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Delivering integrated, cost-effective tools for establishing, documenting, and maintaining Internal Controls around financial reporting is our passion and focus. The goal of our blog is to keep our readers informed on related industry trends, legislative activities, and specific events. We focus on Sarbanes-Oxley and SAS-related compliance topics for public and private companies and provide our own perspective to assist our clients, partners, and readers with making informed decisions about their compliance needs and strategies. We would appreciate your feedback on our blog posts and welcome open discussion on any topics we cover or that our readers would like to discuss.

--Teresa Bockwoldt, CIO & Founder 

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Acounts Payables Internal Controls: Signature Example Sheet Available

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Time Want to save your accounts payable department time and money?  Help them perform their job better and faster by providing them with a signature example sheet. This sheet should list the name, title, signature example, and initials example of each person who is authorized to approve payments for your company.  This way, the AP Clerk will be able to recognize the approval signature and not have to ask questions or better yet, recognize when the approval signature is not correct and then escalate concerns...

We have a nice signature example template that we would be happy to give to you.  Register via the below button to receive this document.

Register

 

Accounts Payable Internal Controls: Employee Expense Report Example Available

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ToolsAnother very good control to have in the accounts payables process is that employee expense reports should be reviewed and approved by someone who is not the owner of the expense report - this goes for company founders and C-level executives as well.  This review needs to be formally documented to pass Sarbanes-Oxley.

A great way to accomplish this is to use an employee expense report form.  We have a great employee expense report that we'd be happy to give to you.  Register via the button below to receive it.

Register

 

Accounts Payables Internal Controls: Check Request Form Available

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ToolsA very good control to have is that any non-purchase order approved payment requests should have audit support for the approval via an approved check request form, email, or the like. 

For instance, someone needs to buy printer toner in bulk that costs $1000.  The employee may verbally ask the AP department to cut a check to pay for the toner which seems harmless but in a Sarbanes-Oxley compliance world, you cannot prove that the conversation took place so you would need to put in procedures to make the approval process, auditable.

A great way to accomplish this is use a check request form.  We have a great check request form that we'd be happy to give to you.  Register via the button below to receive it.

 

Register Button

 

Compliance Breaking News: FASB Amends Subsequent Events Guidance

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From a breaking news email I received from PwC today: 

The FASB has amended its guidance on subsequent events to remove the requirement for SEC filers (as defined in ASU 2010-09) to disclose the date through which an entity has evaluated subsequent events.  This change alleviates potential conflicts with current SEC guidance.  The amended guidance also clarifies that an entity that is a conduit bond obligor for conduit debt securities that are traded in a public market (a domestic or foreign stock exchange or an over-the-counter market, including local or regional markets) must evaluate subsequent events through the date of issuance of its financial statements and must disclose such date.

 

Sarbanes-Oxley Reprieve for Non-Accelerated Filers: The clock is ticking….

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Here is the Sarbanes-Oxley non-accelerated filer reprieve reality for fiscal filers with yearend dates between June 15 and December 31.  Your auditors are going to expect you to provide them with at least two quarters worth of functioning controls data.  They will also expect to be able to go back in time to randomly test at least two quarters worth of data (so just because you give them your test work does not mean that is all they will ask you for. They will ask for other samples in an attempt to uncover any attempts by you to give them only clean examples and they will watch you pull the samples to ensure you do not have the opportunity to fix problems prior to handing over the documentation). 

The legislation states that the controls must be working as of the last day of the fiscal year but I have never seen that honored by an auditor with the small exception of some IT access controls.   What this means is that generally speaking, your controls will need to be function for the following amount of time:

Control Frequency

Functioning Time

Samples Needed

IT Control

As of last day of the year

1

Annually

As of last day of the year

1

Semi-Annually

As of last day of the year

1

Quarterly

At least the last two quarters of the year

2 sometimes 3 if you use PwC

Monthly

1 quarter

3 sometimes up to 5 if you use PwC

Semi-Monthly

At least the last 4 months

4 - 7 samples

Weekly

At least the last 3 months

5-13 samples

Daily

At least the last month

20-25 samples

More than daily

At least the last month

25-35 samples

Long story short, if you are holding out hope for the permanent non-accelerated filer reprieve and have a fiscal year-end of June 30 for instance and have not started this work - you could be setting yourself up for disaster.  Especially if you have signed your 302 certifications and indicated in your 10K/Q that you had a clean internal control infrastructure (which would be fraud by the way).   This is not something to mess around with.  We have options to get you compliant for as low as $5,590 and completed in less than 1 day - why risk your reputation, your company's stock value, and the potential for a shareholder lawsuit and/or jail for such a small amount of money and effort?  CALL US AT 1-888-4VIBATO!!

