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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Vendor Selection

When shopping for an IT solution for your enterprise, there are two things you should scrutinise: the product (or service) itself and its vendor. Many times, companies overlook the importance of the latter, giving the reason that “it’s only the product we need”.

Wrong.

What about after-sales technical support and training? Ok, so you have an in-house team with the required competency for that IT solution in question… not that I believe it’s reasonable basis to pass up on the expertise that the vendor can provide. How about upgrades, patches, and documentation?

Still unperturbed? Here’s one factor that you may not have started to consider – What happens to your product if the vendor goes bankrupt or gets swallowed by a merger and acquisition? Surely, you no longer believe this is far from possible, do you?

But how are you supposed to know the financial stability of each vendor or whether it is an acquisition target? Well, you can either conduct your own research or you can leave that up to us. Part of our job includes not only establishing linkages in the industry but also being in-the-know on such relevant information.

Evaluation of Business Needs

You can’t separate vendor selection from the process of choosing the desired IT tool. That’s why our vendor selection services starts by defining exactly what your business needs are.

Once we’ve pinned down your needs, we can then narrow down the list of possible IT solutions. Only then can we proceed with the main vendor selection process.

Have you ever been caught in a situation wherein you thought you knew what you wanted, only to end up realising it’s not what you were looking for after all? We’re here to make sure you don’t get caught in that kind of situation when choosing an enterprise-class IT solution.

With the TCO (total cost of ownership) of such solutions typically running up to hundreds of thousands of euros, you can’t afford to arrive at what you really want by way of trial and error.

These are the things you stand to benefit the moment we start working with you:

  • Thorough assessment of your IT needs. We’ll consult the people in your organisation who’ll be affected the most in order to obtain a clear picture of what your specific needs really are. Most IT solution purchases are made with very little consultation that, after installation, many of the end users don’t benefit at all.
  • Minimal interruption during assessment. As with all our other services, we see to it that the interruptions we make are absolutely necessary. So the moment we start with our work, you can still continue with yours.
  • Insightful suggestions of the required IT solution. You still know your business better. So even after we’ve gone through the assessment and given our recommendations, the decision as to what IT tool should be pursued will still be up to you. The difference now is, you’ll be making a decision based on expertly gathered information put forward in an insightful proposal.

Request and Evaluation of Vendor Proposals

With so many IT solutions companies mushrooming, it is becoming more difficult to keep track of them, their specialities, strengths, and weaknesses.

Companies selling best-of-breed products may be relatively easy to spot. But there are also other attributes that are equally important but not as well publicised. For instance, which companies offer better quality management philosophies? Which companies have strategic visions running parallel to yours? Which of them possess implementation capabilities that can cater to your rapidly growing IT requirements?

Vendors who answer positively to these queries need to be given the appropriate importance in the selection process. We see to it that these and other relevant attributes are factored into our scorecards and evaluation processes.

These are the things you can look forward to when you grant us the opportunity to serve you.

  • Experience is a vital item in our vendor selection criteria. Our vast knowledge of the reliable players in the industry will lead you to experienced vendors who can hit the ground running from day one and continue with the same vigour onward.
  • We can help you draw positive response for each of your Request For Proposals (RFPs) or Request For Information (RFIs). Did you expect these vendors to be enthusiastic in sending out proposals each time you asked them to? Think again. You’ll have to persuade them first of your sincerity to become a potential customer. With our help, your RFPs will make preferred vendors see “opportunity” written all over.
  • No need to go “Eany, meeny, miny, moe”. Deciding which vendors should move up in the selection process can take up a lot of time if you don’t know which criterion should be given more weight. Our scorecards are designed to collect the most relevant information and to generate results that will help you decide on these matters at a glance.

Interview, Negotiation, and Monitoring

As soon as you start getting positive response to your Request For Proposals, the interview process should be next. It’s at this point that vendors can present and highlight their strengths while we try to glean as much information of their true capabilities as well as their dedication to the project.

Some companies can provide proof-of-concepts and we may require them as part of the interview process. This will not only give us a better idea as with regards to their product’s capabilities, but also to their level of expertise on the solution in question.

  • We’ll help you set up the interview process and organise the evaluation committee. Members of the committee will typically include representatives from each department that will be affected by the new technology, which we would have already identified during our Evaluation of Business Needs.
  • Since our scorecards are designed to expedite the filtering and selection process, you may eventually be able to choose the finalists yourself. However, in the event that two or more vendors turn out evenly matched, we’ll help you identify the better company.
  • We’re very familiar with the price ranges of various IT solutions, including the effects on price of certain variables. As such, we can tell you whether a product’s price tag is justified or not.
  • Our exceptional familiarity on both the IT industry and the entire negotiation processes itself will give you the edge when it’s time for us to haggle for the best bang for the buck.
  • After the contract is awarded, we’ll even be on hand to monitor whether deliverables are handed over and milestones are achieved as promised.
Finding the Best Structure for Your Enterprise Development Team

An enterprise development team is a small group of dedicated specialists. They may focus on a new business project such as an IoT solution. Members of microteams cooperate with ideas while functioning semi-independently. These self-managing specialists are scarce in the job market. Thus, they are a relatively expensive resource and we must optimise their role.

