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#1525054 - 03/22/11 03:31 PM Sarbanes Oaxley and Internal Auditing??
ecrew,CRCM Offline
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These questions are being asked by my Internal Control Auditor. I've been trying to research it, but I'm stuck....

1. When does the bank need to apply the Sarbanes Oaxley auditing procedures? (per# of stockholders or per # of Employees, or per size of bank etc.)?

2. Does the auditing need to be performed and certified by a certain degree (CPA etc) or does the Internal Control of the bank qualify?

3. Where can we get instruction (examples etc.) sheets of documentation required to cover the extra Sarbanes Oaxley? tasks?

I thank you in advance for any help we receive. smile
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#1525118 - 03/22/11 04:24 PM Re: Sarbanes Oaxley and Internal Auditing?? ecrew,CRCM
DeeQ Offline
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I would start here, and see where you fit in:

http://www.sec.gov/rules/final/33-8238.htm
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#1525120 - 03/22/11 04:26 PM Re: Sarbanes Oaxley and Internal Auditing?? DeeQ
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#1525181 - 03/22/11 05:17 PM Re: Sarbanes Oaxley and Internal Auditing?? DeeQ
J2C Offline
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Big Brother knows and that's a...
Your internal control auditor is asking you at what point does SOX get implemented? Sounds like the internal auditor is a little behind the times on that one and should have that information already....from a professional standpoint. At least the basics....
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#1525458 - 03/22/11 08:31 PM Re: Sarbanes Oxley and Internal Auditing?? ecrew,CRCM
WonderWoman Offline
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There's a lot to it - not as easy as 1, 2, 3. Who audits your financials? They should know all of this.

1) an entity is considered an accelerated filer as of 12/31 for the year in which they were in excess of $75 million in non-affiliated market capitalization as of 6/30 for that year.

To find public float:
Gross Number of shares outstanding (as of June 30)
-(minus) Insider Shares (as of June 30)
Multiplied by share price (as of June 30)

An accelerated filer is one that meets all of the following conditions as of the end of its fiscal year:

  • The registrantís common equity public float was $75 million or more as of the last business day of its most recently completed second fiscal quarter;
  • The registrant has been reporting under Section 13(a) or 15(d) of the 1934 Act for at least 12 months;
  • The registrant has previously filed at least one annual report; and
  • The registrant is not eligible to report under the small business issuer rules.


2) if you qualify as an Accelerated Filer - then you'll need need the auditor attestation on internal controls. You'll have to work with your auditor and see where they are comfortable.

Example: my auditors (A CPA Firm) are comfortable with most of my testing as an independent source, but they do conduct their own sampling of controls.
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#1525564 - 03/23/11 11:49 AM Re: Sarbanes Oxley and Internal Auditing?? WonderWoman
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This is the site I go to for answers regarding SOX related questions: http://pcaobus.org/Pages/default.aspx It is the Public Accounting Oversight Board or the PCAOB which is a nonprofit corporation established by Congress to oversee the audits of public companies in order to protect investors and the public interest by promoting informative, accurate, and independent audit reports. It sets the standards!
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#1525580 - 03/23/11 12:44 PM Re: Sarbanes Oxley and Internal Auditing?? CEK
A_G Offline
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You will also find a ton of information here:

http://www.aicpa.org/Pages/Default.aspx

The very first hit when I searched "Sarbanes" brought up a book called, "Sarbanes-Oxley and the New Internal Auditing Rules."
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#1525614 - 03/23/11 01:24 PM Re: Sarbanes Oxley and Internal Auditing?? A_G
ecrew,CRCM Offline
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We are a small banking and growing. The SOX is actually new to us.

I appreciate everybody's input and suggestions. smile
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#1525646 - 03/23/11 01:43 PM Re: Sarbanes Oxley and Internal Auditing?? ecrew,CRCM
Kathleen O. Blanchard Offline

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You really should discuss with your external financial auditors. They must be in agreement with whatever process you develop.
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#1525751 - 03/23/11 02:50 PM Re: Sarbanes Oxley and Internal Auditing?? Kathleen O. Blanchard
ecrew,CRCM Offline
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I believe that is what she is going to do. smile
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