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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Reduce Cost and Improve Productivity

Whether the economy is in a downturn or not, management will always aim for a more cost effective IT solution. If your current IT infrastructure is hurting your profitability, our expertise is both ‘tested and proven”.? Also “bleeding edge” solutions in the industry will enable us to find inexpensive alternatives for you.

For instance, have you started to wonder whether having a constantly growing number of servers, many of which are underutilised, is really the norm? Well, that used to be the case. However, with the advent of virtualisation and replication, that expensive exercise is steadily becoming a thing of the past.

By implementing solutions powered by these two technologies, organisations can now manage excess storage capacities and hardware resources by performing simpler processes at lesser costs. In addition to that, using the same pair of technologies, companies can also decrease the downtime suffered during maintenance and upgrades.

Thus, at the end of the day, not only do companies stand to reduce expenditures, they can also boost revenues as a result of increased productivity time.

Do we still have other IT solutions that tackle a different set of problems but arrive at the same outcome, i.e. reduced costs + improved productivity = higher profits? You bet we do.

Basically, this is how we’ll help your company arrive at the same winning formula:

  • Provide insights as to where and when changes have to be made. Oftentimes, initiatives to reduce cost and improve productivity are not preceded by the appropriate study especially as with regards to their impact on all departments in the organisation. This usually results in unnecessary duplication of resources, a sure way to increase costs instead.
  • Consolidate and automate. We’ll work within your budget in finding ways to consolidate your applications, hardware, storage, databases, and processes. Then we’ll integrate automation practices to simplify management and maintenance of all these assets. This will substantially free not only your IT infrastructure but also your IT staff, giving them more opportunities to innovate.
  • Create an innovative environment. One of the benefits you gain in having room to innovate is the potential to discover new ways to drive costs even further. A fraction of your savings can then be used to develop even better IT solutions, thus creating a productive cycle: IT solutions > savings and innovation > better IT solutions. Our role is to help you harness your potentials to keep that cycle running.
  • Work to reduce carbon footprint in all your procedures. By ensuring that energy consumption is brought to a minimum in every step you take, you can rest assured that costs have only one way to go – down. Check out our Energy Management Software ecoVaro.

Find out how we can increase your efficiency even more:

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK
Maturing Into CMMI

 

In all likelihood, the reason why you landed on this page was because you were seeking CMMI experts to help you meet the demands of a growing number of potential clients who require CMMI compliance.

Whether or not you’re here for that reason, you might want to know why CMMI or Capability Maturity Model Integration is steadily becoming a common denominator among highly successful software and engineering development companies. If you stay for a while, we can show you how CMMI can substantially increase your organisation’s chances of:

  • reducing development costs;
  • acquiring new customers and retaining old ones;
  • beating deadlines;
  • bringing down development time;
  • increasing the overall quality of your products and services; and
  • improving the level of satisfaction of customers, employees, and all other stakeholders.

Surely, no organisation can be too small or too big to aspire for such benefits of attaining high levels of maturity and capability.

If you want to look beyond Maturity Level ratings, then you’ve come to the right place. We focus on introducing CMMI principles and blending them into your organisation’s culture to achieve a truly superior and sustainable business advantage. Compliance will then be an inevitable offshoot of the actions you make.

Likewise, if you simply want to obtain a deeper understanding of CMMI and learn how it can be applied either to your entire organisation or to specific projects, we’d be happy to assist you in that regard as well.

Finally, when you’re ready, we can also conduct CMMI appraisals either for benchmarking purposes or simply for determining how well your process improvement initiatives are going.

CMMI Consulting

Are you worried that implementing CMMI might entail an overhaul of your current processes? Don’t be.

CMMI is all about improving current processes, not replacing them. Ideally, the final result of all process improvement activities should be hinged on your own business objectives and context, so we’ll make sure it remains that way when we work with you.

We rely on our extensive knowledge and experience in CMMI, engineering, software development, and technologies as well as in change and project management in providing model-based process improvement services. Whether you’re gearing up for an appraisal or simply want to employ CMMI-based practices, these are the things we can do for you.