 

2/23/10 News on the 404(b) Sarbanes-Oxley Permanent Reprieve - No Vote Yet

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There hasn't been any action yet in the Senate. 

The next step for the permanent non-accelerated filer reprieve for Section 404(b) of the Sarbanes-Oxley Act of 2002 is that the Senate must pass the bill and then it must be signed into law by the President.  Many fear that the new Republican Senator, Scott Brown, will cause the bill to fail in the Senate or that the section of the bill that is specific to Sarbox will be removed and therefore require non-accelerated filers to comply by the new deadline of June 15, 2010 (or your next fiscal year-end after that date).

 

According to Matt Kelly, editor-in-chief of Compliance Week, "...even if a Section 404(b) exemption gets inserted into the bill, and Republicans settle their differences with Dodd, and the Senate reconciles its bill with the House bill, and the 404(b) exemption survives that process, and both chambers then vote in favor of the full bill, and the president signs it into law-all this assumes Washington doesn't have other demands on its time, like starting over with healthcare legislation, or cutting the deficit, or running for re-election."

 

Long story short, if you haven't completed steps 1, 2 and 3 in the graphic below, you need to start thinking about it.  Especially considering steps 1, 2, and 3 have been required since 12/15/2007. 

implementation cycle

 

We track the progress of the bill daily.  If you would like to get up to the minute information about this bill, feel free to register and we will alert you immediately of any changes.  

Register

 

Vibato, High Street Partners and Silicon Valley Bank Webinar on 3/4/2010

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ToolsJoin us for a great discussion on things you should consider prior to going public.  This discussion is free and open to everyone.  

Topic: Pre-IPO Preparedness

Interactive discussion about planning for public offerings, with an international perspective on compliance considerations.

Hosts: 
Larry Harding, President, High Street Partners
Teresa Bockwoldt, CEO, Vibato
Jim Anderson, President, Silicon Valley Bank Analytics

Date:

  • March 4, 2010
  • 1:00 - 4:00 pm (EST) 

Cost:

Free

register button

Sponsors:

Vibato

Silicon Valley Bank

OC

 

GTN

HSP

 

Compliance Tools: Even More Codification Cheat Sheet Information

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ToolsHere is even more codification information from the FASB Accounting Standards.  Please verify the accuracy of this information prior to relying on it. 

We hope this information is helpful! 

We have a 30+ page listing of Codification cross reference information available for download via this link.

DERIVATIVES

Accounting Standards

FASB Codification

Definition

FAS 133, par. 6, 9

FSPEITF 00-19-2

ASC 815-10-15

ASC 825-20

Scope exceptions

FAS 133, par. 10

FAS 133, par. 11a

EITF 07-5

EITF 00-19

DIG A6

DIG A10

DIG A12

DIG C12

ASC 815-10-15

ASC 815-10-15-74

ASC 815-40-15

ASC 815-40

ASC 815-10-55

ASC 815-10-15

ASC 815-10-55-99 thru 110

ASC 815-10-15-39

Embedded Derivatives

FAS 133, par. 12, 13, 61

DIG B16

 

