HOW MUCH IS IT GOING TO COST? DO THE COSTS NEED TO BE ‘DISPROPORTIONATELY HIGH,’ AS SOME MEMBERS OF CONGRESS WARN?
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THE NEWS ISN’T ALL BAD: Proven Savings
The high cost of Sarbanes mostly occurs due to the amount of testing that needs to be carried out. The greatest savings are found by reducing the number of tests and the level of rigor needed to perform these tests, and then performing them efficiently. Fewer controls and simpler test plans in the Risk Control framework will result in substantial savings.
Three areas of potential optimization stand out: risk and control redundancy; replacement of high frequency controls with compensating low frequency or entity-level controls; and standardization of controls and testing definitions. The new guidelines provide added rationale for such optimization to go wider and deeper still.