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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Why DevOps Matters: Things You Need to Know

DevOps creates an agile relationship between system development and operating departments, so the two collaborate in providing results that are technically effective, and work well for customers and users. This is an improvement over the traditional model where development delivers a complete design ? and then spends weeks and even months afterwards, fixing client side problems that should never have occurred.
Writing for Tech Radar Nigel Wilson explains why it is important to roll out innovation quickly to leverage advantage. This implies the need for a flexible organisation capable of thinking on its feet and forming matrix-based project teams to ensure that development is reliable and cost effective.
Skirmishes in Boardrooms
This cooperative approach runs counter to traditional silo thinking, where Operations does not understand Development, while Development treats the former as problem children. This is a natural outcome of team-centred psychology. It is also the reason why different functions pull up drawbridges at the entrance to their silos. This situation needs managing before it corrodes organization effectiveness. DevOps aims to cut through this spider web of conflict and produce faster results.

The Seeds of Collaboration

Social and personal relationships work best when the strengths of each party compensate the deficiencies of the other. In the case of development and operations, development lacks full understanding of the daily practicalities operating staff face. Conversely, operations lacks ? and should lack knowledge of the nuances of digital automation, for the very reason it is not their business.
DevOps straddles the gap between these silos by building bridges towards a co-operative way of thinking, in which matrix-teams work together to define a problem, translate it into needs and spec the system to resolve these. It is more a culture than a method. Behavioural change naturally leads to contiguous delivery and ongoing deployment. Needless to say only the very best need apply for the roles of client representative, functional tester and developer lead.

Is DevOps Worth the Pain of Change?

Breaking down silos encroaches on individual managers? turf. We should only automate to improve quality and save money. These savings often distil into organisational change. The matrix team may find itself in the middle of a catfight. Despite the pain associated with change resistance, DevOps more than pays its way in terms of benefits gained. We close by considering what these advantages are.

An Agile Matrix Structure ? Technical innovation is happening at a blistering rate. The IT industry can no longer afford to churn out inferior designs that take longer to fix than to create. We cannot afford to allow office politics to stand in the way of progress. Silos and team builds are custodians of routine and that does not sit well with development.

An Integrated Organization ? DevOps not only delivers operational systems faster through contiguous testing. It also creates an environment whereby cross-border teams work together towards achieving a shared objective. When development understands the challenges that operations faces ? and operations understands the technical limiters – a new perspective emerges of ?we are in this together?.

The Final Word ? With understanding of human dynamics pocketed, a DevOps project may be easier to commission than you first think. The traditional way of doing development – and the waterfall delivery at the end is akin to a two-phase production line, in which liaison is the weakest link and loss of quality inevitable.

DevOps avoids this risk by having parties work side-by-side. We need them both to produce the desired results. This is least until robotics takes over and there is no longer a human element in play.

How Volvo Dublin achieved Zero Landfill Status

The sprawling New River Valley Volvo plant in Dublin, Virginia slashed its electricity bill by 25% in a single year when it set its mind to this in 2009. It went on to become the first carbon-neutral factory in 2012 after replacing fossil energy with renewable power. Further efforts rewarded it with zero-landfill status in 2013. ecoVaro decided to investigate how it achieved this latest success.

Volvo Dublin?s anti-landfill project began when it identified, measured and evaluated all liquid and solid waste sources within the plant (i.e. before these left the works). This quantified data provided its environmental project team with a base from which to explore options for reusing, recycling and composting the discards.

Several decisions followed immediately. Volvo instructed its component suppliers to stop using cardboard boxes and foam rubber / Styrofoam as packaging, in favour of reusable shipping containers. This represented a collaborative saving that benefited both parties although this was just a forerunner of what followed.

Next, Volvo?s New River Valley truck assembly plant turned its attention to the paint shop. It developed methods to trap, reconstitute and reuse solvents that flushed paint lines, and recycle paint sludge to fire a cement kiln. The plant cafeteria did not escape attention either. The environment team made sure that all utensils, cups, containers and food waste generated were compostable at a facility on site.

The results of these simple, and in hindsight obvious decisions were remarkable. Every year since then Volvo has generated energy savings equivalent to 9,348 oil barrels or if you prefer 14,509 megawatts of electricity. Just imagine the benefits if every manufacturing facility did something similar everywhere around the world.

By 2012, the New River Valley Volvo Plant became the first U.S. facility to receive ISO 50001 energy-management status under a government-administered process. Further technology enhancements followed. These included solar hot water boilers and infrared heating throughout the 1.6 million square foot (148,644 square meter) plant, building automation systems that kept energy costs down, and listening to employees who were brim-full with good ideas.

The Volvo experience is by no means unique although it may have been ahead of the curve. General Motors has more than 106 landfill-free installations and Ford plans to reduce waste per vehicle by 40% between 2010 and 2016. These projects all began by measuring energy footprints throughout the process. ecoVaro provides a facility for you to do this too.

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Disaster Recovery

Because information technology is now integrated in most businesses, a business continuity plan (BCP) cannot be complete without a corresponding disaster recovery plan (DRP). While a BCP encompasses everything needed – personnel, facilities, communications, processes and IT infrastructure – for a continuous delivery of products and services, a DRP is more focused on the IT aspects of the plan.

If you’re still not sure how big an impact loss of data can have, it’s time you pondered on the survival statistics of companies that incurred data losses after getting hit by a major disaster: 46% never recovered and 51% eventually folded after only two years.

Realising how damaging data loss can be to their entire business, most large enterprises allocate no less than 2% of their IT budget to disaster recovery planning. Those with more sensitive data apportion twice more than that.

A sound disaster recovery plan is hinged on the principles of business continuity. As such, our DRP (Disaster Recovery Plan) blueprints are aimed at getting your IT system up and running in no time. Here’s what we can do for you:

  • Since the number one turn-off against BCPs and DRPs are their price tags, we’ll make a thorough and realistic assessment of possible risks to determine what specific methods need to be applied to your organisation and make sure you don’t spend more than you should.
  • Provide an option for virtualisation to enjoy substantial savings on disaster recovery costs.
  • Provide various backup options and suggest schedules and practices most suitable for your daily transactions.
  • Offer data replication to help you achieve business continuity with the shortest allowable downtime.
  • Refer to your overall BCP to determine your organisation’s critical functions, services, and products as well as their respective priority rankings to know what corresponding IT processes need to be in place first.
  • Implement IT Security to your system to reduce the risks associated with malware and hackers.
  • Introduce best practices to make future disaster recovery efforts as seamless as possible.

We can also assist you with the following:

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