DIG B38

DIG B39

EITF D-109

ASC 815-15-25

ASC 815-15-25-42 thru 43, and 815-15-55-13

ASC 815-10-15-107 thru 109

ASC 815-15-25-37 thru 39, and 815-15-55-25

ASC 815-10-S99-3

HEDGING

Accounting Standard

FASB Codification

Eligibility/ Designation

DIG G2

DIG G13

FAS 133, par. 20c, 28c

FAS 133, par. 29

FAS 133, par. 32

FAS 133, par. 40a

ASC 815-20-55-111 Example 8

ASC 815-20-55-88 Example 4

ASC 815-20-25-94

ASC 815-20-25-15

ASC 815-30-40-1 thru 3

ASC 815-20-25-61

Hedge effectiveness and ineffectiveness

FAS 133, par. 68

DIG G20

FAS 133, par. 120c

FAS 138 FV Example

DIG G7 Method 1

DIG G7 Method 2

DIG G7 Method 3

DIG H8

DIG E7

ASC 815-20-25-102 thru 117

ASC 815-20-25-126, 55-209, and 35-33

ASC 815-25-55-53 Example 9

ASC 815-25-55-72 Example 11

ASC 815-30-35-16

ASC 815-30-35-25

ASC 815-30-35-31

ASC 815-35-35

ASC 815-20-35

OTHER BROAD TRANSACTIONS

Accounting Standard

FASB Codification

Transfers

FAS 140/FAS 166***

 

FAS 156

ASC 860, ***Not yet codified

ASC 860-50-35 and 860-50-50-5

Consolidations

FIN 46R/FAS 167***

 

ARB 51

FAS 160

EITF 96-16

EITF 04-5

EITF 85-12

ASC 810, ***Not yet codified

ASC 810-10

ASC 810-10-65-1

ASC 810-10-25-1 thru 14

ASC 810-20-25-1 thru 20, and 810-20-55-1 thru 16

ASC 810-10-25-15

Leasing

FAS 13

FAS 98

EITF 97-10

EITF 01-8

EITF 00-13

ASC 840

ASC 840-40

ASC 840-40-55

ASC 840-10-15/55

ASC 360-20-15/55

Foreign Currency Matters

FAS 52

EITF D-55

ASC 830

ASC 830-10-45-12 and 830-10-55-2

 

Compliance Tools: More Codification Cheat Sheet Information

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ToolsHere is more codification information from the FASB Accounting Standards.  Please verify the accuracy of this information prior to relying on it. 

We hope this information is helpful! 

We have a 30+ page listing of Codification cross reference information available for download via this link.

LOANS

Accounting Standards

FASB Codification

Classification

FAS 65

SAB 109 (Topic 5: DD)

ASC 948-310

ASC 815-10-S99-1

Recognition

FAS 91

SOP 01-6

SOP 03-3

FAS 157

FAS 159

ASC 310-20

ASC 310-10, 835-30

ASC 310-30

ASC 820

ASC 825-10-25

Impairment / Other Events

FAS 5

FAS 114

SAB 102 (Topic 6:L)

FAS 15

EITF 01-07

ASC 450

ASC 310-40

ASC 310-10-S99-4

ASC 310-40

ASC 310-20-35-11

Securities/Other Investments

Accounting Standard

FASB Codification

Classification

FAS 115/FAS 124

FAS 155

APB 18

EITF 04-5

EITF 02-14

EITF 03-16

ASC 320

ASC 815-15-25

ASC 323-10-35

ASC 810-25 and 55

ASC 323-10-55

ASC 323-30-15 and 35

Recognition

FAS 91

EITF 96-15

FAS 157

FAS 159

ASC 310-20

ASC 320-10-35, 830-20-35

ASC 820

ASC 825-10-25

Impairment / Other Events

FSPFAS 115-1/124-1

FSPFAS 115-2/124-2

SOP 03-3

EITF 99-20

FAS 141R

ASC 320-10-35

ASC 320-10-65

ASC 310-30

ASC 325-40-15, 35, and 55

ASC 805

Distinguishing Liabilities vs. Equity

Accounting Standard

FASB Codification

Classification

FAS 150

ASR 268

FAS 133

EITF D-98

FSP APB 14-1

ASC 480

ASC 480-10-S99-3A

ASC 815

ASC 480-10-S30 and S55

ASC 470-20

Recognition

APB 14

EITF 98-5

EITF 00-27

ASC 470-20

ASC 470-20

ASC 470-20

Liabilities

Accounting Standard

FASB Codification

Classification

FAS 5

FAS 6

FAS 78

FIN 45

FTB 79-3

ARB 43

EITF 86-30

ASC 450

ASC 470-10

ASC 470-10

ASC 460

ASC 470-10-45-2 and 50-3

ASC 440-10, 450-20, 470-10, 505-20

ASC 470-10-45-1 and 55-3 thru 6

Recognition

FAS 84

APB 26

AIN-APB 26

APB 21

ASC 470-20

ASC 470-50

ASC 470-20-40-4 and 470-50-15-3 and 40-5

ASC 835-30

Impairment / Other Events

FAS 15

EITF 02-04

EITF 96-19

EITF 06-6

EITF 98-14

ASC 470-60

ASC 470-60-55

ASC 470-50-40/55

ASC 470-50-40-12, 40-15 thru 16

ASC 470-50-40, 45, and 55

 

