes. What’s more, they could browse through more choices at a fraction of the time they?d have spent doing the same thing in brick and mortar establishments.

So if your potential buyers are already out there, what’s stopping you from opening your virtual doors to greet them?

Antiquated e-Commerce

Now, before you start getting excited in setting up your own idea of an eCommerce-ready website, you might want to be aware of what a sound e-commerce investment entails these days. If all you’re thinking is a site that accepts orders and have someone enter those orders in your accounting system, then you’ve got it all wrong.

You’re never going to get good returns on your investment that way. While you’re opening doors for new income streams, you’re also introducing additional costs and sophistication for processes that are highly susceptible to errors, inconsistencies, delays, and, eventually, client dissatisfaction.

Doing it right with integrated e-Commerce

To compete with others who are also offering the same products and services as yours, you need to ensure complete customer satisfaction. The best way to achieve this is to employ integrated e-commerce. This is an e-commerce system that combines your payment system, accounting, ERP, CRM, inventory management, analytics, and others into a cohesive, synchronised environment.

The idea is to do away with majority of your manual tasks in order to achieve fast, efficient, accurate, and secure transactions and other related processes.

eCommerce integration will allow you to do business 24/7 without requiring any of your staff to render the same number of hours. That means, your company continues to operate and earn even while all of you are fast sleep.

Then when you’re up, you can view reports telling you what transpired overnight, over the weekend or over any specified period of time. The information you obtain can help you make well-informed decisions and act on issues much quicker.

And because your business is on the Web, you can serve customers and obtain new ones from geographical locations far from where your office or store is actually located. If you want, you can even gain customers from halfway around the world.

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