Corporate records management is not about policies, procedures, retention schedules and inventory and email control software. It’s about enforcement that is consistent, systematic and defendable. With the rapid and very public evaporation of the venerable Arthur Andersen company, we have seen how a multi-billion dollar firm can be put out of business because of lapses […]
Internal Controls
Text Of Sarbanes-Oxley Section 404: Management Assessment Of Internal Controls
(a) RULES REQUIRED- The Commission shall prescribe rules requiring each annual report required by section 13 of the Securities Exchange Act of 1934 (15 U.S.C. 78m) to contain an internal control report, which shall– (1) state the responsibility of management for establishing and maintaining an adequate internal control structure and procedures for financial reporting; and […]
Complexity, Integration Are Barriers To Compliance
Buried deep in a recent study of financial-services compliance was some interesting information about typical barriers that prevent companies from achieving “first-rate” compliance. Most of the data collected in the study, which was conducted by PricewaterhouseCoopers and the Economist Intelligence Unit, was focused on financial institutions, and was therefore not entirely relevant to most CW […]


