According to the Institute of Internal Auditors (IIA), an effective system of internal controls helps ensure that our organizational processes are functioning properly, that our financial information is reliable, and that we’re in compliance with applicable regulations. Businesses primarily implement internal controls systems to protect themselves from internal fraud and abuse, while many do so with regulatory or standards compliance in mind.

It is interesting to note that, in many cases, the internal control system at many companies consists of volumes of instruction-like procedures that document activities. If a company is taking the time and effort to develop a procedure-based financial control system, it’s worth the additional effort it takes to:

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Small public companies like yours may finally have to begin providing the Securities and Exchange Commission (SEC) with certified assessments of their internal controls.  Smaller micro caps will be required to comply with SOX 404(b) reporting requirements beginning June 15, 2010; they’ll have to attest to the effectiveness of their internal controls in their annual reports released on or after June 15 of next year.  So, for those whose annual reports are just seven months away, the time to consider is over — it’s time to take action!

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Question of the month: How can Accounting Policies and Procedures help your organization?

The Accounting Department is an area where policies and procedures are usually a requirement, because they are considered part of the internal controls noted in Sarbanes-Oxley. The real question is: What approach are you taking to developing accounting policies and procedures?

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Everywhere in your organization people are carrying out business processes to make things happen. It doesn’t matter if the processes are well defined, poorly documented or if the staff is trained. If things are getting done – it is because people are executing business processes.

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What is the difference between a well-conceived and well-written accounting policy and a poorly conceived and poorly written accounting policy?  Of course, the needs of every organization are different, and the most important element of an accounting policy is that it helps the organization. Last week we mentioned the importance of gathering accounting policies into the accounting manual.  Now let’s review some important points to consider when crafting policies.

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The question “What should be in your accounting manual?” should first be answered by another question: “Why do you need an accounting manual?” Whether you are looking to purchase a pre-written accounting manual or create your own accounting manual from scratch, these are two important questions to answer.

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When you hear the phrase “internal control system required by Sarbanes-Oxley (SOX) Section 404,” do you automatically think of policies and procedures?  Simply having accounting policies and procedures does not indicate an internal control system.  Well-written accounting procedures that document well-defined accounting processes, however, are an important component of the internal control system you are building. 

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It has been more than five years since most provisions of the Sarbanes-Oxley Act of 2002 took effect (in mid- 2003). Many publicly traded companies, however, still seem to struggle with developing a confident understanding of compliance.

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Question of the Month: How do policies and procedures fulfill requirements of Sarbanes-Oxley and other financial regulations?

This month’s highlight was the release of the Finance Policies, Procedures & Forms manual. Our newest product is the result of a nearly year-long effort of intensive research, writing, editing, and reviewing. The Finance Manual was finally ready for production and shipping last week. We are very pleased with this new product, and the response from our customers, to date, has been tremendous.

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You may be familiar with the COSO (Committee of Sponsoring Organizations of the Treadway Commission) framework for internal control. We have discussed it in past articles, and it has received significant attention when referenced by the Securities and Exchange Commission (SEC) and the Public Company Accounting Oversight Board (PCAOB) as an example of an “internal control” system as required by Sarbanes-Oxley Act (SOX) sections 302 and 404.

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