How Nov. 15, 2004 Deadline for Sarbanes Oxley 404 Compliance Affects You

by: Chris Anderson

Public companies have 90 days from the end of their fiscal year to comply. For those with market capitalization of $75 million or more, this clock starts on Nov. 15, 2004; while all others with less than $75 million market capitalization begin July 15, 2005. Fast Relief for Sarbanes Oxley Section 404 Compliance Section 404 of the Sarbanes-Oxley Act requires management to confirm the effectiveness of their IT and financial controls in an "internal control report", which is contained within the annual report (10-K) issued to the public. But what exactly is an internal control report, and why is it important to you? The Section 404 Internal Control Report First, the internal control report must affirm management’s responsibility for controls and procedure, and second, it must contain an assessment of the effectiveness of the internal controls and procedures for financial reporting. Although both of these issues might at first appear difficult to solve, they are actually not as hard as you would think. Management’s Responsibility for Controls and Procedures Affirming management’s responsibility for controls and procedures means more than to simply say management believes in or trusts their system. The affirmation will also need to include a program for a code of ethics for senior financial officers. The program must include prompt disclosures of any changes to your ethics program. So how do you do this? Business Ethics and Compliance Program You can easily implement a business ethics program using a step-by-step guide for developing your firm’s business ethics and compliance program. This manual will save you time researching, writing and editing your program. It provides sample policies, surveys, forms and training session outlines that are fully editable using MS Word. And it is also fully endorsed by The National Association of Corporate Directors (NACD) as a tool to maintain a culture of integrity. Internal Controls Your internal control report must also contain an assessment of the effectiveness of your internal controls and procedures for financial reporting. In practical terms, control is equivalent to predictability. Everyday management creates forecasts and budgets to predict the future. And the further into the future you can accurately predict, then the more control you have. Achieve More Control Over Your Forecasts And Budgets A training class for creating well defined processes shows you how to attain more control. Real world exercises and examples explain how to increase management effectiveness, achieve process control, communicate clear procedures, and verify if your processes are working. So what about procedures? Procedures Effectiveness For dealing with Section 404 of the Sarbanes-Oxley Act, you can look at products like the Management CFO Value Series that includes Accounting, Human Resources, as well as policies, procedures and forms for other departments. Such procedures will save you time researching best practices, creating a standard format, and thinking of clear and concise paragraphs to write. Easier Section 404 Compliance Your internal control report is the key to your Sarbanes-Oxley Section 404 compliance. You should also look at a business ethics and compliance program, attend a training class for creating well-defined processes to learn more about management effectiveness, and use a CFO Management Value Series to speed the development of your procedures. You want to achieve fast, easy, and effective relief for your Sarbanes-Oxley Section 404 compliance. About the author: Chris Anderson is co-author of policies and procedures manual products, providing the layout, process design and implementation to increase performance. He is currently the Managing Director of Bizmanualz, Inc., and holds a Masters in Business Administration from Pepperdine University and a Bachelor of Science degree in Electrical Engineering from Southern Illinois University. Visit: http://www.bizmanualz.com/accounting?src=ART68 Circulated by Bandoni Media