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

How To Get Started with your IT Compliance Efforts for SOX

There’s no question about it. For many of you top executives in the corporate world, all roads leading to a brighter future have to go through SOX compliance. And because the business processes that contribute to financial reporting (the crux of the Sarbanes-Oxley Act) are now highly reliant on IT systems, it is important to focus a good part of your attention there.

It is a long and arduous path to IT compliance, so if you don’t want your company to fall by the wayside due to inefficient utilisation of resources, it is important to set out with a plan on hand. What we have here are some vital information that will guide you in putting together a sound plan for SOX compliance of your company?s IT systems.

Why focus on IT systems for SOX compliance?

We’ll get to that. But first, let’s take up the specific portions of the Sarbanes-Oxley Act that affect information technology. These portions can be found in Section 302 and Section 404 of the act.

In simplified form, Section 302 grants the SEC (Securities and Exchange Commission) authority to come up with rules requiring you, CEOs and CFOs, to certify in each annual or quarterly financial report the following:

  • that you have reviewed the report;
  • that based on your knowledge, the report does not contain anything or leave out anything that would render it misleading;
  • that based on your knowledge, all financial information in the report fairly represent the financial conditions of the company;
  • that you are responsible for establishing internal controls over financial reporting; and
  • that you have assessed the effectiveness of the internal controls.

Similarly, Section 404, stated in simplified form, allows the SEC to come up with rules requiring you, CEOs and CFOs, to add an internal control report to each annual financial report stating that you are responsible for establishing internal controls over financial reporting.

You are also required to assess the effectiveness of those controls and to have a public accounting firm to attest to your assessment based upon standards adopted by the Public Company Accounting Oversight Board (PCAOB).

While there is no mention of IT systems, IT systems now play a significant role in financial reporting. Practically all of the data you need for your financial reports are stored, retrieved and processed on IT systems, so you really have to include them in your SOX compliance initiatives and establish controls on them.

Now that that’s settled, your next question could very well be: How do you know what controls to install and whether those controls are already sufficient to achieve compliance?

Finding a suitable guide for IT compliance

The two bodies responsible for setting rules and standards dealing with SOX, SEC and PCAOB, point to a well-established control framework for guidance – COSO. This framework was drafted by the Committee of Sponsoring Organisations of the Treadway Commission (COSO) and is the most widely accepted control framework in the business world.

However, while COSO is a tested and proven framework, it is more suitable for general controls. What we recommend is a widely-used control framework that aligns well with COSO but also caters to the more technical features and issues that come with IT systems.

Taking into consideration those qualifiers, we recommend COBIT. COBIT features a well thought out collection of IT-related control objectives grouped into four domains: Plan and Organise (PO), Acquire and Implement (AI), Deliver and Support (DS), and Monitor and Evaluate (ME). The document also includes maturity models, performance goals and metrics, and activity goals.

A few examples of COBIt’s detailed control objectives are:

DS4.2 – IT Continuity Plans
DS4.9 – Offsite Backup Storage
DS5.4 – User Account Management
DS5.8 – Cryptographic Key Management
DS5.10 – Network Security
DS5.11 – Exchange of Sensitive Data

By those titles alone, you can see that the framework is specifically designed for IT. But the document is quite extensive and, chances are, you won’t need all of the items detailed there. Furthermore, don’t expect COBIT to specify a control solution controls for every control objective. For example, throughout the control objective DS4 (Ensure Continuous Service), you won’t find any mention of virtualisation, which is common in any modern business continuity solution.

Basically, COBIT will tell you what you need to attain in order to achieve effective governance, management and control, but you’ll have to pick the solution best suited to reach that level of attainment.

Articles highly relevant to the one you just read:

Month End Accounting The Way It Should Be Today
Spreadsheet Woes ? Burden in SOX Compliance and Other Regulations
Spreadsheet Woes ? Limited Features For Easy Adoption of a Control Framework
How Internal Auditors Can Win The War Against Spreadsheet Fraud

5 Ways To Grow Your Business | How Field Service Management Software Helps

Building up any business is already hard, more so when it involves providing field services.

A field service business owner has to manage the usual tasks, like scheduling jobs efficiently or inventory checks, and you have to do it while your employees are scattered about on various locations.

It’s the reason FieldElite was created, to provide companies with a much better way to manage and monitor their field workers.

Aside from effective management for your workforce on the move, field service management software can also help your business grow.

5 Ways Using Field Service Management Software Grows Your Business

1. Management Integration

You replace manual field service processes. If your business also uses other management apps, like CRM, payroll, industry-specific software, etc., make sure to integrate them with your chosen field service management software.?

Make those software work side-by-side with your field service management app to achieve streamlined business management.

Integration also removes the possibility of duplicate input on the regular system used and your field service management software, maximising your efficiency and business growth.

2. Improved Tracking

Utilising a field service management software gives you better tracking of every aspect of your field service business.

  • Track your inventory numbers in real-time ? know exactly how much stock is on hand for parts, and when it’s time to order more
  • Constant updates on Key Performance Indicators ? ensure your business is running smoothly
  • First-time fix rates tracking ? avoid wrong rate application
  • Monitor your technician?s performance ? ensuring quality work, in turn, profit.

Grow your business by having improved tracking on meaningful data and analytics produced from your field service management software.

3. Cost Cutting

Cutting costs can improve your bottom line and a lot of businesses turn to laying off technicians to cut costs. With a field service management software, there?s no need to go this route.

You cut costs through no manual processes needing to be completed. No need to hire back-office staff to field service calls or produce paperwork orders.

Your field service software should have all your automated needs met for efficient field job management.

An example of cost-cutting using field service app:

Track how much your technicians drive and find alternate routes for them to take.

