SOX

Posted By: mfc9

SOX - 02/03/05 07:03 PM

Just wondering if anyone is having a difficult time with SOX??
Posted By: Jokerman

Re: SOX - 02/03/05 07:11 PM

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.
Posted By: Anonymous

Re: SOX - 02/03/05 07:50 PM

What triggers SOX for a bank to have to comply?
Posted By: tia

Re: SOX - 02/03/05 09:15 PM

We have just started the process of documenting our procedures.
Posted By: Anonymous

Re: SOX - 02/03/05 11:11 PM

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.
Posted By: Jokerman

Re: SOX - 02/04/05 02:39 PM

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.
Posted By: Anonymous

Re: SOX - 02/04/05 03:56 PM

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!
Posted By: Anonymous

Re: SOX - 02/04/05 04:48 PM

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!!!
Posted By: Angel Eyes

Re: SOX - 02/04/05 05:26 PM

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.
Posted By: Anonymous

Re: SOX - 02/04/05 07:10 PM

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.
Posted By: Creditcopper

Re: SOX - 02/11/05 07:40 PM

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??
Posted By: Cmone

Re: SOX - 02/15/05 05:13 PM

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?
Posted By: Anonymous

Re: SOX - 02/15/05 06:53 PM

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?
Posted By: Anonymous

Re: SOX - 02/15/05 07:32 PM

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.
Posted By: rlcarey

Re: SOX - 02/15/05 07:44 PM

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".
Posted By: Anonymous

Re: SOX - 02/15/05 07:53 PM

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.
Posted By: Anonymous

Re: SOX - 02/15/05 07:55 PM

Nevermind...found it. Banks >500 Million are subject to FDICIA
Posted By: rlcarey

Re: SOX - 02/15/05 07:56 PM

That is correct
Posted By: mfc9

Re: SOX - 02/17/05 07:04 PM

We have been working on SOX since August or September and are still not done.
Posted By: E.E.G.B

Re: SOX - 02/17/05 07:19 PM

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.
Posted By: Kathleen O. Blanchard

Re: SOX - 02/17/05 09:58 PM

It doesn't end until it is repealed!
Posted By: Retired DQ

Re: SOX - 02/18/05 12:46 PM

Uh, kaybee, I don't think that's going to happen, huh?
Posted By: KAT

Re: SOX - 03/03/05 05:43 PM

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
Posted By: Pinkie CRCM

Re: SOX - 03/03/05 09:42 PM

Be prepared to sweat (from the heat of the copier), and bleed (from all the paper cuts) and cry (from roll forward testing)...
Posted By: Anonymous

Need your help for SOX Testing. - 05/03/05 05:15 PM

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.