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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Do you really need a Cloud Broker?

A cloud broker is someone who can serve as your trusted adviser when it comes to your dealings with a cloud service provider. Sort of an IT consultant who: is familiar with cloud computing, can negotiate a mutually beneficial relationship between you and a provider, and help you manage usage, performance and delivery of cloud services.?But do you need one?

Is it even time for cloud adoption?

Of course, if you haven’t even started considering moving your IT systems to the cloud, what’s the point of reading this article, right? Well, if you’re running a business in Ireland or the UK maybe you should start thinking about it. The benefits (of moving to the cloud) are simply overwhelming. But then that’s for another post.

For now, let’s just briefly talk about the rate of cloud adoption so far. This should give you an idea what other decision makers nearby think about cloud computing and what they’ve done in this regard so far.

According to research conducted by the Cloud Industry Forum (CIF), the number of first-time users of cloud computing in the United Kingdom has risen by about 27% compared to last year.

The study, which was carried out by research company Vanson Bourne and which involved IT decision-makers from both the private and public sector in UK, also showed that 61% of companies are subscribing to cloud-based services. A similar research conducted last year (2011) revealed only 48%.

In Ireland, plans are underway to adopt cloud computing. According to Pricewaterhouse Coopers, 75% of Ireland’s CIOs and IT directors are already adopting a cloud computing strategy.

Definitely, the number of cloud adopters is growing. If that number already includes your hottest competitor, then perhaps there’s no time to waste.

But while a migration to the cloud should be in your pipeline, it shouldn’t be something you should rush into. Generally speaking, there are at least three kinds of services offered by cloud service providers: IaaS (Infrastructure as a Service), PaaS (Platform as a Service), and SaaS (Software as a Service).

Some providers offer variations of these services. You might only need one type of service or a little of everything. There are also technical and regulatory compliance issues that need consideration.

Obviously, if you have no idea where or how to start, you’ll need someone who can help you. But what kind of help do you need?

Let’s proceed by talking about the kinds of services cloud brokers offer as these are obviously indicative of the needs of current cloud customers.

What cloud brokers do?

Cloud brokers offer three main types of services.

Cloud?inter-mediation

Cloud inter-mediation services are designed to add value to existing services and improve capabilities. ?Examples of cloud inter-mediation include managing access to cloud-based services, carrying out performance reporting, and establishing stronger security.

Cloud aggregation

As mentioned earlier, some cloud customers may end up subscribing to multiple cloud services; most likely from different cloud service providers. To get optimal return on their various cloud subscriptions, these customers will need to apply data integration and make these disparate systems work together. They will also have to make sure data flowing from one system to another is kept secure. This is where cloud aggregation comes into play.

Cloud arbitrage

This entails finding the best cloud service provider(s) to solve a particular problem. One example is comparing different providers offering data storage services and identifying the one offering the most competitive rates.

Other cloud arbitrage brokers develop new solutions by combining the services of different cloud service providers and then offer them to cloud customers. While there are similarities between cloud arbitrage and cloud aggregation, the former is more flexible and allows the customer to transfer from one provider to another where conditions are more favourable.

Problems a cloud broker can help you solve

Just like with natural clouds, your experiences in cloud computing won’t be all white and fluffy. You’ll also encounter gray and uncertain (or even stormy) clouds.

One major issue in cloud computing is cloud security. In fact, cloud security (or the apparent lack of it) is the one thing that’s really clouding up the sky of cloud computing. But that doesn’t mean the cloud is totally insecure. Besides, there are certain types of information that really don’t require a high level of security. These types you can easily migrate to the cloud.

For sensitive information, you really need to conduct due diligence to make sure your cloud service providers’ data centres are secure enough.

Where exactly will your data be stored? Are there enough provisions for regulatory compliance? How will your data be segregated? Does the infrastructure readily support ?data forensics? Is there a sound disaster recovery/business continuity plan? These are just some of the questions that need clear answers before you sign a contract with a cloud service provider.

Suggested reading: 9 Cloud Security Questions You Need To Ask Service Providers

Also, before you sign, you need to study the SLA (Service Level Agreement) very carefully. Look at the guaranteed uptime. Is it enough to meet your own desired service levels?

Bear in mind that the answers to these questions may be too technical. This is one of those instances when a cloud broker can come in handy. As your trusted adviser, your cloud broker can break down the technical jargon and present everything in a language that you can make intelligent decisions from.

A cloud broker will also be able to study the cloud provider’s security architecture and policies and determine whether they’re sufficient to meet your own security requirements. Basically, a cloud broker will not only help you obtain answers to your questions.

He will also know exactly what vital information to extract from providers in order to ensure that you find the best deal possible.

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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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Be pound poor and become Penny rich

Energy management is and should be perceived as a long-term investment by organisations. Having said this, the need for all organisations to implement energy management strategies now cannot be overstated as these strategies will save their costs of running the business in future.

Many organisations may shy off from implementing energy efficiency measures in place opting to save the associated costs or to use the cash for other projects that may be perceived as high priority in the short run. This is most likely to occur when cost cutting is a priority. Long-term planning is however critical for energy efficiency programs. Taking steps to improve building management and energy efficiency will and does pay dividends in the near-term and may be a competitive tool in the long-term.

Be energy smart
All energy management projects begin with being energy smart which calls for the understanding of energy usage. Use of Smart Meters that give real time readings of energy usage, can dramatically help businesses understand the benefit which energy management brings to the organisation.

Smart meters also cut the amount of time businesses spend on administration by allowing them to pay accurate bills, based on accurate readings. Some suppliers also support businesses to identify areas of energy wastage/inefficiency and help setting targets for energy reduction that guide behavioural change with regard to energy in the organisation.

Use of technologies that record the energy usage at the water or electricity meters putting data into a system where the users can graph it has made it easy to compare energy consumption in various departments, sites or buildings. Appropriate measures can then be implemented to improve the efficiency.

Partnerships between businesses and energy suppliers
Since the long-term benefits of reduced energy consumption is beneficial to both suppliers and consumers; the responsibility of managing energy consumption is being taken by both. Businesses should work with the suppliers on cost reduction strategies through identifying areas where energy is being wasted and advising businesses on how to save energy. Of key importance when choosing an energy supplier therefore is their depth of understanding of a business’ energy management needs.

Capitalise on government incentives
Businesses should always explore varied financing mechanisms for their energy efficiency programs e.g. government schemes generating electricity and selling it to the grid.

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