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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Which KPI?s to Use in CRM

Customer relationship management emerged in the 1980?s in the form of database marketing. In those tranquil pre-social media days, the possibility of ?managing? clients may have been a possibility although Twitter and Facebook took care of that. Modern managers face a more dynamic environment. If you are one, then what are the trends you should be monitoring yourself (as opposed to leaving it to others).

If you want to drip feed plants, you have to keep the flow of liquid regular. The same applies to drip-feed marketing. Customers are fickle dare we say forgetful. Denizon recommends you monitor each department in terms of Relationship Freshness. When were the people on your list last contacted, and what ensued from this?

Next up comes the Quality of Engagements that follow from these efforts. How often do your leads respond at all, and how many interfaces does it take to coax them into a decision? You need to relate this to response blocks and unsubscribes. After a while you will recognise the tipping point where it is pointless to continue.

Response Times relate closely to this. If your marketing people are hot then they should get a fast response to sales calls, email shots and live chats. It is essential to get back to the lead again as soon as possible. You are not the only company your customers are speaking too. Fortune belongs to the fast and fearless.

The purpose of marketing is to achieve Conversions, not generate data for the sake of it. You are paying for these interactions and should be getting more than page views. You need to drill down by department on this one too. If one team is outperforming another consider investing in interactive training.

Finally Funnel Drop-Off Rate. Funnel analysis identifies the points at which fish fall off the hook and seeks to understand why this is happening. If people click your links, make enquiries and then drift away, you have a different set of issues as opposed to if they do not respond at all.

You should be able to pull most of this information off your CRM system if it is half-decent, although you may need to trigger a few options and re orientate reporting by your people in the field. When you have your big data lined up speak to us. We have a range of data analysts brimming over with fresh ideas.

How Energy Conservation saved Fambeau River Paper

Rising energy costs caught this Wisconsin paper mill napping, and it soon shut down because it was unable to innovate. Someone else bought it and turned it around by measuring, modifying, monitoring and listening to people.

The Fambeau River Paper Mill in Prince County, Wisconsin USA employed 13% of the city?s residents until rising energy costs shut it down in 2006. Critics wrote it off as an energy dinosaur unable to adapt. But that was before another company bought it out and resuscitated it as a fleet-footed winner.

Its collapse was a long time coming and almost inevitable. Wisconsin electricity prices had grown a third since 1997, the machinery was antiquated and the dependence on fossil power absolute. So what did the new owners change, and is there anything we can learn from this?

The key to understanding what suddenly went right was the new owners? ability to listen. They requested a government Energy Assessment that suggested a number of small step changes that took them where they needed to go in terms of energy saving. These included enhancements in steam systems and fuel switch modifications. However they needed more than that.

The second game changer was tracking down key members of the old workforce and listening to them too. This combination enabled them to finally hire back 92% of the original labour force under the same terms and conditions – and still make a profit (the other 8% had moved on elsewhere or retired). The combined energy savings produced a payback plan of 5.25 years. Three years into the project their capital investment of $15 million had already clawed back the following electricity savings.

  • Evaporator Temperature Control $2,245,000
  • Hot Water Heat Recovery $2,105,000
  • Paper Machine Devronisers $1,400,000
  • Increased Boiler Output $1,134,000
  • Paper Machine Modifications; $761,000
  • Motive Air Dryer $610,000
  • Accumulator Savings $448,000
  • Densified Fuels Plant $356,000

In terms of carbon dioxide produced, the Fambeau River Paper Mill?s contribution dropped from 1 ton to 600 pounds.

How well do you know where your company?s energy spend is concentrated, and how this compares with your industry average; could you be doing better if you innovated, and by how much? Get these questions answered by asking ecoVaro how easy it could be to get on top of your carbon metrics. This could cost you a phone call and a payback on it so rapid it’s not worth stopping to calculate.

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New Focus on Monitoring Soil

There is nothing new about monitoring soil in arid conditions. South Africa and Israel have been doing it for decades. However climate change has increased its urgency as the world comes to terms with pressure on the food chain. Denizon decided to explore trends at the macro first world level and the micro third world one.

In America, the Coordinated National Soil Moisture Network is going ahead with plans to create a database of federal and state monitoring networks and numerical modelling techniques, with an eye on soil-moisture database integration. This is a component of the National Drought Resilience Partnership that slots into Barrack Obama?s Climate Action Plan.

This far-reaching program reaches into every corner of American life to address the twin scourges of droughts and inundation, and the agency director has called it ?probably ?… one of the most innovative inter-agency tools on the planet?. The pilot project involving remote moisture sensing and satellite observation targets Oklahoma, North Texas and surrounding areas.

Africa has similar needs but lacks America?s financial muscle. Princeton University ecohydrologist Kelly Caylor is bridging the gap in Kenya and Zambia by using cell phone technology to transmit ecodata collected by low-cost ?pulsepods?.

He deploys the pods about the size of smoke alarms to measure plants and their environment.?Aspects include soil moisture to estimate how much water they are using, and sunlight to approximate the rate of photosynthesis. Each pod holds seven to eight sensors, can operate on or above the ground, and transmits the data via sms.

While the system is working well at academic level, there is more to do before the information is useful to subsistence rural farmers living from hand to mouth. The raw data stream requires interpretation and the analysis must come through trusted channels most likely to be the government and tribal chiefs. Kelly Caylor cites the example of a sick child. The temperature reading has no use until a trusted source interprets it.

He has a vision of climate-smart agriculture where tradition gives way to global warming. He involves local farmers in his research by enrolling them when he places pods, and asking them to sms weekly weather reports to him that he correlates with the sensor data. As trust builds, he hopes to help them choose more climate-friendly crops and learn how to reallocate labour as seasons change.

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