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Sarbanes-Oxley One Year Later: Sign-Offs on Financials "Trickle Down" to Other Finance Staff

AFP survey reveals widespread practice of "subcertification"

JULY 29, 2003 -- BETHESDA, MD --One year after the Sarbanes-Oxley Act required CFOs and CEOs to certify their company's financial statements, a new survey by the Association for Financial Professionals (AFP) reveals that companies are asking other corporate financial professionals to vouch for reported information as well.

This additional compliance step, deemed subcertification, raises the spotlight on financial professionals and their critical role in supplying accurate financial reporting. It requires the employees responsible for a company's financial information to certify the data they provide that is later included in public financial reports. It is not required by law, but viewed as an extra measure of protection.

The job titles held by financial professionals surveyed range from treasurers and assistant treasures to cash managers, controllers, directors and managers. Key findings of the survey:

  • Roughly one-third of financial professionals who provide information used in their company's reports to the Securities and Exchange Commission (SEC) are asked to "subcertify" the documents by signing an affidavit.
  • While nearly 80% of financial professionals asked to sign an affidavit expressed a "high" or "moderate" level of concern about their liability, 21% have sought counsel from the company attorney and 2% from a personal attorney.

"I believe the prevalence of subcertification, while a direct result of Sarbanes-Oxley, reflects the increased level of importance that financial professionals hold within their companies," said Jim Kaitz, AFP's president and CEO. "Greater accuracy in financial reporting and increased accountability will ensure that most companies are honest and report earnings accurately. This knowledge will ultimately lead to a more stable economic environment."

Financial professionals are asked to subcertify a number of items; including: 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, and compliance with company code of conduct.

In June 2003, AFP sent 3,000 of its members a 13-question survey on their financial reporting responsibilities and the prevalence of subcertification. There were 425 corporate practitioner member responses. AFP sent an additional 3,000 surveys to other financial professionals garnering an additional 130 responses. At a 95% confidence level, the survey responses are accurate within a four-percentage point interval.

To navigate the requirements of Sarbanes-Oxley, AFP published a white paper on subcertification issues that addresses specific concerns employees might have.

The Association for Financial Professionals in Bethesda, Maryland, supports more than 14,000 individual members from a wide range of industries throughout all stages of their careers in various aspects of treasury and financial management. AFP is the preferred resource for financial professionals for continuing education, financial tools and publications, career development, certifications, research, representation to legislators and regulators, and the development of industry standards.

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