SOX Life: Living with Sarbanes-Oxley

Knowledge Management and Corporate Governance

2008-04-22T12:37:00.000-07:00

Knowledge Management (KM) is more than a buzz phrase running through organizations, so if you were hoping this discussion was going to abruptly end, think again.With so many organizations facing labor shortages as the baby boomers look toward retirement, it becomes not only a staffing but a very practical governance conversation about addressing this talent gap. What would happen if all your

Reader Question - Understanding & Evaluating Segregation of Duties

2008-04-17T16:54:00.001-07:00

I appreciate when readers share their challenges in applying issues and concepts, as invariably there are an additional dozen people also struggling with this same topic.One professional writes:I am new at this and need to understand about SOX and SOD, do you have any other resources? I am looking for Purchases Orders to Negotiations for credit terms, to who enters the new vendor and who signs

SEC's SOX for Small Business Reference

2008-04-10T13:23:00.000-07:00

Dreading your pending SOX initiative? Or the thoughts of IPO? Or how you might refine your implementation?Hopefully, "Sarbanes-Oxley Section 404A Guide for Small Business" from the SEC takes some of the sting out of it. This incorporates much of the thinking and discussion in the last 18 months about "how much is enough" for small business. I also think it gives existing implementations an

Risk-Based SOX Implementation - Deloitte Gets Succinct on SOX

2008-02-06T11:12:00.000-08:00

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

Tides of Change - Retooling of Accounting Standards

2008-01-16T13:53:00.000-08:00

The Global Public Policy Symposium IV was recently held in NY, with representation and discussion among the top international auditing firms.With the ongoing discussion around more principle-based (IFRS) accounting standards versus the more familiar rules-based (GAAP) standards in the US, many are interested - if not regularly dialed into - the discussion of adoption and the implications of

Segregation of Duties - Part II

2007-05-19T08:29:00.000-07:00

From Free IT Solutions, a few links to conflicts of interest as described for SAP (but useful in their generic sense regardless of underlying system):List One of Activity ConflictsList Two of Activity ConflictsList Three of Activity ConflictsIf you have lists you would like to share that are helpful for evaluating segregation of duties, please send to my attention and I'll be sure to post for

Explaining Segregation of Duties

2007-05-19T08:04:00.000-07:00

As a controls professional, I'm sensitive to any employee that has too much on their plate, and have to consider if proper Segregation of Duties are in place. They get burned out. They get tired. They feel rushed. They risk simply going through the motions.But worst of all, they are at risk for creating justifications for less-than-professional performance. I'm not thinking about just fraud (

Where do You find Talent? New Inside Sarbanes Oxley Job Board

2007-05-16T22:27:00.000-07:00

One of the things that I've not been quite satisfied with has been our jobs board these last few, uh, years. Originally new jobs were posted via the discussion board, and many folks had a hard time navigatintg the security to get jobs loaded up. A true discussion killer.We've now rebuilt the Inside Sarbanes Oxley Jobs Board page using some very new tools and are offering an introductory rate on

How Little Is Enough?

2007-03-09T15:47:00.000-08:00

Would you ever just walk straight into an Iron Man Triathlon? No experience, no training, no prep, not even having proper equipment? No verification of your overall health with your physician? Ignoring your diet for years leading up to the race?I really hope not. That sounds insane, and will probably be your undoing.But this is precisely how the proposed legislation feels to eliminate 404

SOX Work spurs Professional Passion - "More than a Living"

2007-03-09T07:53:00.000-08:00

In my risk and control work - both inside companies and more recently as a consultant - I continue to be challenged by personnel that are idling in place. No interest in moving up, no interest in moving on, no interest in getting on board with the changes at hand.This has been hard - for everyone. Employers would prefer that competent people stay in their current seats (less risky, as such people

Investor Valuation of Governance

2007-03-09T07:36:00.000-08:00

Dan Swanson's listserv recently passed a link to the ICAEW, providing discussion on "what is governance?" and "why is it important?"Most notably in this piece, this McKinsey quote struck me:There is evidence that investors value companies with good corporate governance. McKinsey surveyed over 200 institutional investors and found that 80% of respondents would pay a premium for well-governed

Going Once, Going Twice...

2007-02-27T07:42:00.000-08:00

I really hope you aren't still complaining about the gyrations AS2 causes.While it has been the law of the Sarbanes Oxley landscape for the last several years, the last two months have given all SOX professionals and managers at publicly traded companies alike the opportunity to review and weigh in on a more effective way to live with this much needed discipline.With the comment period closed,

Help Wanted: A Call for Peer Network

2007-02-06T17:00:00.000-08:00

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

SEC Votes to Propose Interpretive Guidance for Management to Improve Sarbanes-Oxley 404 Implementation

2006-12-18T07:58:00.000-08:00

The Securities and Exchange Commission today voted to propose for public comment interpretive guidance for managements regarding their evaluations of internal control over financial reporting. The Commission also proposed amendments to Rules 13a-15 and 15d-15 that would make it clear that a company choosing to perform an evaluation of internal control in accordance with the interpretive guidance

All Atwitter over Upcoming Changes

2006-11-22T09:31:00.000-08:00

I'm a nut for changes. I've yet to encounter a process, product, or professional that couldn't benefit from reflection and additional refinement to how goals are achieved. I think many are eagerly (if skeptically) anticipating revisions to AS2 and the utilization of Section 404.In a speech given by Mark Olson to the FEI "International Shaping the Future of Financial Reporting Conference" in New

Who Cares about Fraud, Anyway?

2006-11-10T14:02:00.000-08:00

A listserv I subscribe to recently sent this question across my email:Who cares about fraud anyway if the shrinkage is still reported in the financial statements?I recently had an external auditor tell me that management has a custodial duty to shareholders to protect both their assets and interests, and that he viewed his work as not only the assurance of financial accuracy, but confirmation of

Election Fallout

2006-11-08T11:10:00.000-08:00

Whew.I've been digging about a bit for details on teh implications for SOX now that the Dems have the House, and maybe even the Senate (some are repeats from past weeks, but I resubmit them collectively).My favorite read has been not only the article, but the rants from readers at The New Republic. Clay Risen really stirred it up in this Oct 17 article, looking forward to possible implications

What is Driving your CFO Agenda?

2006-11-05T18:38:00.000-08:00

Old news for some, but I just came across a Mercer Consulting article "How CFOs Are Managing Changes in Roles and Expectations" (Feb 2006). Not a surprise for many I'm guessing, but a nice validation that others are facing the same issues.If you thought your flavor of accountability was unique, recognize that the landscape has shifted for finance leaders. This may be a useful point of reference

You want to see Float? Consider accelerating your adoption of XBRL

2006-10-10T10:51:00.000-07:00

If cash is king to keeping the doors opne, transparency is the crown prince of addressing investor fears.