Thought Leadership of the Week

Compliance Making You Feel Like a Sitting Duck? Free Forrester Trends Report, Courtesy IBM

The Resource Exchange

Job Description: Chief Compliance Officer
Submitted by CCO at $1 Billion Pharma

Job Description: Chief Compliance Officer
Submitted by CCO at $310 Million Apparel Co.

Upcoming Webcasts

CPE Credit: Income Tax in IFRS
Dec. 2; Part of Our Ongoing IFRS Webcast Series

MetroPCS Integrates Sabrix & Oracle E-Business
Dec. 11, Free, Sponsored by Sabrix

Featured Databases

Corporate Bylaws & Policies
Search Incorporation Certificates, Bylaws, More

Whistleblower Guidelines
Compare How Companies Handle Complaints

Featured Job Listing

Sarbanes-Oxley Manager
General Motors - Detroit, MI

Event of the Week

Keeping on Top of PCI Compliance
Free Webcast Courtesy of SafeNet

Recent Columns By Rick Steinberg On §404, ERM, More

Headshot
The principal author of COSO's internal control and ERM frameworks, Compliance Week Columnist Richard Steinberg is a well-known governance and auditing expert. The founder and former leader of PricewaterhouseCoopers' corporate governance practice, Steinberg has authored numerous seminal governance reports, including Corporate Governance and the Board—What Works Best. Some of his most recent columns for Compliance Week are below:

