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Compliance Week TV In our first Compliance Week TV video we hear from Frank Diana, executive vice president of enherent Corporation, who discusses the challenges involved in information management. Watch the video in full screen now CPE Credits On Demand! Subscribers can now earn FREE Continuing Professional Education (CPE) credits by watching Compliance Week Webcasts on critical topics related to corporate compliance and risk -- on demand, so at your convenience! For subscribers only. Earn CPE for free now Compliance Week Podcasts … This week’s podcast features Lucy Marcus, CEO of Marcus Venture Consulting, talking about shareholder and director activism, and how corporate executives can work with them more effectively. Hear the podcast now or … Follow Compliance Week podcasts on iTunes. … and Compliance Week on Twitter! You can also follow Compliance Week Editor Matt Kelly on Twitter, for the latest regulatory observations and updates. More than 2,600 followers and ranked the most influential Twitter feed on compliance! Compliance Week LinkedIn Group Visit the Compliance Week has a companion group on LinkedIn, where members can network and discuss the compliance and governance news of the day among themselves. Open to all, free to join.

Webcasts of the Week Defining and Executing Systematic, Risk-Based Third-Party Due Diligence for FCPA Compliance Sponsored by The Steele Foundation

Help Wanted: Ad of the Week Compliance Education & Communications Mgr. Submitted by Oracle

Event of the Week Corporate Governance Programs Courtesy of Harvard Business School

Thought Leadership of the Week Access Management: Efficiency, Confidence, Control Courtesy of SAP

The Resource Exchange Code of Conduct Submitted by BP Sample Risk Acceptance Request Submitted by Circuit City

Featured Databases Whistleblower Guidelines Search Whistleblower Policies, Contract Options Class-Action Filings Download Text of Class-Action Complaints

GRC Illustrated Series Improving GRC by Visualizing Your Data The 24th Installment in This Exclusive Series

Welcome to Compliance Week’s Remediation Center

ompliance Week’s Remediation Center is an anonymous forum in which subscribers can submit questions, confidentially, to securities and accounting experts.

RELATED RESOURCES

Ask A Question Compliance Week’s Remediation Center is an anonymous forum in which subscribers can submit questions, confidentially, to securities and accounting experts. Compliance Week’s editors review all questions and then submit them—anonymously—to specialists who can address the issues. Ask your own question below: Click Here to Submit an Anonymous Question Warning, Disclosure Compliance Week’s Remediation Center is an information service only. Answers to questions should not be construed to be legal guidance. Consult with your auditors, internal counsel, external counsel, and/or other securities experts on all critical compliance and governance matters. Specialists are solicited by the editor to answer Remediation Center questions based on their knowledge of the subject matter and their ability to provide commentary in their particular area of expertise. In some cases, the experts who answer questions in the Remediation Center may also be Compliance Week subscribers, or may work at firms that advertise in Compliance Week.

Compliance Week’s editors review all questions and then submit them—anonymously—to specialists who can address the issues. The questions and responses are then reprinted in a future edition of Compliance Week. Simply click here to ask a question, or review recent Q&As below:

RECENT QUESTIONS

• CCOS, Subsidiary Boards, & Reporting Roles
  On reporting roles at companies with subsidiaries
  Ellen Brotman, Montgomery, McCracken, Walker & Rhoads
  — Aug. 3, 2010

• Do the Red Flag Rules Apply Overseas?
  On how the Red Flag Rules affect foreign businesses
  Rick Harris, Day Pitney
  — Jan. 12, 2010

• When the Chief Audit Executive Serves Two Masters
  On the Chief Audit Executive’s connection to Board, CEO
  Susan Lione, The IIA
  — Dec. 8, 2009

• ‘Good Faith’ in Internal Investigations
  On getting credit for conducting ‘good faith’ probes
  Larry Finder, Haynes Boone
  — Nov. 10, 2009

• Constructing a Privacy-Risk Assessment
  On how to structure a privacy-risk assessment
  David Wood, IBM
  — Oct. 6, 2009

• Sharing e-Discovery Expenses
  On sharing e-discovery costs with opposing counsel
  Susan Salmon, Quarles & Brady, LLP
  — Sept. 15, 2009

• Filing in XBRL Using the New Codification
  On Codification vs. GAAP for XBRL filings
  Neal Hannon, Gilbane Group
  — Aug. 11, 2009

• Non-Compliance With 409A: How Serious an Issue?
  On deferred comp agreements and Section 409A
  Jeff Capwell, McGuireWoods
  — July 21, 2009

• Overseeing Subsidiaries’ Internal Controls for SOX
  On when to watch a subsidiary’s internal controls
  Brian Gramm, Milo Belle Consultants
  — June 23, 2009

• When Do Family Ties Equal Insider Trading?
  On when business and family don’t mix
  Michael MacPhail, Holland & Hart
  — April 28, 2009

• Any wiggle room when accounting for kept assets?
  On the limited ways to account for kept assets
  Dr. Cindy Ma, Houlihan Lokey
  — Feb. 3, 2009

• Is our company subject to the auditor attestations of Section 404(b)?
  On when companies can avoid 404(b) compliance
  Answered by Bob Benoit, Lord & Benoit
  — Jan. 6, 2009

• What Supports Exist for External Financial Reporting?
  On what supports exist to test the reliability of the external financial reporting function
  Answered by Kevin Hyams, J.H. Cohn
  — Oct. 18, 2008

• Will Solid 2009 Controls Curb Weakness in 2008?
  On proving a solid remediation plan for 2009 and avoiding material weakness in 2008
  Answered by Jonathan Marks, Crowe Horwath
  — Sept. 23, 2008