Organisation?Size and Enterprise Development Team Structure

Organisation structure depends on the size of the business and the industry in which it functions. An enterprise development team for a micro business may be a few freelancers burning candles at both ends. While a large corporate may have a herd of full-timers with their own building. Most IoT solutions are born out of the efforts of microteams.

In this regard, Bill Gates and Mark Zuckerberg blazed the trail with Microsoft and Facebook. They were both college students at the time, and both abandoned their business studies to follow their dreams. There is a strong case for liberating developers from top-down structures, and keeping management and initiative at arm?s length.

The Case for Separating Microteams from the?Organisation

Microsoft Corporation went on to become a massive corporate, with 114,000 employees, and its founder Bill Gates arguably one of the richest people in the world. Yet even it admits there are limitations to size. In Chapter 2 of its Visual Studio 6.0 program it says,

‘today’s component-based enterprise applications are different from traditional business applications in many ways. To build them successfully, you need not only new programming tools and architectures, but also new development and project management strategies.?

Microsoft goes on to confirm that traditional, top-down structures are inappropriate for component-based systems such as IoT solutions. We have moved on from ?monolithic, self-contained, standalone systems,? it says, ?where these worked relatively well.?

Microsoft’s model for enterprise development teams envisages individual members dedicated to one or more specific roles as follows:

  • Product Manager ? owns the vision statement and communicates progress
  • Program Manager ? owns the application specification and coordinates
  • Developer ? delivers a functional, fully-complying solution to specification
  • Quality Assurer ? verifies that the design complies with the specification
  • User Educator ? develops and publishes online and printed documentation
  • Logistics Planner ? ensures smooth rollout and deployment of the solution

Three Broad Structures for Microteams working on IoT Solutions

The organisation structure of an enterprise development team should also mirror the size of the business, and the industry in which it functions. While a large one may manage small microteams of employee specialists successfully, it will have to ring-fence them to preserve them from bureaucratic influence. A medium-size organisation may call in a ?big six? consultancy on a project basis. However, an independently sourced micro-team is the solution for a small business with say up to 100 employees.

The Case for Freelancing Individuals versus Functional Microteams

While it may be doable to source a virtual enterprise development team on a contracting portal, a fair amount of management input may be necessary before they weld into a well-oiled team. Remember, members of a micro-team must cooperate with ideas while functioning semi-independently. The spirit of cooperation takes time to incubate, and then grow.

This is the argument, briefly, for outsourcing your IoT project, and bringing in a professional, fully integrated micro-team to do the job quickly, and effectively. We can lay on whatever combination you require of project managers, program managers, developers, quality assurers, user educators, and logistic planners. We will manage the micro-team, the process, and the success of the project on your behalf while you get on running your business, which is what you do best.

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Green Business!

Carbon emissions reduction has evolved beyond simply good citizenship to being a business tool. Implementing ?green? initiatives is now a competitive weapon which defines real business opportunities and bottom line savings that can contribute significant financial value to the organisation while meeting demanding customer requirements for sustainable and low-carbon products.

Energy efficiency is a low cost resource for achieving carbon emissions reduction. Better energy efficiency simply translates to lesser carbon emissions and less energy usage which translates into saved costs.

Reduction of an organisations carbon footprint is each and everyone?s responsibility. Human activities are the key responsibility for the release of greenhouse gas emissions into the atmosphere. These include usage of electricity generated from fossil fuel, heating or driving.

At the corporate level, various measures can be instigated to increase energy efficiency. Some of these can be, having zone lighting with sensors to minimise unnecessary office lighting, timers on large IT equipment, promoting energy efficient behaviour in the office, asking staff to switch off and unplug appliances when not in use and minimising staff travel.
At the individual level; it is the small habits that count; cultivating the habit of switching off unnecessary lights, plugging out appliances that are not in use, using video conferencing or online chatting instead of having to travel to meetings, using public transport instead of taking a taxi/ personal car and using energy efficient cars.

All these initiatives assist organisations in their corporate social responsibility reports and play a role in sustainability rankings which is instrumental to customers who are increasingly considering sustainability rankings in investment decisions, while achieving the goal of cost reduction internally.

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