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


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How SOA can help Transformation

Undoubtedly, today’s business leaders face myriad challenges ranging from fierce market competition to increasing market unpredictability. In addition, the modern consumer is more informed and in control of what, where and how they purchase. Couple these challenges with effects of globalization, and you will appreciate that need for business transformation is more of a necessity than a privilege.

As recent business trends show, top companies are characterized by organizational and operational agility. Instead of being shaken by rapid technological changes and aftershocks associated with market changes, they are actually invigorated by these trends. In order to survive in these turbulent times, business leaders are opting to implement corporate transformation initiatives to develop leaner, more agile and productive operations. In line with this, service oriented architecture (SOA) has emerged as an essential IT transformation approach for implementing sustainable business agility.

By definition, service oriented architecture is a set of principles and techniques for developing and designing software in form of business functionalities. SOA allows users to compile together large parts of functionality to create ad hoc service software entirely from the template software. This is why it is preferred by CIOs that are looking to develop business agility. It breaks down business operations into functional components (referred to as services) that can be easily and economically merged and reused in applicable scenarios to meet evolving business needs. This enhances overall efficiency, and improves organizational interconnectivity.

SOA identifies shortcomings of traditional IT transformation approaches that were framed in monolithic and vertical silos all dependent on isolated business units. The current business environment requires that individual business units should be capable of supporting multiple types of users, multiple communication channels and multiple lines of business. In addition, it has to be flexible enough to adapt to changing market needs. In case one is running a global business enterprise, SOA-enabled business transformation can assist in achieving sustainable agility and productivity through a globally integrated IT platform. SOA realizes its IT and business benefits by adopting a design and analyzing methodology when developing services. In this sense a service consists of an independent business unit of functionality that is only available through a defined interface. Services can either be in the form of nano-enterprises or mega-enterprises.

Furthermore, with SOA an organization can adopt a holistic approach to solve a problem. This is because the business has more control over its functions. SOA frees the organization from constraints attributed to having a rigid single use application that is intricately meshed into a fragmented information technology infrastructure. Companies that have adopted service oriented architecture as their IT transformation approach, can easily repurpose, reorganize and rescale services on demand in order to develop new business processes that are adaptable to changes in the business environment. In addition, it enables companies to upgrade and enhance their existing systems without incurring huge costs associated with ‘rip and replace’ IT projects.

In summary, SOA can be termed as the cornerstone of modern IT transformation initiatives. If properly implemented great benefits and a sharp competitive advantage can be achieved. SOA assists in transforming existing disparate and unconnected processes and applications into reusable services; creating an avenue where services can be rapidly reassembled and developed to support market changes.

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Will UK Retailers Skim the Cream with ESOS?

The British Retail Consortium (BRC) was quick out on the starting blocks with an ambitious plan to cut energy costs by 25% in 5 years. Their ?25-in-5? initiative is chasing a target of ?4.4 billion savings during the duration. Part of this program involves ?cutting a path through a complex and inaccessible policy landscape?. BRC believes this drawback is making its members think twice about making energy efficiency investments.

The UK?s sprawling network of grocers, department stores and malls is the nation?s second most hungry energy customer, having spent ?3.3 billion on it in 2013 when it accounted for almost 20% of carbon released. If you think that sounds bad, it purchased double that amount in 2005. However the consortium believes there is still more to come.

It bases this assumption on the push effect of UK energy rates increasing by a quarter during the duration of the project. ?So it makes sense to be investing in energy efficiency rather than paying bills,? Andrew Bolitho (property, energy, and transport policy adviser) told Business Green. The numbers mentioned exclude third party transport and distribution networks not under the British Retail Consortium umbrella.

The ?complex and inaccessible policy landscape? is the reflection of UK legislators not tidying up as they go along. BRC cites a ?vast number of policies ? spreading confusion, undermining investment and making it harder to raise capital?. The prime culprits are Britain?s CRC Energy Efficient Scheme (previously Carbon Reduction Commitment) which publishes league tables and ESOS. Andrew Bolitho believes this duality is driving confused investors away.

The British Retail Consortium is at pains to point out that this is not about watering things down, but making it simpler for participating companies to report on energy matters at a single point. It will soon go live with its own information hub providing information for retailers wishing to measure consumption at critical points, assemble the bigger picture and implement best practice.

Ecovaro agrees with Andrew Bolitho that lowering energy demand and cutting carbon is not just about technology. We can do much in terms of changing attitudes and providing refresher training and this does not have to cost that much. Studies have shown repeatedly that there is huge benefit in inviting employees to cross over to our side. In fact, they may already be on board to an extent that may surprise.

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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