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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Month End Accounting the way it should Be Today

Month end accounting has always been a business critical exercise. Without the balance sheet, income statement, and other financial reports this exercise ultimately produces, management could not make informed decisions to keep the company in the right direction and at the ideal operational speed.

Now, in order to maintain optimal business velocity, month end activities have to be carried out as swiftly and as accurately as possible. Delays will only inhibit managers from reacting and effecting necessary adjustments in time. Inaccurate information, on the other hand, obviously lead to bad decisions.

But that’s not all. Never has the month end close been as demanding as it is today. Regulations like the Sarbanes-Oxley Act, Solvency II, Dodd-Frank Act, and others, which call for more stringent controls and more robust risk management practices, are now forcing companies to find better ways to face the end of the month.

Sticking to old month-end practices while striving to achieve regulation compliance can either cost a company more (if they add manpower) or simply bog it down (if they don’t). Among the worst of these practices is the use of spreadsheets.

These User Developed Applications (UDAs) are very susceptible to errors. (See spreadsheet risks)

What’s more, consolidating data from spreadsheets as well as carrying out reconciliations on them is very time consuming. These activities usually require data from outside sources – i.e. a workstation in a different department, building, or (in the case of really large corporations) geographical locations.

Furthermore, if one of these sources fail, the financial reports won’t be complete. This is not a far-fetched scenario, considering that spreadsheet storage and backup is typically carried out by the average end user. This leaves the spreadsheet data vulnerable to hard disk crashes, virus attacks, and unexpected disasters.

Thus, in order to produce accurate financial reports on time all the time, you need a financial/IT solution that offers optimal provisions for risk management, collaboration, backup, and business continuity. Learn about server-based solutions and discover a better way to carry out month end accounting.

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:

Operational Reviews

IT OPERATIONAL REVIEWS DEFINED
An IT operational review is an in-depth and objective review of an entire organisation or a specific segment of that organisation. It can be used to identify and address existing concerns within your company such as communication issues between departments, problems with customer relations, operating procedures, lack of profitability issues, and other factors that affect the stability of the business.
Operational reviews allow the organisation members to evaluate how well they are performing, given that they perform appropriately according to the procedures set by them, allocating their resources properly, and performing such tasks within time frame set and using cost-effective measures. More importantly, it also shows your company how well it is prepared to meet future challenges.
Simply put, the goals of an operational review are to increase revenue, improve market share, and reduce cost.

THE BENEFITS OF AN IT OPERATIONAL REVIEW
The main objective of IT operational reviews is to help organisations like yours learn how to deal with and address issues, instead of simply reacting to the challenges brought about by growth and change.
In such review, the information provided is practical from both a financial and operational perspective. Using these data, the management can then come up with recommendations, which are not only realistic, but more importantly, can help the organisation achieve its goals. The review recognises the extent to which your internal controls actually work, and enables you to identify and understand your strengths, weaknesses, opportunities and threats

To be more specific, let’s list down the ways wherein an effective operational review can contribute to the success of the organisation.

The review process can:
– assess compliance within your own organisational objectives, policies and procedures;
– evaluate specific company operations independently and objectively;
– give an impartial assessment regarding the effectiveness of an organisation’s control systems;
– identify the appropriate standards for quantifying achievement of organisational objectives;
– evaluate the reliability and value of the company?s management data and reports;
– pinpoint problem areas and their underlying causes;
– give rise to opportunities that may increase profit, augment revenue, and reduce costs without sacrificing the quality of the product or service.
Thus, each operational review conducted is unique, and can be holistic or specific to the activities of one department.

Our Operational Efficiencies cover the entire spectrum:

  • What to buy
  • Optimising what you’ve already bought e.g. underutilised servers, duplicate processes, poorly managed bandwidths
  • Making your team comfortable with the changes
  • Instilling Best Practices

UNCOVER WAYS TO DRIVE YOUR PROFITS UP, THROUGH OPERATIONAL REVIEWS

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