Compliance Tools: Pre-IPO Preparedness Webinar

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ToolsJoin us for a great discussion on things you should consider prior to going public.  This discussion is free and open to everyone.  

Topic: Pre-IPO Preparedness

Interactive discussion about planning for public offerings, with an international perspective on compliance considerations.

Hosts: 
Larry Harding, President, High Street Partners
Teresa Bockwoldt, CEO, Vibato
Jim Anderson, President, Silicon Valley Bank Analytics

Date:

  • March 4, 2010
  • 1:00 - 4:00 pm (EST) 

Cost:

Free

register button

Sponsors:

Vibato

Silicon Valley Bank

OC

 

GTN

HSP

 

Compliance Tools: How to properly review a SAS 70 - the checklist

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ToolsSo I can't tell you how many times I have asked a client if they have reviewed the SAS 70's of their applicable service providers (ADP, Equity Edge, Wells Fargo, etc.) and I get the old "Yep - reviewed it and even signed the cover to prove it." To which I reply, "OK, so what controls does it tell you that you must have to ensure your product/cash is safe?" 

<INSERT BLANK LOOK HERE>

Then I get..."I DON'T HAVE TIME TO READ THAT WHOLE THING?!?! I received it, isn't that good enough?"

So yes, reading a SAS 70 would be equivalent to chewing glass since the things are typically 50+ pages of pretty much all together boring information (unless you enjoy audit talk (which I actually do)) BUT, they do require a read and actually, an analysis. 

SAS 70's will tell you all kinds of information including:

  1. What controls were tested at your service provider
  2. What deficiencies were found
  3. What controls they expect you to have in order to protect your products/cash
  4. and lots more.

The way to properly review a SAS 70 is to examine all of the information in the document (all 50+ pages) and then come to a conclusion about how the vendors control environment, or lack thereof, could impact your company and whether or not your assets are at risk because of their controls...or....lack thereof.

If that seems confusing, it basically is so what I recommend is for you to use our SAS 70 review checklist.  It will tell you what to look for and after it is filled out once, all you will need to do is a cursory review in the following years to ensure the answers and conclusions are staying consistent.  Our checklist does not take the place of your inside knowledge about your company and how the details in the SAS 70 could impact you but it will give you some structure around what you should look for and the questions you should ask yourself after you have read the SAS. 

The checklist is complimentary and available for download via this link.

Remember, service providers who create a SAS 70 typically have a material amount of goods or cash of yours and could truly cause a bad day if said goods / cash walked away because of lack of internal control - ESPECIALLY - if they told you there was a problem in their SAS 70 and you didn't make the time to read all about it.  So, yes, you must read that thing but spend your time wisely and get our checklist to help you.

SAS70 Stamp

One final point, many SAS 70's cover odd periods such as March 31 - September 15.  If you encounter this odd period of time and if a SAS 70 does not cover your entire fiscal year period then you must request a "Negative Assurance Memo" or a "Gap Letter" for the remainder of your fiscal year. The names in "quotes" are what people commonly call a letter that you may receive from your vendor that will detail the effectiveness of the vendor's internal controls during the periods between the end of the old SAS 70 and the beginning of the new one or the in-between period when the new one has not been published yet. 

Getting these letters can sometimes be a hassle but your auditors will require this - without fail (I've had external auditors almost hold a 10K filing because a very common payroll provider was late getting their Negative Assurance Memo out.  They would have held the K but the memo was issued in time).  So, start harassing your vendor early about getting the letter so this isn't a roadblock at the 11th hour. 

