This was an excellent article on why it is more important than ever to accurately document your company-specific risk exposure. The SEC Top 10 List of most frequently questioned issues over the last two years includes “Ineffective internal or disclosure controls”, an area that we believe will be receiving even greater scrutiny in light of the recent Sarbanes-Oxley 404(b) exemption for non-accelerated filers.
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Tags: Sarbanes-Oxley Articles & Information, risk assessment, 404, deadline, 404 audit, Non-accelerated filer 404(b) information, compliance, risk management, Sarbanes-Oxley, audit scope, external auditing, Sarbanes-Oxley for Non-Profits
The Public Company Accounting Oversight Board has made a concept release on the "Possible Rulemaking Approaches to Complement Application of Section 105 (C)(6) of the Sarbanes-Oxley Act of 2002."
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Tags: Sarbanes-Oxley Articles & Information, Announcements, 404, deadline, 404 audit, Non-accelerated filer 404(b) information, compliance, risk management, Sarbanes-Oxley, external auditing
Now that the wait for the 404(b) reprieve is over, it appears that a new trend is emerging to investigate 404(a) statements more closely, as expressed in recent articles on investor and auditor sentiment regarding the legislative change. We are hearing from auditors directly that they will be applying more scrutiny to 404(a) statements made by their clients in their financial reports, to ensure that there is a real basis for self-certification. The newly aggressive SEC and DOJ are expanding personnel and focusing on Corporate Governance and the role of Audit Committees, Directors and Company Officers in Compliance and Financial reporting.
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Tags: Sarbanes-Oxley Articles & Information, risk assessment, Announcements, 404, 404 audit, Non-accelerated filer 404(b) information, Wall Street Reform, risk management, Sarbanes-Oxley for Non-Profits
Here at Vibato, we were recently questioned about what the Wall Street Reform Act means for non-accelerated filers with June 30th year-ends. Some lawyers have been claiming that the Wall Street Reform Act will be retroactively applied to these companies, so we contacted the SEC about the issue.
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Tags: Sarbanes-Oxley Articles & Information, Announcements, 404, 404 audit, Non-accelerated filer 404(b) information, Sarbanes-Oxley, Sarbanes-Oxley for Non-Profits
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!
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Tags: Sarbanes-Oxley Articles & Information, Compliance tools, 404, 404 audit, audit costs, Non-accelerated filer 404(b) information, Sarbanes-Oxley Training, risk management, external auditing
