PCAOB Alert!
"PCAOB Proposes Auditing Standard on Communications with Audit Committees, Amendments to PCAOB Interim Standards
Washington, D.C., March 29, 2010 --The PCAOB today proposed for comment an auditing standard on Communications with Audit Committees, and a series of related amendments to its interim standards.
The proposal addresses requirements for auditors to communicate with audit committees of public company boards of directors. The proposal considers a number of factors, including the importance of accounting judgments and estimates in financial reporting. "
To read the full release, click here.
Great article from my dear friend and mentor Clark Keeler at Burr, Pilger, Mayer:
The Tip
In a 2007 interview, Michael Koss, the CEO of Koss Corp., complained bitterly about the burden of Sarbanes-Oxley (SOX). He said hours wasted in audit committee meetings would be better spent on “strategic planning.” Considering the $31 million fraud at a company with only $38 million in annual sales, it looks like Mr. Koss was in fact wasting his time. I’m not sure what they talked about at those audit committee meetings, but apparently it wasn't internal controls. The fraud at Koss triggered a fire-storm of litigation that may yet destroy the company his father founded.
Here’s the tip: Think Seriously About Internal Controls.
Many corporations have developed what I call a “compliance mentality” when it comes to internal controls; doing just enough to satisfy the requirements of SOX. The sad truth is that internal controls don’t get much more than “lip service” at most U.S. companies. Almost every fraud I see, and I see a lot of them, involves inadequate segregation of duties and inadequate supervisory review; both are basic internal controls. Good internal controls will prevent most frauds from happening and find them faster when they do occur. The difference between a small fraud and one that involves millions is typically a matter of time; in my experience it’s about a year. If you’re not thinking seriously about your internal controls, you’re “whistling past the graveyard”.
From our friends at Burr, Pilger, Mayer:
On March 30 2010, President Obama made history by signing into law the Health Care and Education Reconciliation Act of 2010 (HR 4872). This monumental moment follows last week's passage of the Patient Protection and Affordable Care Act (HR 3590).
Both acts will work hand-in-hand to overhaul the entire health care system of the United States. Select the category below to read about tax changes in the new health care legislation:
To find out more, contact your BPM representative or e-mail us at bpm@bpmcpa.com.
We are again delighted to announce yet another client win for our SOX Compliance Made Simple® product suite! Vibato won ZBB Energy on 3/26/2010 and we are very excited to get started on this great client!
Vibato is delighted to announce that Pizza Inn, Inc has selected us to assist them with their Sarbanes-Oxley / internal controls implementation! We look forward to working with this great client!
After much thought and reflection, I have decided to step down as CEO of Vibato, LLC and instead, I have been appointed to CIO. I feel this change will allow me to focus on doing what I love to do best; helping our clients meet their day-to-day compliance needs and enhancing our product line rather than focusing on Vibato's business needs. Bill Bockwoldt has taken the helm and in all truthfulness, he has been performing CEO activities for a long time. We all feel this change will allow Vibato to get to the next level in our business efforts and allow us to provide even greater customer support than we already do. Please join me in congratulating Bill on this well earned promotion!
The Senate is meeting right now that could cause the inclusion or exclusion of Section 404(b) from the omnibus financial reform bill (H.R. 4173) or the "Wall Street Reform and Consumer Protection Act of 2009."
The amendment, proposed by Reps. Scott Garrett (R., N.J.) and John Adler (D., N.J.), to grant a permanent exemption to Section 404(b) (for those public companies with a market capitalization below $75 million), was NOT included in the bill that is before the Senate for vote now. The amendment could be included in the proposals today.
As it stands now, non-accelerated filers must comply with 404(b) by June 15, 2010; 404(a) has been in effect since 2007 and is not in debate.
Listen to the meeting here:
http://banking.senate.gov/public/index.cfm?FuseAction=Hearings.Hearing&Hearing_ID=b8c4a3bd-db46-4b8d-a759-5024b72204cd
The omnibus financial reform bill (H.R. 4173) or the "Wall Street Reform and Consumer Protection Act of 2009" was passed by the House of Representatives via a vote of 223-202 on December 11, 2009. This bill would seek to permanently grant a 404(b) reprieve for non-accelerated filers (those with a market capitalization below $75 million). The bill must now be passed by the Senate to be put into law and their vote has yet to be scheduled. As it stands now, non-accelerated filers must comply with 404(b) by June 15, 2010; 404(a) has been in effect since 2007 and is not in debate.