 

Compliance Tools: IT Controls Network Network Diagram Example Available

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ToolsWe have a wonderful IT General Computer Control network diagram example built in the Microsoft program, Visio, available for complimentary download available via this link.  You must have Visio or at least download the free 2003 Visio Viewer from Microsoft available via this link:

http://www.microsoft.com/downloads/details.aspx?FamilyID=3fb3bd5c-fed1-46cf-bd53-da23635ab2df&displaylang=en

The diagram can be used for general documentation efforts or for compliance purposes (Cobit controls) and is a great head start for someone trying to understand how to complete a network diagram.

Cobit

We hope you enjoy this information and find it useful.

 

Compliance Tools: IT Controls Network Subnet Layout Example Available

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ToolsWe have a wonderful IT General Computer Control subnet layout example built in the Microsoft program, Visio, available for complimentary download available via this link.  You must have Visio or at least download the free 2003 Visio Viewer from Microsoft available via this link:

http://www.microsoft.com/downloads/details.aspx?FamilyID=3fb3bd5c-fed1-46cf-bd53-da23635ab2df&displaylang=en

The diagram can be used for general documentation efforts or for compliance purposes (Cobit controls) and is a great head start for someone trying to understand how to complete a network diagram.

Cobit

We hope you enjoy this information and find it useful. 

 

Compliance Tools: Codification Cross Reference Guide & Cheat Sheets

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ToolsWe have complimentary codification cross reference cheat sheets to help with compliance with the new financial reporting requirements available for download via this link. 

Please note - we uploaded this because we were hoping it would be a useful point of reference.  Any cross-reference tables we provide should be verified for accuracy. 

These sheets offer clear one-to-one guidance and do not really show well in HTML but here is some information that could be useful. 

Standard

FASB Codification Topic

FAS 5

ASC 450 Contingencies

FAS 13

ASC 840 Leases

FAS 52

ASC 830 Foreign Currency Matters

FAS 57

ASC 850 Related Party Disclosures

FAS 87; 88, and 106

ASC 715 Compensation-Retirement Benefits

FAS 95

ASC 230 Statement of Cash Flows

FAS 109 / FIN 48

ASC 740 Income Taxes

Standard

FASB Codification Topic

FAS 115

ASC 320 Investments-Debt and Equity Securities

FAS 123(R)

ASC 718 Compensation-Stock Compensation

FAS 128

ASC 260 Earnings Per Share

FAS 130

ASC 220 Comprehensive Income

FAS 131

ASC 280 Segment Reporting

FAS 133

ASC 815 Derivatives and Hedging

FAS 140 / FAS 166

ASC 860 Transfers and Servicing

Standard

FASB Codification Topic

FAS 141(R)

ASC 805 Business Combinations

FAS 142

ASC 350 Intangibles-Goodwill and Other

FAS 143

ASC 410 Asset Retirement and Environmental Obligations

FAS 144

ASC 360 Property, Plant, and Equipment

FAS 146

ASC 420 Exit or Disposal Cost Obligations

FAS 150

ASC 480 Distinguishing Liabilities from Equity

FAS 157

ASC 820 Fair Value Measurements and Disclosures

Standard

FASB Codification Topic

FAS 165

ASC 855 Subsequent Events

FAS 168

ASC 105 Generally Accepted Accounting Principles

ARB 51 / FIN 46(R) / FAS 160 / FAS 167

ASC 810 Consolidation

APB 18

ASC 323 Investments-Equity Method and Joint Ventures

APB 28

ASC 270 Interim Reporting

APB 29

ASC 845 Non Monetary Transfers

FIN 45

ASC 460 Guarantees

 

Compliance Tools: Codification (TM) Cheat Sheet - The ASC Topic Listing

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ToolsHere you go gang, more codification information. I hope this is useful and please review it for accuracy before relying on it.  This is a link to a nice article about Codification: http://asc.fasb.org/imageRoot/63/6537863.pdf

