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

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How SOA can help Transformation

Undoubtedly, today’s business leaders face myriad challenges ranging from fierce market competition to increasing market unpredictability. In addition, the modern consumer is more informed and in control of what, where and how they purchase. Couple these challenges with effects of globalization, and you will appreciate that need for business transformation is more of a necessity than a privilege.

As recent business trends show, top companies are characterized by organizational and operational agility. Instead of being shaken by rapid technological changes and aftershocks associated with market changes, they are actually invigorated by these trends. In order to survive in these turbulent times, business leaders are opting to implement corporate transformation initiatives to develop leaner, more agile and productive operations. In line with this, service oriented architecture (SOA) has emerged as an essential IT transformation approach for implementing sustainable business agility.

By definition, service oriented architecture is a set of principles and techniques for developing and designing software in form of business functionalities. SOA allows users to compile together large parts of functionality to create ad hoc service software entirely from the template software. This is why it is preferred by CIOs that are looking to develop business agility. It breaks down business operations into functional components (referred to as services) that can be easily and economically merged and reused in applicable scenarios to meet evolving business needs. This enhances overall efficiency, and improves organizational interconnectivity.

SOA identifies shortcomings of traditional IT transformation approaches that were framed in monolithic and vertical silos all dependent on isolated business units. The current business environment requires that individual business units should be capable of supporting multiple types of users, multiple communication channels and multiple lines of business. In addition, it has to be flexible enough to adapt to changing market needs. In case one is running a global business enterprise, SOA-enabled business transformation can assist in achieving sustainable agility and productivity through a globally integrated IT platform. SOA realizes its IT and business benefits by adopting a design and analyzing methodology when developing services. In this sense a service consists of an independent business unit of functionality that is only available through a defined interface. Services can either be in the form of nano-enterprises or mega-enterprises.

Furthermore, with SOA an organization can adopt a holistic approach to solve a problem. This is because the business has more control over its functions. SOA frees the organization from constraints attributed to having a rigid single use application that is intricately meshed into a fragmented information technology infrastructure. Companies that have adopted service oriented architecture as their IT transformation approach, can easily repurpose, reorganize and rescale services on demand in order to develop new business processes that are adaptable to changes in the business environment. In addition, it enables companies to upgrade and enhance their existing systems without incurring huge costs associated with ‘rip and replace’ IT projects.

In summary, SOA can be termed as the cornerstone of modern IT transformation initiatives. If properly implemented great benefits and a sharp competitive advantage can be achieved. SOA assists in transforming existing disparate and unconnected processes and applications into reusable services; creating an avenue where services can be rapidly reassembled and developed to support market changes.

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Top 3 reasons to get into Multi-Channel Retail

Multi-channel retail, which nowadays understandably includes online channels, is something you just have to do this year. Every single day you put off doing it, the competition gobbles up market share that should have been yours. There are a number of reasons why even successful retailers are now going into multi-channel retailing. Here?s three of the most important ones.

1. You’ll get a BIG jump in sales

Not counting this year, which could be getting a big boost from major activities like the Queen?s Diamond Jubilee and the 2012 Olympics, sales of UK retailers have been experiencing tremendous growth particularly from their online channels. Already two years ago (2010), a number of UK retailers boasted significant increases in sales as a result of multi-channel retail initiatives. These retailers included:

  • Argos, which got a whopping ?1.9bn from multichannel sales back then;
  • House of Fraser, which reported a 150% jump in its online sales in just 6 months; and
  • Debenhams, whose profits rose by 20%

There were many others. Now, the reason I?m showing you 2010 figures is because online retail sales increased by 14% in 2011 and those same businesses still added to that growth. So, if only you had enough foresight and started expanding your business to the Web two years ago, you could just imagine what your sales would have been today.

The good news is that, it’s not yet too late if you start now. Here?s why…

2. Those numbers are going to keep on growing

We’re getting all sorts of predictions from leading researchers regarding the possible growth of the Internet economy. All these predictions have one thing in common. They all have a positive outlook. The Boston Consulting Group (BCG), for instance, predicts an average growth of no less than 10% per year in the G-20 nations.

3. Most online retailers aren’t doing it right yet

Although many retailers have already started bringing their business to the Web, most of them are doing it the wrong way. For example, many of them fail to integrate their offline and online channels. This is a serious shortcoming because it leads to customer dissatisfaction.

When a customer goes to your website and sees something he likes, you wouldn’t want him to drive all the way to your store only to find out that the item isn’t available there or, if the item is there, that it isn’t priced as he expected. The lack of multi-channel integration is very common among multi-channel retailers.

These inadequacies are actually good news because it means there are still many areas you can improve on. After improving on them, you can then highlight those areas as your key differentiators.

If you’re still looking for more reasons on why you should go into multi-channel retailing, read this post:

“5 Numbers Showing Why the Time to Invest on eCommerce in the UK is Now”

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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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