We are investigating the report below now and we will keep you posted. The post below is confusing to us because it speaks mainly about a delay and not the repeal. Check back soon for more information.
From Thomson Reuters (thomsonreuters.com):
Thursday, March 18, 2010 7:42 AM
Reform plan makes no room for SOX 404(b) delay
Summary: The financial reform bill the House passed in December included an amendment to delay compliance with SOX Section 404(b). The draft of the bill before the Senate has no such provision. It may take months to see whether the delay makes it to the final version of the bill that emerges from the House-Senate conference.
From the moment Congress embarked on its plan to overhaul the U.S. financial regulatory system, the question of small-company compliance with Section 404(b) of the Sarbanes-Oxley Act of 2002 has been batted around like a volleyball. Now that the latest version of the reform bill has emerged from the Senate Banking Committee, questions about Section 404(b)'s future are bound to be asked in earnest. Unlike the reform bill that passed the House in December, the legislation before the Senate has no provision to delay Section 404(b) compliance.
The House bill also requested the SEC and Government Accountability Office to produce a report on small company compliance by June. Nonaccelerated filers, meaning public companies with floats less than $75 million, are being given until June 2011 to comply with Section 404 (b). Whether other senators friendly to small business will push for the deferral to be added to the bill is not certain.
Victoria Ekstrom, a spokeswoman for the Senate Committee on Small Business and Entrepreneurship, said she does not know if the committee or any of its members will push to include the Section 404 (b) delay. Sen. Mary Landrieu (D-LA) chairs the committee. Sen. Olympia Snowe (D-ME) is the ranking member.
The absence of the Section 404(b) exemption is “unfortunate,” said National Small Business Association spokeswoman Molly Brogan. “Despite the good intentions of enhancing accountability and compliance, Section 404(b) compliance for small businesses is extremely burdensome and costly,” she said.
Most companies can expect to encounter few problems with Section 404(b), said Gordon Weber, a partner in the Minneapolis office of law firm Faegre & Benson. But documentation may prove to be a sore spot. “The level of documentation and verification that is required just becomes excessively costly for them,” he said. Weber said if the exemption does not make it to the final reform bill signed by President Obama, the SEC and Congress will probably hear plenty of complaints. Small businesses spent years asking for, and usually getting, deferrals, and they are bound to continue lobbing lawmakers and regulators.
The PCAOB's Auditing Standard No. 5, (AS 5), An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements, was designed to get auditors to focus on the riskiest portion of a company's internal controls and prepare the way for small company compliance with the management reports in Section 404(a) and the auditor attestations for Section 404(b).
Weber said AS 5 was a positive step, but regulators could do more to help small companies. “I think smaller companies are not opposed to the idea of having the independent auditors do something,” he said. “But they still want it to be better scaled to the size of their operations.”
Vibato is delighted to announce that Callidus Software has selected us to perform their Segregation of Duties Analysis using our SOX Compliance Made Simple® product suite! View our Segregation of Duties Analysis via this link. We look forward to working with this great client!
We are delighted to start offering our SOX Compliance Made Simple Toolset in other languages. To start with, we have a nice Section 404, sub-certification sheet available for free download with registration. Here is a sample of what it looks like:
Please answer the following questions to support this confirmation for your process:
请回答以下问题，来支持确认您的流程 |
Comments (as needed)
解释（如需要） |
| Have you reviewed the process narrative and informed management of any updates required?你是否有查看过过程叙述文字并将所有需要的更新资料通知管理层？ |
|
Does this process have open control deficiencies from prior periods?
从前段时间来看,这个运行过程存在明显的控制缺陷吗? |
|
Have deficiencies been identified this quarter in this process (see the exceptions tab)?
本季度运行过程中,发现缺陷,不足了吗? |
|
Are action plans in place for all deficiencies identified?
这些行动方案替代了所有被认可的缺陷吗? |
|
Register by clicking on the button below to receive this document.
Small Non-Accelerated Filers Now Have a Cost-Effective Option for Sarbanes-Oxley, Section 404(b) Compliance
SAN FRANCISCO, Calif. - February 17, 2010 - Vibato, the only provider of the fixed-price, best-practice, modular approach to meeting Sarbanes-Oxley (SOX) and SAS-related compliance requirements, today announced the release of SOX BASIC®. This revolutionary approach to SOX compliance delivers a size-specific SOX implementation to smaller reporting companies in just one day, and for less than $6,000; a fraction of the cost of competing alternatives and a compelling solution for this under-served segment of the market.
The latest SEC report, "Study of the Sarbanes-Oxley Act of 2002 Section 404 Internal Control over Financial Reporting Requirements," estimates the average cost of outside vendor assistance for companies with less than $75M market capitalization for their 2008 fiscal year to be approximately $82,000 for initial implementation (table 8, pg. 44). This is the result of the traditional time-and-materials approach to scoping and implementing a SOX engagement, but does not align with the budget and resource constraints faced by many smaller public companies today.
With the rapidly approaching deadline of June 15, 2010 for the auditor attestation of internal controls or SOX Section 404(b), non-accelerated filers need a reasonable solution that fits their budget, level of resource availability and ongoing maintenance requirements.
For the first time, a fully-integrated, best-practice approach to establishing and documenting internal controls for smaller public companies, as well as startups or larger companies with smaller initial requirements, is available in the form of a comprehensive toolset that can be implemented in one day and for a fixed price.
"We were impressed with the rapid implementation, thorough integration and cost-effective approach delivered in the SOX BASIC toolset from Vibato," said Rod Meisel, corporate controller, Cereplast, Inc. "The initial implementation was a very straightforward process. It got us on the right track for our year-end audit and met our budget constraints."
SOX BASIC is built on the same proven, integrated framework originally introduced in SOX Compliance Made Simple® (SCMS), but designed specifically for companies with fewer than 25 employees, or who need fewer than 20 internal controls to meet their compliance requirements. SOX BASIC includes the features listed below in a unique integration of the industry-proven, best-practice approach offered in the SCMS framework:
- Support - Includes consulting time to perform the implementation and help set up a controls testing plan.
- Risk Assessment - Measures both quantitative and qualitative factors for determining in-scope processes and identifying the high-risk areas of the business.
- Control Matrix - Supports up to 20 predefined best-practice controls available from the 17 process cycles currently offered by Vibato, covering all key areas of the business in addition to the following fully-integrated items:
o Dashboard to track initial results and ongoing updates
o Internal controls sub-certification for the 302 Attestation
o Automatic change control tracking
o Project plan with milestone deliverables
o Recommended testing sample sizes based on auditor selection
o PBC listing and summary
o Summary of aggregated deficiencies
o One-click roll-forward functionality that saves relevant historical data and prepares the tool for the next year
- Segregation of Duties Analysis - Analyzes 304 unique segregation conflicts, and identifies the specific resources affected along with suggested remediation strategies.
- Integrated Testing and Documentation - Includes test plans and every policy, checklist, form, and other documents necessary to execute each control as written.
SOX BASIC is also available for licensing by financial services and public accounting and consulting firms looking for a different approach to assisting their existing and potential clients with their compliance objectives.
"We developed SOX BASIC specifically for smaller public companies who have limited resources and internal controls needs," said Teresa Bockwoldt, chief executive officer, Vibato. "Our belief is that having a solid best-practice approach to use as a guide while a company grows will give companies an advantage from the start. SOX BASIC allows a company to start very small and scale as they grow."
To download the SOX BASIC product flyer, please click here.
Vibato is delighted to announce that we will be implementing our SOX Basic® product at two more facilities in Shanghai, China for Worldwide Manufacturing USA, Inc. This will allow me to stay in China for another week to complete the implementations. As many of you know, our implementations are very quick; less than 1 day per location. I will be staying an additional day at each location to gather testing evidence and then leaving to come back to the states on 3/19.
Vibato is delighted to announce the win of Magnum d'Or Resources Inc. for Sarbanes-Oxley Compliance. Magnum d'Or Resources came to us as a referral from our friends at
MantylaMCREYNOLDS LLC in Salt Lake City, Utah. We are excited to get started at this great company!
The Clock is Ticking!