  • Reduce gas expenses
  • Reduce repair bills for the truck
  • Finding better alternate routes can give more time to get to more jobs
  • Increased efficiency for the field technician

4.? Mobile Adaptability

Field service companies are focusing on mobility to grow their business. With a field service management software, technicians have on hand the tools and information needed to complete their job.

Field technicians can utilise the following field service software features:

  • Limit how much time they spend completing administrative work with the automated work-order management
  • Complete checklists on their mobile device and follow step-by-step instructions
  • Check service history
  • Close job orders/calls, collect signatures and start the invoice process

With a mobile app, technicians can complete a call faster, increasing the number of job order scheduled each day, giving additional revenue and that helps to grow your business.

5. Automation

What good is a field service management software without automated features??

Automation, in any industry, is an important factor in managing and growing your business.

Here are some examples of automation features and tools that your software needs in field service:

  • Create and convert quotations into work orders
  • Schedule/Reschedule jobs
  • Accept jobs in the field
  • Convert jobs into invoices
  • Preventative maintenance service
  • Customer updates
  • Automated job reports

Business Growth with your Field Service Management Software

Field service management software is growing businesses through automation, tracking and workflow management.

Your operation can run smarter and more efficiently, all while empowering your field technicians to do their job smoothly.

If you haven’t turned to a field service management software yet, you’re missing out on chances to grow your business.

Check out FieldElite to help grow your field service business today!

How to Improve Corporate Efficiency through IT

When revenues are low, what do you do to improve your profit? Obviously, those same revenues should at least remain the same. So, the objective would be to deliver the same products and services for less cost. More for less. Such is the essence of corporate efficiency.

There are many things that can make a company inefficient. There are outdated procedures, poor coordination between departments, managers? lack of business visibility, and prolonged down times, to mention a few. As a company grows, these issues get more severe.

You can overcome all these by deploying the right IT solutions. But don’t IT solutions increase spending instead? Au contraire. The last couple of decades have seen the rise of IT solutions that help companies’realise obvious cost savings in no time.

Streamline processes and keep departments in-sync

Company inefficiencies are largely due to outdated systems and procedures. These systems and procedures were not built for the dynamic and complex business environments of today that are being shaped by increasingly onerous regulations, fierce and growing competition, significant economic upswings and downturns, new battlefronts (like the Web) and logistical strategies (like outsourcing), and IT-savvy crooks.

So when your employees force outdated systems to meet today?s business demands, they’re just not able to deliver. At least not efficiently.

Another major cause of inefficiency is the discordance among departments, business units, and even individual staff members themselves. There are those who still use highly personalised spreadsheets and other disparate applications, which make data consolidation take forever and the financial close a perennial headache.

Costly devices like mobile phones, netbooks, and tablet PCs, which are supposedly designed to provide better communication, are not fully maximised. If these are subsidised by the company, then they also contribute to company inefficiency.

One way to deal with these issues is to deploy server based solutions. By centralising your IT system, you can easily implement various improvements that can pave the way for better communication and collaboration, stronger security, faster processes and transactions, and shorter down times for troubleshooting and maintenance. All these clearly translate to cost savings.

Gain better visibility

Corporate efficiency can be improved if your decision makers can make wise and well-informed decisions, faster. But they can only do this if reports they receive from people down the line are timely, accurate, and reliable. Basically, data should be presented in a way for managers to gain quick insights from.

If your people take too much time scrutinising, interpreting, and reconciling data, you can’t hope to gain a significant competitive advantage. Equally important to managing an ongoing project is the speed at which you make a go/no go decision to start or stop a project. A wise, quick decision will help you avoid wastage.

The same holds true when making purchases and investment decisions. It’s all about quickly eliminating waste and investing only on those that will give you fast, positive returns.

Clear business visibility will allow managers to allocate resources where they are most effective, to pinpoint what products and services being offered are more profitable, and to identify which customers are giving better business from an overall perspective.

These are all possible with business intelligence. We know, we know. You’ll say BI solutions will force you to break the bank. Not anymore. At least, not all. There are already two main types of BI solutions: on-premise and SaaS. The latter will generally cost you less.

Of course, each type has its own advantages, and you’ll really have to look into the size of your organisation, the number of source systems your decision-making platform is connected to, integration requirements, budget, etc. to make sure you get the most out of your investment.

But IT solutions cost an arm and a leg

Again, not anymore. These days, you can find IT products that are faster, more functional, and more powerful than their predecessors at a fraction of the cost. When it comes to getting more affordable IT products and services, you now have many options.

For example, you can turn to open source solutions to save on license costs. These solutions are typically backed by vibrant and helpful communities where you can find an extensive source of technical support – many of which are for free. With popular open source products, you can easily tap from a large pool of developers with affordable rates any time you want to make system enhancements or customisation.

On another front, virtualization solutions allow you to save on CAPEX and OPEX by eliminating certain expenses normally used for setting up infrastructure or buying hardware and maintaining them. Server virtualisation, for instance, will allow you to consolidate servers and put them together into just one machine, while desktop virtualisation will enable you to eliminate unproductive hours associated with desktop down times by allowing you to redeploy a malfunctioning desktop very quickly.

Closely related to those are cloud-based solutions like SaaS (Software as a Service), IaaS (Infrastructure as a Service), and DCoD (Data Center on Demand). SaaS and IaaS will help you realize savings in acquisition and maintenance costs for software and hardware, while DCoD?s scalable services allow you to request for additional capacity, power and storage only as you need them, thus making you spend only according to your current infrastructure requirements.

Like we said, there are many, many options out there just waiting to be tapped.

Ready to work with Denizon?