Not all roads lead to successful IPO

Welcome guest blogger, Jason Chiang. With RGP for nearly 8 years, Mr. Chiang has more than 20 years of experience and expertise in Audit, Risk and Compliance. He has consulted with a range of companies from financial services, biotech, manufacturing, healthcare and other industries. Mr. Chiang is a Certified Public Accountant (inactive) and Certified Internal Auditor. He has served on both sides of the house as a senior audit manager and senior auditor as well as a risk manager. It is evident that he understands the motivations and hurdles facing these organizations and approaches their complex issues with integrity and professionalism.

The following article was written by Jason Chiang (with editing support from Stephenie Buehrle). The approach and recommendations are his.


Not all roads lead to successful IPO

When a company approaches their initial public offering (IPO), it enters a very different arena. Having access to public funds, that is the retirement savings of Main Street USA, the company must meet quarterly SEC filing requirements. This is a significant amount of work. An investment in the people experienced with technical accounting, SEC financial reporting, and Sarbanes Oxley Compliance (SOX) evaluations combined with an investment in systems and tools to do the work efficiently and with completeness and accuracy is crucial to meet the filing deadlines.

One cannot audit all internal controls over financial reporting (ICFR). Thus, performing a SOX risk assessment is necessary to identify the significant accounts and their relevant assertions. If you happen to be one of these companies developing a road-map to your IPO, SOX may not be the place where you want to focus significant time and financial resources, but you realize that it has to get done. Be sure that you consider, at minimum, these critical components:

Risk Assessment                                  

A risk assessment is the process of identifying significant accounts and disclosures and their respective relevant assertions as they relate to financial statements. A properly done risk assessment will allow the company work smart by focusing its internal controls evaluation on the areas where there is a possibility of a material error.

The Risk Assessment must include:

  • Quantitative factors such as account balance, frequency of transactions, dollar value of each transaction; and
  • Qualitative factors such as complexity of related transactions, subjectivity of accounting rules over related transactions, and fraud considerations.
  • As business and risks change, the risk assessment needs to be updated.

Narrative                                                                

A narrative provides mid-level detail of the transactions and internal controls within a business process and includes who, how frequent, and in what location the transactions and controls are being performed. The initial creation of narratives provides the process owners an opportunity to revisit and reflect on the current processes, and make improvements for operational efficiency or control effectiveness. It is a written document that can be read by internal employees, internal auditors, and external consultants and auditors to gain a preliminary understanding of the process. As processes change, the narrative provides a format to document the change.

What critical things must be considered regarding Narratives?

  • The narrative should be written knowing that auditors will be a primary reader and will be looking for controls that mitigate risks.
  • When describing management review processes in the narrative, articulating how the manager gains assurance of the completeness and accuracy of the supporting evidence before signing off. If the manager is using judgment, describing the factors considered.
  • Narratives should be updated as changes are implemented in the organization. The updates should follow a workflow where there is a review process for significant changes.

Control Matrix                                      

A control matrix lists the controls the company has identified to mitigate risks. The control matrix serves as evidence that identified risks are mapped to controls which are to be evaluated for management’s assessment of internal controls. The control matrix also is a primary client document auditors leverage to perform their independent test of controls.

Take care to ensure that:

  • The controls in the Controls Matrix are mapped to risks.
  • The Controls Matrix is in a format where it is sortable or reportable by controls mapped to risks for test of controls purposes, and risks are mapped to controls for an evaluation whether risks are mitigated by controls.
  • Controls in the Controls Matrix should be labeled and provided an abbreviated title (10 words max) for ease of reporting and reference purposes.

Testing                                                                      

Testing is the evaluation of design and operating effectiveness of the company’s controls. The results of testing of controls provide company management with a baseline to that might have impacts to strategic and operational decisions. For publicly held companies, testing is an SEC requirement.

Critical considerations for testing:

  • Important, if deemed necessary, to be able to re-perform the actual control performed by the employee (e.g. for 3-way match of purchase order, invoice, and shipping docs, test that an employee had performed this and has evidence of such, rather than the auditor requesting the 3 docs and testing oneself).
  • When testing management review controls, cannot just accept sign-off, but need to understand the steps and judgments used by the manager, and test accordingly.
  • The documentation of testing should allow someone else to reasonably re-perform the testing. If testing is being relied upon by external auditors, then the breadth of documentation is more important. If not, not all needs to be retained, but should be readily retrievable when needed.

Certifications                                        

Control owners certify to the CFO and CEO that controls are operating effectively on a quarterly basis, and if not operating effectively, the remedial action plans. The control owners are held directly accountable for their controls as they are certifying to the top two officers of the company.