SOX 404(b) deadline is June 15, 2010
As many non-accelerated filers impatiently await the results of legislative activity or another SEC reprieve, the clock keeps ticking for 404(b) compliance. Your auditors are going to expect you to provide them with at least two quarters worth of functioning controls data for your year-end filings after June 15. 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. If your year-end is June 30, you only have two weeks to get started! 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 we have never seen that accepted 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 functioning for the following amount of time:
|
Control Frequency |
Functioning Time |
Samples Needed |
|
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. To avoid this potential pitfall, we have options to get you compliant for as low as $5,590 and implemented in less than 1 day. Is it really worthwhile to risk your reputation, your company's stock value, and the potential for a qualified opinion for the limited cost and effort to get this work done?
We would be happy to speak to you about your compliance needs and how to get you quickly and cost-effectively compliant.
February 18, 2010
Vibato Releases SOX Basic® for Small Companies
Vibato, a provider of Sarbanes-Oxley and SAS-related compliance solutions, has announced the release of SOX BASIC for small companies, delivering a size-specific SOX implementation to smaller reporting companies in just one day.
SOX BASIC is designed specifically for companies with fewer than 25 employees, or who need fewer than 20 internal controls to meet their compliance requirements. SOX BASIC includes the following key features:
- Support, including consulting time to perform the implementation and to help set up a controls testing plan;
- Risk assessment, measuring both quantitative and qualitative factors for determining in-scope processes and identifying the high-risk areas of the business;
- Segregation of duties analysis, analyzing 304 unique segregation conflicts, and identifies the specific resources affected along with suggested remediation strategies;
- Integrated testing and documentation, including test plans and every policy, checklist, form, and other documents necessary to execute each control as written; and
- Control matrix, supporting up to 20 predefined best-practice controls available from the 17 process cycles currently offered by Vibato, covering all key areas of the business.
SOX BASIC is also available for licensing by financial services and public accounting and consulting firms looking for a different approach to assisting their existing and potential clients with their compliance objectives.
Posted by: jjaeger @ 12:24 pm
Read the full article here.
March 3, 2010
Vibato Introduces SOX BASIC for Small Public Companies
By Staff
2010 MAR 6 - (VerticalNews.com) -- Vibato, the only provider of the fixed-price, best-practice, modular approach to meeting Sarbanes-Oxley (SOX) and SAS-related compliance requirements, announced the release of SOX BASIC(R). This revolutionary approach to SOX compliance delivers a size-specific SOX implementation to smaller reporting companies in just one day, and for less than $6,000, a fraction of the cost of competing alternatives and a compelling solution for this under-served segment of the market.
The latest SEC report, "Study of the Sarbanes-Oxley Act of 2002 Section 404 Internal Control over Financial Reporting Requirements," estimates the average cost of outside vendor assistance for companies with less than $75M market capitalization for their 2008 fiscal year to be approximately $82,000 for initial implementation (table 8, pg. 44). This is the result of the traditional time-and-materials approach to scoping and implementing a SOX engagement, but does not align with the budget and resource constraints faced by many smaller public companies today.
With the rapidly approaching deadline of June 15, 2010 for the auditor attestation of internal controls or SOX Section 404(b), non-accelerated filers need a reasonable solution that fits their budget, level of resource availability and ongoing maintenance requirements.
For the first time, a fully-integrated, best-practice approach to establishing and documenting internal controls for smaller public companies, as well as startups or larger companies with smaller initial requirements, is available in the form of a comprehensive toolset that can be implemented in one day and for a fixed price.
"We were impressed with the rapid implementation, thorough integration and cost-effective approach delivered in the SOX BASIC toolset from Vibato," said Rod Meisel, corporate controller, Cereplast, Inc. "The initial implementation was a very straightforward process. It got us on the right track for our year-end audit and met our budget constraints."
View the full article here.
Functioning internal controls = cleaner financials and less rework which is not value added. I'm not the only person saying this...
From CFO.com:
Restatements on the Decline
Sarbox and a more tolerant SEC may be why companies are restating financial results less frequently, says a new report.
Alix Stuart - CFO.com | US
March 4, 2010
The number of financial restatements fell in 2009 for the third year in a row, according to a new report. The report, by research firm Audit Analytics, posits that the Sarbanes-Oxley Act and the Securities and Exchange Commission are behind the decline.
