Text/HTML
Text/HTML
If you are a registered user please log in to see more postings.
 

The AAO Weblog covers accounting issues and current events as they relate the practice of investment analysis.

 
 
Dec 15

Written by: Jack Ciesielski
12/15/2006 6:59 AM 

The SEC voted on Wednesday to "propose interpretive guidance for management to improve Sarbanes-Oxley 404 implementation."

The actual proposal isn't yet posted to the SEC's website, but you can get the drift from the press release: more judgment will be exercised in what to test (as it always has been allowed, really) with an emphasis on risk and materiality. The proposal intends for management to:

1) Evaluate the design of the controls to determine if it's reasonably possible that a material misstatement in the financial statements wouldn't be contained in a timely manner.

2) Gather and analyze evidence about the operation of the controls being evaluated based on a risk assessment of those controls.


Now that those principles will be spelled out in black and white (actually, making them rules - watch out what you wish for!), then managers and their auditors might feel more comfortable about actually exercising judgment. Maybe.

The proposed document intends to be more specific about how to handle four problem areas the SEC has identified in existing 404 examinations: identification of risks to reliable financial reporting and the related controls; evaluation of the operating effectiveness of controls; reporting the overall results of management's evaluation; and documentation.

All to be developed in coordination with the PCAOB as it reviews auditing standards for the same kind of streamlining.

It's kind of ironic that more rules are being written to espouse the principles built into the existing standards. You almost have to believe that as the SEC and PCAOB write more such "principle-based guidance," there'll be more and more requests for "examples." This, as we head into the third season of internal control reviews - and farther down the learning curve.

Tags:
 

Unexplored Obligations: Other Postretirement Benefits

Defined benefit pension plans take center stage in the pantheon of investors’ fears when it comes to worrying about liquidity effects or earnings distortions. Yet they rarely consider the cash demands and earnings distortions resulting from other postretirement benefit plans.

Since they’ve been required to measure - and display - a figure expressing the value of the promises made for providing employee health care benefits, managers have dealt vigorously with the obligations. Their growth has been held in check while pension obligations have grown ever higher. Yet even as they’ve become more controlled, other postretirement benefit plans are worth investor attention. As the benefit plans become less fearsome, the accounting principles involved have helped an increasing number of companies recognize phantom earnings - negative benefit costs - even while they’re putting cash into benefit payments under these plans. It’s better to be alert to such a trend early: firms may not always bring it to the attention of investors.

A recent edition of The Analyst’s Accounting Observer looks at the problematic reporting, with an eye focused on the "phantom income" results shown by 42 companies having negative OPEB costs. While the report is available only to paid subscribers, a condensed version is available for free upon request. To receive it, send an e-mail to Brenda Rappold at brappold@accountingobserver.com, with “OPEB Costs” in the subject line.


For information about subscribing to The Analyst’s Accounting Observer, click here.