Electronic Notation Evidence for Sarbanes-Oxley Compliance in a Remote Work Environment
For many companies, management’s review controls are evidenced manually on printed reports, spreadsheets, checklists, including the disclosure checklists for Form 10-Q’s and 10-K’s for public companies. Since the COVID-19 virus has forced personnel to work from home, the notation of tick-marks and recalculations as well as signing and dating such documents as evidence has been challenging, if not impossible.
There are notation techniques that can be performed electronically on reports in pdf formats or Excel spreadsheets that are acceptable to most companies and their auditors. It takes training and practice to perform these techniques, and in the long run it is well worth the effort. Larger companies that have already implemented these techniques learned that it is beneficial by simply reducing the printing and storage of paper, plus the added benefit of people being able to review and provide audit documentation from remote locations.
In the current crisis, we have been reviewing the controls and requirements for Sarbanes-Oxley compliance, and assisting client personnel with training on techniques for electronic notations that are acceptable to external auditors. Since this situation may continue for the foreseeable future, Sirius Solutions is reaching out to assist clients and others that would like to make this change to a fully electronic notation environment for compliance with SOX or other regulations.
Bill Mansfield, Director, Delivery – Sirius Solutions, L.L.L.P.
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