Overall, 630 companies filed 674 restatements last year, says the report, representing a 27% decline from 2008. The number of restatements peaked in 2006, when 1,564 companies filed 1,795 restatements."
Read the full article here.
Get out!
How to Take the Risk Out of IPOs
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March 2, 2010
By Paul Ausick, Contributing Editor, InvestorPlace
|
The market for IPOs appears to be getting better in the US. In 2008, just 43 new listings were offered; in 2009 the number went up to 63. So far this year, there are more than 100 companies lined up to go public.
...
One thing that may be helping the market for US IPOs is the perceived increase in transparency resulting from the 2002 Sarbanes-Oxley Act. Where SarbOx was once blamed for sending IPOs to London or Shanghai, now the effects of the act enhance the US's position as a leader in improving corporate transparency and governance.
It's also true that a listing on a US exchange gives a company access to the most liquid market in the world, as well as the prestige that goes along with a US listing. From year-ago lows, the S&P 500 index has increased by about 60%. The index fell from mid-January to mid-February, but has begun to recover its upward movement. That's good news for the IPO market."
Read the full article here.
China is going great. Shanghai is FREEZING cold right now but not snowing.
I am really enjoying my time here with the Intech - Detron & Worldwide Energy and Manufacturing Corp USA teams. Mindy Wang, VP Finance of Worldwide Energy is absolutely amazing and a true success story.
This is my second time implementing our product, SOX Compliance Made Simple®, in China and once again I am amazed at how versatile our controls are. Our best-practice controls not only span industries but also countries. I went in to Intech - Detron today with 20 of our predefined, controls and they fit right in without issue. Intech - Detron believes the controls we put in place today will help with their ISO 9000 requirements as well.
This trip has also allowed us to create some very nice forms, checklists, 302 certifications, and policies written in Mandarin which I will blog about when I return and that we will offer for free download. Check back soon!
Vibato is delighted to announce the win of a full HIPAA implementation with a national insurance firm who specializes in the following products & services:
- Alternative Risk Financing and Risk Transfer
- Captive Formation and Management
- Directors & Officers / Employment Practices Liability
- Errors and Omissions
- Executive Benefits
- Fiduciary / Crime
- Health and Welfare Plans
- Intellectual Property
- Key Person Coverage and Business Perpetuation Planning
- Life, Disability and Long Term Care
- Personal Insurance and Individual Risk Management
- Products Liability
- Professional Liability
- Program Formation and Management
- Property Conservation
- Retirement Savings and Planning
- Risk Management Services
- Self-funded Benefit Plans
- Self-insurance Groups
- Surety
- Wealth Management
- Workers Compensation
- Claims Advocacy and Loss Mitigation
- Client Communications
- Contract Review and Analysis
- EPIC Seminar Series
- Job Site Safety Services
- Risk Control and Loss Prevention
We are delighted to participate in this project!
The PCAOB rejected an application from Price & Gartrell, P.C. to become a public accounting company. The reason for the rejection is as follows:
"PCAOB NO.1 02-2009-006
December 3, 2009
Basis of Disapproval
12. The Board has considered the following information, which includes information obtained by the Board in connection with Price's application as well as the requirements of the Act and the Board's rules -
a. On or about August 17, 2009, Price certified the financial statements, including the balance sheet and income statement, of Indiana Merchant Banking & Brokerage Company, Inc. ("Merchant"), a registered broker-dealer, for the fiscal year ended June 30, 2009, which Merchant subsequently filed with the Commission.
b. Section 17(e) of the Securities Exchange Act of 1934, required that the balance sheet and income statement filed with the Commission by Merchant for the fiscal year ended June 30, 2009 be certified by a registered public accounting firm.
c. On the date that Price certified the Merchant balance sheet and income statement for the fiscal year ended June 30, 2009, Price was not a registered public accounting firm.
d. Although Price's conduct with respect to Merchant's financial statements did not involve, and the Board is unaware of conduct by Price involving, the audit of any "issuer" (as defined in the Act and the Board's Rules), approval of Price's registration application would make it lawful for Price to provide audit reports for issuers.
