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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.

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Pension & Other Benefit Plans: A Look Ahead


    Investors in firms with defined benefit pension plans always face the risk of suddenly being pushed farther back in line when it comes to being served their returns. Variability in plan assets and variability in benefit plan obligations are the reason: poor asset returns coupled with sinking interest rates always spell tough times for defined benefit plan funding. In that regard, this year’s asset returns combined with the Fed’s “Operation Twist” add up to “Operation Agony” for defined benefit pension plans. If trends continue along their current path, firms that may have anticipated moving to more realistic pension accounting - like Honeywell, AT&T and Verizon already have done - might forego that decision. It could be just too painful. 

    Pensions aren’t the only kind of benefit plan affected by Operation Twist. Other postemployment benefit (OPEB) plans share much the same accounting model as pensions, including the calculation of a projected benefit obligation that similarly incorporates a discount rate - one that will also be affected by Operation Twist. The net OPEB obligations were slightly less than pension obligations at the end of 2010, but also promise to grow in 2011. Investors perceive them as less threatening than pension obligations because they don’t require funding. Strangely, there are a number of firms that are recognizing income from these benefit plans - without ever creating a dime of cash for investors.

A recent edition of The Analyst’s Accounting Observer dissects these issues, and 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 “PENSIONS” in the subject line.

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