Format

ASC XXX-YY-ZZ-PP

  • XXX = Topic
  • YY = Subtopic
  • ZZ = Section
  • PP = Paragraph

100 General Principles

105 Generally Accepted Accounting Principles

200 Presentation

205 Presentation of Financial Statements

210 Balance Sheet

215 Statement of Shareholder Equity

220 Comprehensive Income

225 Income Statement

230 Statement of Cash Flows

235 Notes to Financial Statements

250 Accounting Changes and Error Corrections

255 Changing Prices

260 Earnings Per Share

270 Interim Reporting

272 Limited Liability Entities

274 Personal Financial Statements

275 Risks and Uncertainties

280 Segment Reporting

300 Assets

305 Cash and Cash Equivalents

310 Receivables

320 Investments-Debt and Equity Securities

323 Investments-Equity Method and Joint Ventures

325 Investments-Other

330 Inventory

340 Other Assets and Deferred Costs

350 Intangibles-Goodwill and Other

360 Property, Plant, and Equipment

400 Liabilities

405 Liabilities

410 Asset Retirement and Environmental Obligations

420 Exit or Disposal Cost Obligations

430 Deferred Revenue

440 Commitments

450 Contingencies

460 Guarantees

470 Debt

480 Distinguishing Liabilities from Equity

500 Equity

505 Equity

600 Revenue

605 Revenue Recognition

700 Expenses

705 Cost of Sales and Services

710 Compensation-General

712 Compensation-Nonretirement Postemployment Benefits

715 Compensation-Retirement Benefits

718 Compensation-Stock Compensation

720 Other Expenses

730 Research and Development

740 Income Taxes

800 Broad Transactions

805 Business Combinations

808 Collaborative Arrangements

810 Consolidation

815 Derivatives and Hedging

820 Fair Value Measurements and Disclosures

825 Financial Instruments

830 Foreign Currency Matters

835 Interest

840 Leases

845 Nonmonetary Transactions

850 Related Party Disclosures

852 Reorganizations

855 Subsequent Events

860 Transfers and Servicing

900 Industry

905 Agriculture

908 Airlines

910 Contractors-Construction

912 Contractors-Federal Government

915 Development Stage Entities

920 Entertainment-Broadcasters

922 Entertainment-Cable Television

924 Entertainment-Casinos

926 Entertainment-Films

928 Entertainment-Music

930 Extractive Activities-Mining

932 Extractive Activities-Oil and Gas

940 Financial Services-Broker and Dealers

942 Financial Services-Depository and Lending

944 Financial Services-Insurance

946 Financial Services-Investment Companies

948 Financial Services-Mortgage Banking

950 Financial Services-Title Plant

952 Franchisors

954 Health Care Entities

958 Not-for-Profit Entities

960 Plan Accounting-Defined Benefit Pension Plans

962 Plan Accounting-Defined Contribution Pension Plans

965 Plan Accounting-Health and Welfare Benefit Plans

970 Real Estate-General

972 Real Estate-Common Interest Realty Associations

974 Real Estate-Real Estate Investment Trusts

976 Real Estate-Retail Land

978 Real Estate-Time-Sharing Activities

980 Regulated Operations

985 Software

995 U.S. Steamship Entities

ASC Section List

05 Overview and Background

10 Objectives

15 Scope and Scope Exceptions

20 Glossary

25 Recognition

30 Initial Measurement

35 Subsequent Measurement

40 Derecognition

45 Other Presentation Matters

50 Disclosure

55 Implementation Guidance and Illustrations

60 Relationships

65 Transition and Open Effective Date Information

70 Grandfathered Guidance

75 XBRL Definitions

S99 SEC Materials

 

Sarbanes-Oxley Project Conclusion Memo Available

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ToolsWe have a great SOX project conclusion memo available for complimentary download available via this link.  The idea with this document is to have a project wrap-up memo detailing, at a high-level, what happened with the project and the conclusions reached.  An example of some of the discussion topics within the document include:

  1. Scoping & Risk Assessment
  2. Selection of Business Units / Locations
  3. Entity Level Assessment
  4. Activity Level Assessment
  5. Evaluation of Deficiencies

All you will need to do is modify the language within the headings slightly to match your situation.  Again, as we have said before, it is always easier to edit something already drafted than to start from scratch. 

We hope you enjoy this information and find it useful.  It is a nice way to put a bow on the project and present data to the Audit Committee, investors, shareholders, and management.

 

Don't pay for an Ethics Line / Whistleblower Hotline to pass Sarbanes-Oxley

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ToolsOne of the requirements as laid out by the Committee of Sponsoring Organization or COSO for the Entity Level control is a whistleblower hotline. 

