Price Waterhouse Coopers has a thoughtful, and lengthy, whitepaper
laying out their vision of a "Governance, Risk, and Compliance Operating Model" (it’s consultant-speak;
they can’t help themselves) which actually embodies a belief I’ve held
for awhile: That we should take Sarbanes-Oxley
and make lemonade.
In other words, if a business has to re-evaluate
its financial, accounting, and auditing plumbing from the ground up,
why not take the opportunity to derive more business value from the
exercise rather than succumb to the instinct that it’s nothing but government-mandated
pain? I would wager that very few financial-reporting systems
bear any resemblance to what one would create if starting with a clean
sheet of paper. SOX can be that clean sheet.