Spreadsheet Woes – Burden in SOX Compliance and Other Regulations

End User Computing (EUC) or end User Developed Application (UDA) systems like spreadsheets used to be ideal ad-hoc solutions for data processing and financial reporting. But those days are long gone.

Today, due to regulations like the:

  • Sarbanes-Oxley (SOX) Act,
  • Dodd-Frank Act,
  • IFRS (International Financial Reporting Standards),
  • E.U. Data Protection Directive,
  • Basel II,
  • NAIC Model Audit Rules,
  • FAS 157,
  • yes, there?s more ? and counting

a company can be bogged down when it tries to comply with such regulations while maintaining spreadsheet-reliant financial and information systems.

In an age where regulatory compliance have become part of the norm, companies need to enforce more stringent control measures like version control, access control, testing, reconciliation, and many others, in order to pass audits and to ensure that their spreadsheets are giving them only accurate and reliable information.

Now, the problem is, these control measures aren’t exactly tailor-made for a spreadsheet environment. While yes, it is possible to set up a spreadsheet and EUC control environment that utilises best practices, this is a potentially expensive, laborious, and time-consuming exercise, and even then, the system will still not be as foolproof or efficient as the regulations call for.

Testing and reconciliation alone can cost a significant amount of time and money to be effective:

  1. It requires multiple testers who need to test spreadsheets down to the cell level.
  2. Testers will have to deal with terribly disorganized and complicated spreadsheet systems that typically involve single cells being fed information by other cells in other sheets, which in turn may be found in other workbooks, or in another folder.
  3. Each month, an organisation may have new spreadsheets with new links, new macros, new formulas, new locations, and hence new objects to test.
  4. Spreadsheets rarely come with any kind of supporting documentation and version control, further hampering the verification process.
  5. Because Windows won’t allow you to open two Excel files with the same name simultaneously and because a succession of monthly-revised spreadsheets separated by mere folders but still bearing the same name is common in spreadsheet systems, it would be difficult to compare one spreadsheet with any of its older versions.

But testing and reconciliation are just two of the many activities that make regulatory compliance terribly tedious for a spreadsheet-reliant organisation. Therefore, the sheer intricacy of spreadsheet systems make examining and maintaining them next to impossible.

On the other hand, you can’t afford not to take these regulations seriously. Non-compliance with regulatory mandates can have dire consequences, not the least of which is the loss of investor confidence. And when investors start to doubt the management’s capability, customers will start to walk away too. Now that is a loss your competitors will only be too happy to gain.

Learn more about our server application solutions and discover a better way to comply with regulations.

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Disadvantages of Spreadsheets


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Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


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Why Spreadsheets can send the pillars of Solvency II crashing down

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Uncover hidden opportunities with energy data analytics

What springs to mind when you hear the words energy data analytics? To me, I feel like energy data analytics is not my thing. Energy data analytics, however, is of great importance to any organisation or business that wants to run more efficiently, reduce costs, and increase productivity. Energy efficiency is one of the best ways to accomplish these goals.

Energy efficiency is not about investment in expensive equipment and internal reorganization. Enormous energy saving opportunities is hidden in already existing energy data. Given that nowadays, energy data can be recorded from almost any device, a lot of data is captured regularly and therefore a lot of data is readily available.

Organisations can use this data to convert their buildings’ operations from being a cost centre to a revenue centre through reduction of energy-related spending which has a significant impact on the profitability of many businesses. All this is possible through analysis and interpretation of data to predict future events with greater accuracy. Energy data analytics therefore is about using very detailed data for further analysis, and is as a consequence, a crucial aspect of any data-driven energy management plan.

The application of Data and IT could drive significant cost savings in company-owned buildings and vehicle fleets. Virtual energy audits can be performed by combining energy meter data with other basic data about a building e.g. location, to analyse and identify potential energy savings opportunities. Investment in energy dashboards can further enable companies to have an ongoing look at where energy is being consumed in their buildings, and thus predict ways to reduce usage, not to mention that energy data analytics unlock savings opportunities and help companies to understand their everyday practices and operating requirements in a much more comprehensive manner.

Using energy data analytics can enable an organisation to: determine discrepancies between baseline and actual energy data; benchmark and compare previous performance with actual energy usage. Energy data analytics also help businesses and organisations determine whether or not their Building Management System (BMS) is operating efficiently and hitting the targeted energy usage goals. They can then use this data to investigate areas for improvement or energy efficient upgrades. When energy data analytics are closely monitored, companies tend to operate more efficiently and with better control over relevant BMS data.

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

How Bombardier Inc. scored a Bulls Eye

When travelling anywhere in the world on land, sea or air, chances are, you will travel courtesy of something made by aerospace and transportation company Bombardier based in Montreal, Canada. In 2009, it set itself the goal of carbon neutrality by 2020. In other words, it hoped to remove as much carbon dioxide from the atmosphere as it was putting in.

By 2012, Bombardier concluded it was not going to become carbon neutral by 2020 at its current rate of progress. It discounted purchasing carbon offsets because it believed it would serve its interests better by introducing new energy-saving products to market faster. That way, it would achieve its objectives vicariously through the decisions of its customers. But that was not all that forward-thinking Bombardier did. It also set itself the following inward-facing objectives:

  • Reduce carbon footprint through efficient use of energy and less emissions
  • Involve the Bombardier workforce to raise awareness of behaving responsibly
  • Implement sustainable initiatives to further reduce the company carbon footprint

Specific Examples

At its Wichita site, Bombardier (a) fitted a white roof and insulation reducing summer energy consumption by 40%, (b) added an energy recovery wheel to balance air circulation, and (c) introduced skylights with integrated controllers to lower energy consumption by lighting.

At Mirabel, it enhanced the flue-gas management system by adding a pressure differential damper.

At Belfast, Bombardier (a) optimised HVAC systems to reduce pressure on chilling and air-handling plants, (b) installed solar panels on the roof, and (c) obtained approval for a waste-to-energy plant that will convert 120,000 tonnes of non-recyclable waste material annually.

By the end of 2013, Bombardier had already beaten its immediate targets by:

  • Reducing energy consumption by 11% against 2009
  • Reducing greenhouse gas emission by 23% against 2009
  • Reducing water consumption by 6% against 2012

Future Plans

Bombardier will never stop striving to reach its goal of carbon neutrality by 2020. It has a number of other projects in the pipeline waiting for scarce resources to fund them. During 2014, it continued with energy efficient upgrades at its French, Hungarian, Polish, Swiss, and UK plants.

These include consumption monitoring systems, LEDs for workshop lighting, new heating systems, and outdoor energy-saving tower lighting. The monitoring is important because it helps Bombardier focus effort, and provides measured proof of progress.

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