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

Uncover hidden opportunities with energy data analytics

What springs to mind when you hear the words energy data analytics? To me, I feel like energy data analytics is not my thing. Energy data analytics, however, is of great importance to any organisation or business that wants to run more efficiently, reduce costs, and increase productivity. Energy efficiency is one of the best ways to accomplish these goals.

Energy efficiency is not about investment in expensive equipment and internal reorganization. Enormous energy saving opportunities is hidden in already existing energy data. Given that nowadays, energy data can be recorded from almost any device, a lot of data is captured regularly and therefore a lot of data is readily available.

Organisations can use this data to convert their buildings’ operations from being a cost centre to a revenue centre through reduction of energy-related spending which has a significant impact on the profitability of many businesses. All this is possible through analysis and interpretation of data to predict future events with greater accuracy. Energy data analytics therefore is about using very detailed data for further analysis, and is as a consequence, a crucial aspect of any data-driven energy management plan.

The application of Data and IT could drive significant cost savings in company-owned buildings and vehicle fleets. Virtual energy audits can be performed by combining energy meter data with other basic data about a building e.g. location, to analyse and identify potential energy savings opportunities. Investment in energy dashboards can further enable companies to have an ongoing look at where energy is being consumed in their buildings, and thus predict ways to reduce usage, not to mention that energy data analytics unlock savings opportunities and help companies to understand their everyday practices and operating requirements in a much more comprehensive manner.

Using energy data analytics can enable an organisation to: determine discrepancies between baseline and actual energy data; benchmark and compare previous performance with actual energy usage. Energy data analytics also help businesses and organisations determine whether or not their Building Management System (BMS) is operating efficiently and hitting the targeted energy usage goals. They can then use this data to investigate areas for improvement or energy efficient upgrades. When energy data analytics are closely monitored, companies tend to operate more efficiently and with better control over relevant BMS data.

How Ventura Bus Lines cleaned up its Act

Melbourne?s Ventura Bus Lines grew from a single bus in 1924 to a mega 308-vehicle fleet by the start of 2014. The family-owned provider has always been community centric; when climate-change became an issue it took quick and urgent action. As a result it now stands head and shoulders above many others. Let’s take a closer look at some of its decisions that made the difference.

The Important Things to Focus On

Ethanol Buses ? Ventura is the only Australian company that uses ethanol power produced from sugar cane for experimental public transport. It compares emissions within its fleet, and knows that these produce significantly less CO2 while also creating jobs for locals.

Electric Buses ? The company has been operating electric buses since 2009. These carry 42 seated among a total 68 passengers. The ride is smooth thanks to twin battery banks kept charged by braking and forward momentum. When required, a two-litre VW engine kicks in automatically.

Ongoing Driver Training ? Ventura provides regular retraining sessions emphasising safe, environmentally-friending operations. Drivers are able to see their fuel consumption and carbon emissions online and experiment with ways to improve these.

Bus U-Turns ? The capacity to measure throughput convinced the company to abandon the principle that buses don’t do U-Turns for safety?s sake. Road re-engineering made this possible in a busy downtown street. This reduced emissions equivalent to 4,000 cars and reduced vehicle downtime for servicing.

Increased Business – These initiatives allowed Ventura Bus Lines to improve its service as customers experience it. This led to an uptake in patronage and a corresponding downturn in the number of passenger car hours. The pleasure of travelling green no doubt contributed to this.

How Measuring Made the Difference

Ventura Bus Lines is big business. Its 308 buses operate out of 5 depots, cover 31% of the metropole, and transport close to 70,000 passengers on average daily which is no minor task. The ability to track, measure and analyse carbon emissions throughout the area has earned it compliance with National Greenhouse Energy Reporting Threshold 1 legislation.

It also uses the data to re-engineer bus routes to further reduce fuel consumption, energy consumption and operating costs. It’s amazing how measuring is affecting its bottom line, and the health of the Melbourne community at large.

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK
Which Services to Share?

It often makes sense to pool resources. Farmers have been doing so for decades by collectively owning expensive combine harvesters. France, Germany, the United Kingdom and Spain have successfully pooled their manufacturing power to take on Boeing with their Airbus. But does this mean that shared services are right in every situation?

The Main Reasons for Sharing

The primary argument is economies of scale. If the Airbus partners each made 25% of the engines their production lines would be shorter and they would collectively need more technicians and tools. The second line of reasoning is that shared processes are more efficient, because there are greater opportunities for standardisation.

Is This the Same as Outsourcing?

Definitely not! If France, Germany, the United Kingdom and Spain has decided to form a collective airline and asked Boeing to build their fleet of aircraft, then they would have outsourced airplane manufacture and lost a strategic industry. This is where the bigger picture comes into play.

The Downside of Sharing

Centralising activities can cause havoc with workflow, and implode decentralised structures that have evolved over time. The Airbus technology called for creative ways to move aircraft fuselages around. In the case of farmers, they had to learn to be patient and accept that they would not always harvest at the optimum time.

Things Best Not Shared

Core business is what brings in the money, and this should be tailor-made to its market. It is also what keeps the company afloat and therefore best kept on board. The core business of the French, German, United Kingdom and Spanish civilian aircraft industry is transporting passengers. This is why they are able to share an aircraft supply chain that spun off into a commercial success story.

Things Best Shared

It follows that activities that are neither core nor place bound – and can therefore happen anywhere ? are the best targets for sharing. Anything processed on a computer can be processed on a remote computer. This is why automated accounting, stock control and human resources are the perfect services to share.

So Case Closed Then?

No, not quite. ?Technology has yet to overtake our humanity, our desire to feel part of the process and our need to feel valued. When an employee, supplier or customer has a problem with our administration it’s just not good enough to abdicate and say ?Oh, you have to speak to Dublin, they do it there?.

Call centres are a good example of abdication from stakeholder care. To an extent, these have ?confiscated? the right of customers to speak to speak directly to their providers. This has cost businesses more customers that they may wish to measure. Sharing services is not about relinquishing the duty to remain in touch. It is simply a more efficient way of managing routine matters.

Ready to work with Denizon?