tag:blogger.com,1999:blog-8262085Fri, 07 Aug 2009 17:24:21 +0000Not "living with Sarbanes Oxley" in a Three's Company sort of way. More a chronicle of one's existence under the regime of the Sarbanes-Oxley Act or SOX or SarbOx or 404...http://www.insidesarbanesoxley.com/soxlife/index.aspnoreply@blogger.com (Rick Turoczy)Blogger53125tag:blogger.com,1999:blog-8262085.post-7089703003506682965Tue, 22 Apr 2008 19:37:00 +00002008-04-22T12:52:40.680-07:00change managementhuman capital managementbaby boomerscorporate governanceknowledge managementKnowledge 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 http://www.insidesarbanesoxley.com/soxlife/2008/04/knowledge-management-and-corporate.aspnoreply@blogger.com (Toby Lucich)1tag:blogger.com,1999:blog-8262085.post-7790483047669130225Thu, 17 Apr 2008 23:54:00 +00002008-04-17T18:08:53.654-07:00access managmentsegregation of dutiesseperation of dutiesCOSOfraudI 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 http://www.insidesarbanesoxley.com/soxlife/2008/04/reader-question-understanding.aspnoreply@blogger.com (Toby Lucich)1tag:blogger.com,1999:blog-8262085.post-2192400111358775804Thu, 10 Apr 2008 20:23:00 +00002008-04-10T13:35:53.328-07:00SECguidancereferenceCOSOsmall businessDreading 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 http://www.insidesarbanesoxley.com/soxlife/2008/04/secs-sox-for-small-business-reference.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-4105585127257461323Wed, 06 Feb 2008 19:12:00 +00002008-02-06T11:39:57.615-08:00SOX implementationSAS109guidanceDeloitteFor 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 http://www.insidesarbanesoxley.com/soxlife/2008/02/risk-based-sox-implementation-deloitte.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-6238067213030901877Wed, 16 Jan 2008 21:53:00 +00002008-01-16T14:14:08.466-08:00IFRSGlobal Public Policy Symposiumprinciple-based accounting standardsThe 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 http://www.insidesarbanesoxley.com/soxlife/2008/01/tides-of-change-retooling-of-accounting.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-2066400359247590741Sat, 19 May 2007 15:29:00 +00002007-05-19T08:35:28.002-07:00activity conflictssegregation of dutiesFrom 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 http://www.insidesarbanesoxley.com/soxlife/2007/05/segregation-of-duties-part-ii.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-4714123448609158718Sat, 19 May 2007 15:04:00 +00002007-05-19T08:24:30.447-07:00segregation of dutiesAs 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 (http://www.insidesarbanesoxley.com/soxlife/2007/05/explaining-segregation-of-duties.aspnoreply@blogger.com (Toby Lucich)2tag:blogger.com,1999:blog-8262085.post-3016915015764098381Thu, 17 May 2007 05:27:00 +00002007-05-16T22:36:37.186-07:00publisher messagejob boardOne 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 http://www.insidesarbanesoxley.com/soxlife/2007/05/where-do-you-find-talent-new-inside.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-578872294839042013Fri, 09 Mar 2007 23:47:00 +00002007-03-09T16:28:18.897-08:00investmentinvestorriskstandards404rewardWould 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 http://www.insidesarbanesoxley.com/soxlife/2007/03/how-little-is-enough.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-2993523752661685523Fri, 09 Mar 2007 15:53:00 +00002007-03-09T08:27:27.697-08:00expertiseriskfeedbackskillmore than a livingtalentIn 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 peoplehttp://www.insidesarbanesoxley.com/soxlife/2007/03/sox-work-spurs-professional-passion.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-2232584700845153088Fri, 09 Mar 2007 15:36:00 +00002007-03-09T07:50:31.503-08:00risk value investor mckinseyDan 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 http://www.insidesarbanesoxley.com/soxlife/2007/03/investor-valuation-of-governance.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-4564735229846808742Tue, 27 Feb 2007 15:42:00 +00002007-02-27T07:44:21.985-08:00I 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, http://www.insidesarbanesoxley.com/soxlife/2007/02/going-once-going-twice.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-2751568380313302691Wed, 07 Feb 2007 01:00:00 +00002007-02-06T23:33:12.660-08:00sarboxsoxsarbanes oxleynetworkindependentimplementationconsultingAs 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 http://www.insidesarbanesoxley.com/soxlife/2007/02/help-wanted-call-for-peer-network.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-116645765592962324Mon, 18 Dec 2006 15:58:00 +00002006-12-18T08:02:21.446-08:00The 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 http://www.insidesarbanesoxley.com/soxlife/2006/12/sec-votes-to-propose-interpretive.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-116421685845507488Wed, 22 Nov 2006 17:31:00 +00002006-11-22T09:34:18.466-08:00I'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 http://www.insidesarbanesoxley.com/soxlife/2006/11/all-atwitter-over-upcoming-changes.