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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Benefits of Integrating IoT and Field Service

Owing to the complexity of its definition, many people loosely use the phrase Internet of Things (IoT) without having a solid grasp of its true meaning. A majority in this category take IoT to be nothing more than the automation of home gadgets, where the internet is used to interconnect computing components embedded in everyday devices.

Granted, the whole idea of IoT got its roots from the home setting. Nevertheless, IoT has outgrown that spectrum and has since penetrated into almost every area of business and industry. By employing IoT, you can literally take full control of everything in your business using a single device. From assigning tasks to monitoring security, managing bills to tracking time, IoT has revolutionized the way business is done.

Interestingly, not so long ago, most technology experts limited their forecasts to machine-to-machine (M2M) integration and Augmented Reality (AR), which also, admittedly, hit the technology industry with an admirable suave. Back then, it could have been laughable for anyone to have suggested that IoT would be so commanding in almost every industry, including real estate, medicine, automobile, and more.

It’s not for nothing, therefore, that the field service industry has also embraced IoT, integrating it in the daily running of business activities, including tracking machine diagnostics, detecting breakdowns, and assigning field engineers to attend to customer needs.

How the Field Service Industry is Benefiting from IoT

Machine uptime has remained an ongoing concern for many customers. In the traditional approach, whenever a machine breaks down, the customer alerts the service provider and then the field service manager checks to see if there is any field engineer available for a new task. Once an engineer has been identified, he?s then dispatched to the site. This worked, but it resulted in an extended machine downtime, a terrible experience for customers.

Thanks to IoT, things are now happening differently.

IoT is now integrating machines to a central communications centre, where all alerts and status updates are sent. The notifications are instant. The field service manager, therefore, gets to learn of the status of machines at the exact time of status change. An engineer who?s not engaged would then be immediately assigned to undertake any needed servicing or repair.

By employing IoT, the service provider receives timely reports relating to diagnostics, machine uptime, part failures, and more. The field manager can, as a result, foretell and forestall any possible downtime.

How has this been helpful?

Before giving a definite answer to that question, it’s crucial to note that more than half of all field service organizations now employ IoT in their Asset Management Systems and Field Service Management. And to answer the question, all the organizations that have the two systems integrated using IoT experience twice as much efficiency as those that don’t, states an Aberdeen Group report. As you already know, improved efficiency results in a corresponding upshot in customer satisfaction.

Apps Making a Difference in IoT-Field Service

The integration of IoT into almost every aspect of business prompted the design and development of different applications to link computing devices. Since the advent of IoT, the software development for the technology has come of age. Powerful and lightweight apps that don simple yet beautiful user interfaces are now readily available at affordable price tags.

A good example of such an App is ecoVaro by Denizon.

ecoVaro not only helps businesses to monitor energy and other relevant environmental data such as Electricity, Gas, Water, Oil, Carbon, Temperature, Humidity, Solar Power, and more, but also provides analytics and comprehensive yet easy to understand reports. The data received from devices such as meters is converted into useful information that’s then presented in figures and graphs, thus allowing you to make decisions based on laid down controls.

The focus of the app is to instantly alert service engineers to go on site to fix issues.

With ecoVaro, field service engineers no longer have to return to the office to get new instructions. Also, customers don’t have to manually fire alerts to the service provider whenever something isn’t working correctly. By employing the latest in IoT, ecoVaro sends notifications to field service managers and engineers about respective customers that need support.

How ecoVaro Helps

Best-in-class companies aren’t ready to compromise on customer satisfaction. Therefore, every available avenue is used to address customer concerns with the deserved agility. By using IoT, ecoVaro makes it possible for field service providers to foresee and foreclose any possible breakdowns.

The inter-connectivity among the devices and the central communications centre results in increased revenue and improved interactivity between the system and the field engineers. This results in greater efficiency and lower downtime, which translates into improved productivity, accountability, and customer satisfaction, as well as creating a platform for a possible expansion of your customer base.

ecoVaro isn’t just about failed machines and fixes. It also provides diagnostics about connected systems and devices. With this, the diagnostics centre receives system reports in a timely manner, allowing for ease of planning and despatch of field officers where necessary.

Clearly, but using the right application, IoT can transform your business into an excellently performing field service company.

Using Pull Systems to Optimise Work Flows in Call Centres

When call centres emerged towards the end of the 20^th century, they deserved their name ?the sweatshops of the nineties?. A new brand of low-paid workers crammed into tiny cubicles to interact with consumers who were still trying to understand the system. Supervisors followed ?scientific management? principles aimed at maximising call-agent activity. When there was sudden surge in incoming calls, systems and customer care fell over.

The flow is nowadays in the opposite direction. Systems borrowed from manufacturing like Kanban, Pull, and Levelling are in place enabling a more customer-oriented approach. In this short article, our focus is on Pull Systems. We discuss what are they, and how they can make modern call centres even better for both sets of stakeholders.

Pull Systems from a Manufacturing Perspective

Manufacturing has traditionally been push-based. Sums are done, demand predicted, raw materials ordered and the machines turned on. Manufacturers send out representatives to obtain orders and push out stock. If the sums turn out wrong inventories rise, and stock holding costs increase. The consumer is on the receiving end again and the accountant is irritable all day long.

Just-in-time thinking has evolved a pull-based approach to manufacturing. This limits inventories to anticipated demand in the time it takes to manufacture more, plus a cushion as a trigger. When the cushion is gone, demand-pull spurs the factory into action. This approach brings us closer to only making what we can sell. The consumer benefits from a lower price and the accountant smiles again.

Are Pull Systems Possible in Dual Call Centres

There are many comments in the public domain regarding the practicality of using lean pull systems to regulate call centre workflow. Critics point to the practical impossibility of limiting the number of incoming callers. They believe a call centre must answer all inbound calls within a target period, or lose its clients to the competition.

In this world-view customers are often the losers. At peak times, operators can seem keen to shrug them off with canned answers. When things are quiet, they languidly explain things to keep their occupancy levels high. But this is not the end of the discussion, because modern call centres do more than just take inbound calls.

Using the Pull System Approach in Dual Call Centres

Most call centre support-desks originally focused are handling technical queries on behalf of a number of clients. When these clients? customers called in, their staff used operator?s guides to help them answer specific queries. Financial models?determined staffing levels and the number of ?man-hours? available daily. Using a manufacturing analogy, they used a push-approach to decide the amount of effort they were going to put out, and that is where they planted their standard.

Since these early 1990 days, advanced telephony on the internet has empowered call centres to provide additional remote services in any country with these networks. They have added sales and marketing to their business models, and increased their revenue through commissions. They have control over activity levels in this part of their business. They have the power to decide how many calls they are going to make, and within reason when they are going to make them.

This dichotomy of being passive regarding incoming traffic on the one hand, and having active control over outgoing calls on the other, opens up the possibility of a partly pull-based lean approach to call centre operation. In this model, a switching mechanism moves dual trained operators between call centre duties and marketing activities, as required by the volume of call centre traffic, thus making a pull system viable in dual call centres.

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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.