How COBIT helps you achieve SOX Compliance

First released way back in 1996, COBIT has already been around for quite a while. One reason why it never took off was because companies were never compelled to use it ? until now. Today, many CEOs and CIOs are finding it to be a vital tool for achieving SOX compliance in IT.

Thanks to SOX, COBIT (Control Objectives for Information and related Technology) is now one of the most widely accepted source of guidance among companies who have IT integrated with their accounting/financial systems. It has also gained general acceptability with third parties and regulators. But how did this happen?

Role of control frameworks in SOX compliance

You see, the Sarbanes-Oxley Act, despite having clearly manifested the urgency of establishing effective internal controls, does not provide a road map for you to follow nor does it specify a yardstick to help you determine whether an acceptable mileage in the right direction has already been achieved.

In other words, if you were a CIO and you wanted to find guidance on what steps you had to take to achieve compliance, you wouldn’t be able to find the answers in the legislation itself.

That can be a big problem. Two of your main SOX compliance obligations as a CEO or CIO is to assume responsibility in establishing internal controls over financial reporting and to certify their effectiveness. After that, the external auditors are supposed to attest to your assertions. Obviously, there has to be a well-defined basis before you can make such assertions and auditors can attest to anything.

In the language of auditors, this ?well-defined basis? is known as a control framework. Simply put, once you certify the presence of adequate internal controls in your organisation, the external auditor will ask, ?What control framework did you use??

Knowing what control framework you employed will help external auditors determine how to proceed with their evaluations and tests. For your part, a control framework can serve as a guide to help you work towards specific objectives for achieving compliance. Both of you can use it as a common reference point before drawing any conclusions regarding your controls.

But there are many control frameworks out there. What should you use?

How SOX, COSO, and COBIT fit together

Fortunately, despite SOX?s silence regarding control frameworks, you aren’t left entirely to your own devices. You could actually take a hint from the SEC and PCAOB, two of the lead organisations responsible for implementing SOX. SEC and PCAOB point to the adoption of any widely accepted control framework.

In this regard, they both highly endorse COSO, a well-established internal control framework formulated by the Committee of Sponsoring Organisations of the Treadway Commission (COSO). Now, I must tell you, if you’re looking specifically for instructions pertaining to IT controls, you won’t find those in COSO either.

Although COSO is the most established control framework for enterprise governance and risk management you’ll ever find (and in fact, it’s what we recommend for your general accounting processes), it lacks many IT-related details. What is therefore needed for your IT processes is a framework that, in addition to being highly aligned with COSO, also provides more detailed considerations for IT.

This is where COBIT fits the bill.

How COBIT can contribute to your regulatory compliance endeavors

COBIT builds upon and adheres with COSO while providing a finer grain of detail focused on IT. You can even find a mapping between COBIT IT processes and COSO components within the COBIT document itself.

Designed with regulatory compliance in mind, COBIT lays down a clear path for developing policies and good practice for IT control, thus enabling you to bridge the gap between control requirements, technical issues, and business risks.

Some of the components you’ll find in COBIT include:

IT control objectives

These are statements defining specific desired results that, as a whole, characterise a well-managed IT process. They come in two forms for each COBIT-defined IT process: a high-level control objective and a number of detailed control objectives. These objectives will enable you to have a sense of direction by telling you exactly what you need to aim for.

Maturity models

These are used as benchmarks that give you a relative measurement stating where your level of management or control over an IT process or high-level control objective stands. It serves as a basis for setting as-is and to-be positions and enables support for gap analysis, which determines what needs to be done to achieve a chosen level. Basically, if a control objective points you to a direction, then its corresponding maturity model tells you how far in that direction you’ve gone.

RACI charts

These charts tell you who (e.g. CEO, CFO, Head of Operations, Head of IT Administration) should be Responsible, Accountable, Consulted, and Informed for each activity.

Goals and Metrics

These are sets of goals along with the corresponding metrics that allow you to measure against those goals. Goals and metrics are defined in three levels: IT goals and metrics, which define what business expects from IT; process goals and metrics, which define what the IT process should deliver to support It’s objectives; and activity goals and metrics, which measure how well the process is performing.

In addition to those, you’ll also find mappings of each process to the information criteria involved, IT resources that need to be leveraged, and the governance focus areas that are affected.

Everything is presented in a logical and manageable structure, so that you can easily draw connections between IT processes and business goals, which will in turn help you decide what appropriate governance and control is needed. Ultimately, COBIT can equip you with the right tools to maintain a cost-benefit balance as you work towards achieving SOX compliance.