Recommendations for certifications:

  • The number and level of person certifying to the CFO and CEO should be carefully considered. The level should be their direct reports and one level removed to maintain the efficiency and integrity of the certification. If it is a larger organization, there can also be sub-certifications up to the senior manager level.
  • The certification questions should have a combination of checklist questions, as well as, open ended questions to encourage a thoughtful process.
  • Utilizing software for tracking, follow-up, and retention purposes is advised.

Depending on the number of people involved with the inputs into the various components, one might decide that performing and capturing the work in Excel is sufficient, while others might prefer utilizing a SOX tool where there are extra protections in version control while allowing multiple users to perform inputs simultaneously in multiple locations. A SOX tool may also provide management with options for review, analysis and oversight that are not available in Excel.

To avoid unexpected setbacks, be sure to plan enough time into your IPO readiness map for SOX evaluations. The initial SOX program development and implementation is likely to require six months and can vary depending on your access to subject matter experts. Coordination and alignment of the SOX efforts and objectives among the audit committee, senior management, process owners, and internal and external auditors is paramount for a successful implementation.


If your organization is approaching your initial public offering and you’re interested in learning more about how RGP can support you with subject matter expertise and a tailored technology solution to help ensure that you are prepared for your SEC filing and financial reporting requirements, reach out to us (Information@policyIQ.com, 412.263.3330) and we’ll connect you with our RGP colleagues near you!

ICYMI: Assessments and Scoping in policyIQ

Did you miss our recent training session on completing our SOX Risk Assessments and scoping exercises in policyIQ?  Not to worry – we have you covered!

How Can I Catch Up?

If you want to get into the details, we have the training session and materials available for download!

  • You can access the slides here.
  • You can also view the recording from our policyIQ training page.
    The training page is linked from your policyIQ login page – and available from within the online Help Guide.  If you don’t have access to the training page, please reach out and we’ll send you the link!

Just the Highlights, Please!

This training session aimed to ensure that participants are able to…

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We discussed common SOX risk assessments at the financial statement line item level, targeting risk factors like…

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In addition to illustrating how to create the calculation directly in policyIQ, we also acknowledged that some folks love their MS Excel process.  policyIQ can handle that, too, through the import option!

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Then we took a close look at the relationships between the content that allows for the most effective scoping options.

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And finally, we walked through the reports that provide the final step in the scoping process.

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We would love to help YOU get started on your risk assessments in policyIQ, so that we can link into your SOX work for ease of annual scoping.  Contact us today and we’ll meet with you at no cost to help you get on your way!

Our next great feature: Linked Fields in policyIQ

Does the task of updating control documentation in more than one location seem redundant and a drag on your day?

Changing the description or general governing details of any page in policyIQ can create a wave of changes that need to be made in other places in the site.  Wouldn’t it be great to make the update once, and have that update be reflected everywhere?

It definitely would be.  Consider it done!

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The next update of policyIQ will include a new field type: Linked Fields.  This field will be a field that is auto-populated with the data from an existing field  on a linked page.  For our SOX and Audit clients, think about things like control descriptions.  These descriptions are periodically tweaked, and that change needs to be reflected anywhere the description appears.  We’ll create a linked field on our test result pages that are likely linked to this control page, and point it at the description of the control page.  Because of this setup, the control page can be updated, and the test page will automatically pick up those changes.

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Creating new linked fields is easy, and it’s coming to your policyIQ site in the next few months!  Please contact us with any questions or thoughts on how you may take advantage of this huge new feature.

 

Efficiency Throughout the SOX Process

In a number of blog posts, we’ve highlighted the ways that policyIQ can be used throughout the entire SOX process – from risk assessments through issue remediation.  This past Thursday, July 28th, we took an hour to walk through the entire process in a CPE webinar to highlight ways to create efficiency at each step.

Did you miss it?

Before we hit the highlights below, we want to point you to the session recording and the slides, both of which are available for download.

The Big Picture

We highlighted a number of big picture advantages of using policyIQ not just for SOX, but for all of your compliance initiatives.  We talked about…

  • Simplicity of rolling out and managing a cloud-based
  • Advantages of being able to assign security and access
  • And the efficiency of a single source of information through the entire compliance and audit environment.

A single source means that when you make a change in one place, that change feeds all of the different perspectives on the data.

