Wednesday, February 06, 2008

SOX Life Blog: Risk-Based SOX Implementation - Deloitte Gets Succinct on Sarbox

For so many companies, internal discussions have largely gotten past SOX compliance to a point of business as usual.

What I do appreciate however, is that good, clear guidance continues to be developed. For those many professionals that have moved onto new challenges, the issue now becomes one of implementing the familiar COSO framework in a new organization.

Deloitte continues to put forth webcasts and whitepapers, the most recent to hit my inbox being "Sarbanes-Oxley Section 404 for Non-Accelerated Filers: Applying a Top-Down, Risk-Based Approach", a white paper just released in January.

Risk-Based SOX Implementation - Deloitte Gets Succinct on SOX

Labels: Deloitte, guidance, implementation, sas109, SOX Life Blog

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Tuesday, February 27, 2007

Kerry, Snowe Urge Sarbanes-Oxley Extension for Small Firms

Today Senators John Kerry (D-Mass.) and Olympia J. Snowe (R-Maine) called for a delayed
implementation of the Sarbanes-Oxley Section 404 requirements for small public firms to ease the burden on complying with the expected new auditing
standards. Section 404 requires firms to establish internal control frameworks and to file internal control reports. The Securities and
Exchange Commission (SEC) and the Public Company Accounting Oversight Board (PCAOB) proposed rules and guidance late last year addressing this section
and are accepting public comments through Monday, February 26th.

"We can have strong corporate accountability standards while also reducing the burden for small firms who spend more time and money earned
than big companies to comply with Sarbanes-Oxley," said Kerry. "We must do everything possible to appropriately reduce red tape in order for small
firms to grow and become dynamic public companies."

A recent Government Accountability Office (GAO) report requested by Senators Snowe and Mike Enzi (R-Wyo.) found that small public companies
spend considerably more on implementing Sarbanes-Oxley, particularly Section 404. The report found that firms with less than $75 million in
market capitalization were spending 877 percent more than larger counterparts -- $1.14 in audit fees per $100 of revenue, compared to just
$.13 per $100 for firms with greater than $1 billion in market capitalization.

Kerry, Snowe Urge Sarbanes-Oxley Extension for Small Firms

Labels: extension, implementation, sarbanes oxley, small business

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Tuesday, February 06, 2007

Help Wanted: A Call for Peer Network

As a consultant interested in participating in challenging projects while working with great people, it seems that, as independents, we have the contacts or the opportunities, but not always the right network of professionals with the necessary availability to deliver the specific details of a project. I want to make an effort to remedy this challenge.

I am keen on making contacts with independents that are interested in developing an informal relationship with other specialists in this space to share work in challenging projects. Given the wealth of areas for specialization in the risk and control field, I am interested in cultivating relationships with professionals interested in project work, or looking for assistance in efforts that have lined up.

I would love to hear from folks interested in expanding their network of professionals for possible project work in the future.

For those that have been reading Inside Sarbanes Oxley since it launched in the fall of 2004, I hope we've done a good job of keeping you informed of emerging issues and developments around the regulatory impact of Sarbanes Oxley. You will recognize that we've not done much in the way of connecting with readers and practitioners within this community, because so many professionals have been buried beneath the chore of just getting projects across the finish line. I now want to reach out, making connections with people that are still grooving on this work after a few implementations.

As Publisher of Inside Sarbanes Oxley and a risk and controls consultant, I continue to thrive on this work. I love the opportunities that come with a new engagement and control environment implementation, and seeing the dramatic changes that occur within an organization in a period as short as a few months. I also appreciate the new opportunities for learning that come from working with new people, and drawing new insights from their experiences.

As the breadth of the on-going compliance requirements continue to be hashed out, it occurs to me that full implementations (risk assessment through year 1 testing) will continue to shrink. Obviously there a few opportunities that remain, but the vast majority of work seems to already be shifting toward outsourced testing resources and internal control environment managers (solo artists asked to oversee the health over testing results and manage change into the documentation developed to-date).

I recognize that not everyone shares the risk tolerance of the independent consultant. I also recognize that not everyone is interested in engagements across the country or around the globe. That said, I welcome the opportunity to begin conversations that could lead to collaborative opportunities for the many of you running small (or individual) consultancies.

If gaining visibility to such a community would be of interest to you, please drop me a note at toby.lucich@insidesarbanesoxley.com, or connect to me at LinkedIn (http://www.linkedin.com/in/tobylucich). Note that connections via LinkedIn are public, so contact me at toby.lucich@insidesarbanesoxley.com for a more discrete point of contact.

I would welcome discussion about what you love to deliver to a client, the type of challenge you would love to land next, and upcoming availability or opportunities. I look forward to discussions of areas of expertise (i.e. projects managed, cycles documented, processes redesigned, industry experience) as well as your level of interest in future projects (regionally within the US or on a global basis).

Labels: consulting, implementation, independent, network, sarbanes oxley, sarbox, sox

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