SOX Professionals Group

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Controls around preparation and review of SEC disclosures

  • 1.  Controls around preparation and review of SEC disclosures

    Posted 04-04-2024 08:45 PM


    I wanted to reach out to the community and see what others are doing regarding controls specific to SEC disclosures. Our SEC reporting team receives disclosures that go into 10K-10Q from multiple teams. GL, Revenue, Inventory, Stock admin etc. Within GL there are different teams that prepare and provide disclosures related to leases, FA, intangibles etc. The understanding is that in each team an individual prepares and their managers review it before passing it on to the SEC team for inclusion in the filing. We have controls related to overall tie-out but not related to preparation and review of disclosures. This is because the nuances are each disclosure is different, there are different owners and reviewers of this process and it would not be practical to create a specific control for each disclosure. On the other hand, a generic controls covering all disclosures is not helpful since it one team messes up, then the entire control fails impacting all teams. How is this addressed by others? I have a situation where I have an error in one of the disclosure tables. In analyzing the error and identifying which control failed to catch it, i dont have a specific control that i can map here. But i also dont believe this is a design deficiency and a control is missing. Simply creating a generic control wont help and creating multiple controls is not manageable. 


    Hetal Bhuta
    Dir. Financial Compliance
    Roku. Inc.