Saturday, April 30, 2005

What needed to know for Sarbanes-Oxley compliance

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Here is the list of questions that, according to Ernst and Young, need to be answered in order to gauge a company's compliance with the Sarbanes-Oxley act.

1) How are off-balance-sheet transactions and commitments tracked and reported?
2) Are payments to the external auditing firm monitored through the transactional flags on purchase orders, check requests, or other means within the system?
3) Are rolling forecasts deployed throughout the business (business unit, product line, functional levels)?
4) How many tools are used in the forecasting process? The budgeting process?
5) Do the reporting systems trace back to the general ledgers?
6) Is cash flow from operations and generally-accepted-accounting-principles (GAAP) cash flow automatically calculated?
7) Are key measures (drivers of financial results) delivered to operational manager's desktops daily, weekly, monthly?
8) Are tax reporting systems integrated with the company's consolidation system?
9) Are consolidation and reporting activities performed on spreadsheets?
10) Do transactional reporting systems have agent-based alerts?
11) How are manual entries identified and approved?
12) How much time is spent compiling data and the financial statements versus analyzing the data?
13) How many top-level adjustments are made in the consolidation process?
14) Are reporting activities performed on spreadsheets?
15) How often is control documentation updated for new changes to the internal controls (transactional and financial statement)?
16) Are controls in place to ensure that any off-balance-sheet items are properly approved?
17) Do reporting systems flag reserves and other estimated accounts?
18) Have the systems been updated to identify new responsibilities under the Sarbanes-Oxley Act?
19) Are earnings forecasts tied to predictive models?
20) Do you forecast your business on cash flow drivers?
21) Are variance between the forecast and actual results reviewed and causes identified?
22) How long is the process to develop forecasts? Budgets?
23) Is there a significant difference between financial statements depending on timing, function, or system?
24) Are standard charts of accounts used across the company?
25) How long does it take the company to get the results of operations?
26) What procedures are in place by the company to detect and prevent fraud?
27) Has the company identified high risk areas where fraud may occur and developed controls to prevent this from occurring?
28) Are the following categories of non-financial drivers measured: Leadership, communication, brand equity, reputation, networks/alliances, technology, human capital, culture, innovation, intellectual capital, or adaptability?
29) Do sales systems flag quarter-end sales volumes over selected limits?
30) How long does it take to develop ad hoc reports?
31) Do you model the sensitivity of your off-balance-sheet commitments (swap agreements, foreign exchange risk, purchase commitments, etc.)? How often?
32) Does the company have the ability to determine the profitability by using "what if" scenarios?
33) Have financial models been created for all high-risk operations, programs, etc.?
34) How long does it take to create the management package?
35) Does each operating unit have a financial model for the key drivers of its business?
36) Are documents backed up periodically to ensure significant reports and information are maintained?
37) Does the company have a retention policy for electronic information?
38) Are internal control reviews incorporated into all new system implementations (financial and non-financial)?
39) How often do you back up your data?
40) What controls are in place over record retention to avoid tampering with the data?
41) What best describes your IT capabilities related to financial transaction processing in your company?
42) How many control weakness/changes have there been to the financial statements controls (including in the authorization of transactions, safeguarding assets, maintaining records and over the reconciliation process) in the past year?
43) How many different systems are involved in the financial statement development process?
44) Are IRS and other data retention requirements being met?
45) Is your starting point for your tax return GAAP-audited financial statements?
46) Are there flags in place to alert key resources of specific transactions taking place in the company?
47) Does the company review its transactions for unusual entries?
48) What controls are in place to detect wire/mail?

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