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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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:

Denizon’s Business Continuity Services

Disruptions to business operations can be as catastrophic as a Hurricane Katrina or a 9/11 or as relatively trivial as a minor power outage or a planned shutdown. What ever the gravity, scope and duration the disruption has, your company should be able to handle each situation so that you can declare “business as usual” and really mean it. (more…)

Implementing Large-Scale Complex Business Change

Sometimes, driving your people to work harder is not enough for your organisation to withstand the pressures laying siege to it. With uncertain economic conditions, unpredictable fresh competition, and looming threats from the environment or even pandemic-grade diseases, empowering your people to not only ‘think’ but also to ‘step’ out of the box is currently the name of the game.

However, such initiatives typically require sweeping changes throughout your entire organisation … and to think even the slightest change is often met with hard resistance.

Whether you’re about to undergo an M&A, relocate due to a major catastrophe, scale down to a skeletal workforce, or implement a brand-new company-wide strategy, our systematic approach to large-scale complex business change can help you make the transition as seamless as possible.

We understand the importance of the human aspect in change management. That is why we’ll focus on making your people appreciate the benefits of having to learn new skills, perform new tasks, employ modern technologies, and go through new processes in order to tone down the resistance level.

Our entire process spans from top to bottom, wherein we’ll start with your sponsors, down to your managers, and then to other stakeholders in making them appreciative of the needed changes and in order to achieve alignment with your organisation’s goals. Our top to bottom approach is also aimed at casting a positive “shadow of the leader” on people down the line, enabling them with an optimistic view despite the gruelling tasks before them.

We invite you to have a look at the steps we take in implementing large-scale complex business change to win over a strong and lasting commitment to it.

Evaluating the Required Change

Large-scale complex business change initiatives can be implemented expeditiously and economically if you’ve clearly defined the scope of the change as well as the forces that shape your organisation. You’ll want to know which areas yield easily and which are hard to change to determine where and how you’re going to focus more of your efforts on.

To arrive at a sound and systematic plan, we first gather as much information as needed and analyse them. We determine whether your departments have the required capabilities and how we can arrive at a clear organisational alignment. That way, we don’t waste time, effort and resources when the moment comes to carry out the plan.

These are some of the diagnostic procedures we perform in evaluating the required change.

  • Change complexity analysis. We’ll assess the contribution of people and task factors to the overall complexity of the change project. This will help us determine how to approach the problem efficiently.
  • Causal analysis. By establishing cause and effect relationships, we can identify root or circular causes. This will allow us to pinpoint problem areas and prevent a repetition of past mistakes.
  • Structural analysis. Any company is propped up by a number of structures: organisational, process, motivational, social, and physical, among others. Understanding the structures that drive, motivate, hamper, connect, and influence your people’s behaviours can provide insights as to how or where structural change can best be executed.
  • Context analysis. We’ll look into market forces as well as political, economic, social, technological, legal, and environmental factors enveloping your business. We’ll also analyse your driving objectives, organisational alignment, and organizational capabilities. By analysing the internal and external environment in which your business currently operates, we can formulate a customised strategic and effective plan of action.

Managing Stakeholders

Change initiatives won’t prosper without total commitment from all stakeholders. Stakeholders refer to people in your organisation who either have interests in the change project or can be affected by it.

We deal with your stakeholders starting from the top because if we can’t gain full commitment from those already in the best position to spur the diverse entities in your company into active cooperation, striving to secure commitment from other areas will be futile.

That is, if you don’t have the full support of your key and principal sponsors, i.e. the people who have the biggest say and have greatest control over resources in your organisation, you can’t hope to sustain the change endeavour, let alone provide the much needed spark to get it started.

Here’s how we carry out our stakeholder management actions.

  • Conduct research to identify all stakeholders: the sponsors, your internal and external partners, the main targets of the change, and all interested parties. That way you can “switch on” implementors of each change action in the proper sequence.
  • Not everyone will offer resistance to your change endeavours. We’ll help you identify those stakeholders and sponsors who are willing to offer support, evaluate the level of support they are willing to give, harness all available supports and utilise them extensively to benefit the change.
  • Gain a deeper understanding as to why certain stakeholders are willing to lend support. In doing so, we can implement the right strategies that will encourage them to continue supporting you.
  • Assemble a leadership team that will champion your change initiatives. We’ll facilitate effective collaboration among its team members, transforming them into a cohesive force designed to carry out plans and motivate everyone else down the line.
  • Upon realisation of the change project, we’ll see to it that all stakeholders get a taste of the carrot at the end of the stick. This will encourage them to continue active cooperation in future change initiatives.

Planning for the Change

Anyone who has experienced having their car stuck in the mud knows that stepping on the accelerator will only get the vehicle trapped even deeper. Without the aid of a towing truck, getting the car out will require careful planning since different combinations of pulling, pushing, lifting, rocking to-and-fro, and stepping on the accelerator may be needed.

Of course, some combinations are just better than others. The same principle holds when effecting change.

Our approach to change management typically varies depending upon the information we obtain from the different analyses performed earlier. For instance, since not all organisations are suitable for a collaborative approach, we will employ either collaborative, consultative, directive, or coercive change management strategies wherever applicable.

A well-planned change will result in a smoother, less costly, and less disruptive transition. Here’s how we’ll help you plan your change initiatives.

  • When put in a predicament similar to the car-in-the-mud, the basic strategy entails identifying the current resisting forces and predicting what other resisting forces may be encountered along the way. After researching and pointing out your organisation’s resistance forces, we’ll lay out the most appropriate facilitation, education, and negotiation techniques.
  • To bring down wastage to the lowest possible levels, we’ll engineer a change delivery plan that involves the most cost-effective sequence of driver, process, technology, organisational, and people alignment.
  • To win and maintain a high level of trust, confidence and commitment from all sponsors and stakeholders, we’ll present a clear road map of the change process as well as landmarks that will prove how far we will have gone. These landmarks will then be brought to each sponsor’s and stakeholder’s attention each time they are arrived at in order to build up assurance and continued commitment.
  • We’ll design measurement tools and schedule reporting deadlines so that you’ll know what to look forward to and when to expect them.

Managing the Change

Your company will hold a better chance of maintaining a sizeable lead over the rest of the pack if you constantly establish a rally point and instil in your stakeholders the drive to rally to that point from the get-go. To make this happen, your company must undertake the unfreezing, transition, and refreezing phases of change skilfully in order to bring all stakeholders into the right mindset.

Our specialists’ systematic and efficient methods for each of these phases are designed to simplify the management of each phase as well as provide a seamless shift from one phase to the next. This is what we’ll do:

  • Set up a change project management office to ensure that everything associated with the change initiative is given the needed attention and resources even while all the other usual processes in your organisation run concurrently.
  • To unfreeze your people and get them started on the road of change, we’ll employ unfreezing techniques wherever they are most appropriate. We’ll resort to different kinds of methods ranging from presenting persuasive evidence justifying the need for change to showing a motivational vision for inspiring your people to embark on the change process.
  • Since it is during the transition phase when your people can find themselves groping in the dark, we’ll offer executive coaches for your senior managers; facilitators to provide guidance during team meetings and other change activities; coaches to educate and inspire them to meet the change with the right attitude; trainers to teach new systems, procedures, and technologies; as well as employ a variety of other techniques in order to make the transition phase as seamless as possible.
  • Although your people should always be ready to undertake the next major change after a previous one, there should be points in between where they can taste the spirit of success, establish a temporary base to rejuvenate, and immediately gain a deeper understanding of the nearby terrain so as to envision the next rally point. We’ll see to it that this vital phase of change is carried out completely.

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