ICCS Partners

Sarbanes-Oxley Compliance Services

ICCS Partners assists companies overcome the operating and reporting requirements imposed on management by the Sarbanes-Oxley Act of 2002.  Though we can’t take away management’s responsibility with respect to meeting the obligations under 404, ICCS Partners can take away the burden.  Our professionals have extensive experience in developing process and control documentation, minimizing the number of control activities, remediating control gaps, testing internal controls, and supporting the auditor's attestation effort.  In addition to developing and implementing a Company's Sarbanes-Oxley compliance plan, ICCS Partners also helps companies sustain their momentum as they move into Year Two and beyond.  

For accelerated filers, or for those non-accelerated filers with substantial human and financial resources to support the Section 404 effort, ICCS has developed a phased-approach to meeting the requirements of 404, as follows:

• Phase I – Develop an Action Plan.

• Phase II – Document and assess the “as-is” internal controls for design effectiveness.  This phase includes drafting written narratives, risk-control matrices, analyses of control activities, testing procedures for key controls, flowcharts, and QC review.

• Phase III – Perform remediation on the design effectiveness of the internal controls – perform remediation on those deficiencies identified under Phase II.

• Phase IV – Conduct preliminary testing of the operating effectiveness of the internal controls.

• Phase V – Update documentation to reflect new “as-is” internal controls over financial reporting.

• Phase VI – Perform remediation on the operating effectiveness of the internal controls, i.e. perform remediation on those controls where procedural breakdowns were identified under Phase IV.

• Phase VII – Perform 2^nd round of testing.

• Phase VIII – Support the auditor’s attestation of management’s assessment of the internal controls over financial reporting, including implementing additional remediation, if any, resulting from the auditor’s attestation.

  ICCS works with its clients to document and assess the effectiveness of their as-is internal controls and provide remedial action, if necessary.  

  Our initial service encompasses developing a customized Action Plan that details the approach, scope, work program, timing and resources necessary to satisfy management’s obligations under 404.  Typically, it takes three to four weeks to complete the Action Plan.  Once completed, management has the information to determine what tasks can be performed internally and what tasks need to be supported by outside consultants. 

  ICCS can take the burden - not the responsibility - away from management with respect to meeting their obligations under 404.   We have the technical resources to perform all, or parts, of the tasks described under Phases I-VIII above.

  An evaluation of the effectiveness of internal control using the COSO Framework is a complex and time-consuming process that likely will require considerable investment of a company’s time and resources.  Accordingly, starting now rather than later will help companies not only prepare for the 404 reporting requirements, but also might result in:

  • Reducing the cost of accounting processes.
  • Identifying existing control procedures that are redundant, inefficient, or cost ineffective.
  • Simplifying systems.
  • Increasing productivity.
  • Improving the effectiveness of the design or operation of controls.

  For example, some companies may find that automating certain manual controls improves both efficiency and compliance with management’s policies.  Others may find that certain procedures are duplicative or no longer effective or necessary.

  An early start is also essential if companies expect to complete an evaluation of internal control over financial reporting and allow sufficient time for their auditors to complete their attestation work.