Asset Management in Software

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Audit of asset management deals mostly with authorization, financial expenditure, and appropriate depreciation and reporting Have key assets (such as software, data, hardware, middleware, and facilities) been inventoried and their company owners identified Examples of asset-management-related items that may be reviewed during a SOX audit include inventory, asset disposal, change management of asset inventory, and an overall understanding of asset procedures Records management is an indispensable part of the asset-management plan
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Within asset management, companies should consider facilities controls Are data center facilities equipped with adequate environmental controls to maintain systems and data For example, fire suppression, uninterruptable power supply, air conditioning, elevated floors, and documented emergency procedures may be appropriate to review See 4 for more information pertaining to auditing facilities controls
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Costs for reviewing internal controls and complying with SOX were initially a critical concern both in internal resources and external services Many internal auditors lacked the background, knowledge, or experience with evaluating controls to assess adequately whether the current environment meets SOX requirements Employees also often lacked motivation for thorough documentation or communication As a result, external services companies capitalized on the opportunity to provide a gap analysis to help determine control deficiencies between their interpretation of SOX requirements and the present state of controls in the company These projects in many cases resulted in the need for new infrastructure, services, software, headcount, and related requirements Despite the perceived high cost of compliance, ineffective controls or noncompliance will result in a much higher cost These controls, once adopted by the business, should become part of everyday business operations SOX is not about becoming compliant once a year to pass an audit Should a company s external auditor find material weaknesses in controls, the competency and credibility of the company may be questioned thus causing a drop in share price and capital availability Investors views of the risks associated with management structure and controls affect their interest in investing in a company In multinational corporations, auditors may be pressed to question more closely any suspicious payments that have the earmarks of bribes In the past, corporate executives were not required to disclose questionable payments that were paid to receive offshore services This may no longer be an option For more specific points to consider, illustrative controls, or tests of those controls, see wwwisacaorg/sox for the IT Control Objectives for Sarbanes-Oxley 2nd Edition
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The formal title of this law is the Financial Services Modernization Act The act, more commonly known as the Gramm-Leach-Bliley Act (GLBA), was directed primarily at allowing expanded functions and relationships among financial institutions The law covers how and under what circumstances bank holding companies can undertake new affiliations and engage in previously restricted activities
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From the perspective of an impact on internal controls, the GLBA Title V section provides a series of specific regulations governing how individual information for customers of financial institutions may be shared GLBA requires that financial firms disclose to customers the institutions privacy policies and practices The law provides some
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17: Regulations
limited control to customers about how the information retained by a financial institution may be retained via an opt-out option On an annualized basis, the financial institution is required to reinform clients of the institution s privacy policies Enforcement of the act s provisions is assigned to the Federal Trade Commission, the federal banking agencies, the National Credit Union Administration, and the SEC
Customer Privacy Provisions
GLBA requires financial institutions to review and, in many cases, overhaul how they deal with maintaining the privacy of customer information Further, the act requires an ongoing review of who has access to what information, under what circumstances the information could be shared, and with whom The most pervasive impact of the act is an ongoing requirement to control access to and use of client information on an individual-by-individual basis The legislated opt-out requirement made operational and marketing activities much more complicated
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