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:

It requires multiple testers who need to test spreadsheets down to the cell level.
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.
Each month, an organisation may have new spreadsheets with new links, new macros, new formulas, new locations, and hence new objects to test.
Spreadsheets rarely come with any kind of supporting documentation and version control, further hampering the verification process.
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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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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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
How Internal Auditors Can Win The War Against Spreadsheet Fraud

Will UK Retailers Skim the Cream with ESOS?

The British Retail Consortium (BRC) was quick out on the starting blocks with an ambitious plan to cut energy costs by 25% in 5 years. Their ?25-in-5? initiative is chasing a target of ?4.4 billion savings during the duration. Part of this program involves ?cutting a path through a complex and inaccessible policy landscape?. BRC believes this drawback is making its members think twice about making energy efficiency investments.

The UK?s sprawling network of grocers, department stores and malls is the nation?s second most hungry energy customer, having spent ?3.3 billion on it in 2013 when it accounted for almost 20% of carbon released. If you think that sounds bad, it purchased double that amount in 2005. However the consortium believes there is still more to come.

It bases this assumption on the push effect of UK energy rates increasing by a quarter during the duration of the project. ?So it makes sense to be investing in energy efficiency rather than paying bills,? Andrew Bolitho (property, energy, and transport policy adviser) told Business Green. The numbers mentioned exclude third party transport and distribution networks not under the British Retail Consortium umbrella.

The ?complex and inaccessible policy landscape? is the reflection of UK legislators not tidying up as they go along. BRC cites a ?vast number of policies ? spreading confusion, undermining investment and making it harder to raise capital?. The prime culprits are Britain?s CRC Energy Efficient Scheme (previously Carbon Reduction Commitment) which publishes league tables and ESOS. Andrew Bolitho believes this duality is driving confused investors away.

The British Retail Consortium is at pains to point out that this is not about watering things down, but making it simpler for participating companies to report on energy matters at a single point. It will soon go live with its own information hub providing information for retailers wishing to measure consumption at critical points, assemble the bigger picture and implement best practice.

Ecovaro agrees with Andrew Bolitho that lowering energy demand and cutting carbon is not just about technology. We can do much in terms of changing attitudes and providing refresher training and this does not have to cost that much. Studies have shown repeatedly that there is huge benefit in inviting employees to cross over to our side. In fact, they may already be on board to an extent that may surprise.

Saving Energy Step 2 ? More Practical Ideas

In my previous blog, we wrote about implementing a management system. This boils down to sharing a common vision up and down and across the organisation, measuring progress, and pinning accountability on individuals. This time, we would like to talk about simple things that organisations can do to shrink their carbon footprints. But first let’s talk about the things that hold us back.

When we take on new clients we sometimes find that they are baffled by what I call energy industry-speak. We blame this partly on government. We understand they need clear definitions in their regulations. It’s just a pity they don’t use ordinary English when they put their ideas across in public forums.

Consultants sometimes seem to take advantage of these terms, when they roll words like audit, assessment, diagnostic, examination, survey and review across their pages. Dare we suggest they are trying to confuse with jargon? We created ecoVaro to demystify the energy business. Our goal is to convert data into formats business people understand. As promised, here are five easy things your staff could do without even going off on training.

Right-size equipment? outsource peak production in busy periods, rather than wasting energy on a system that is running at half capacity mostly.
Re-Install equipment to OEM specifications ? individual pieces of equipment need accurate interfacing with larger systems, to ensure that every ounce of energy delivers on its promise.
Maintain to specification ? make sure machine tools are within limits, and that equipment is well-lubricated, optimally adjusted and running smoothly.
Adjust HVAC to demand ? Engineers design heating and ventilation systems to cope with maximum requirements, and not all are set up to adapt to quieter periods. Try turning off a few units and see what happens.
Recover Heat ? Heat around machines is energy wasted. Find creative ways to recycle it. If you can’t, then insulate the equipment from the rest of the work space, and spend less money cooling the place down.

Well that wasn’t rocket science, was it? There are many more things that we can do to streamline energy use, and coax our profits up. This is as true in a factory as in the office and at home. The power we use is largely non-renewable. Small savings help, and banknotes pile up quickly.