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


Spreadsheet Risks in Banks


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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IT Risk and Control Solutions Specialists – Why you need them more than ever

Over the years, the capabilities of IT systems have certainly grown by leaps and bounds. But so have the risks that accompany them. Countless threats to IT systems now exist that are capable of seriously disrupting business operations. That’s why companies have to conduct assessments aimed at making sure their systems are still capable of functioning effectively, efficiently, and securely all the time.

If you think you’ve been lucky enough to be spared from these threats, then maybe it’s because you haven’t conducted a risk assessment on your IT system recently. All too often, we hear of CIOs who believed their IT system was in tip-top condition, only to be later caught off-guard by a critical system breakdown that would eventually cripple their business for days or weeks.

More information assets to look after

If, before, you only had to worry about regular office applications, workstations, a LAN and a server, today’s varied and more sophisticated information assets are more challenging to maintain.

In addition to network operating systems, database management systems, content management systems, email systems, virtualization platforms, document management systems, business intelligence applications, and accounting software, a typical enterprise may also have to look after firewalls, intrusion detection systems, storage and backup systems, and data loss prevention systems, to mention a few.

These understandably require the services of experts spanning a wide range of skill sets.

Rising threats to corporate identity and privacy

Individuals are no longer just the ones being preyed upon by identity thieves. Businesses can now be subject to corporate identity theft as well. You could wake up one day finding your business already accused of carrying out illegal activities, a big chunk of your money gone, and your directors? seats already occupied by complete strangers.

To make things worse, corporate threats aren’t just coming from the outside.

Threats to corporate privacy, for instance, can come from within the organisation itself. Sensitive information like trade secrets and financial data are often leaked out (purposely or inadvertently) by employees. This is largely caused by the ever growing number of options for communications and transferring data (e.g. emails, instant messaging, blogs, social networking sites, ftp, P2P, etc.).

Greater challenges in designing, developing, and implementing policies and programs

Laws and regulations like SOX and Solvency II, which have direct impacts on IT, are on the rise. That is why corporate policies and programs now require sweeping changes. You now have to be more deliberate in integrating IT when establishing governance, internal controls, change management, incident management, and performance management.

A solid understanding on widely accepted frameworks and good practices like COBIT, COSO, and CMMI will help you considerably in such undertakings. Using these frameworks as guidelines will not only help you keep your policies and programs attuned to the times, they will also keep you in compliance with regulations.

Increasing demand for disaster recovery and business continuity capabilities

Every time you have a down time, you increase the probability of losing your customers to competitors. The longer the down time, the greater that probability becomes. Therefore, when a major disruption strikes, you should be able to recover at the soonest. If possible, you should be able to deliver products and services as usual.

This of course requires spending to increase your disaster recovery (DR) and business continuity (BC) capabilities. Are you ready for it? Migrating your IT infrastructure from traditional systems to the latest technologies that are better equipped for BC/DR requires careful planning and implementation to ensure an optimal return on investment.

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8 Best Practices To Reduce Technical Debt

When past actions in software development return to haunt you…

Is your business being bogged down by technical debt? Let’s look at measures that you can take to reduce it and scale your operations without the weight pulling you back. 

 

Work with a flexible architecture.

Right from the word go, you want to use architecture whose design is malleable, especially with the rapid rate of software evolution witnessed today. Going with an architecture that keeps calling for too much refactoring, or whose design won’t accommodate future changes will leave you with costly technical debt. Use scalable architecture that allows you to modify or add new features in future releases. While on this, complex features required in the final product should be discussed at the planning stage, that way simplified solutions that will be easier to implement can be identified, as this will lead to less technical debt in the long run. 

 

The Deal with Refactoring 

This is basically cleaning up the code structure without changing its behaviour. With the updates, patches, and new functionalities that are added to the systems and applications, each change comes with the threat of more technical debt. Additionally, organisations are increasingly moving their IT infrastructure from on-premises facilities to colocation data centres and deploying them on the cloud. In such scenarios, some workarounds are often needed to enable the systems to function in the new environments, which they hadn’t been initially developed to accommodate. Here, you will need to take some time to refactor the existing system regularly, streamlining the code and optimizing its performance – and this will be key to pay down the tech debt. When working with a flexible architecture from the start, the amount of work that goes into this will be reduced, meaning there’ll be less tech debt involved. 

 

Run discovery tests

Discovery testing essentially takes place even before a line of code is written for the system or application. This takes place at the product definition stage, where human insight software is used to understand the needs of the customer and is particularly helpful in setting priorities for the development work that will be carried out. It gives your business the opportunity to minimize the technical debt by allowing customers to give you a roadmap of the most pertinent features desired from the product. 

 

Routine code review

Getting a fresh look at the product or application from different sets of eyes in the development team will improve the quality of the code, thus reducing technical debt. There’s a catch though – this should be planned in a convenient way that doesn’t end up becoming a burden for the developers. Here are suggestions:

Break down pull requests

Instead of having complex pull requests where numerous changes in the code are introduced at a go, have this broken down into smaller manageable pull requests, each with a brief title and description about it. This will be easier for the code reviewer to analyse. 

● Define preferred coding practices

Documenting the preferred coding style will result in cleaner code, meaning the developers will focus their effort on reviewing the code itself, not losing time on code format debates.

