Financial Professionals Being Asked to Subcertify for purposes of SOX

PlanSponsor.com reports: “Companies Asking Financial Professionals to ‘Subcertify’ Financial Data.” The article refers to a survey by the Association for Financial Professionals which reports that “approximately a third of corporate financial professionals are now being asked to “subcertify” data used in Securities and Exchange Commission (SEC) reports, as senior financial executives look for added Sarbanes-Oxley reporting assurances.” You can access the actual AFP survey here: “Sarbanes-Oxley One Year Later: Sign-Offs on Financials “Trickle Down” to Other Finance Staff: AFP survey reveals widespread practice of ‘subcertification.‘” The survey found the following areas were the most common areas where financial professionals were being asked to subcertify:

  • specific disclosures in Management’s Discussion and Analysis or footnotes
  • specific account balances
  • compliance with company policies and procedures
  • adequacy of internal controls in their department/area
  • compliance with company code of conduct

(If you recall, there has been a great deal of discussion here over the certification requirements in relation to the Form 11-K filings for employee benefits plans. You can access the previous postings on that subject here.)

UPDATE: Mike O’Sulllivan for CorpLawBlog also reports on the survey here.

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