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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Are Master Data Management and Hadoop a Good Match?

Master Data is the critical electronic information about the company we cannot afford to lose. Accordingly, we should sanitise it, look after it, and store it safely in several separate places that are independent of each other. The advent of Big Data introduced the current era of huge repositories ?in the clouds?. They are not, of course but at least they are remote. This short article includes a discussion about Hadoop, and whether this is a good platform to back up your Master Data.

About Hadoop

Hadoop is an open-source Apache software framework built on the assumption that hardware failure is so common that backups are unavoidable. It comprises a storage area and a management part that distributes the data to smaller nodes where it processes faster and more efficiently. Prominent users include Yahoo! and Facebook. In fact more than half Fortune 50 companies were using Hadoop in 2013.

Hadoop – initially launched in December 2011 ? has survived its baptism of fire and became a respected, reliable option. But is this something the average business owner can tackle on their own? Bear in mind that open source software generally comes with little implementation support from the vendor.

The Hadoop Strong Suite

  • Free to download, use and contribute to
  • Everything you need ?in the box? to get started
  • Distributed across multiple fire-walled computers
  • Fast processing of data held in efficient cluster nodes
  • Massive scaleable storage you are unlikely to run out of

Practical Constraints

There is more to Hadoop than writing to WordPress. The most straightforward solutions are uploading using Java commands, obtaining an interface mechanism, or using third party vendor connectors such as ACCESS or SAS. The system does not replace the need for IT support, although it is cheap and exceptionally powerful.

The Not-Free Safer Option

Smaller companies without in-depth in-house support are wise to engage with a technical intermediary. There are companies providing commercial implementations followed by support. Microsoft, Amazon and Google among others all have commercial versions in their catalogues, and support teams at the end of the line.

Understanding Carbon Emissions

Carbon emission is one of the hottest issues in the world of energy and environment today. While it is supposedly an essential component of the ecosystem, it has already become a large contributing factor to climate change. Carbon emission might be good but abuse of this natural process has made it harmful to people across the globe.

This series of articles aims to help people understand the intricacies of carbon emission and what society can do to efficiently manage this natural occurrence.

Natural Carbon Cycle

Two important elements in the carbon cycle are carbon, which is present in every living thing all over the world; and oxygen, which is found in the air that people breathe. When these two bond together, they create a colourless and odourless greenhouse gas known as carbon dioxide, which is then crucial to trapping infrared radiation heat in the atmosphere and also for weathering rocks.

Carbon is not only found in the atmosphere of the earth. It is also an element found in oceans, plants, coal deposits, oil and natural gas from deep down the earth?s core. Through the carbon cycle, carbon moves naturally from one portion of the earth to another. Looking at this scenario, one can see that the natural carbon cycle is a healthy way to release carbon dioxide into the air in order to be absorbed again by trees and plants.

Altered Carbon Cycle

The natural circulation of carbon among the atmosphere is vital to humankind. However, studies show that humans misuse this natural cycle and abuse it instead. Whenever people burn fossil fuels such as coal, oil and natural gas, they produce carbon dioxide ? which is an excess addition to the natural flow of carbon in the environment. The problem is that the release of carbon dioxide is much more than what plants and trees can re-absorb. People are not only adding CO2 to the atmosphere, they are also influencing the ability of natural sinks, such as forests, to remove it from the atmosphere. Humans alter the carbon cycle by contributing doubled or tripled greenhouse gas to the atmosphere, faster than nature can ever eliminate. Worst, nature?s balance is destroyed.

The Result

Greenhouse gases include carbon dioxide, methane, nitrous oxide, fluorinated gas and other gases. Although these gasses contribute to climate change, carbon dioxide is the largest greenhouse gas that humans emit. The reason why people talk about carbon emissions most, is because we produce more carbon dioxide than any other greenhouse gas.

The increasing amount of carbon emissions cause global warming to become more evident. All the extra carbon dioxide causes the earth?s overall temperature to rise as well. As the temperature increases, climate also changes unpredictably. Flood, droughts, heat waves and hurricanes are now widely experienced even in places where these phenomenon never used to happen.

To be able to reduce the risk of more severe weather conditions means burning less fossil fuels and shifting more to renewable sources. This is never easy. But, definitely, it’s worth a try.

Cloud Computing Trends: Where is the Cloud Headed Next?

Cloud adoption has been quick and painless at the consumer level. For instance, everyone’s on Gmail, YouTube, Facebook and Twitter on a daily basis yet most think nothing of the fact that they’re already using cloud-based services. Small businesses have also discovered how cloud solutions have raised efficiency in the workplace up a notch or two, while also bringing about significant cost savings. Cloud applications, particularly those for communication, file sharing, office software, backup and storage, and customer management, have rapidly grown in usage among SMBs.

In the same manner, large corporations are starting to see the potential of moving some of their IT department, whether its infrastructure or network management, to the cloud. By all indications it would seem that whether we are ready for it or not, cloud computing technology is here for the long haul.

So where is the cloud headed to next? In this post we examine the trends in the world of cloud computing and what likely lies in store in the near future for cloud users.

Focus on Security

Security has always been a key concern in the cloud computing industry and this will not go away anytime soon. If anything, data security in the cloud will only get to be in the limelight even more as cloud adopters grow in number. That’s why we expect professional cloud services providers to start implementing measures that will help slowly build up confidence in cloud security.

We should soon see more advanced security techniques and protocols that would increase the overall level of privacy and protection for cloud-stored information. Tighter security for login encryptions and prevention of unauthorized access are priority although there are a lot more issues that may need to be addressed. Now it remains to be seen whether these moves are enough for corporate clients to put their full trust in the cloud. But then again, they can always find ways to stay secure while making use of cloud computing where they can, which brings us to the next cloud trend.

Hybrid Approach

Large businesses are taking a longer time to get used to and actually use cloud services, and understandably so. After all, these companies have more at stake when it comes to dealing with such valid issues as security, compliance, outages, legacy systems, and more. However, they also cannot ignore the very appealing characteristics of the cloud. For big companies that have substantial IT needs, scalability, business agility, and faster deployment are listed as the biggest draws of the cloud.

This is why analysts predict that as as these businesses look toward leveraging the benefits of the cloud while at the same time maintaining control over mission critical data and systems, the use of a hybrid approach, i.e. putting some services in a public and at the same time opting to utilize a private cloud for other applications, will see enormous growth.

Mobile Cloud Computing

The BYOD or Bring Your Own Device business policy is another emerging trend that would not have been possible if not for cloud technology. This practice involves having employees bring their mobile devices to work, allowing them to access company files, data, and applications from their personally-owned gadgets in and out of the workplace.

As with any new business practice, the concept of BYOD can be both advantageous and disadvantageous. On the one hand, some believe it helps increase employee productivity and lifts their morale, while reducing overall IT costs. On the other hand, BYOD also opens up a whole new set of problems that are quite consistent with what many businesses take issue with with cloud technology: security. Do the pros outweigh the cons or vice versa? This much isn’t clear yet but what is evident is that more cloud apps are going mobile.

Efficiency, Innovation

While cost savings has always been one benefit that cloud proponents are quick to point out, its capability to improve and streamline business processes, thereby increasing efficiency and agility within the organization, is another key opportunity that the cloud offers. This is evident when you take a look at the most commonly used cloud services: backup and archiving, business continuity, collaboration tools, and big data processing.

Moreover, the cloud is making it easier for individuals to create new products and produce new lines of business. With access to higher IT capacity at lesser cost and at faster deployment rates, businesses can scale into more innovation without having to worry about the availability of computing resources.

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