 

Test automation

Relying only on scheduled manual testing opens you up to the risk of technical debt accruing rapidly, and not having sufficient resources to deal with the accumulated problems when they are identified. Automated testing on the other hand enables issues to be uncovered quicker, and with more precision. For instance, you can have automated unit tests that look at the functioning of the individual components of a system, or regression testing where the focus is on whether the code changes that have been implemented have affected related components of the system. However, establishing and maintaining automated testing will require quite some effort – making it more feasible for the long-term projects.

 

Keep a repository that tracks changes made

Do you have a record of changes made in the software? Keeping one in a repository that is accessible by the development team will make it easy to pin-point problems at their source. For instance, when software is being migrated to a new environment, or legacy software is in the process of being modernised, you will want to have an accurate record of changes that are being introduced, that way if there is an undesired impact on the system this it will be easier to zero-down on the cause.

 

Bring non-technical stakeholders on board

Does this conversation sound familiar?

Development Team: “We need to refactor the messy code quickly”

Product Team: “We have no idea what you are saying”

On one hand, you have the management or product team defining the product requirements, creating a project roadmap, and setting its milestones. On the other hand, there’s the software development/engineering that’s primarily focused on the product functionality, technical operations and clearing the backlog in code fixes. Poor communication between the two teams is actually a leading cause of technical debt.

For you to take concrete steps in managing your technical debt, the decision-makers in the organisation should understand its significance, and the necessity of reducing it. Explain to them how the debt occurred and why steps need to be taken to pay it down – but you can’t just bombard them with tech phrases and expect them to follow your thought process. 

So how do you go about it? Reframe the issues involved with the technical debt and explain the business value or impact of the code changes. Basically, the development team should approach it from a business point of view, and educate the management or production team about the cost of the technical debt. This can include aspects such as expenses in changing the code, salaries for the software engineers especially when the development team will need to be increased due to the workload piling up, as well as the revenue that is lost when the technical debt is allowed to spiral. 

The goal here is to show the management or production team how issues like failing to properly define the product requirements will slow down future software development, or how rushing the code will affect the next releases. That way, there will be better collaboration between the teams involved in the project. 

 

Allocate time and resources specifically for reducing technical debt

With management understanding that working with low-quality code is just like incurring financial debt and it will slow down product development, insist on setting time to deal with the debt. 

For instance, when it comes to the timing of application releases, meetings can be conducted to review short- and longer-term priorities. These meetings – where the development team and product team or management are brought together, the developers point out the software issues that should be resolved as a priority as they may create more technical debt. Management then ensures that budgets and plans are put in place to explicitly deal with those ongoing maintenance costs.

 

Retire old platforms

While most of the resources are going into developing new applications and improving the systems being used, the organisation should also focus on retiring the old applications, libraries, platforms, and the code modules. It’s recommended that you factor this into the application release plans, complete with the dates, processes and costs for the systems involved. 

 

Total overhaul

When the cost and effort of dealing with the technical debt far outweighs the benefits, then you may have to replace the entire system. At this tipping point, you’re not getting value from the technical debt, and it has become a painful issue that’s causing your organisation lots of difficulties. For instance, you may be dealing with legacy software where fixing it to support future developments has simply become too complicated. The patches available may only resolve specific issues with the system, and still leave you with lots of technical debt. Here, the best way out is to replace the system in its entirety. 

 

Final thoughts

Every software company has some level of tech debt. Just like financial debt, it is useful when properly managed, and a problem when ignored or allowed to spiral out of control. It’s a tradeoff between design/development actions and business goals. By taking measures to pay down your organization’s debt and address its interest as it accrues, you will avoid situations where short term solutions undermine your long-term goals. This is also key to enable your business to transition to using complex IT solutions easier, and even make the migration between data centres much smoother. These 8 measures will enable you to manage your technical debt better to prevent it from being the bottleneck that stifles your growth.

Is Your Project Agile, a Scrum or a Kanban?

Few projects pan out the way we expect when starting out. This is normal in any creative planning phase. We half suspect the ones that follow a straight line are the exceptions to the rule. Urban legend has it; Edison made a thousand prototypes before his first bulb lit up, and then went on to comment, ?genius is 1% inspiration, 99% perspiration?. Later, he added that many of life’s failures are people who did not realise just how close they were to success when they gave up.

So be it to this day, and so be it with project planning too. There is no one size fits all approach when it comes to it. Agile, Scrum and Kanban each have their supporters and places where they do well. Project planning often works best when we use a sequential combination of them, appropriate to what is currently happening on the ground.

Of the three, Agile is by far the most comprehensive. It provides a structure that begins with project vision / conceptualisation, and goes as far as celebration when the job is over, and retrospective discussion afterwards. However, the emphasis on daily planning meetings may dent freethinking, and even smother it.

Scrum on the other hand says ?forget all that bureaucracy?. There is a job to do and today is the day we are going to do it. Although the core Agile teamwork is still there it ignores macro project planning, and could not be bothered with staying in touch with customers. If using Scrum, it is best to give those jobs to someone else.

The joker in the pack is Kanban, It believes that rules are there to substitute for thought, and that true progress only comes from responsible freedom. It belongs in mature organisations that have passed through Scrum and Agile phases and have embarked on a voyage towards perfection.

That said, there can be no substitute for human leadership, especially when defined as the social influence that binds the efforts of others towards a single task.

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