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-116319647097110970Fri, 10 Nov 2006 22:02:00 +00002006-11-10T14:07:50.983-08:00A 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 http://www.insidesarbanesoxley.com/soxlife/2006/11/who-cares-about-fraud-anyway.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-116301399003650566Wed, 08 Nov 2006 19:10:00 +00002006-11-08T11:41:11.396-08:00Whew.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 http://www.insidesarbanesoxley.com/soxlife/2006/11/election-fallout.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-116278102584688916Mon, 06 Nov 2006 02:38:00 +00002006-11-05T18:43:45.860-08:00Old 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 http://www.insidesarbanesoxley.com/soxlife/2006/11/what-is-driving-your-cfo-agenda.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-116050281098813182Tue, 10 Oct 2006 17:51:00 +00002006-10-10T10:53:31.003-07:00If cash is king to keeping the doors opne, transparency is the crown prince of addressing investor fears.<!-- ARTICLE_RENDERER --><!-- LINE 113 Got StoryData from request --><!-- START: paginate --><!-- END: paginate - pages: 2 --><!-- START: insert authors --><!-- END: insert authors --><!-- renderer: c:\xml\cfo\displayNITF.xslt--><!-- Loop page:1 --><!-- BEFORE: NITF size: 5303 --><!-- AFTER: http://www.insidesarbanesoxley.com/soxlife/2006/10/you-want-to-see-float-consider.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-115980117390223758Mon, 02 Oct 2006 14:57:00 +00002006-10-03T23:07:50.326-07:00SOX is an excuse to get your house in Order. Take advantage of it.Kudos to McKinsey on this latest analysis - too little consideration has been given to how the analysis underpinning Sarbanes Oxley compliance implementations can contribute to evaluating organizational design.When a company takes advantage of their tranasactional and entity-level control activities in their SOX implementation to http://www.insidesarbanesoxley.com/soxlife/2006/10/evidence-drive-change-overhaul-your.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-115947280685165443Thu, 28 Sep 2006 19:07:00 +00002006-09-28T12:46:46.883-07:00I often wonder at the surprise of somethings. A recent article notes Bloomberg is engaging McKinsey ("New York to Study Lack of IPOs")to figure out why companies are going public in London or in their own countries instead of the good ol' US of A. There is a preliminary finger wagging at SOX, which reasonably could carry some of the brunt.What wasn't clear to me is the population of new IPOs http://www.insidesarbanesoxley.com/soxlife/2006/09/ipos-popping-abroad-go-figure.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-115933577323356176Wed, 27 Sep 2006 05:09:00 +00002006-09-26T22:43:16.900-07:00Wow.Milken. Ebbers. Fastow. One of these is not like the others. Poor Bernie, with no chance at the speaker tour or to save the family name with a charitable foundation. At least Andrew will still have a crack at public redemption.With the announcment of Fastow's 6-year prison term, I'm sure many pensioners, 401(k) holders, and business professionals are asking, "and then...?" I often wonder if http://www.insidesarbanesoxley.com/soxlife/2006/09/how-to-interpret-fastow-verdict.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-115713922880630979Fri, 01 Sep 2006 19:29:00 +00002006-09-01T12:33:48.816-07:00If you think that savings can be found as a result of reviewing your scope and risk assessments, you might want to play a bit with this calculator from Aline. This is the handy tool we all talk around, but hasn't shown up until now. No surprise - increased reliance on pervasive controls and reduction of the sheer number of controls can save you real money.Action Item: To support your argument http://www.insidesarbanesoxley.com/soxlife/2006/09/calculator-tool-aline-for-sox.aspnoreply@blogger.com (Toby Lucich)1tag:blogger.com,1999:blog-8262085.post-115712807952825597Fri, 01 Sep 2006 16:09:00 +00002006-09-01T09:27:59.586-07:00For all those that struggle with getting their minds around the IT management aspects now required by SOX, good news - others are trying to work through this as well. For all the frameworks and "guidance", practitioners still haven't landed at a place that helps us really apply judgement to risk managment.And some folks are doing something about this. With a core team representing industry and http://www.insidesarbanesoxley.com/soxlife/2006/09/gcc-considerations-gait-on-as2.aspnoreply@blogger.com (Toby Lucich)0tag:blogger.com,1999:blog-8262085.post-114861351118798136Fri, 26 May 2006 03:03:00 +00002006-05-25T20:18:31.233-07:00A reader writes,Does the SEC make available to the public a database of enforcement for section 304 of sox? i.e. the amounts of money recovered from CEOs and CFOs for periods when financial statements must be restated? I fear that enforcement may be non-existent.LarrySpringfield, MOUnfortunately, I've not been able to turn up much. A May 2, 2006 article from Fortune "CEO pay: They didn't earn ithttp://www.insidesarbanesoxley.com/soxlife/2006/05/where-has-section-304-gone.aspnoreply@blogger.com (Toby Lucich)0