  Title & Description Date Type of Article
1. Risk-Management Lessons From the Credit Crisis
As the United States and the world sort through the credit crisis, and the financial markets continue to gyrate and governments craft and recraft programs in an attempt to avert disaster, one wonders what went so very wrong with those much-touted risk management systems of major financial institutions. Weren’t the big guys with the highly polished reputations supposed to have in-depth knowledge of what their risks were, and manage those risks to be profitable and sustainable? How did they, and we, end up here?
 By Richard M. Steinberg
11/18/08 Columns & Editorials
2. Brightening the Future of Our Financial Markets
We know that the regulatory structure of our financial system is about to change. As I write this column Congress continues to struggle to approve some sort of “rescue” package, with both the House and Senate reworking the first $700 billion plan that didn’t pass muster. But whatever package lawmakers ultimately pass, we can expect sometime thereafter to see an entirely new financial system-wide regulatory structure.
 By Richard M. Steinberg
10/21/08 Columns & Editorials
3. Debunking SOX Theories One Misconception at a Time
Having worked with many boards of directors, it’s clear that most directors now understand what Sarbanes-Oxley is all about. They’ve spent the last few years dealing with many of its provisions, with audit committees spending significant time on Section 404’s internal control requirements. Some initially lost sight of other important responsibilities, although generally boards have returned to a more balanced approach of providing effective advice, counsel, and direction on strategic business issues in addition to their compliance monitoring roles.
 By Richard M. Steinberg
09/16/08 Compliance Week Coverage
4. When Executives Discuss ERM Challenges
Recently I had the privilege of leading a forum of senior executives experienced in risk management in a discussion of the challenges of developing, implementing, and gaining the benefits of ERM.
 By Richard M. Steinberg, Compliance Week Columnist
08/19/08 Columns & Editorials
5. CEO Pay—Can We Get It Right?
This is the second in a two-part series on the subject of CEO pay.
 By Richard M. Steinberg, Compliance Week Columnist
07/15/08 Columns & Editorials
6. Tracing the Past and Future of CEO Pay
Editor’s note: This is the first in a two-part series on the subject of CEO pay.
 By Richard M. Steinberg, Compliance Week Columnist
06/17/08 Compliance Week Coverage
7. The Big Risk: CEOs Never See It Coming
When the fraud at Societe Generale burst into view several months ago, I analyzed what went wrong and why in “Why It’s So Shocking Societe Generale Was Shocked” (in the March 2008 edition). Well, now we see that CEO Daniel Bouton is stepping down, which comes as no surprise. He was at the helm when the SocGen ship hit an iceberg that clearly should have been seen and avoided. Management knew the company was in dangerous waters (regulators and others apprised them that damage appeared to have already been done), but did nothing to investigate and steer clear of disaster.
 By Richard M. Steinberg, Compliance Week Columnist
05/20/08 Columns & Editorials
8. Why Using the Right Words Really Does Matter
We all know the importance of effective communication, in both formal and informal settings, to get our messages across as intended. But how many times have we been misunderstood, or we didn’t understand an idea someone else was trying to convey? The consequences of bad communication range from simply extending a conversation to gain clarity, to talking at cross-purposes resulting in extraordinarily bad business decisions. Yes, tone of voice and body language are important in sending the right message, but using the right words is usually critical.
 By Richard M. Steinberg, Compliance Week Columnist
04/22/08 Columns & Editorials
9. Delivering Peace Amid Shareholder Anger
It’s extraordinarily clear that shareholders are angry! They’re angry about lots of things, from opaque or otherwise bad financial reporting to outrageous CEO compensation, poison pills, staggered boards, and anything else that emanates from the thought that boards of directors are not doing their jobs. The underlying cause, some say, is a still too-cozy relationship between the board and CEO, and directors uncaring of legitimate shareholder needs.
 By Richard M. Steinberg, Compliance Week Columnist
03/18/08 Columns & Editorials
10. Why It’s So Shocking Societe Generale Was Shocked
By now we’ve all seen the headline—“French Bank Rocked by Rogue Trader!”—heralding the debacle at Societe Generale as the largest bank fraud in history.
 By Richard M. Steinberg, Compliance Week Columnist
02/20/08 Columns & Editorials
11. How Governance Failed in the Sub-prime Mess
It’s difficult to pick up a newspaper or visit a business news Web site without encountering yet more information about the sub-prime mortgage mess—and “mess” is probably too kind a word. With the extraordinary losses and personal pain, terms like “debacle,” “fiasco,” or “disaster” are more accurate. With each new report we learn a bit more about what went wrong and the extent of the consequent suffering.
 By Richard M. Steinberg, Compliance Week Columnist
01/23/08 Columns & Editorials
12. What’s Coming in Governance in 2008
For several years now in my holiday season columns I’ve put forth a wish list for improvements in corporate governance. This year (again with a mug of hot chocolate in hand) I’d like to take a crack at predicting what we might see in governance in the coming years. So, as you listen to the pitter-patter of Santa’s reindeer on the roof or enjoy the light of candles fueled by miracle oil, or however you celebrate the holidays, sit back with me and ponder what the future holds.
 By Richard M. Steinberg, Compliance Week Columnist
12/18/07 Columns & Editorials
13. Empowering CEOs in a Shifting Landscape
