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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The Future of Cloud Backup and Recovery

We came across a post on Docurated that pulled together thirty-seven suggestions for the top cloud storage mistakes user companies make. Given that cloud storage seems to be the best backup solution for now at least, we decided to turn these ideas around to sense the direction cloud backup and recovery needs to take, if it is still to be relevant in say ten years? time.

Has Cloud Storage Largely Saturated the West?
It probably has. Outside of major corporates who make their own arrangements ? and SME?s that use free services by email providers ? the middle band of companies in Europe and America have found their service providers, although they may have never tested the recovery process, to see if it works.

The new gold rush in the cloud backup and recovery business is, or should be emerging markets in Asia, Africa, South America, and the Middle East. There, connectivity is brittler than over here. To be relevant in these fragile, more populous areas our cloud backup and recovery industry need to be more agile and nimble.

? It must provide a simpler service emerging commerce can afford, refresh its user interfaces in third world languages, have more accessible help, and be patient to explain how cloud storage works to newbies. In other words, it must source its call centre operators in the areas it serves.

? It must adapt to local connectivity standards, and stop expecting someone with ADSL broadband to keep up with cloud server networks running at up to 1GBPS compared to their 10MBPS at best. For user sourcing and retention purposes, these new cloud backup and recovery services must be the ones who adapt.

? It must facilitate disaster recovery simulations among its clients in calmer moments when things are going well. Are they backing up the right files, are they updating these, and are their brittle ADSL networks able to cope with their cloud service providers? upload and download speeds?

? It must develop lean and agile systems slim enough to accommodate a micro client starting out, but sufficiently elastic to transfer them seamlessly to big data performance. The Asian, African, South American, and Middle Eastern regions are volume driven, and individual economies of scale are still rare.

? It must not expect its users to know automatically what they need, and be honest to admit that Western solutions may be wrong-sized. Conversion funnels in the new gold rush are bound to be longer. Engagements there depend on trust, not elevator sales letters. Our competition in these countries already works this way.

? It must be honest and admit cloud storage is only part of the solution. To recruit and retain users it must step back to 1983, when Compuserve offered its customers 128k of disc space, and spent an amount of effort explaining how to filter what to put there.

Cloud Storage of Data is Only One Part of the Solution
Governance reports and stock certificates burn just as easily as do servers in a fire. We must not transfer bad habits to exciting new markets. We close this article with the thoughts of John Howie, COO of Cloud Security Alliance, as reported in the Docurated post we mentioned, and these apply across the globe, we believe.
There is no single most important thing to carry forward into the future of cloud backup and recovery. We must be mindful when moving data that this can be fragile too. We must also create layers of backup the way insurance companies re-insure, that make any one cloud backup and recovery business redundant if it happens.
We hold the trust of our customers in our hands but trust is delicate too. We must cease trying to make a pile of money quickly, and become more interested in ensuring that data transferred back and forth is synchronised. The cloud backup and recovery industry needs only one notorious mistake, to become redundant itself in the ten years we mentioned.

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Reducing Your Carbon Footprint

Climate change creates a loud buzz across the globe. People are talking about how extreme the weather is, how polluted the environment has become or how devastating the results of carbon emissions are. While it is true that humans contribute a large impact to the worsening climate situations, people are also the most influential key towards making this world a better place. As much as the increase in carbon emissions results from what you do, the healthy change can also start in you.

Although it is a bit difficult to determine what you can do to help the society, do not be disheartened. The devastating forces may be massive for you to work through, but there are countless simple actions?you can take to reduce your carbon footprints day by day.

Home

While you are in the comfort of your home, you can start saving energy to reduce your carbon emission. You could’replace your standard light bulbs with compact fluorescent ones. A compact fluorescent bulb saves more than 2/3rds or up to 1,300 pounds of carbon dioxide in its lifetime. This bulb contains mercury, so make sure to choose a brand that has lower mercury than others.

Another thing, you can do to reduce your carbon footprint at home, is to mind your electronics. When you do not use your gadgets and appliances, make sure you unplug them. If you buy new ones, take time to look at the energy rating of the electronics to save you more energy in future use.

Alternative renewable energy is also a good thing to shift into. Try solar, hydro or wind power at home. Setting up your own residential solar panels and building your own turbines are excellent ways to choose green energy.

Food

The food industry is one of the largest contributors of carbon emissions. You may not have control over the food processing, but you can lower your carbon footprint by buying local products in the market. These local products are not transported from far off places, so the carbon dioxide released from them is lower compared to imported ones. Take a look at the packaging as well; less packaging means less waste.

If you have a big backyard, you could use your it to grow food. ?Eating food, either fruit or vegetable, which you grow at home is energy efficient. No more fuel combustion from transportation and other consequent food processing.

Travel

When you have your own car, accelerating it slowly and smoothly, as well as maintaining speed while driving will help lower your carbon emissions. If you drive a lot, it would be better to get a green car. As of now, you can consider using?public transportation and go for road travel rather than air travel when you take long distance trips. But when you need to take planes, better choose a non-stop flight instead of connecting ones.

Indeed, there are many ways you can combat global warming and climate change. The road to improved life quality through energy efficiency might be hard, but a transformed lifestyle can make a big difference. Start now ? lighten your carbon footprint and help save the world.

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Web Design and Development

The first few seconds of a first-time website visitor is very crucial. If they don’t like what they see or if they think it takes too long just to load what they’re supposed to see, chances are, that would be the last time you’d ever catch them on your site.

Therefore, striking a balance between your website’s appearance and its loading speed is important for first impressions. Once you’ve captured the visitor’s attention, the next objective is to keep them glued long enough for them to browse through your merchandise. It is at this point that the benefits of a well organised and highly intuitive graphical user interface come into play.

An excellent combination of stylish web design and sharp web development can play a major role in lowering bounce rates and increasing returning visitors. We see to it that our web designers and developers not only excel at what they do individually, but also understand the interplay between their individual creations and how it affects the overall appeal of the website.

This is what you can expect from our brand of web design and development:

  • Conversion-motivated web design. Since we understand that your primary motivation for entering into the eCommerce arena is to turn torrential web traffic into sales, we’ve put conversion as a primary consideration in our web designs.
  • SEO-friendly content. First-time visitors don’t reach your site because they entered your URL somewhere. Rather, they must have stumbled upon your links on search engine results or on other websites.
  • Engaging web content. Because excellent graphics alone can’t sell products but engaging web content can, we invest in excellent copywriters.
  • Visitor-friendly user interface. Before a visitor will ever read content on the current and succeeding pages, they’ll need to interact with your site’s UI first. We’ll make sure your user interface is visually appealing enough to invite visitors to click on your buttons.
  • Superior expertise in web development technologies. Our web developers are certified experts in web related technologies including Javascript, AJAX, SQL, PHP, CSS, Java, Silverlight, CMSes, and Magento, among others. Thus, we can offer extreme flexibility and scalability in our web development services.

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