• Monthly Flux Analysis Has Company in Flux
  On relying on the monthly flux analysis to ensure transactions are properly coded
  Answered by Parveen Gupta, Lehigh University
  — July 29, 2008

• Auditing Royalty Payments From Overseas
  On the best approach to auditing royalties for tangible goods
  Answered by Arnold Schanfield, ERM Associates; Dan Helming, Weiser LLP
  — May 6, 2008

• Tying SOX Compliance to Compensation
  On failing to meet SOX goals affecting compensation
  Answered by Lee Barken, Haskell & White
  — April 15, 2008

• Managing SoD Challenges in Oracle
  On control weaknesses with PeopleSoft’s accounting modules
  Answered by Tony Klimas BearingPoint
  — April 1, 2008

• Using Work of Others (or Not) in SOX Audits
  On internal auditors’ reliance on outside consultants
  Answered by Tim Leech, Navigant Consulting
  — Jan. 29, 2008

• Surviving Data Breaches in the PCI World
  On PCI compliance protection against a breach
  Answered by Prat Moghe, Tizor Systems
  — Oct. 10, 2007

• Stock Option Strike Prices Under 409A
  On permissible “average price” methods under 409A
  Answered by S. Tony Ling, Jenner & Block
  — Sept. 11, 2007

• Should Management Letters Be Disclosed
  On whether management letters merit 10-K disclosure
  Answered by Anthony Popanz, Jefferson Wells
  — June 5, 2007

• Recordkeeping Considerations
  SOX documentation at a soon-to-be-divested business
  Answered by Cozen O’Connor Partner Ralph De Martino
  — May 8, 2007

• Disclosing Non-Qualified Contributions
  On the location of NQDC Plans in the new summary table
  Answered by July H. Bell, Counsel with Hogan & Hartson
  — March 6, 2007

• Delegating Authority And Weaknesses
  On signature delegation and potential weaknesses.
  Answered by Cohn Consulting Services Managing Partner Anthony Zecca
  — Feb. 13, 2007

• Control Frameworks, Internal Audit, 404
  On IA being a necessary part of the control framework
  Answered by Moody, Famiglietti & Andronico's Travis Drouin
  — Feb. 13, 2007

• Intersection Of FCPA, SOX Compliance
  On the interplay between FCPA and SOX Sections 302, 404
  Answered by PricewaterhouseCoopers' Albert Vondra
  — Nov. 21, 2006

• When Your Vendor Flunks SAS 70 Audit
  What happens when your vendor has a significant deficiency?
  Answered by Accenture partner Les Stone
  — Oct. 31, 2006

• SOX And Discontinued Operations
  SOX 404 documentation and testing at units for sale.
  Answered by Grant Thornton's Richard Davis
  — Sept. 17, 2006

• Going Private With Public Debt
  Private equity buyouts and SEC reporting requirements
  Answered by Leonard, Street and Deinard's Stephen Quinlivan
  — Aug. 1, 2006

• When Spinoffs Meet SOX 404
  When must spinoffs comply with Section 404?
  Answered by Thunderbird Professor Thomas Selling
  — June 5, 2006

• Mechanics Of 404 Exclusions
  Regarding exclusions based on acquisition size, timing
  Answered by Russell Ryan, King & Spalding
  — May 16, 2006

• Amended Filings & Internal Controls
  Regarding 10-K discrepancies, and control objectives
  Answered by Tony Popanz, Jefferson Wells
  — Apr. 18, 2006

• Aggregating Material Deficiencies
  How should divisional deficiencies be considered?
  Answered by Jack Finley, Hudson Financial Solutions
  — Mar. 14, 2006

• FDICIA Control Documentation
  Should FDICIA control documents be separate from SOX ones?
  Answered by Kathleen Blanchard, Ent. Financial Consulting
  — Feb. 14, 2006

• Auditing The Use Of Spreadsheets
  Regarding how to audit the use of spreadsheets for SOX 404.
  Answered by Robert D. Kugel, Ventana Research
  — Jan. 24, 2006

• Remediation Materiality Thresholds
  Regarding disclosure of significant deficiency remediation.
  Answered by Lehigh Prof. Parveen Gupta; Paisley's Tim Leech
  — Jan. 10, 2006

• 404 Exit Clause For Accelerated Filers
  Regarding rules on exiting from accelerated filer status.
  Answered by Karl Strait, McGuireWoods
  — Jan. 10, 2006

• Tabulating Accumulated Deficiencies
  Regarding the ways to count weaknesses, deficiencies.
  Answered by Tim Leech, Paisley Consulting
  — Dec. 13, 2005

• What's A “Public Trading Market”
  Trading markets, public float, and accelerated filers.
  Answered by Charles E. Hord III, Partner, Chadbourne & Parke
  — Dec. 6, 2005

• AJCA 409A And Stock Options Valuations
  Regarding ‘market value’ estimate at pre-IPO company.
  Answered by John Wirtshafter, McDonald Hopkins
  — Nov. 29, 2005

• M&A And SOX 404 Testing
  Regarding ‘grace periods’ for acquired companies.
  Answered by Henry Ristuccia, Partner, Deloitte & Touche
  — Nov. 22, 2005
  • Follow-Up Question On M&A, 404
    Regarding compliance and the one-year exemption.
    Answered by Henry Ristuccia, Deloitte & Touche
    — Dec. 13, 2005

• Market Cap Or Public Float?
  Regarding the definition of an accelerated filer.
  Answered by Paul Sachs, Managing Director, Protiviti
  — Nov. 22, 2005

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