My last two columns dealt with the tug of war between boards of directors and shareholders and how boards are best comprised to effectively carry out their responsibilities. Central to these issues is the relationship with the chief executive officer; specifically, how to provide the kind of oversight that enables the CEO to run the business and achieve growth and return objectives.
 By Richard M. Steinberg, Compliance Week Columnist
11/20/07 Columns & Editorials
14. Composing Your Board the Right Way
Last month’s column, “Tug of War Between Board and Shareholders,” focused on shareholders’ demands for greater involvement in governance, including determining who sits in the boardroom. My message was to be careful what you wish for; there’s great danger in having board composition driven by disjointed parties with self-appointed agendas.
 By Richard M. Steinberg, Compliance Week Columnist
10/23/07 Columns & Editorials
15. Tug of War Between Board and Shareholders
The war between boards of directors and shareholders has been raging for many years, heating up and cooling down based on success or failure, evolving goals and opportunities, and opponents’ actions. Some might not see it as a tug of war, instead viewing the respective roles of boards and shareholders as continuing to evolve and mature with the common purpose of enhancing share value. Probably both viewpoints are accurate, depending on one’s perspective and where we are at a particular point in time.
 By Richard M. Steinberg, Compliance Week Columnist
09/18/07 Columns & Editorials
16. The Role of Gifting in Corporate Social Responsibility
Many large (and not-so-large) companies have embraced a measure of responsibility for social needs, based in part on the premise that the corporation owes its existence to the state, or society, and consequently should be a good citizen. Few would argue with this.
 By Richard M. Steinberg, Compliance Week Columnist
08/21/07 Columns & Editorials
17. Being Legal, Honest, And Candid And …
As a Compliance Week reader, you know well the difference between taking an action that’s legal and one that’s ethical. “Legal,” of course, includes acting according to written laws and related regulations, as well as what is deemed legally correct by the judicial system. Acting ethically involves going beyond what is legal, focusing on principles of correct moral conduct. Much has been written about the distinction, and there are other definitions, but we need not get into further detail here.
 By Richard M. Steinberg, Compliance Week Columnist
07/24/07 Compliance Week Coverage
18. What Organizations Don’t Want To Know Can Hurt
Like most Compliance Week readers, I read the business press rather extensively and sometimes come across an article that piques my interest. One, the title of which I'm borrowing as the heading of this column, appeared some months ago in The New York Times.
 By Richard M. Steinberg, Compliance Week Columnist
06/19/07 Columns & Editorials
19. What The New Guidance Will Mean To You
Much has been written about the proposals from the Securities and Exchange Commission and the Public Company Accounting Oversight Board on Sarbanes-Oxley Section 404. If you’ve been dealing with 404 implementation, you’re probably already familiar with what the proposals say, so I won‘t bore you with another recitation.
 By Richard M. Steinberg, Compliance Week Columnist
05/22/07 Columns & Editorials
20. Methodologies For Successfully Implementing ERM
This is the last column in the series on enterprise risk management. The first two described the “what” and “why” of ERM—what it actually is, and why companies are using it. The next two highlighted some of the more effective techniques for applying ERM and where executive responsibility for ERM best resides.
 By Richard M. Steinberg, Compliance Week Columnist
04/17/07 Columns & Editorials
21. Who Should Have Responsibility For ERM?
In the fourth installment of his five-part series on enterprise risk management, Rick Steinberg, the lead project partner in developing the COSO Internal Control—Integrated Framework, looks at where responsibility and accountability for ERM need to rest.
 By Richard M. Steinberg, Compliance Week Columnist
03/20/07 Columns & Editorials
22. Techniques To Implement ERM Successfully
In his third column on enterprise risk management, Richard Steinberg discusses some of the techniques that companies are using to get optimum benefit from their ERM processes.
 By Richard M. Steinberg, Compliance Week Columnist
02/21/07 Columns & Editorials
23. Why Embrace Enterprise Risk Management?
In the second installment of a series on enterprise risk management, Richard Steinberg explores the “why” of ERM—that is, why companies are moving forward with an ERM initiative, including the impetus for doing so and the benefits it brings.
 By Richard M. Steinberg, Compliance Week Columnist
01/23/07 Columns & Editorials
24. ERM Deconstructed: What It’s Really About
At the risk of putting the cart before the horse, let’s look at some misconceptions of ERM. The reality is that many people use the term—including board members, chief executives and other senior executives, consultants and others—all too often meaning very different things.
 By Richard M. Steinberg, Compliance Week Columnist
12/19/06 Columns & Editorials
25. A Holiday Wish List For Corporate Boards
Now that the holiday season again is upon us, I’d like once more to draw on my experience with boards of directors to focus on where improvements are needed. Of course, no two boards are exactly alike, and some are doing a great job. But too many still need to move to a higher level of value-added effectiveness.
 By Richard M. Steinberg, Compliance Week Columnist
11/21/06 Columns & Editorials
26. A Series Of Serious Mistakes At HP Board
As I write this month’s column soon after the Hewlett-Packard board fiasco became front page news, I’m enjoying the moment. Having had the privilege this morning of being featured on CNBC and Bloomberg TV, I’m now on my way to a speaking engagement on the West Coast, and will be seeing one of my sons this evening for dinner. So, with a bit of down time, and this morning’s topic fresh in my mind, now seems as good a time as any to put the fingers to the keyboard.