13. As provided in PCAOB Rules 2106(b)(2)(ii) and 5201 (c), and on the basis of the information described in paragraph 12, the Board identifies the following proposed grounds for disapproving Price's registration application -
a. Price certified the balance sheet and income statement of a registered broker-dealer, for filing with the Commission, for a period with respect to which Price knew or should have known that those financial statements were required by law to be certified by a registered public accounting firm.
b. Price's certification of these financial statements while not registered with the Board appears to demonstrate an unwillingness or inability to exercise sufficient care with respect to relevant legal requirements."
To read the full statement, click here.
Auditing public companies is a privilege, not a right. Just because you are an accountant does not mean you can audit public company financials and Price found this out the hard way. Because this right can be revoked if the PCAOB finds an audit to be inadequate during their review of the auditors work, auditors are sometimes a little paranoid which can cause them to over scope their audits out of fear - it is a never-ending cycle - management over scopes to try to make the auditors happy, auditors over scope to try to make the PCAOB happy. This is why a risk assessment performed and understood by management is VITAL. Management can control the scope of their audits and they should because their auditors will never know their company as well as they do.
Michael Oxley, co-author of the Sarbanes-Oxley Act of 2002, was questioned on whether or not he believed the Supreme Court would find Sarbox unconstitutional. The Supreme Court is currently reviewing the legislation for constitutionality. An auditor from Nevada claims the Public Companies Accounting Oversight Board or PCAOB, put him out of business. He then filed a lawsuit claiming the PCAOB and the legislation is unconstitutional and the case has escalated to the Supreme Court.
"I'd be surprised to see the court find the entire act unconstitutional," said Oxley, a former House member from Findlay, Ohio. But the decision will "almost certainly will come down to a 5-to-4 vote."
Michael Oxley and Richard Thornburgh
Keith Hodan | Tribune-Review
Oxley continued, "We set up the [PCAOB] so the Securities and Exchange Commission would appoint the commissioners, and anything they did would have to be approved by the SEC," Oxley said. He also said he expects a court decision in the next few weeks.
Here is a little irony for you, the PCAOB, who enforce the need to scrutinize financials for reasonableness and accuracy, and, who have the authority to set auditing standards for public companies and can discipline accounting firms whose audits are deemed deficient, can set the fees they charge public companies without any oversight from the President of the United States. To put this into perspective, the US President makes $400,000 a year as a salary for the job. The PCAOB Chairman, Mark Olson, took home $654,406 in 2008 and several other employees took home over $500K. This salary EXCEEDS the $500,000 salary cap set by the Obama administration for executives of banks taking bailout money.
I still stand by my previous statements, since the government had the power to require such things as Sarbanes-Oxley, they should also have the power to regulate how much it should cost companies to comply. If this means the current structure of the PCAOB is unconstitutional because it falls outside of the ability to be overseen by the Government, then it should be changed. The PCAOB enforces the requirement that audit firms be overseen, shouldn't be PCAOB be overseen by someone too?
I will be in Sacramento on Friday, 3/5, taking meetings. I am available at 707-477-0008 in the event someone would like to meet.
Michael Fung, our Senior Technical Developer and I will be in San Diego tomorrow, 3/3, taking meetings. We are reachable at 707-477-0008 in the event someone would like to meet up.
I will be in in Shanghai from 3/6 - 3/13 and then and Shenzhen, China from 3/13- 3/19 taking meetings. I will be reachable at tbockwoldt@vibato.com. I will also be reachable through Andrew Wilson at 510-910-1604 or Bill Bockwoldt at 707-789-9988.
If you are interested in a meeting or dinner then please let me know. I would be delighted to meet and discuss Sarbanes-Oxley needs, FAS 123 (R) / ASC 718 Compensation-Stock Compensation or accounting / finance issues and our products and services.
We have just posted a significant amount of FAS 123(R) ASC 718 Compensation - Stock Compensation codification cross reference information to our Codification Tools page.
View the FAS 123R / ASC Topic 718 Codification Information page by clicking here
This is for all of those KPMG, PwC, IRS, and Federal Reserve people who look at our Codification cross reference tools everyday (including Saturdays....poor things...).
I've moved it all to one page so you can search by terms, etc and I am going to be adding to it shortly. Here is where it is now located:
http://www.vibato.com/resources/codification-tools/
GO CRAZY!