
Sarbanes-Oxley
Public Company Accounting Reform and Investor Protection
Act
Supporting
Sarbanes-Oxley Compliance with Enterprise Portfolio
Management
Michael
Lester | Chairman, PMXML Consortium
Under
the Sarbanes-Oxley Act of 2002, publicly traded
companies are now required to implement processes
that support an "adequate internal control
structure and procedures for financial reporting."
As part of Sarbanes-Oxley, company executives must
certify their financial results and disclose information
about material changes to their financial condition
in a rapid and current basis. Enterprise Portfolio
Management (EPfM) provides essential visibility
into the portfolio of corporate investments - projects,
applications, assets - that can affect that financial
condition.
In
the last few years, everyone has been affected,
in some form, by the misuse of corporate resources
and power. As a result of that misuse, Congress
passed the Sarbanes-Oxley Act that requires publicly
traded companies to ensure the integrity of financial
results through a certification by the CEO and CFO.
With the support and mandate of executive teams,
many companies are investigating and initiating
activities to support this new legislation and the
regulations established by the Securities and Exchange
Commission (SEC). The SEC is requiring organizations
to build a framework for information gathering,
analysis, and validation.
Many
companies have immature processes for gathering
information to assess the state of projects, assets
and other investments that can directly affect the
company's financial condition. In addition, these
processes are often inconsistent across business
units, the type of information varies, and the information
is often outdated by the time it makes it to the
desks of the executive team. How can a CEO validate
that the business has rapid and current visibility
to the changes that can affect the company's financial
condition?
The
first place most executives will turn to understand
what activities can affect the financial condition
of the company is the CFO and the Finance Department.
The reports generated by Finance can provide an
excellent picture into how money is being spent
or planned to be spent, but it can't tell you that
your major ERP initiative is 2 years behind schedule.
Using the information provided by Finance is a little
like piloting an aircraft by watching the fuel gauge.
You can see that you have enough fuel, but can you
tell that you're flying into a headwind, there is
a thunderstorm ahead that you need to avoid, or
that you're about to experience some mechanical
problems with the aircraft? Companies seeking to
comply with Sarbanes-Oxley need more than financial
reports to understand the material changes that
can affect their financial condition.
The
information gathering framework required by the
SEC is similar to the first critical step for implementing
Enterprise Portfolio Management (EPfM). Due to the
similarities, EPfM is getting a lot of attention
as a business discipline that can significantly
improve compliance with Sarbanes-Oxley. At a high
level, EPfM leverages a cycle of planning, analyzing,
and monitoring investments - projects, processes,
applications, and assets - to enable smart decisions
that keep the business focused on returning the
most value. To support the cycle of planning, analysis,
and monitoring, companies begin the process by building
a portfolio - an inventory of all current and future
investments. This first step is not uncommon to
the many reports and spreadsheets that are probably
compiled and used today. The key is making and keeping
the information about the portfolio up-to-date.
A number of software tools exist that facilitate
the EPfM process, using integration into project
planning systems, financial systems, asset management
systems, and others to keep the information in the
portfolio current. These tools eliminate the manual
processes to build and refresh the portfolio that
typically require many people and a considerable
amount of time.
Once
the portfolio inventory is established, and processes
are in place to keep it maintained, benefits can
almost immediately be recognized. Visibility into
all of the company's investments enables management
to identify and eliminate redundant investments,
focus resources on critical, strategic investments,
and avoid investments that have unacceptably high
risk or low return on invested capital (ROIC). EPfM
uses this visibility to allow the company to stay
focused on business priorities, avoiding the commitment
of human and financial resources to investments
that may be non-strategic, low value, or just wasteful.
Like the new high-tech systems used by the military
to redirect resources towards crucial, strategic
points in an operation, the real-time monitoring
provided by EPfM tools give executives the same
abilities with business resources. Businesses must
be able to pinpoint and rapidly realign their portfolio
of business investments to address competitive,
regulatory or internal issues that cause the business
to falter or fail.
Once
a business has a current portfolio of investments
in process, the next step is to begin planning future
investments and understanding their impact on the
other investments in the portfolio. As time progresses,
the status or health of existing investments may
falter, making it more appealing to redirect resources
from a failing investment towards a proposed or
postponed investment. Additionally, businesses can
use the portfolio information to prepare possible
scenarios to support executive planning, or risk
mitigation. It is very similar to the different
types of portfolio mixes you see when you discuss
your personal investment portfolio with your financial
advisor. They will prepare a model of how your current
investments are allocated, and then compare it against
various scenarios that are optimized to achieve
specific goals such as long-term growth or short-term
risk avoidance. Portfolio planners for the business
can use the portfolio inventory to model scenarios
that can help direct the organization towards its
goals.
The
information gathering framework mandated by the
SEC needs to be dynamic and support new or changing
regulations, so any processes and tools considered
need to support this type of dynamic environment.
Because of the nature of EPfM as a continuous business
process, it is an ideal way to support the current
legislation and support future regulations. In addition,
with a proactive EPfM practice, a company can provide
real-time results to support Sarbanes-Oxley and
leverage that information to become a more agile
business, gaining a positive competitive advantage.
Michael
Lester is a Senior Product Manager for Pacific Edge
Software where he leads product strategy for Pacific
Edge's Portfolio Management solutions. Mr Lester
has led the PMXML Consortium since joining Pacific
Edge. He has over ten years of experience in project
and quality management, including personal and enterprise
solutions for Microsoft, Dell, BuildNet, The Cobalt
Group, and Franklin Covey. He studied Political
Science at Brigham Young University.