 By Richard M. Steinberg, Compliance Week Columnist
10/24/06 Columns & Editorials
27. Does Director Pay Taste Better With Coke?
Some months ago Coca-Cola announced a new pay method for its directors. I had planned to devote a column then, while it was hot news, but as other events took priority I decided it might be useful to wait a while and see what further reaction would ensue in the business community.
 By Richard M. Steinberg, Compliance Week Columnist
09/19/06 Columns & Editorials
28. The New COSO Guidance: Wisdom For All
COSO—the Committee of Sponsoring Organizations of the Treadway Commission—recently released the long-awaited guidance for small business. It’s designed to help non-accelerated filers and other companies reduce the burdensome costs that have been or would be incurred in dealing with SOX Section 404.
 By Richard M. Steinberg, Compliance Week Columnist
08/22/06 Columns & Editorials
29. And They Say 404 Simply Won’t Stop Fraud ...
While thinking about possible topics for this month’s column, an inspiration came to me out of the blue—or rather, from cyberspace. The following email appeared on my screen commenting on my July column (published June 20 electronically). By the way, I include the writer’s first two sentences only for the sake of completeness and full disclosure!
 By Richard M. Steinberg, Compliance Week Columnist
07/18/06 Columns & Editorials
30. Getting Things Right On Section 404
As we hear or read about what’s good and bad with Sarbanes-Oxley Section 404, there seem to be almost as many viewpoints as observers. Virtually everyone believes he or she has the right “fix” for what’s wrong with the well-intentioned law, and its requirements that management assess and report on the company’s internal control system, and that the external auditor audit the system and management’s assessment of it.
 By Richard M. Steinberg, Compliance Week Columnist
06/20/06 Columns & Editorials
31. Chairman vs. CEO: Empowering Leaders Wisely
A recent New York Times headline caught my eye: “Fewer chiefs also serving as chairmen.” The article goes on to say that Disney made the break, as did Fannie Mae, Hewlett-Packard and Dell, and now the number of S&P companies with a separate chair and CEO has moved up from 21 percent five years ago to 29 percent today.
 By Richard M. Steinberg, Compliance Week Columnist
05/23/06 Columns & Editorials
32. Implementing ERM: How To Get It Right
There’s much discussion in boardrooms and executive offices these days about enterprise risk management. Certainly, general counsels, compliance officers and internal auditors are among those actively considering whether and how to move forward with some form of risk management.
 By Richard M. Steinberg, Compliance Week Columnist
04/18/06 Columns & Editorials
33. Grasping At The “Holy Grail” Of Governance
In working with boards of directors, senior managements and institutional investors over many years, it’s become evident that while the notion of adding shareholder value is universally accepted and embraced, how companies seek to do so varies widely.
 By Richard M. Steinberg, Compliance Week Columnist
03/21/06 Columns & Editorials
34. Will 404 Really Prevent Financial Reporting Fraud?
Guest columnist Richard Steinberg gets back to the basics of internal controls, and connects how the Sarbanes-Oxley Act tries to prevent what prompted Sarbanes in the first place: fraud instigated at the highest levels of management.
 By Richard M. Steinberg, Compliance Week Columnist
02/21/06 Columns & Editorials
35. Examining Section 404, With Two Years Of Hindsight
Nothing seems to generate more passionate reaction in the business world these days than the Sarbanes-Oxley Act. And nothing gets emotions churning quite like its internal control provisions, Section 404. For the most part, however, SOX and its Section 404 and related rules are here to stay. So now that the second year of Section 404 work is being wrapped up, let’s take a fresh look at whether these requirements really make sense.
 By Richard M. Steinberg, Compliance Week Columnist
01/24/06 Columns & Editorials
36. 2006 Holiday Wish List For Corporate Boards Of Directors
As I curl up with a mug of hot chocolate—OK, it’s a gin and tonic—and feel the warmth of the fire, I find myself in the holiday spirit. The kids’ gifts are ready, there’s a decent football game on television, and I’m mostly content.
 By Richard M. Steinberg, Compliance Week Columnist
01/03/06 Columns & Editorials
37. Directional Shifts: 404 Moves From Project To Process
In my last column, which was published in Compliance Week's November 2005 monthly print magazine, I outlined some of emerging thinking—and changes in direction—regarding compliance with Section 404 of Sarbanes-Oxley. This month we continue the discussion, now looking at what some companies are doing to shift 404 from a yearly project to an ongoing, readily sustainable process.
 By Richard M. Steinberg, Compliance Week Columnist
11/22/05 Columns & Editorials
38. Resources, Ownership And Discipline; Key 404 Lessons
Now that most accelerated filers are coming down the homestretch regarding Section 404 of the Sarbanes-Oxley Act, it’s worth looking at what companies have experienced, and how they’re building on lessons they learned from last year’s efforts. And though there’s still work to do, patterns and trends are emerging that show how companies are dealing with what continues to be viewed as an onerous, burdensome requirement.
 By Richard M. Steinberg, Compliance Week Columnist
10/18/05 Columns & Editorials
39. Putting “Watchdog” To Rest; Boards Don't Just Monitor
The use of the word “watchdog” in connection with boards of directors is troubling for several reasons. First, the word has regulatory oversight implications that may not be appropriate. And second, use of the word without reference to boards’ other responsibilities ignores activities that are critical to satisfying the interests of public company shareowners.
 By Richard M. Steinberg, Compliance Week Columnist