  • Help you interpret how CMMI can be implemented in relation to your business.
  • Assist in convincing sponsors and stakeholders to support your CMMI implementation initiatives.
  • Introduce the necessary training to all individuals who need to undertake them.
  • Conduct a Gap Analysis to find out where your company’s current processes stand relative to their CMMI specifications.
  • Assemble a process group that will champion your process improvement initiatives. We’ll facilitate effective collaboration among its team members, transforming them into a cohesive force designed to carry out plans and motivate everyone else down the line.
  • Introduce tools and practices that will improve the efficiency of our process improvement initiatives.
  • Carry out periodic evaluations and produce reports to provide sponsors and stakeholders a clear picture of our progress.

CMMI Training

Still not convinced CMMI is right for you? There’s only one way to fully grasp the benefits of implementing CMMI – take the Introduction to CMMI course. Although what happens next is entirely up to you, we’re pretty sure you’ll make the right decision after passing it.

Do you need to include people from your organisation in a SCAMPI (Standard CMMI Appraisal Method for Process Improvement) team? They’ll have to undergo this course too. The Introduction to CMMI is for systems and software engineering managers and practitioners, appraisal team members, process group members, and basically anyone who want to grasp CMMI fundamentals.

This is what you’ll be able to do after going through 3 days of lectures and exercises:

  • Gain a deeper understanding of the various components of CMMI-DEV models and their relationships.
  • Discuss the process areas in CMMI-DEV models.
  • Extract and interpret aspects in the model relevant to your own organisation’s processes.

We also offer highly specialised training and workshops such as those for:

  • Achieving High Maturity Levels
  • Top Executives
  • Team Building in Preparation for Appraisals

CMMI Appraisal

An organisation new to CMMI will want to know first how far their current processes are relative to the implementation of model-based improvements in order to determine the resources and time that have to be spent to get there.

Similarly, an organisation already well acquainted with CMMI and has begun taking steps in improving processes, will eventually want to know how close it has come to the Maturity Level it has aimed for.

In both cases, these organisations will have to be assessed by a qualified CMMI appraiser to obtain an accurate picture of their current status. We can perform appraisals on either your entire organisation or on specific projects/practices within a process area. Our appraisers can conduct the following SCAMPI (Standard CMMI Appraisal Method for Process Improvement) appraisals:

  • SCAMPI Class A – This is what you’ll need if you’re aiming for a level rating.
  • SCAMPI Class B – You may want to use this for process reviews or for preparing for a SCAMPI Class A.
  • SCAMPI Class C or Gap Analysis – We typically conduct this for organisations who have yet to implement CMMI-based initiatives so that they can design the most cost-effective road map for the implementation proper.
Mobile Security

Today’s advanced enterprises make extensive use of mobile devices in order for team members to exchange information, collaborate, and carry out business whenever and wherever they need to. BlackBerries, iPhones, Google Phones, and other smartphones as well as PocketPCs and PDAs are now allowed wireless remote access to the enterprise network.

As a result, they introduce additional vulnerabilities into the system.

  • Bluetooth exploits and unencrypted passwords can allow malicious individuals to gain access to private information.
  • Various wireless technologies that have substantially simplified the task of transferring data have provided openings for malicious code. In addition, the diversity of these wireless technologies combined with the constrained environments of these devices have made it difficult to come up with an all-in-one solution.
  • All PocketPCs, PDAs and smartphones can be synchronised with PCs and laptops, giving malware an entry point into computers and networks. Memory cards are guilty of this too.
  • VoIP, which are usually unencrypted, allow other people to perform unauthorised capture and recording of private conversations.

Mobile security is still an emerging discipline. Because of this, many organisations that allow members’ mobile phone access into the network don’t actually have a specific security policy for such devices.

That’s why we’re here to help. We’ll conduct a thorough evaluation of your security policies and systems in relation to mobile devices and seal gaps we spot along the way. If you don’t have the needed policies or if what you have needs an overhaul, we’ll set everything up (including the needed applications and infrastructure) for you.

Once we’ve got everything in place, you won’t have to worry about the vulnerabilities mentioned earlier. In addition to that, your organisation will already be capable of preventing the following:

  • Access to company information when the phone ends up in the hands of anyone other than the authorised user.
  • Being billed for phone usage due to virus activity
  • Unauthorised phone activity monitoring through spyware
  • Other disruptions caused by mobile-based malware

Other defences we’re capable of putting up include:

Ready to work with Denizon?