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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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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Field service and customer transparency

These days, a business is as good as it is transparent. Businesses are on unsteady ground because of the ever changing face of social media and a never-seen-before demand for information. With many sources of info on the internet, being credible is a sure way of building trust and loyalty among clients.

Here is an example. Customers will always believe what they see. If they see the work you put into furnishing their favourite products, you have a greater chance of getting their approval. They can invest more in what they see. The clothing merchandise Patagonia did this for their Footprint Chronicles line to show how their jackets are made and worked out fine for them.
Transparency is a must. Nowadays, customers never forget when they feel cheated. It is even harder to ensure transparency because many clients are also experts who scrutinise every detail. So, how can you keep transparency at the forefront?

Have transparent workforce management

Customers always look for new information and want to be in the know. There is nothing worse than not being able find a product manual or an easy way to set up appointments. By giving your clients a self-service option, they can pick the services they want. This leaves more time to get stuff done rather than answering unending service calls from dissatisfied customers.

For instance, you could have a field service customer self-service application that allows customers to look for personalised services, a machine manual, book appointments, or solve any other problem. Customers then get feedback anytime. This one-on-one approach can help customers feel like their questions are being answered. They?ll also not go through the hassle of long hold times to reach an available customer service representative.

Create transparency in field service repair projects

If field technicians have access to field service software, it allows technicians to be more open to customers. This gives them vital information like customer history and the ERP, so that they can explain changes that were made after past enquiries and what is being done in current products. Such information can be a guide for future updates or let the techs suggest products that suit a client’s taste. Unlike always staying offline and out of touch with your client, using field service software can allow entry of allowances and mileage, and also let the customer know the delivery time for their products.

Show customers what they’re paying for

With field service automation, billing will also be transparent. By using the available information about your field service solution, the station can send updated service reports to the customer like mileage, allowances, parts, hours worked, and photos of broken parts from the service. After the customer authenticates the transaction with a signature, the field service agent can generate and sent to the customer an invoice based on the agreed upon services. In case allowances and mileage can be forwarded to the customer, it will be shown on the invoice.
Because you use field service automation, it means that the customer will receive the invoice really fast ? in days rather than weeks ? and transparency will skyrocket because the whole experience of the service will leave a permanent mark in their mind.

Mistaking information for transparency

Being honest with your customer is the one thing. Wasting their time with unnecessary information is another. Here is an experience I had with a small retailer. Tracking information is only useful if it has recent updates and is accurate. If the company want to use real time tracking, let them do so under one condition ? updates should be regular and on time so as not to leave the customer frustrated because they also make plans based on the same information. Late updates shed light on the nature of the service command. Everyone hates cooked-up real time information.

A company must not always have a one to one exchange of information with customers to maintain transparency..

Use simple language that all customers can understand
Don’t use abbreviations that only employees know
Never ever air your failures and flaws to your customers

It is interesting that most of the tools we use to keep in touch with our clients and servicing their requests can also be used to gather data and iron out possible errors to improve products and services. This is a good chance for service providers to evaluate and make necessary amendments.

There are some areas that will need improving while others will not, nevertheless, the client needs to always be informed and know why things are the way they are. Not all details should be told, so filter what you share.

5 ways field service supports customer service

Sales organisations are always in motion, working to deliver the right product to their customers. To keep customers smiling all times is hard and only needs close communication and fulfilling promises that were made to them. This is where the field service delivery team comes in. Field service can either meet this demand or fall short plummeting satisfaction rates.
This is a task that relies on right people using various parts and information to get the job done. No matter what, the customer always expects to get exceptional services whether it be over the phone, chats, in the field, online messaging, over email, or social media.

These five field service points are suitable for any business model and guarantee excellent company-client relations.

Proactive service

A proactive service gives more to the customer. More attention is given to the customer so that the right actions, deliveries and repairs are done. By getting everything right the first time, the customer has less to do ensuring that they are satisfied with the services.
However, the field service technician is flooded with a myriad of unpredictable situations; overheating equipment, stalled machines, and insufficient precaution. But through field management software, they get more data about the customer and type of service or parts expected and they easily ride through any storm and prevent future damage.

Transparency

Nothing frustrates a customer more than a schedule that delays repairs. They easily ditch you for better services elsewhere. By offering the customer a service where they book appointments based on their own availability, we can easily sync this to the technicians and manager?s calendar. This not only saves time but also money from otherwise idle equipment.

On-site and off-site collaboration

Having seamless communication between field and office technicians is vital. Field technicians need to know more about parts, repairs, client maintenance history, and predict what should be changed in the long run. The faster they do this the better.

There should be a system that creates and automates communication between field and office technicians. Let each have the upper hand when providing parts, products or services to the customer.

Flexibility

Information is key to field service agents. They make the first impression since they make the initial contact with clients. Regardless of the resources, the field technician must always be armed with mobile tools they will need to access online resources and be ready for any emergency.

Actionable performance improvements

Customers demand excellent service a company could offer. But as the game constantly shifts, the service management technicians must also come up with plans to stay up to par with competition. All these stems from coming up with KPIs, measuring them and turning them into a workable plan for the future.

Energy efficiency- succeed and benefit

Energy is neither created nor destroyed; it is only transformed. This being the law of conservation of energy, and given that the process of transforming energy is inefficient resulting in loss of usable energy in the process of transforming one form of energy into another form, Energy Efficiency finds a home.
Talking of Energy efficiency, think of how much useful energy can be obtained from a system or a particular technology. It is also about the use of technology that requires a lesser amount of energy to carry out the same task.

Energy efficiency is the responsibility of both demand side and supply side. Supply-side energy efficiency refers to a set of actions taken to ensure efficiency through the electricity supply chain. Supply side efficiency measures are about efficiency in electricity generation; be it operation and maintenance of existing equipment or upgrading existing equipment with state-of-the-art energy-efficient generating equipment.

The demand side energy efficiency on the other hand refers to the actions taken to use less/demand less energy. Think of less energy usage in relation to improvement of energy efficiency in buildings, solar water heaters, energy efficient lighting systems such as Compact Fluorescent Lamps, conducting energy audits to identify potential energy saving opportunities, efficient water heating systems and the list is endless.

Success of energy efficiency is a win ? win to YOU-ME-US – the energy consumers, to THEM the energy producers and suppliers and to our precious ENVIRONMENT.
Gain to energy suppliers: – Less energy usage and better energy usage patterns among consumers consequently reduces the customer load which reduces losses on the supply side. Less energy loss creates capacity on the system to serve more customers.

Gain to you-me-us: – Less energy usage and better energy usage patterns Benefits the customer through reduced Electricity bills / $ savings through lower bills.

Benefits to the environment: – Usage of less energy reduces use of fossil fuels, hence reduction in GHG emissions hence conserving our environment. Companies look at means to make rational use of their least efficient generating equipment. The objective is to improve the operation and maintenance of existing equipment or upgrade it with state-of-the-art energy-efficient technologies. Some companies have on-site electricity generation alternatives and thus tend to consider the supply side in addition to demand-side energy efficiency.