萨班斯-奥克斯利法案404条款的实施.ppt

Enterprise Solutions Group Sarbanes - Oxley Sec. 404 Implementation Framework for Evaluating Deficiencies Topics to be Covered Update on recent Lessons Learned from completed Y2 US and FPI 404 engagements Definitions in A Framework for Evaluating Controls Exceptions and Deficiencies (the “Framework”) Framework charts and explanations Illustrative exceptions evaluated through the Framework Lessons Learned – FPI Frequent Material Weaknesses Accounting documentation, policy and/or procedures. Control environment. Competency, training and sufficiency of accounting resources. Information technology, software, security and access. Segregation of duties. Presentation and classification of the statement of cash flows. Revenue recognition. Income tax accounting. Derivative financial instruments. Related parties. Inventory and cost of sales. Statistics – Material Weaknesses –  Lessons Learned - Evaluation of Deficiencies Framework for evaluating control exceptions and deficiencies continues to be a useful tool: Still required significant judgment by management and the auditor; Additional practical experience will be helpful. Areas which created the most difficulties: Interim materiality; Aggregation; “Could factor”; Compensating controls; Well reasoned position. Lessons Learned - Remediation Point in time concept allowed companies to remediate existing material weaknesses: Controls must be designed, in place and capable of operating as of year-end; Must be able to demonstrate operating effectiveness for a sufficient period of time. (See next slide for details of “sufficient period) Remediation took longer than expected: Number of control weaknesses; IT remediation was time consuming – particularly ITGC. Significant amount of remediation in Year 1 was a “stop gap” approach; progress made Year 2, but more to do in Year 3. Frequency/Minimum time frames Lessons Learned – Market Reaction Although there has been “one off” reaction to ineffective ICFR market general