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Spreadsheet Fraud

To any company executive or business owner, the mere possibility of fraud can be enough to send alarm bells ringing – for good reason. In a prolonged recession, the last thing investors would want to discover is a huge, gaping hole where supposedly a neat profit should have been. Also to find out that such loss was brought about by deliberately falsified accounting and poor spreadsheet controls only makes the situation even more regrettable.

Why?

Because these losses would not have occurred had there been a stronger risk management program in place and more stringent quality control on critical data to begin with.

But given the nature of a spreadsheet system i.e. its sheer flexibility and easy accessibility, plus the fact that they were never intended to be enterprise-level tools, there are no hard and fast rules for auditing spreadsheets. Also because of the lack of internal controls for end user computing (EUC) applications, in this case spreadsheets, you can’t expect these systems to yield consistently accurate results.

In fact, most managers assume that major spreadsheet errors should result in figures that are blatantly out of touch with how things stand in the real world, making these errors easily detectable.

Well they assumed wrong. You’ll find cases where the losses ran to millions of dollars without anyone being the wiser.

In instances of fraud, the problem becomes more complicated as these errors are deliberately hidden and cleverly disguised, perhaps one erroneous cell at a time. Even if these cover-ups started out with smaller figures that may have had negligible impact on a company?s operation, the cumulative costs of these ?insignificant? errors multiply exponentially as the spreadsheets are reused and utilised as bases for other related reports.

While there is no generally accepted definition of the term ?spreadsheet fraud?, its quite easy to identify one when a case crops up. Fraud arising from spreadsheets are typically characterised by:

Fallacious inputs – correct figures are deliberately replaced with false values.

Erroneous outputs owing to data alteration – hyperlinks are linking to the wrong spreadsheets or cells; use of macros or special lines of code which are understandable only to the person who developed the code.

Concealment of critical information – can be done with easy ?tweaks? such as hidden rows and columns, using the same colour for both the font and the background, or hard coding additional values into a cell.

There is nothing really highly-sophisticated or technical in any of these methodologies. But without internal spreadsheet controls in place, it would take a discerning eye and a thorough review to catch the inconsistencies contained in a spreadsheet fraught with errors. Also, if these errors are knowingly placed there, the chances of finding them are close to nil.

Learn more about our server application solutions and discover a better way to protect your company from spreadsheet fraud.

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Spreadsheet woes – ill equipped for an Agile Business Environment


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Spreadsheet woes – Burden in SOX Compliance and other Regulations


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What is Business Intelligence?

How well do you know your customers? That is, can you actually pinpoint which among them are you most profitable with and which are making you spend more? Are you content with the accuracy of your forecasts and market predictions? Do you feel you’re spending more on legal costs and regulatory compliance than you should?

Your IT department may be handling these concerns pretty well but perhaps you’d like to know how you can further improve things.

What we’ve got is an IT solution wrapped in a fancy name called ‘Business Intelligence’ or BI. If you think that’s too strong a term, we invite you to read more below, then you be the judge.

Dashboards – Determine the health of your business at a glance

Most drivers rarely make use of their car’s dashboard. After all, you can still reach your destination by just using the steering wheel, pedals, gear stick and so on. But that’s not exactly the most efficient way to drive, right?

If you want to save on fuel, you’ll want to glance on the RPM and speedometer from time to time. You might also want to utilise the trip meter to determine which route is the shortest to a given destination. Other dashboard components like the fuel gauge, tire pressure gauge, engine temperature indicator, and volt meter can likewise provide information about your car’s health.

The same concept applies to business management. If you want to run your business intelligently, you can make use of BI dashboards. These are tools in a typical business intelligence package that will allow you to determine the health of your business via a set of smartly configured gauges and other intuitive graphical representations.

So that, literally, at a mere glance, you’ll already know whether various units in your company are working efficiently. A dashboard will also give you instant feedback of the strategies you’ve recently implemented; to let you know if things are working as planned.

If you want more information than a dashboard can provide, our BI packages also include highly customised reports.

Reports that help you decide faster

Dashboards are great for getting valuable information at a glance but they won’t tell you everything. For more details, you’ll need to view highly customised reports. Our reports are tailor made for each user. We see to it that, by default, each person gets the information he needs the most.

If you belong to the sales department, you normally won’t need a presentation of the data that is appropriate for people in accounting. That way, you don’t spend time filtering. Instead, you and your people can move on to making well-informed decisions.

Our BI systems make use of your vast collection of data to provide reports that will organise your regulatory requirements and call your attention to approaching deadlines. The same system will provide the right information for your people on the field. If your team members are equipped with smart phones and Pocket PCs, they can retrieve whatever it is they need to know to close deals, make sales, and serve clients faster than the competition.

