Re: Sarbanes-Oxley Act of 2002

[Lisa Wright <liwright -at- earthlink -dot- net>]

Anthony,
Hopefully you've already reviewed the messages in the TechWr-L archive 
from last month. There were also some discussions last year.
Are you just asking out of curiosity or have you been asked to do some 
specific things? Curiosity is great, but if you have specific areas 
we'll be able to better answer if you tell us what they are! ;-)

The PCAOB requirements were published last month. They specify a good 
deal, including documentation requirements, as does the original 
legislation. You need a process narrative, a flowchart, something 
documenting the controls and the objectives (there is a slew of 
information you have to provide around controls) and test plans.

I am still doing QC review for a whole slew of SOX 404 processes. 
Interesting today, my software documentation training kept coming into 
play and I kept wanting to know about systematic things that weren't 
really relevant from a financial reporting perspective. That's one of 
the big things I've had to do is switch my mindset. It's also a big 
challenge for the people developing the information that is documented. 
The people who have the information are usually very concerned with 
operational/process controls, when SOX is largely concerned with 
controls that have a material impact on financial reporting. It's 
difficult for them to separate from that--they want you to include all 
sorts of information that isn't relevant, and it's the job of the 
project team to empathize with their concerns without getting caught up 
in them because the audience for your documents is the external audit 
team, not the operational folks.

This week I'm helping one of my teams organize their information in a 
logical order, find gaps and assumptions, etc. Really not all that 
different, just a different focus. Still basically acting as an editor.	

The sox-online.com site has lots of good information. The Approaches 
section might be a good place to start because it describes an overall 
project framework and the important role of documentation. The site must 
be optimized for IE...it's not behaving correctly with Firefox.

Lisa

Anthony wrote: