Thread Options
#312134 - 02/03/05 07:03 PM SOX
mfc9 Offline
Junior Member
Joined: Aug 2004
Posts: 46
Just wondering if anyone is having a difficult time with SOX??

Return to Top
Audit
#312135 - 02/03/05 07:11 PM Re: SOX
Jokerman Offline
10K Club
Joined: Nov 2003
Posts: 12,846
I think everyone who is involved with SOX on any level is having a difficult time, though 'difficult' may qualify for the Understatement of the Year Award.

Return to Top
#312136 - 02/03/05 07:50 PM Re: SOX
Anonymous
Unregistered

What triggers SOX for a bank to have to comply?

Return to Top
#312137 - 02/03/05 09:15 PM Re: SOX
tia Offline
New Poster
Joined: Mar 2004
Posts: 15
Northern Michigan
We have just started the process of documenting our procedures.

Return to Top
#312138 - 02/03/05 11:11 PM Re: SOX
Anonymous
Unregistered

If you're publically traded you have to comply with SOX and should already be done documenting your controls. KPMG is reviewing our documentation and testing now for our 2004 financial statements.

Return to Top
#312139 - 02/04/05 02:39 PM Re: SOX
Jokerman Offline
10K Club
Joined: Nov 2003
Posts: 12,846
Quote:

If you're publically traded you have to comply with SOX and should already be done documenting your controls. KPMG is reviewing our documentation and testing now for our 2004 financial statements.




Not everyone is an accelerated filer.

Return to Top
#312140 - 02/04/05 03:56 PM Re: SOX
Anonymous
Unregistered

Thanks anon #2, I am anon #1. I am changing jobs soon and I am going from a non publically traded bank to another non publically traded bank and could not remember what triggered SOX. Thanks again!

Return to Top
#312141 - 02/04/05 04:48 PM Re: SOX
Anonymous
Unregistered

Well, it SUCKS is all I know. I am in the internal audit department and we are dealing with E & Y. It is something else. I heard through the grapevine that another bank in my state outsourced SOX to Deloit and Touche and a "certain" accounting firm said their documentation wasn't suffecient. I think this is going to be NEVERENDING!!!

Return to Top
#312142 - 02/04/05 05:26 PM Re: SOX
Angel Eyes Offline
Power Poster
Angel Eyes
Joined: May 2001
Posts: 4,599
SOX is a never ending process. There are constantly changes in the way things are done, new technologies being added etc. And that means new documentation and new testing. We have enough Key Controls that testing for one year will be a full time job for one person, although we of course didn't hire someone to do it. It just became additional duties for compliance and audit.

Return to Top
#312143 - 02/04/05 07:10 PM Re: SOX
Anonymous
Unregistered

Market Cap has to be greater than $75M to be an early filer. We just got done with year one SOX work but year two and foward should be just as exciting.

Even though you're bank isn't public, don't be surprised if SOX haunts you in the future. The Fed and other gov't regulators will surely adapt to many regulated entities, even if they aren't public. I.E. not-for-profits etc.

Documenting Controls, testing, re-testing, re-documenting, it's all part of the excitement. Fortunately/Unfortunately...depending how you look at it, SOX will not end after year 1. It's only beginning. So good luck and make the best of it.

Return to Top
#312144 - 02/11/05 07:40 PM Re: SOX
Creditcopper Offline
100 Club
Creditcopper
Joined: Sep 2004
Posts: 203
Michigan
Quote:

We have just started the process of documenting our procedures.




Tia, I would be interested in chatting with you on how you went about getting started. Exec. management decided to internalize the formation of our program vs. paying a consultant so I'm the lucky duck. We aren't having our external auditors come in until March this year to help "kick off" SOX. I want to try and get up to speed as much as possible. Where in Northern Michigan are you? I'm in metro Detroit. Would you be interested in speaking with me??
_________________________
Is it cocktail time yet? Make mine a double!

Return to Top
#312145 - 02/15/05 05:13 PM Re: SOX
Cmone Offline
Member
Joined: Aug 2004
Posts: 67
Deep South
Does anyone have suggestions on how to incorporate SOX testing into our regular audit schedule we still have to complete? Last year for the implementation we devoted 2 months to just SOX testing, which put us way behind on our regular schedule. Has anyone run into the same problem?

