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SOX 404: Mastering the ICFR Evaluation Process

CPE Credits: 8 Program Level: Overview Prerequisites: exp

Learning Objective: To provide an understanding of the internal control reporting requirements of Sarbanes-Oxley Section 404.

  • Review the SEC's Management Guidance and PCAOB's Audit Standard 5
  • Understand how to use the COSO framework in the evaluation process
  • Learn how entity level controls impact the process
  • Learn how to optimize your control effectiveness testing
  • Understand how to re-evaluate scoping and testing decisions
  • Review when to use walk-throughs and related procedures
Date City Register
May 16, 2012 Dallas, TX Register

Agenda

Day 1
8:00 - 8:30 a.m. Registration/Continental Breakfast
8:30 - 8:45 a.m. Workshop Overview – The State of the 404 Process
  • Workshop schedule, administrative matters and introductions
  • Overview areas for improvement
8:45 - 9:15 a.m. The SOX Process Today
  • Structure of the SOX process as it should be
  • SEC management guidance process
  • PCAOB Audit Standard 5 process
  • How does the guidance compare to your process?
9:15 -11:00 a.m. The SEC's New Guidance for Management
  • Two basic principles
  • Structure of the process
  • The three levels of entity level controls
  • Where can entity level controls be used to reduce process level testing
  • Identifying financial reporting risks
  • What is a material weakness?
  • Issues in scoping
  • Identifying controls that address financial reporting risks
  • Design effectiveness evaluation
  • Operating effectiveness evaluation
11:00 - Noon The PCAOB's New Audit Standard 5
  • Overview of the auditor's SOX 404 process
  • "Top-down" now required by AS 5
  • Entity level control issues
  • Starting with the financial statements
  • The new definition of significant account
  • Is process documentation required?
  • Testing issues
  • Refining sample size decisions
  • Maximizing efficiency of testing by finding opportunities to combine walkthroughs, design effectiveness and operating effectiveness testing
  • Maximizing efficiency in testing controls with multiple objective tests
  • Making more efficient sample size decisions
  • Timing your testing to make remediation efforts on a timely basis
Noon - 1:00 p.m. Lunch
1:00 - 2:00 p.m. Dealing Effectively with IT Issues
  • Determining which IT general controls to document and test
  • Issues in hard-to-obtain SAS 70 service organization reports
  • Effective documentation of IT application controls in process documentation
2:00 - 3:00 p.m. SOX as it Exists versus the New Guidance
  • Adjusting testing to identify only material weaknesses
  • Operational control issues
  • Entity level controls – when could they be enough?
  • Could you reduce some process level documentation?
3:00 - 4:00 p.m. Summary of Areas for Change
  • Focus on material weakness issues
  • Eliminating operational control issues
  • Identifying financial reporting risks
  • Using entity level controls
  • Reducing "significant accounts"
  • Testing effectively
  • Self assessment and other testing regimens
4:00 - 4:15 p.m. Material Weakness and Other Reporting Issues
  • The large CPA firm's "Framework" document for analyzing control deficiencies – adapting for the new definitions
  • Reporting the remediation of material weaknesses and AS 4
  • When must changes in internal control be reported in Form 10-Q and 10-K?
  • The requirement for "robust" disclosure of material weaknesses
  • Tips for writing a clearer, more effective report
4:15 - 4:30 p.m. Questions and Answers
  • Getting benefit and building lasting value from establishing and improving internal control
  • Should you use the COSO's Enterprise Risk Management Framework?
  • Benchmarking, what cost information is available? Averages per company?
  • What is the market impact of reporting material weaknesses?
  • Learning curves - getting better each time
  • Avoiding mistakes from earlier years
  • COSO's new "Implementing the COSO Control Framework in Smaller Businesses"
Date City Register
May 16, 2012 Dallas, TX Register

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       Year after year, an excellent program. I expect to attend this program every year until I retire!

Pamela B. Bruno Vice President, Controller & CAO BNP Residential Properties, Inc. Charlotte, NC

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