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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The Matrix Management Structure

Organizations exploit matrix management in various ways. A company, for instance, that operates globally uses it at larger scale by giving consistent products to various countries internationally. A business entity, having many products, does not assign its people to each product full-time but assign those to different ones on a part time basis, instead. And when it comes to delivering high quality and low cost products, companies overcome industry pressures with the help of many overseeing managers. In a rapidly changing environment, organizations respond quickly by sharing information through a matrix model.

Understanding the Matrix Management Structure

A basic understanding of matrix management starts with the three key roles and responsibilities that applies in the structure.

  • Matrix Leader ? The common person above all the matrix bosses is the matrix leader. He ensures that the balance of power is maintained in the entire organization by delegating decisions and promoting collaboration among the people.
  • Matrix Managers ? The managers cooperate with each other by defining the respective activities that they are responsible for.
  • Matrix Employees – The employees have lesser direct authority but has more responsibilities. They resolve differing demands from more than one matrix managers while they work things out upwards. Their loyalty must be dual and their relationships with managers must be maintained.

Characteristics of a Matrix Structure

Here are some features that define the matrix management structure:

  • Hybrid Structure ?The matrix structure is a mix of functional and project organization. Since it is a combination of these two, matrix management is hybrid in nature.
  • Functional Manager ? When it comes to the technical phases of the project, the functional manager assumes responsibility. The manager decides on how to get the project done, delegates the tasks to the subordinates and oversees the operational parts of the organization.
  • Project Manager ? The project manager has full authority in the administrative phases, including the physical and financial resources needed to complete the project. The responsibilities of a project manager comprise deciding on what to do, scheduling the work, coordinating the activities to diverse functions and evaluating over-all project performance.
  • Specialization ?As the functional managers concentrate on the technical factors, the project managers focus on administrative ones. Thus, in matrix management, there is specialization.
  • Challenge in Unity of Command ? Companies that employs matrix management usually experience a problem when it comes to the unity of command. This is largely due to the conflicting orders from the functional and project managers.

Types of Matrix Structure

The matrix management structure can be classified according to the level of power of the project manager. Here are three distinct types of matrix structures that are widely used by organizations.

  • Weak Matrix ? The project manager has limited authority and power as the functional manager controls the budget of the project. His role is only part-time and more like a coordinator.
  • Strong Matrix ? Here, the project manager has almost all the authority and power. He controls the budget, holds the full time administrative project management and has a full time role.
  • Balanced Matrix ? In this structure type, both the project and functional managers control the budget of the project. The authority and power is shared by the two as well. Although the project manager has a full time role, he only has a part time authority for the administrative staff to report under his leadership.

Successful companies of today venture more on enhancing the abilities, skills, behavior and performances of their managers than the pursuit of finding the best physical structure. Indeed, learning the fundamentals of the matrix structure is essential to maximize its efficiency. A senior executive pointed out that one of the challenges in matrix management is not more of building a structure but in creating the matrix to the mind of the managers. This comes to say that matrix management is not just about the structure, it is a frame in the mind.

The Future is Smarter with a Smart Meter

Traditionally, electricity and water meter consumption was measured via analogue meters. Utility billing was based on actual consumption units obtained from the meter by meter readers. This entailed physical visits to the metering point. Lots of challenges came with meter reading; talk of customers feeling their privacy is intruded, meter readers encountering hostile customers, dogs, closed gates. The result was estimated bills that were most often than not very high.

Smart meters can be dubbed as the ?next generation? type of meters. Smart meters send wireless electronic meter readings to one?s energy supplier automatically. There are both gas smart meters and electricity smart meters. Smart meters come with in-home displays, which give someone real-time feedback on their energy usage and the associated cost.

Smart meters communicate meter readings directly to utility companies therefore no one has to come to your home to read your meter; and neither are you required to submit meter readings yourself. This not only reduces costs, but leads to more accurate electricity bills practically eliminating estimated bills. Smart meters signal the end of estimated bills, and the end of overpaying or underpaying for energy.

Whereas a smart meter in itself does not save you money, the add-ons (in-home displays) that come with the smart meters and which give someone real-time feedback on their energy usage helps them to reduce the unnecessary energy use and this ultimately leads to better oversight into how to lower utility bills hence better management of one?s energy use.

In summary, a smart meter is a technology that enables energy consumers to see their energy as they use it, a technology where energy is displayed as it is being used and wireless ratings sent. Adoption of smart meters would mean the end of estimated energy bills.

Smart meters are also promising a smart future where all energy consuming devices can be connected to the internet and centrally controlled using computers or smartphones. This means one is able to switch off lights and other energy consuming devices from a central point, hence make savings and this will enable them to have greater control of their energy use, hence more comfort, convenience and life will be cheaper for all. This is the smarter future we are all looking forward to.

Quality Assurance

 

There is a truism that goes “The bitterness of poor quality is remembered long after the sweetness of low price has faded from memory”.

While every consumer can probably relate to this idea, business enterprises offering goods and services are the ones that should heed this the most.

Quality Management Systems

The concept of quality was first introduced in the 1800’s. Goods were then still mass-produced, created by the same set of people, with a few individuals assigned to do some “tweaking” on the product to bring it to acceptable levels. Their idea of quality at that time may not have been that well-defined, but it marked the beginnings of product quality and customer satisfaction as we know it now.

Since then, quality has developed into a very basic business principle that every organisation should strive to achieve. Yet while every business recognises the importance of offering product and service quality, it is not something that can be achieved overnight.

If you’ve been in any type of business long enough, you should know that there is no “quick-fix” to achieving quality. Instead, it is an evolving process that needs to be continually worked on. And this is where the importance of having a workable Quality Management System (QMS) in an organisation comes in.

Whatever Quality tools and processes you need to implement the change needed in your organisation, we can help you with it. We are ready to work in partnership with your team to develop strategic systems which will produce significant performance improvements geared towards the achievement of quality.

What is a Quality Management System?

A Quality Management System is defined as the set of inter-related objectives, processes, and operating procedures that organisations use as a guide to help them implement quality policies and attain quality objectives.

Needless to say, the ultimate goal of every quality management system is to establish quality as a core value of the company among all employees, and across all products and services. Why? Because quality services make for happy customers, and satisfied customers ensure continued business for the company.

A Quality Management System does not stop with simply having a set of guidelines that the leaders of a company can easily have their organisation members accept and adhere to. Rather, effective QMS can be implemented when management provides a culture of pride and patience, which will inspire acceptance of individual and group responsibility.

In this manner, not only the heads of the organisation but the employees as well, will develop the desire to achieve company goals that will benefit:

  • All contributing teams;
  • The customers; and
  • The company as a whole.

Find out more about our Quality Assurance services in the following pages:

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