Return to Top
#312146 - 02/15/05 06:53 PM Re: SOX
Anonymous
Unregistered

Quote:

If you're publically traded you have to comply with SOX and should already be done documenting your controls. KPMG is reviewing our documentation and testing now for our 2004 financial statements.




Also, if over 500million in assets or over 500 shares of stock issued and outstanding...correct?

Return to Top
#312147 - 02/15/05 07:32 PM Re: SOX
Anonymous
Unregistered

Each of the line areas is responsible for completing certifications of the controls. IA has added an employee who is part audit & part SOX to test the certs, update the control documentation, etc.

We dropped all the regular audits for six months to get through the big SOX project. The audit committee understood, so we just restarted the schedule where we left off. Don't know what the FDIC will think of that, but there was nothing else we could do.

Return to Top
#312148 - 02/15/05 07:44 PM Re: SOX
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,548
Galveston, TX
Quote:

Also, if over 500million in assets or over 500 shares of stock issued and outstanding...correct?




SOX is not predicated on the size of the institution or the number of shares outstanding - it's predicated on "publicly traded".
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#312149 - 02/15/05 07:53 PM Re: SOX
Anonymous
Unregistered

Quote:

Quote:

Also, if over 500million in assets or over 500 shares of stock issued and outstanding...correct?




SOX is not predicated on the size of the institution or the number of shares outstanding - it's predicated on "publicly traded".




Isn't there something with those 2 numbers...They stick in my mind for some reason.

Return to Top
#312150 - 02/15/05 07:55 PM Re: SOX
Anonymous
Unregistered

Nevermind...found it. Banks >500 Million are subject to FDICIA

Return to Top
#312151 - 02/15/05 07:56 PM Re: SOX
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,548
Galveston, TX
That is correct
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#312152 - 02/17/05 07:04 PM Re: SOX
mfc9 Offline
Junior Member
Joined: Aug 2004
Posts: 46
We have been working on SOX since August or September and are still not done.

Return to Top
#312153 - 02/17/05 07:19 PM Re: SOX
E.E.G.B Offline
Power Poster
E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
Some of our clients have been working on SOX things for over a year, and still aren't done and don't expect to be ever done.
_________________________
I disbelieved what he was saying so hard, I probably created an alternate universe where it wasn't true.

Return to Top
#312154 - 02/17/05 09:58 PM Re: SOX
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
It doesn't end until it is repealed!
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#312155 - 02/18/05 12:46 PM Re: SOX
DeeQ Offline
10K Club
DeeQ
Joined: Dec 2002
Posts: 40,760
Turnpike Exit 10
Uh, kaybee, I don't think that's going to happen, huh?
_________________________
Get your facts first, then you can distort them as you please. - Mark Twain

Return to Top
#312156 - 03/03/05 05:43 PM Re: SOX
KAT Offline
Platinum Poster
Joined: Aug 2004
Posts: 986
Massachusetts
Today it came out that non-accelerated files have until 7/15/06 to report. What great news for those that fit in that category

Return to Top
#312157 - 03/03/05 09:42 PM Re: SOX
Pinkie CRCM Offline
Gold Star
Joined: Aug 2003
Posts: 399
KY
Be prepared to sweat (from the heat of the copier), and bleed (from all the paper cuts) and cry (from roll forward testing)...

Return to Top
#312158 - 05/03/05 05:15 PM Need your help for SOX Testing.
Anonymous
Unregistered

Would deeply appreciate it if any of you SOX / IT Audit folks could write ( or email me at gobriga@yahoo.com ) a few points on how you did your SOX testing? If you did not do it, but, observed how the EA's did it, even that knowledge would help.

Sharing your pratical SOX testing strategy, methodology, and how you did it, will help me extremely at a very critical juncture. Please consider writing the steps you did in your testing. Also, was test data given to you or did you have to prepare them, etc.

Thank you very much in advance.

Return to Top

Moderator:  Andy_Z