Many organizations have sprung up offering this service in a variety of forms.  One of the most sophisticated I have seen included a voice camouflage (think 20/20 and the way the voice is changed when an undercover person speaks). 

These are wonderful alternatives for companies who are able to afford it but do not be fooled into thinking that an anonymous hotline is required to pass Sarbanes-Oxley. 

Here are some free options that we have implemented that have successfully passed audit:

  1. Installing a separate line in the CFO's office and publishing the number on posters in the break room & in the employee handbook.  Sure, this is not necessarily anonymous but with some creativity (i.e., pay phones), people can make it relatively anonymous.  We even did this with the CFO's regular line.
  2. Posting the email account of the Audit Committee Chair on a poster in the break room and in the employee handbook to let people know that if they have a concern, they should write - not call because a number was not available - the Audit Committee Chair directly.  The auditors fussed a little because they were used to seeing "hotlines" that were manned by an independent 3rd party but in some cases, this is just not an expense that companies can afford.  $100+ per month is $100!  And again, in this case, a person could create an anonymous email from Yahoo! or MSN that would provide the level of anonymity they desire. 

The point of a "Whistleblower Hotline" is to have an avenue whereby people can explain a grievance in a manner that is taken seriously; that does not mean you are required to pay for a subscription to a service. 

An interesting tidbit, in my over 50 implementations of SOX, the most significant whistleblower communications I have witnessed have come from vendors and customers - not employees. 

We have a nice Whistleblower Hotline poster that you made download via this link after registration.  The file is in Microsoft® Publisher so you may change it as necessary.  Here is an example of what it looks like:

Whistelblower

 

Audit Committee / Board Sarbanes-Oxley Presentation Templates Available

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LeftHaving trouble deciding what to present to your Audit Committee or Board of Directors about your Sarbanes - Oxley efforts for the year? 

We have a complimentary Audit Committee / Board of Directors presentation template that could be just the thing to help you out.  We here at Vibato are believers that it is easier to get your brain going and edit something that is already drafted then starting from scratch so feel free to ask for a copy via this link.

 

More codification cross reference cheat sheet information!

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ToolsWe have some codification(tm) cross reference cheat sheets information available to help with compliance with the new financial reporting requirements available for download via this link. 

This information is intended to be useful but you should verify its accuracy prior to relying on it.

These sheets offer clear one-to-one guidance including and do not really show well in HTML but here is some information that could be useful:

Accounting Standard

Accounting Standards Codification

FIN 45 Guarantor's Accounting and Disclosure Requirements for Guarantees, Including Indirect Guarantees of Indebtedness of Others-an interpretation of FASB Statements No. 5, 57, and 107 and rescission of FASB Interpretation No. 34 ASC 460 Guarantees
FIN 46(R) Consolidation of Variable Interest Entities (revised December 2003)-an interpretation of ARB No. 51 ASC 810‐10 Consolidation
SFAS 5 Accounting for Contingencies ASC 450 Contingencies
SFAS 34 Capitalization of Interest Cost ASC 835‐20 Interest ‐ Capitalization of Interest
SFAS 35 Accounting and Reporting by Defined Benefit Pension Plans ASC 960 Plan Accounting ‐ Defined Benefit Pension Plans
SFAS 66 Accounting for Sales of Real Estate

ASC 360‐20 and ASC 976 Property, Plant, and Equipment ‐ Real Estate Sales; and Real Estate ‐ Retail Land

SFAS 67 Accounting for Costs and Initial Rental Operations of Real Estate Projects ASC 970 Real Estate ‐ General

SFAS 91 Accounting for Nonrefundable Fees and Costs Associated with Originating or Acquiring Loans and Initial Direct Costs of Leases-an amendment of FASB Statements No. 13, 60, and 65 and a rescission of FASB Statement No. 17

ASC 310‐20 Receivables ‐ Nonrefundable Fees and Other Costs

SFAS 95 Statement of Cash Flows ASC 230 Statement of Cash Flows
SFAS 133 Accounting for Derivative Instruments and Hedging Activities ASC 815 Derivatives and Hedging

SFAS 140 Accounting for Transfers and Servicing of Financial Assets and Extinguishments of Liabilities‐a replacement of FASB Statement No. 125

ASC 860 Transfers and Servicing
SFAS 141R Business Combinations ASC 805 Business Combinations

