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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Are Master Data Management and Hadoop a Good Match?

Master Data is the critical electronic information about the company we cannot afford to lose. Accordingly, we should sanitise it, look after it, and store it safely in several separate places that are independent of each other. The advent of Big Data introduced the current era of huge repositories ?in the clouds?. They are not, of course but at least they are remote. This short article includes a discussion about Hadoop, and whether this is a good platform to back up your Master Data.

About Hadoop

Hadoop is an open-source Apache software framework built on the assumption that hardware failure is so common that backups are unavoidable. It comprises a storage area and a management part that distributes the data to smaller nodes where it processes faster and more efficiently. Prominent users include Yahoo! and Facebook. In fact more than half Fortune 50 companies were using Hadoop in 2013.

Hadoop – initially launched in December 2011 ? has survived its baptism of fire and became a respected, reliable option. But is this something the average business owner can tackle on their own? Bear in mind that open source software generally comes with little implementation support from the vendor.

The Hadoop Strong Suite

  • Free to download, use and contribute to
  • Everything you need ?in the box? to get started
  • Distributed across multiple fire-walled computers
  • Fast processing of data held in efficient cluster nodes
  • Massive scaleable storage you are unlikely to run out of

Practical Constraints

There is more to Hadoop than writing to WordPress. The most straightforward solutions are uploading using Java commands, obtaining an interface mechanism, or using third party vendor connectors such as ACCESS or SAS. The system does not replace the need for IT support, although it is cheap and exceptionally powerful.

The Not-Free Safer Option

Smaller companies without in-depth in-house support are wise to engage with a technical intermediary. There are companies providing commercial implementations followed by support. Microsoft, Amazon and Google among others all have commercial versions in their catalogues, and support teams at the end of the line.

IT Systems Implementation

Are you ready to find out how your newly accepted IT system fares in the real world? Although a rigorous Acceptance testing process can spot a wide spectrum of flaws in a newly constructed IT system, there is no way it can identify all possible defects. The moment the IT system is delivered into the hands of actual end users and other stakeholders, it is effectively stepping out of a controlled and secure environment.

Thus, it is during this phase wherein issues having direct impact on the business can arise.

It is our duty to ensure that the Systems Implementation phase is carried out as thoroughly, professionally, and efficiently as possible.

Thoroughly, because we need to include all relevant data and other deliverables, eliminate hard-to-detect miscalculated results, and substantially reduce the probability of business and mission critical issues popping up in the future;

Professionally, because it is the best way to address the sensitive process of turning over a new system to users who have gotten used to the old one;

And efficiently, because we want to minimise the duration over which all stakeholders have to adapt to the new system and allow them to move on to the process of growing the business.

Preparation

Louis Pasteur once said, “Luck favours the mind that is prepared.”

While we certainly won’t leave anything to chance, we do put substantial weight on the Preparation stage of Systems Implementation. We’re so confident with the strategies we employ in Preparation, that we can assure you of an utterly seamless Deployment and Transition phase.

By this we mean that issues that may arise during Deployment and Transition will be handled smoothly and efficiently because your people will know exactly what to do.

Here’s how we will prepare your organisation for Deployment:

  • Identify all key players for the Systems Implementation phase and orient them on their specific roles. We’ll make sure they know what possible hitches may come their way and how to deal with them.
  • Identify all end users and their corresponding functions, then assign appropriate access rights.
  • Draw multi-layered contingency plans to capture and address each possible concern that may crop up during Deployment.
  • Prepare a systematic step-by-step procedure and checklist for the entire Deployment stage. Both of them should have been copied from a similar procedure and checklist used in the Acceptance testing phase.
  • Make all stakeholders understand the conditions required before Deployment can commence.
  • Set the appropriate environment so that all stakeholders know what to expect and when to expect them the moment Deployment commences.
  • Prepare Technical Services and Technical Support personnel for the gruelling mission ahead.
  • Make sure all communication processes are well coordinated so that everyone affected will know who to contact and how to get in touch with them when a problem arises.
  • Plan and schedule training sessions so that they can be conducted “just in time”. Training sessions conducted way ahead of Deployment are often useless because the trainees tend to forget about what they learned when the time comes to apply them. Similarly, training sessions conducted way after Deployment also become useless because trainees are seldom able to internalise instructions delivered during crash courses.

Deployment

There are two sets of issues to keep an eye on during Deployment:

  1. Issues directly related to the technology itself, e.g. application functionality and data integrity, and
  2. Issues emanating from the end users, i.e., their unwillingness to use the new system. One reason may be because they find the interface and procedures too confusing. Another would be due to other inconveniences that come with adapting to a new set of procedures.

Despite all the meticulous scrutiny employed during Acceptance testing, there are just some problems that are made obvious only during Deployment. Issues belonging to the first set are dealt with easily because of the plans and procedures we put in place during the Preparation stage. As an added measure, our team will be on hand to make sure contingency plans are executed accordingly.

While the second set of issues is often neglected by many IT consultancy companies, we choose to meet it head on.

We fully understand that end users are most sensitive to the major changes that accompany a new system. It is precisely for this reason why our training activities during Deployment are designed not only to educate them but also to make them fully appreciate the necessity of both the new system and the familiarisation phase they will need to go through.

The faster we can bring your end users to accept the new system, the faster they can refocus on your company’s business objectives.

Here’s what we’ll do to guarantee the smoothest Deployment process you’ve ever experienced.

  • Employ the procedure and checklist formulated during the Preparation stage.
  • Ensure all end users are well acquainted with any additional tasks they would need to perform (e.g. filling up manual logs).
  • Assess which legacy systems can still be used alongside the new technology and which ones have to be retired.
  • Supervise the installation and optimal configuration of all supporting hardware and software to make sure the likelihood of errors originating from them are brought to near-zero levels.
  • Supervise the installation and optimal configuration of the products themselves.
  • Carry out data migration tasks if necessary.
  • Organise and oversee parallel runs to check for data and report inconsistencies.
  • Conduct training sessions in a professional and well-timed manner to eliminate end-users’ feelings of agitation and to take advantage of memory absorption and retention duration as with regards to their assigned duties and responsibilities.

Transition

Do you often feel uneasy whenever the reins to a newly purchased IT system are handed over to you? Perhaps there are some issues that you feel haven’t been fully settled but, at the same time, find it too late to back out, having already invested so much time and resources.

Alright, so maybe the thought of “backing up” never crossed your mind. However, the concern of being “not yet ready” is raised by many organisations towards the tail end of most Deployment stages. This usually drags the Deployment stage into a never-ending process.

Our team of highly experienced specialists will make sure you reach this point with utmost confidence to proceed on your own.

To wrap up our comprehensive IT Systems Implementation offering, we’ll take charge of the following:

  • Verify that all deliverables, including training materials and other technical documentation, are accomplished and expected outcomes are realised.
  • Make sure all technical documentation are placed in a secure and accessible location.
  • Institute best practices to ensure the IT system becomes fully utilised and to reduce its exposure to avoidable risks.
  • Establish open communication lines with the Technical Support team to enable quick resolution of issues.
  • Ensure complete knowledge transfer has been fully achieved so that your people will spend less time calling Technical Support and more on operations contributory to business growth.

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