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Yes, exactly, this is all process documentation. However, the difference
from what we are used to as process documentation is that it is only
concerned with processes that relate to getting financial information into
the financial statements. This can get a little fuzzy, especially when
you're dealing with collecting revenue, because that can be very tightly
tied to operational procedures. We had a lot of difficulty in some areas
separating operational from financial processes. It was especially difficult
for the process owners, who didn't understand why we sometimes wanted to
leave out certain information. The auditors are looking for different
things.
The legislation requires both verbal and visual documentation, so we did
written narratives in Word and flowcharts in Visio. We also have a
Risk-Control document in Excel that defines all the controls, and test plans
(also Excel) that describe how the controls will be tested. A great deal of
my QC work is to ensure that all those documents match up and controls are
referenced correctly across all 4 documents. This is entirely manual in our
setup.
I don't know if anyone has done any automated toolsets yet that are specific
to SOX 404, but I can see the potential. I did some minimal automation in
terms of using fields in Word/Visio, but that's about it. I can see
parallels with software development docs/tools, such as tying a feature to a
document; you could do the same thing with controls, and tie them to
processes. I don't know if a document management system could also be used
for something like that (maybe more content management?). It would certainly
help with workflow tracking. I've got almost 70 processes to track through
multiple reviews, 4 documents each, all done manually in Excel. There's got
to be a better way.
I am curious if there are other industries where multiple types of
regulatory documentation are required and if there are toolsets to help
automate?
Lisa
-----Original Message-----
From: bounce-techwr-l-53104 -at- lists -dot- raycomm -dot- com
[mailto:bounce-techwr-l-53104 -at- lists -dot- raycomm -dot- com] On Behalf Of John Posada
Sent: Wednesday, March 10, 2004 2:36 PM
To: TECHWR-L
Subject: RE: Sarbanes-Oxley 404 Project Information (LONG)
Lisa...that was a very thorough explanation. I learned stuff.
Is it safe to assume that a great deal of documenting SOX is documenting
processes. Is this done verbally or visually (i.e., flow charts).
Is there software designed specifically for this or is this a Frame/Word and
Visio operation?
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