09/20/05 Columns & Editorials
40. Self-Assessment For The Board: What Works, What Doesn’t
A growing number of boards of directors are assessing the effectiveness of their own performance. Some are doing so because they are required to under rules promulgated by the New York Stock Exchange; others are driven by the guidance of governance-oriented organizations, by perceptions of governance “best practice,” or simply by a desire to bring more value to the company and its shareowners.
 By Richard M. Steinberg, Compliance Week Columnist
08/23/05 Columns & Editorials
41. For Chief Audit Executives: Getting Back To Your Day Job
In the last year or more, chief audit executives and their staffs have stepped up to the plate Big Time in their company’s compliance with the requirements of The Sarbanes-Oxley Act of 2002; studies have shown that internal audit functions spent one-half or more of their resources dealing largely with the internal control requirements of Section 404.
 By Richard M. Steinberg, Compliance Week Columnist
07/19/05 Columns & Editorials
42. Management, Auditor Support Of The Audit Committee
In my last two columns, we discussed the tremendous challenges facing audit committees—from deciding on the scope of the committee’s responsibilities, to determining the most effective and efficient ways to carry out those responsibilities. This month, we’ll look at how the parties with which the audit committee deals most frequently—that is, financial management, and the external and internal auditors—provide information and support to make the committee operate effectively.
 By Richard M. Steinberg, Compliance Week Columnist
06/21/05 Columns & Editorials
43. How Audit Committees Best Carry Out Responsibilities
In this column last month, we discussed how serving as an audit committee member is among the most challenging roles in today’s business environment. Considering how the committees’ responsibilities have expanded—with greater expectations of investors, regulators and the courts—I shared some insights on which responsibilities should be on the audit committee’s plate, and which can best be pushed off.
 By Richard M. Steinberg, Compliance Week Columnist
05/24/05 Columns & Editorials
44. Rules & Expectations: What’s An Audit Committee To Do?
Serving as an audit committee member of a corporate board is among the most challenging roles in today’s business environment. Responsibilities have expanded, market expectations have heightened, and stress levels have intensified. Ever since The Sarbanes-Oxley Act of 2002 was enacted—and related SEC regulations and stock exchange listing standards were codified—audit committee members have been struggling with their elevated roles. Even experienced directors, some of whom initially surmised there would be little change in their corporate behavior, have wrestled with issues of process and scope for their audit committees’ activities.
 By Richard M. Steinberg, Compliance Week Columnist
04/19/05 Columns & Editorials
45. True Stories: Why Setting The Right Tone Really Matters
Whatever your role in your company—be it director, CEO, or senior executive—you’ve undoubtedly heard a great deal about the need for your company to set the right “tone at the top.” But what is the “right” tone? Well, that’s usually easier to identify than articulate; the answer to the question is similar to the oft-paraphrased 1964 indecency opinion provided by U.S. Supreme Court Justice Potter Stewart, who said that we can’t define pornography, but we know it when we see it.
 By Richard M. Steinberg, Compliance Week Columnist
03/22/05 Columns & Editorials
46. Will “Bad” 404 Reports Be The End Of The World?
Now that calendar year accelerated filers are putting the finishing touches on their internal control reports required by Sarbanes-Oxley Act Section 404, many are wondering how many companies will disclose one or more material weaknesses, and what the marketplace reaction will be.
 By Richard M. Steinberg, Compliance Week Columnist
02/15/05 Compliance Week Coverage
47. Corporate Governance Resolutions For The New Year
A list of “corporate governance resolutions” for 2005, by Compliance Week columnist Richard M. Steinberg.
 By Richard M. Steinberg, Compliance Week Columnist
01/18/05 Columns & Editorials
48. What Risk And Compliance Officers Should Be Doing
You’ve seen much written and spoken about chief compliance officers, chief risk officers, and persons holding similar job titles. And there’s no doubt, in the aftermath of Sarbanes-Oxley and the renewed focus on risk and compliance, that an increasing number of companies now have or are in process of establishing such roles. Senior managements and boards of directors considering the need or desirability to follow suit are asking some fundamental questions: Why is a CRO or CCO needed? What do they do? And who should fill the role?
 By Richard M. Steinberg, Compliance Week Columnist
12/14/04 Columns & Editorials
49. Integrated Response To SOX 404, USSC, OCEG, COSO ERM
Without reading minds, it’s safe to say you’re likely at the end of your rope with Sarbanes-Oxley Act Section 404. Whether you’re a board member, CEO, CFO, compliance officer, chief audit executive or have another significant role in the effort to report on your financial reporting controls, you’ve put in more time and effort than you ever anticipated. Even if you recognize the benefit of this exercise in terms of your own company’s processes and the broader issue of regaining investor confidence in the capital markets, you desperately want to get to other pressing business issues.
 By Richard M. Steinberg, Compliance Week Columnist
11/16/04 Columns & Editorials
50. What’s Next? Back-To-Business Boardroom Observations
If you’re a director or otherwise involved in your company’s corporate governance, you’ve probably done a lot—and accomplished a tremendous amount—during the past year. You’ve updated charters, amended codes of business conduct, and established whistleblower procedures.
 By Richard M. Steinberg, Compliance Week Columnist
10/19/04 Columns & Editorials

Records per page: Page: 1 | 2