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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Scrumming Down to Complete Projects

Everybody knows about rugby union scrums. For our purposes, perhaps it is best to view them as mini projects where the goal is to get the ball back to the fly-half no matter what the opposition does. Some scrums are set pieces where players follow planned manoeuvres. Loose / rolling scrums develop on the fly where the team responds as best according to the situation. If that sounds to you like software project management then read on, because there are more similarities?.

Isn’t Scrum Project Management the Same as Agile?

No it’s not, because Scrum is disinterested in customer liaison or project planning, although the team members may be happy to receive the accolades following success. In the same way that rugby players let somebody else decide the rules and arrange the fixtures, a software Scrum team just wants the action.

Scrum does however align closely ? dare I say interchangeably with Agile?s sprints. Stripping it of all the other stages frees the observer up to analyse it more closely in the context of a rough and tumble project, where every morning can begin with a backlog of revised requirements to back fit.

The 3 Main Phases of a Scrum

A Scrum is a single day in the life of a project, building onto what went before and setting the stage for what will happen the following day. The desired output is a block of component software that can be tested separately and inserted later. Scrumming is also a useful technique for managing any project that can be broken into discreet phases. The construction industry is a good example.

Phase 1 – Define the Backlog. A Scrum Team?s day begins with a 15 minute planning meeting where team members agree individual to-do lists called ?backlogs?.

Phase 2 – Sprint Towards the Goal. The team separates to allow each member to complete their individual lines of code. Little or no discussion is needed as this stage.

Phase 3 – Review Meeting. At the end of each working day, the team reconvenes to walk down what has been achieved, and check the interconnected functionality.

The 3 Main Phases of a Scrum ? Conclusions and Thoughts

Scrum is a great way to liberate a competent project team from unnecessary constraints that liberate creativity. The question you need to ask yourself as manager is, are you comfortable enough to watch proceedings from the side lines without rushing onto the field to grab the ball.

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Eliminate The Complexities Of Your IT System

There may have been times when you actually spent on the right IT system but didn’t have adequate expertise to instil the appropriate learning curve for your end users. Oftentimes, users find a new system too complicated and end up spending more hours familiarising with intricate processes than is economically acceptable.

There are also applications that are just too inherently sophisticated that, even after the period of familiarisation, a lot of time is still spent managing or even just using them. Therefore, at the end of each day, your administrators and users aren’t able to complete much business-related tasks.

The first scenario can be solved by providing adequate training and tech support. The second might require enhancements or, in extreme cases, an overhaul of the technology itself.

For instance, consider what happens right after the conclusion of a merger and acquisition (M&A). CIOs from both sides and their teams will have to work hard to bring disparate technologies together. The objective is to hide these complexities and allow customers, managers, suppliers and other stakeholders to get hold of relevant information with as little disruption as possible.

One solution would be to implement Data Warehousing, OLAP, and Business Intelligence (BI) technologies to handle extremely massive data and present them into usable information.

These are just some of the many scenarios where you’ll need our expertise to eliminate the complexities that can slow your operations down.

Here are some of the solutions and benefits we can offer when we start working with you:

  • Consolidated hardware, storage, applications, databases, and processes for easier and more efficient management at a fraction of the usual cost.
  • BI (Business Intelligence) technologies for improved quality of service and for your people, particularly your managers, to focus on making decisions and not just filtering out data.
  • Training, workshops, and discussions that provide a clear presentation of the inter-dependencies among applications, infrastructure, and the business processes they support.
  • Increased automation of various processes resulting in shorter administration time. This will free your administrators and allow them to shift their attention to innovative endeavours.

Find out how we can increase your efficiency even more:

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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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