One Week Implementation Effort Produced a One-Year ROI
PETALUMA, Calif. - August 11, 2010 - Vibato announces the completion of a recent process reengineering project for iMergent, Inc. (AMEX: IIG), a leading provider of proprietary e-commerce software platforms and portfolio services with multiple subsidiaries. iMergent engaged Vibato to reengineer their internal control infrastructure, implement best-practice controls, and provide a fully-integrated testing environment. Vibato implemented a high level risk assessment, six process control cycles and a segregation of duties analysis to give iMergent an improved internal control environment for their 2011 fiscal year, ready for testing work, and reviewed the transition for completeness and accuracy with their external auditors. The process was completed in four days, with active participation by iMergent’s finance organization.
“We wanted a revamp of our internal control environment with a focus on controls reduction and an integrated environment by having more direct and precise controls. We were very impressed with the efficiency and scalability of Vibato’s approach, especially considering our business complexity,” said Jonathan Erickson, Chief Financial Officer of iMergent, Inc. “The significant reduction in controls from 339 down to 107, combined with the integrated testing capabilities, will allow us to be more efficient in our processes and testing. This is a great example of Vibato’s value-driven focus and commitment to customer success.”
“Our tools are designed specifically for this type of implementation project, even for complexities in such areas as software revenue recognition” said Bill Bockwoldt, Chief Executive Officer of Vibato. “I believe our success with iMergent is a clear indication that our unique approach to managing internal controls for financial reporting continues to position us as the most cost-effective compliance provider in this area today.”
iMergent, Inc. (AMEX: IIG) provides proprietary e-commerce software platforms and portfolio services, through their StoresOnline and Crexendo subsidiaries, including web design and development, custom programming, SEO services and internet marketing and training to entrepreneurs and businesses, enabling them to sell and market their products or services over the Internet. For more information, please visit www.imergentinc.com.
Vibato, LLC is dedicated to providing the most cost-effective compliance solutions available. Our mission is to help you reduce audit and compliance fees, improve financial transparency and run your business more efficiently.
Interesting article on User Developed Applications (UDAs). This could also apply to spreadsheets used for internal controls work, especially if they are distributed across departments and not centralized. Applications are typically developed for expense calculation and tracking (e.g. stock comp expense) as well as financial analysis. We try to take an approach that these types of tools should have permission control and be stored in documented locations where appropriate review and updating can be performed. It makes audit-related work much easier in the end!
"Internal Auditors Target Spreadsheets
The practitioners' leading trade group launches a campaign to get better control over spreadsheets and databases created without oversight from IT.
David McCann - CFO.com | US”
Click here to read the full article.
The article below was sent from a dear friend of mine and fellow SOX enthusiast, Clark Keeler, Director, BPM. I find the article to have a significant amount of irony considering it claims that "American business people of a conservative nature have been dreaming about driving a stake through the heart of the Sarbanes-Oxley act ever since the legislation was passed..." It would seem to me that if a person was truly fiscally conservative, they would consider Sarbanes-Oxley to be the prudent choice rather than the radical one. Internal controls require there to be a check point in a business procedure that requires someone other than the preparer of the documentation to verify the accuracy of what was prepared. This verification prevents someone from acting alone when making decisions about shareholder assets (physical assets, capital, intangible assets, etc). I am of the opinion that this double check adds a necessary layer of review considering the potential for fraud, errors, omissions, etc. Considering all that we at Vibato, LLC have found when testing internal controls, this is no longer just opinion but rather, fact. Read more on the article here:
“Two cheers for Sarbanes-Oxley
The Supreme Court gets it right by tweaking, but not overturning, the controversial legislation
Jun 29th 2010
AMERICAN business people of a conservative nature have been dreaming about driving a stake through the heart of the Sarbanes-Oxley act ever since the legislation was passed, back in 2002, in the wake of the Enron, Tyco, WorldCom and Global Crossing scandals. George Bush rightly described the legislation as “the most far-reaching reforms of American business practices since the time of Franklin D. Roosevelt”. But to its critics it is far-reaching in the wrong direction. The American Enterprise Institute, a right-wing think-tank, has dismissed Sarbox as a “colossal failure”. Ron Paul, a Texan libertarian, has argued that it puts America at a competitive disadvantage. The Wall Street Journal thunders that it has “imposed hundreds of billions of dollars in costs on business with no noticeable decline in financial scandals”. Newt Gingrich has urged Congress, the body that he once dominated, to repeal the act.”
See the full article here.
Yesterday the PCAOB released a news release about the Wall Street Reform Act's passage yesterday morning.
Please follow this link to read the whole release.
"From the PCAOB:
Washington, D.C., July 21, 2010 – Today’s enactment of the Dodd-Frank Wall Street Reform and Consumer Protection Act facilitates the PCAOB’s ability to share information with foreign auditor oversight authorities and closes gaps in the Board’s authority to oversee audits of brokers and dealers."
In the wake of a potential Sarbanes-Oxley 404(b) exemption via the Wall Street Reform Act, the PCAOB seems to be doing what it can to require a deeper audit than previously accepted. This is inline with what we at Vibato have also been seeing on the external audit side. Most external auditors we encounter are claiming if the 404(b) reprieve goes through, or, if non-accelerated filers (those companies with a $75M or less market cap) are not required to comply with 404(b) (the section of Sarbanes-Oxley that requires external auditors to review management's internal controls), then they are planning to audit any 404(a) claim as though it were a 404(b) claim. 404(a) is where all public companies are required to attest to the effectiveness of their internal control infrastructure via their 10K, 10Q, and 302 / 906 certifications. Here is the article from CFO.com about the PCAOB activities:
"PCAOB Ups Auditors' Double-Checking Duties
A proposed rule would expand the types of accounts that audit firms need to verify with a third party.
Sarah Johnson - CFO.com | USJuly 16, 2010
The Public Company Accounting Oversight Board has proposed a rule that could help uncover corporate fraudsters' common practice of masking the true amounts of accounts, such as receivables or cash balances.
The proposal updates a 15-year-old rule that governs audit confirmations — how auditors verify their clients' receivables with third parties, such as lenders and customers. The practice is "one of the building blocks of auditing," said PCAOB chairman Daniel Goelzer at a board meeting earlier this week. The board issued the proposal on Tuesday for a 60-day comment period."
Please click here to view the full article.
The Ohio Society of CPAs commented on the "Last-minute attempt made to remove small public company exemption from financial reform" in 404(b) in the article below on 25 June 2010. They discussed the fact that investors in small companies deserve safeguards against possible fraud. After all, if there are no safeguards to prevent fraud for small public companies, that will ultimately lead to a lack of investment in these companies as investors will not feel secure in doing so. Click here to read the full statement.