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.?

Check our similar posts

Can you do away with the Project Initiation Meeting?

Project initiation meetings are often skipped to fast-track projects. Once a sponsor is found, organisations go straight to project planning and execution. But based on our own experience, holding a project initiation meeting can actually eliminate many issues that may crop up in the future and hence may speed things up instead in the long run.

It is in the project initiation meeting where your project objectives and scope are clarified and all stakeholders are brought to the same page. Project sponsors and stakeholders will have to know in a nutshell what is needed from them, what the possible risks are, what different resources are required, and so on. So that, when it’s time to proceed to the next phase, everyone is already in-sync.

So what are taken up in such a meeting? Perhaps an actual example can help. Sometime in the past, we set out to work on an eCommerce website project. After conducting the project initiation meeting, these were some of the things we were able to accomplish:

  • Identified deliverables e.g. site design, interface to payment system, etc.
  • Come up with the project phases
  • Agreed what should be in and out of scope
  • Defined the acceptance test criteria
  • Identified possible risks
  • Identified the possible training and documentation work needed
  • Established whether any analysis was required, e.g. as with regards to payment interfaces
  • Formulated disaster recovery plans
  • Defined roles and responsibilities
  • Drafted timelines and due dates

Aren’t these covered in project planning? If the project is a big one, the answer is no. In a large project, project planning is a much more exhaustive activity. In a project initiation meeting, only the basic framework is defined.

Some questions may still remain unanswered after a project initiation meeting, but at least you already know what answers you need to look for. In the example we gave earlier, we left the meeting knowing that we needed:

  • a list of all necessary hardware to estimate the costs
  • to identify possible dependencies we might have with third parties
  • to identify what software had to be bought and what skills we needed to hire

When it was time to proceed to project planning, everyone involved already knew what direction we were taking. In effect, by not skipping the project initiation meeting, we were able to avoid many potential obstacles.

What are the benefits of digital forms data collection
Field Service Workers are regularly engaged to collect data or carry out inspections and assessments when visiting customer sites or remote area locations. The data collected by Field Service workers, will be used by businesses who will analyse, process and build reports based on the large volumes of data collected. The accuracy and reliability of data collected is vitally important. Traditionally businesses may have deployed mail surveys, telephone interviews, door-to-door surveys and interviews performed by Field Workers to collect data. Digital Transformation is gradually changing many business operations and a great deal of processes which were traditionally executed manually are now accomplished making use of digital methods. Technology is having a major impact not only how businesses research and analyse data, but primarily how data and information is collected. New tools and processes to data collection are improving data collection and analysis, leading to dramatic improvements and maximisation and optimisation of resources and operations. Utilising Digital Data Collection methods enables organisations to not only obtain results quicker but also use the data to make data based decisions faster.

What is a Digital Form?

Digital Forms, also known as Mobile Forms are electronic versions of paper forms that can be completed using:
  • Laptop
  • Tablet
  • Smart Phone
  • Any Mobile Device

Why Use Digital Forms ?

Digital forms can be a simple yet highly effective solution to overcome the challenges presented by paper based forms. Digital forms can be filled out directly using Smart phones and tablets in the field
  • When not connected to the internet or even low speed internet connections
  • When working in remote locations
  • To avoid damage, illegible handwriting or even lost and misplaced forms.
Digital forms can also include data validation logic to ensure field workers complete every form as expected and required, which will enforce and ensure data integrity . Field Service teams appreciate these features and help ensure the validity and accuracy of the data and insights they collect and can be confident regarding making business critical data based decisions. Data and Information collected using mobile forms can be accessible in near real-time, helps enable field teams to sidestep potential obstacles to productivity, and act on opportunities and increasing business agility.

Advantages of Digital Forms

Time and Cost Saving

Using Digital Forms instead of paper-based forms provides a significant impact on improving time and cost savings on printing, storing and distribution costs. Businesses also spend a significant amount of time and money in Administration and double data entry processes incurred by paper based forms. Transferring information from paper based surveys is an error prone process.
Digital Forms can save up to 20 man hours a week in administration costs

Improve data accuracy

Digital Forms can auto-populate fields based on prior data entered and also enable field-level validation. Digital data collection also eliminated data entry errors and data loss. Additional data can also be automatically be gathered such as Username, Geo-location and Time & Date.

Real Time Reporting

The issue with Paper-based data collection is that there will always be a time lag before reports or decision can be made. With a digital platform, such as FieldElite – Mobile Workforce Management , data can be processed and analysed as it is collected. Providing data driven insights to provide proactive rather than reactive reports to improve and optimise operations in real time.

It’s time to go Digital Forms!

Data Collection using Digital Forms will propel your company into the future and transform your data collection, data entry and analysis providing accurate data driven insights in real time. Digital forms are also mobile-optimized, updated in real time, and accessible by multiple parties, eliminating unnecessary meetings and emails. If you have a business and still haven’t used digital forms to gather information, contact Denizon today to organise a Demo of FieldElite – Mobile Workforce Management and discover how we can help you to transform your Field Service Operations

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK
Could Kanban Be?Best for Knowledge Workers?

Knowledge Workers include academics, accountants, architects, doctors, engineers, lawyers, software engineers, scientists and anybody else whose job it is to think for a living. They are usually independent-minded people who do not appreciate project managers dishing out detailed orders. Kanban project management resolves this by letting them choose the next task themselves.

The word ?Kanban? comes from a Japanese word meaning ?billboard? or ?signboard?. Before going into more detail how this works let’s first examine how Japanese beliefs of collaboration, communication, courage, focus on value, respect for people and a holistic approach to change fit into the picture.

The Four Spokes Leading to the Kanban Hub

  1. Visualise the Workflow ?You cannot improve what you cannot see. The first step involves team members reducing a project to individual stages and posting these on a noticeboard.
  2. Create Batches ? These stages are further reduced to individual tasks or batches that are achievable within a working day or shift. More is achievable when we do not have to pick up where we left off the previous day.
  3. Choose a Leader the Team Respects – Without leadership, a group of people produces chaotic results. To replace this with significant value they need a leader, and especially a leader they can willingly follow.
  4. Learn and Improve Constantly ? Kaizen or continuous improvement underpins the Japanese business model, and respects that achievement is a step along the road, and not fulfilment.

The Kanban Method in Practice

Every Kanban project begins with an existing process the participants accept will benefit from continuous change. These adjustments should be incremental, not radical step-changes to avoid disrupting the stakeholders and the process. The focus is on where the greatest benefits are possible.

Anybody in the team is free to pull any batch from the queue and work on it in the spirit of collaboration and cooperation. That they do so, should not make any waves in a culture of respect for people and a holistic approach to working together. All it needs is the courage to step out of line and dream what is possible.

The Kanban Project Method ? Conclusions and Thoughts

Every engine needs some sort of fuel to make it go. The Kanban project management method needs collaboration, communication, courage, focus on value, respect for people and a holistic approach to work. This runs counter to traditional western hierarchies and probably limits its usefulness in the West.

Contact Us

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

Ready to work with Denizon?