Controls

Efficiency at Every Step

We also dug into the efficiency that can be gained at every step of the process.  Just some of those ideas are presented below.  We also mentioned additional training available for some steps, and have linked those training sessions.

process

  1. Risk Assessments
    • Tie risk assessments at the 10K line item level to your risks and controls for ease of scoping.
  2. Control Updates & Review
    • Allow your control owners to make updates directly in policyIQ as things change, or require regular reviews of control documentation.
  3. Walkthroughs & Testing
    • Collaborate early (and often) with external auditors to ensure that your testing is capturing all of the detail expected.
  4. Issue Tracking & Remediation
    • Assign remediation plans to owners and use automated reminders to ensure responses are provided.
  5. Conclusions & Reporting
    • Utilize flexible reporting capabilities to trace issues back to the vulnerable risks and compensating controls to make a final determination about significant deficiencies or material weaknesses.

 

We also included the supporting functions that feed the process.

 

We’re ready to help you build more efficiency into your SOX program.  Contact us today and ask to speak with our client service team to walk you through implementing some new ideas!  Not yet a policyIQ client?  Contact us and ask us for a personalized demonstration!

Save time with Audit Evidence Collection in policyIQ!

For many years, we have been encouraging our clients to utilize policyIQ for all aspects of their compliance programs – from the assessment of risk through the remediation of issues.  However, during a recent conversation with long-time client, Travis Heyer (Director of Internal Audit at Great Lakes Dredge and Dock), we realized that we had not yet clearly illustrated in a live training session how to effectively request and capture audit evidence within policyIQ.

Travis graciously agreed to work with us to create a training session – and brought his colleague, Amit Patel (Senior Auditor) along with him.  On Thursday, March 31, we presented this session to a large number of very active participants.  (You can check out the recording of the session, or download the slides for a quick overview.)

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It’s really all about saving time

Automating the requests for audit evidence can allow your internal audit team to…

  • Avoid playing “Match the evidence to the request!”
  • Minimize risk of using an old version of a file
  • Waste time sending annoying follow-ups
  • Secure documentation more effectively

It comes down to a huge time savings, freeing up internal audit resources to do the real, value-add work that your organization needs.

Pages or Forms?

While the training presentation focused on an evidence collection process in policyIQ pages, a similar process can be built within policyIQ forms.

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Pages offer the advantage of a two-way link between the Evidence Request and the Test page, so that your internal auditors can simply leave the files attached to the Evidence Request.  Pages also allow more than one individual user to contribute directly to the same Request.  However, utilizing Pages requires that all users who participate in the process of providing evidence are Advanced Users, a more expensive license in policyIQ.

Forms offer their own advantages, allowing for a simple issuing and follow-up process.  However, the link between the Evidence Request form and the Test page is less visible.  Evidence files will need to be downloaded and re-uploaded to the Test page by the auditor.  The significant advantage of the Forms process is that any individual providing evidence needs only to have a Standard User license, a less expensive license that can keep costs low!

Getting started in 5 easy steps

Our training session focused on how to get started in just five easy steps:

  1. Create Evidence Request template
  2. Build list of evidence in Excel
  3. Import evidence request list
  4. Assign requests
  5. Track progress and follow-up

We encourage you to check out the recording or the slides for more details on these steps – and reach out to us to help you to get your bearings and get started!

New Company, New Controls: policyIQ Handled it All

Any quick look around the marketplace reveals that companies big and small are constantly acquired, bought, sold and merged on a constant basis.  Many of these public companies then have to figure how how their SOX compliance will be affected, and this can put a ton of stress on the audit teams that bear the responsibility of “making compliance happen”.

Fortunately for companies using policyIQ that have purchased or merged with others, the SOX issue goes from, “Can we make this transition in policyIQ, as well?” to “WOW.  That was pretty easy!”

A recent long time policyIQ client acquired a company, and each had their own set of risks and controls.  Ultimately, their goal was to combine these two separate entities into one SOX environment, and easily distinguish between SOX work from Company A and Company B.

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Our team and product made this easy.  To begin, we simply added a single-select field on their controls and risks called “Entity”, with options for Company A or B.  By doing so, we created an  easily reportable way of sorting content from one company to another.  This was conducted by an Import to Update (via an Excel document), meaning that much of the work was easily done in a simple spreadsheet offline.  Simple!

All new documentation from Company B was then mass imported into policyIQ a few days later.

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Some companies might like this arranged differently, and that makes total sense.  We had discussed using additional folders to distinguish the risks and controls from company to company.  Advantages?  One less field per page, and a more organized folder structure-less content per folder.  Disadvantages?  There are more folders, and some folks like a really simple structure.  A difference in results or reporting?  None!

Do you feel like you should partner with a policyIQ expert to work on your SOX work this year?  Do you have  a couple of ideas you’d  like to run by us?  Send us an email!   Support@policyIQ.com

It’s true! policyIQ is a misfit among typical software providers.

Have you been burned by a software provider?

