Friday, January 16, 2004


It's always best to think first. And, if there is no inspiration as to which way might be up, busy yourself checking facts. For such a sea change as this SOX 404 promises to corporate "life," preemption is everything. 404 was prepared by lawyers to a lawyers' mandate. There are specific legal meanings and protocols in the " rules of evidence." And, they are objective and logical - as in theorem-prover logical. Whatever one might imagine evidence to be, it is not whim and the incantations of oracles spaced out on hallucinogens.

So if it's not to be validation of corporate governance by ethical authority, what then is to be the benchmark and stop rule of compliance? If you stop short of scrutable connectivity to primitive data, are you sure someone else can't figure a way to move the line of compliance closer? If you can generate financial statements from composed data, logically, what prevents logic and rules for data quality from going back to the work face? If you have a theorem which says it can't be done, what are we doing an audit on? Cripes, Trevor, if they dropped your leash and paid your invoices, you'd have design #1 ready in six weeks.

When you tire of this looping exercise of the intellect in foresight v hindsight, you must select one operating platform or the other. Go for "judgment" or go for "evidence." A combination is forbidden, don't bother. If you choose whim-based financial reporting, fine. You get into the ring with other contestants and wrestle for the most ethical prize of social control. If you choose scrutable connectivity, get to work with orchestrating the data (evidence). It's either power-and-control sociology or engineering. Natural law makes mixtures unstable. But, you already know that from experience.

Remember, all this falls under the title and discipline of corporate "internal control" along with risk management, operations and compliance with laws. Is control technology not your middle name? It is why, exactly, I am a certificate-bearing, gold-sealed member of the Institute of Internal Auditors (IIA). The door to their cage is opening in 2004, they have had the charter for 60 years, and they are paralyzed. One of the few things I can be absolutely certain about in my dotage is that nobody knows how this collision will play out.

Yes, it's a jolt. Get over it.