SFAS 144 Accounting for the Impairment or Disposal of Long‐Lived Assets

ASC 360‐10 Property, Plant, and Equipment ‐ "Impairment or Disposal of Long Lived Assets" subsections

SFAS 157 Fair Value Measurements ASC 820 Fair Value Measurements and Disclosures

SFAS 160 Noncontrolling Interests in Consolidated Financial Statements-an amendment of ARB No. 51

ASC 810‐10‐45 and 65 Consolidation ‐ Other Presentation Matters; and Transition and Open Effective Date Information

 

Compliance: SOP 97-2 Revenue Recognition Checklists Available

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ToolsWe have a great SOP 97-2 revenue recognition checklist available that is intended for use with each sale made of software; fill the checklist out and it will take you through the revenue recognition issues you may want to consider when recognizing revenue related to sale of software.  The checklist is in Microsoft Excel and could be helpful for companies dealing with Sarbanes-Oxley issues or not.  Registration is required to receive the checklist.  You may download the checklist by clicking on this text.

We hope you find this information useful.  Please check back often and look through our other blog posts via the links on the left side of this page to find other free useful tools and solutions that may help your organization become more efficient and effective.

 

Sarbanes-Oxley Webinar: Internal Controls for the Equity & Stock Administration Process

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ToolsWe have pre-recorded our webinar series to allow interested parties to view them at their leisure.  The eleventh available webinar entitled, "Internal Controls for the Equity & Stock Administration Process" is available for download by clicking on this text. 

This webinar is intended for listeners who would like to learn about internal controls & the Sarbanes-Oxley requirements surrounding the equity & stock administration process.  Listeners will learn about the best-practice steps within this process including issues surrounding FAS 123 (R) / ASC 718 Compensation-Stock Compensation and how your company can prepare your documentation in such a way that will be best suited for external audit and internal efficiencies. 

We hope you find this information useful.  Check back frequently as we are in the process of pre-recording webinars on a variety of topics. 

 

Sarbanes-Oxley Webinar: Internal Controls for the AR / Revenue Process for Software Companies

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ToolsWe have pre-recorded our webinar series to allow interested parties to view them at their leisure.  The tenth available webinar entitled, "Internal Controls for the AR / Revenue Process for Software Companies " is available for download by clicking on this text. 

This webinar is intended for listeners who would like to learn about internal controls & the Sarbanes-Oxley requirements surrounding the accounts receivables / revenue process for software companies.  Listeners will learn about the best-practice steps within this process including issues surrounding SOP 97-2, EITF 00-21, and SAB 104 and how your company can prepare your documentation in such a way that will be best suited for external audit and internal efficiencies. 

We hope you find this information useful.  Check back frequently as we are in the process of pre-recording webinars on a variety of topics. 

 

Sarbanes-Oxley Webinar: Internal Controls for the AR / Revenue Process

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ToolsWe have pre-recorded our webinar series to allow interested parties to view them at their leisure.  The ninth available webinar entitled, "Internal Controls for the Accounts Receivables / Revenue Process" is available for download by clicking on this text. 

This webinar is intended for listeners who would like to learn about internal controls & the Sarbanes-Oxley requirements surrounding the accounts receivables / revenue process.  Listeners will learn about the best-practice steps within this process including best practices surrounding side letter certificates and when they should be used to ensure your company is protected from your sales team making commitments to customers that your company may or may not agree with. 

We hope you find this information useful.  Check back frequently as we are in the process of pre-recording webinars on a variety of topics. 

 

Sarbanes-Oxley Webinar: Internal Controls for the AP / Purchasing Process

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ToolsWe have pre-recorded our webinar series to allow interested parties to view them at their leisure. The eighth available webinar entitled, "Internal Controls for the Accounts Payables / Purchasing Process" is available for download by clicking on this text.

This webinar is intended for listeners who would like to learn about internal controls & the Sarbanes-Oxley requirements surrounding the accounts payables / purchasing or contact to cash process. Listeners will learn about the best-practice steps within this process including how to prepare payment documentation in a way that will ease the audit burden and ideally save in audit fees.

We hope you find this information useful. Check back frequently as we are in the process of pre-recording webinars on a variety of topics.

 

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