SOX 404: Mastering the ICFR Evaluation Process
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CPE Credits: |
8 |
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Program Level: |
Overview |
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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
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| 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?
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| 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
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| 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
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| 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
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| 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?
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| 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
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| 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
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| 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"
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| Date |
City |
Register |
| May 16, 2012 |
Dallas, TX |
Register |
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