Generating logical information from disparate sources of data scattered over an enterprise-wide organisation is no easy task. But we’ll make it look simple. That’s because we’ve got the expertise to bring it all together into a robust data warehouse and to extract them in the form of reports and dashboards through OLAP.

OLAP and Data Warehousing – Powering the generation of actionable information

Want to know how to generate reports with the highest degree of accuracy and reliability? In theory, what you need is a single repository or a data warehouse. That is, order receipts, sales invoices, as well as customer & supplier data is integrated with regulatory details, personnel data, and others. These are all specially organised for future reporting and analysis.

However, data, no matter how all-embracing, is useless until it is processed into actionable information. Through OLAP or Online Analytical Processing, you can seamlessly collect all relevant data from your vast repository to answer queries like “What is our company’s profitability for the 2nd quarter in all identified key cities for our top-of-the-line products?”.

The strength of OLAP lies in its inherent ability to perform data analysis and very complex calculations, thus enabling it to return complex queries much faster than other database technologies. It is therefore suitable for very large data sources, i.e., data warehouses.

Dashboards and reports will only give your organisation the edge if the information retrieved is reliable, fast, and accurate – exactly the kind OLAP is so good at.

Mobile BI – Step back and see the big picture anytime, anywhere

Spreadsheets are great for displaying detailed information. However, in today’s highly competitive market, retrieving information that matters the most in the shortest possible time is vital in maintaining a sizeable lead over the competition. To step back and see the big picture, you’ll need insightful tools like dashboards and automatically generated reports.

Reports can be beamed to mobile devices such as smart phones and Pocket PCs. They can also be viewed on eBook readers as well. You can also do the same tasks with spreadsheets. But imagine how you’d need to scroll over a large spreadsheet on any of these mobile devices just to know which customer in your current location has performed well over the last month.

If you really want to make quick, well-informed decisions, BI dashboards for mobile devices is the way to go. You can make use of various business objects such as drill-able charts, performance metrics, and metric trend graphs to make crucial decisions even when on you’re in the field.

A Small External Enterprise Development Team is Cheaper than Your Own

Time is money in the application development business. We have to get to market sooner so someone else does not gazump us, and pip us at the post. We increase the likelihood of this with every delay. Moreover, the longer your in-house team takes to get you through the swamp, the higher the project cost to you.

Of course, in theory this should not be the case. Why bring in a team from outside, and pay more to support their corporate structure? Even going for a contract micro team ought not to make financial sense, because we have to fund their mark-up and their profit taking. Our common sense tells us that this is crazy. But, hold that thought for a minute. What would you say if a small external enterprise development team was actually cheaper? To achieve that, they would have to work faster too.

The costs of an Enterprise Internal Development Team

Even if you were able to keep your own team fully occupied ? which is unlikely in the long term ? having your own digital talent pool works out expensive when you factor in the total cost. Your difficulties begin with the hiring process, especially if you do not fully understand the project topic, and have to subcontract the hiring task.

If you decide to attempt this yourself, your learning curve could push out the project completion date. Whichever way you decide to go, you are up for paying advertising, orientation training, technical upskilling, travel expenses, and salaries all of which are going to rob your time. Moreover, a wrong recruitment decision would cost three times the new employee?s annual salary, and there is no sign of that changing.

But that is not all, not all by far. If want your in-house team to keep their work files in the office, then you are going to have to buy them laptops, plus extra screens so they can keep track of what they are doing. Those laptops are going to need desks, and those employees, chairs to sit in. Plus, you are going to need expensive workspace with good security for your team?s base.

If we really wanted to lay it on, we would add software / cloud costs, telephony, internet access, and ongoing technical training to the growing pile. We did a quick scan on PayScale. The median salary of a computer programmer in Ireland is ?38,000 per year and that is just the beginning. If you need a program manager for your computer software, their salary will be almost double that at ?65,000 annually.

Advantages of R&D outsourcing

The case for a small externally sourced enterprise development team revolves around the opportunity cost ? or loss to put in bluntly ? of hiring your own specialist staff for projects. If you own a smaller business with up to 100 people, you are going to have to find work for idle digital fingers, after you roll out your in-house enterprise project. If you do not, you head down the road towards owning a dysfunctional team lacking a core, shared objective to drive them forward.

Compared to this potential extravagance, hiring a small external enterprise development team on an as-needed basis makes far more sense. Using a good service provider as a ?convenience store? drives enterprise development costs down through the floor, relative to having your own permanent team. Moreover, the major savings that arise are in your hands and free to deploy as opportunities arise. A successful business is quick and nimble, with cash flow on tap for R & D.

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