Sheesh—who hasn’t?!

You worked for months (years for some), listening to promises from several different people who kept handing you off and never addressing your concerns. You found yourself with more time and money invested than you care to admit and you have grown to look at all software providers with skepticism (if not disgust).

Does this sound familiar?

I hear you. Your frustration was echoed by countless people that I spoke with at a national conference in March. Because a number of people felt compelled to share their horror stories about other providers with me, I got comfortable jumping quickly to the things that make us different than the typical software company:

  • All-in-one_BubblesRGP is NOT a software company! Integrity is at the core of our firm. We want to create great relationships and serve you so impressively that, when you need a consultant, you already know the quality that you can expect from us.
  • We don’t have a huge policyIQ booth at conferences and our software does not have the huge price-tag required to pay for that presence (policyIQ starts at <$5k/year).
  • We don’t sell multiple modules or products and aim to upsell you. policyIQ really does accommodate multiple business areas and needs in one affordable tool.
  • Our goal is to solve for your information, content, process, and workflow challenges across the Governance, Risk and Compliance (GRC) space, not to land a sale.
  • Your sales person does not make commission or hand you off to an implementation team that’s unaware of promises made during the sales process—we walk alongside you the whole way and help to tailor the implementation to your organization’s needs.
  • Our product does what we tell you it does (and we answer truthfully if you ask us about something we don’t do or plan to develop).
  • We have a support team that truly cares to give you excellent and timely service.

We think of our clients as part of our community with whom we will have a long partnership. We listen to your needs, plans, wishes and heartaches and work continuously to problem solve with you.

We’re proud to be a misfit among typical software providers.

pIQ_Misfit_smWe’re ready to prove it and to earn your trust.

We encourage you to take a peek at this introduction to policyIQ, and then reach out to us!  We’d be glad to schedule a personalized tour of policyIQ. Also, we invite you to kick the tires! Sign up for a 30-day trial, completely risk-free.

We look forward to working with you!

Which part of your SOX program do you want to improve this year? This list of resources will help.

Soup to nuts—or Risk Assessment to Review of Evidence, we are ready to help you make your 2016 Sarbanes Oxley compliance work more efficient than ever! You will notice that we have another post this month that talks about rolling forward last year’s SOX work to create the baseline for your 2016 work. Some of you might not want to repeat last year’s work. Maybe you didn’t use policyIQ last year or you’d like to make improvements on what was done in previous years and take advantage of all that policyIQ has to offer. We have some tips and tools to help you:

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  • Risk Assessment – We previously shared a sample template with you that you might want to implement for 2016. If you already have your Financial Statement Risk Assessment complete, we can help you with your plan to import and tie the results of that assessment to relevant assertions and controls. Capturing the full cycle in one place will not only help your organization to be much more efficient, it will also save time and money when your external auditors are looking to connect.
  • PCAOB’s Auditing Standard No. 5 – Are you looking to make improvements to your process and work more efficiently this year? Check out this visual summary or watch the full recording of the webinar that walks through the application of AS5.
  • chart2Link related compliance elements and utilize various reports to monitor progress, analyze performance, and stay on top of your program. We have lots of ideas about SOX reporting. Check out you online Help manual and this post for some ideas.
  • Automate supporting processes – are you still using Word, Excel, and email to manage your 302 Certifications, Control Self Assessments and Narrative Reviews? One of the most frustrating parts of this work is having to inventory the responses and pester people to get their work done. You can literally perform the setup of these tasks one time and then consider it complete forever after using policyIQ’s Forms functionality to automate the inventory and reminders.
  • consultantsGrant External Auditors access to only that content which you want them to see! Have you done this yet? I recall being scolded by a client who told me that we don’t brag about this benefit enough. He felt that he could have saved a significant amount of time and money over the years and wished he had granted their external auditors access much sooner. It’s really easy to bring them into the fold and show them only what you want them to be able to review. Here’s how.
  • Evidence gathering – If you find that a lot of time is spent by auditors, managers—everyone—rounding up information, perhaps it is time to commit to one main holding place for your evidence. You can even use policyIQ to help automate and monitor the collection of evidence. We have some posts discussing what has been done in the past and we’ll be taking a fresh look at options surrounding the Evidence Collection effort in an upcoming training session—please join us!

E012649We hope that this list of resources is helpful to you or at least has you thinking about things that you’d like to manage more efficiently. We often work with people who feel like they just don’t have time to figure out how to save time! We get it. That’s what we’re here for! If you don’t have time to read posts and play around in policyIQ, but want to realize the benefits sooner than later, reach out to us and we’ll walk you through some simple adjustments that you can make to gain relief and command over your information right away!