Dynamist Blog

Sarbanes-Oxley, Cont'd

In response to my posts (here and here) on the waste and distortions created by Sarbanes-Oxley, Jay Manifold emails:

Yeah, it's a pain. The following excerpt from an internal document (with anything remotely sensitive redacted) gives a hint of just how much, but I can tell you from personal experience that there's nothing quite like dealing with this stuff for the first time, under the kind of deadline pressure characteristic of software release implementations, when obstacles have to be cleared in minutes or hours rather than days or weeks. The new de facto size threshold for publicly-traded companies is one thing, but the stress these requirements are placing on individuals is something else:

Passed in 2002, Sarbanes-Oxley requires Information Technology groups to test, evaluate, reconcile, document, publish, and monitor internal control procedures that directly impact financial information. As such, [deleted] has identified key financial applications that require compliance with Sarbanes-Oxley. Those impacted applications can be viewed on the [deleted] web site under [deleted].

Based on the Sarbanes-Oxley requirements and the compliance audit completed, [deleted] will be making changes to our policies and controls to ensure compliance with Sarbanes-Oxley. The following policy changes will be made effective on [deleted].

Category 4 change requests for Sarbanes-Oxley identified applications will no longer be accepted.

Any automated work order that is a code migration or affects batch scheduling (this includes temporary, permanent and adhoc executions) for Sarbanes-Oxley applications must be tied to a Change Request. These automated work order types will not be implemented to production without a corresponding approved Change Request.

Change Requests for Sarbanes-Oxley applications are required to have a business unit point of contact (name and phone number) for change request approval. The business unit point of contact is defined as a non-[deleted] associate who is authorized to make such a request.

Change Requests for Sarbanes-Oxley applications are required to have a business unit point of contact (name and phone number) to perform user acceptance testing of the change.

Business unit point of contact (name and phone number) must send an email to the implementer signifying formal User Acceptance prior to code being placed into production. This email will be documented in [deleted].

[deleted] infrastructure/maintenance activities will be reviewed by change type to determine if a business unit point of contact is also required. This list of change types will be published when complete.

As I write this, I am -- among other things -- pulling together a list of Sarbanes-Oxley related questions which now appear in our online ticketing systems, with typical answers, so that our people won't have to hack their way through a bureaucratic jungle on a daily basis. Your tech-writer correspondent is dead on -- there's definitely a market for people who can deal with this stuff.

Now for the good news. I expect things to get better with time, not because the regs will ease up, but because process developers like me will gnaw away at this stuff until it's (relatively) painless. The analogy is airport security, where a barrage of questionable (to say the least) requirements resulted, initially, in high costs and annoying delays; but three years on, the procedures -- at least in the airports I've been in -- have been significantly streamlined.

Recall our discussion about process improvements in general of a few months back; my intuitive guess (is there any other kind?) would be that with sufficient dedication, compliance costs could be halved every three years. See also the Kamm quote at the end of my sig. We're not marching toward dystopia; there is a deal of ruin in a nation, as I believe Adam Smith said. That multi-hundred-million-dollar revenue figure for the smallest possible public company may drop quite dramatically within this decade.

This is no defense of Sarbanes-Oxley, which I regard as a triumph of conspiracy theorists who think that all publicly-traded corporations -- well, all corporations, actually; these are just the ones they can get to easiest -- are up to no good and must be constrained with the present-day equivalent of the Nuremberg Laws. Fuckers.

Blogging is light this week, because I'm working not only on my Times column but on a feature for a special Times section on small business. In an interview today, the CFO of the company I'm profiling said in passing that it's no longer feasible for businesses its size ($68 million in sales) to be publicly held. Fortunately for these founders, the grand visions they had at age 26--15 years ago--didn't come true. They built the business steadily, using retained earnings, and never went public. But similarly sized public companies are now looking to go private. Somehow I don't think this particular distortion does much to protect the publi

Autographed Books for Sale

tsos.jpg The hardback version of The Substance of Style is no longer available via Amazon (except for used copies). While I do encourage readers to buy the paperback--which actually has additional material, just like a DVD (that's the way the publisher puts it)--many people simply prefer a hardcover, especially if it's signed. So I'm once again accepting direct orders. The book is $20, plus shipping.

Orders received before February 2 will be filled promptly. (Orders received after then will be shipped on February 15, assuming I don't run out of books.) Please be sure to not only give me your shipping address but also to tell me to whom I should inscribe the book. Thanks!

Prison Rape

Given what goes on in domestic prisons, with little or no public objection, it's hardly surprising to find soldiers torturing and abusing enemy prisoners. From today's Dallas Morning News report:

Four years ago, Mr. Cunningham said, a state corrections officer raped him near the showers of a prison. Afterward, the inmate lay in bed, weeping. "When I was awake, I thought about wanting to die, because I didn't want to live with this," said Mr. Cunningham, 33.

Since 2000, at least 129 Texas prisoners, including Mr. Cunningham, have alleged that they were raped or had had sexual contact with corrections officers, according to state records. Allegations of inmate-on-inmate rape are even more frequent and appear to be increasing. Overall, the number of reported sexual assaults in Texas prisons has increased 160 percent, to 609 in 2004 from 234 in 2000.

Inmate advocates – who have launched a nationwide legal campaign against assaults and the complacency that they say allows them to flourish – say that the problem is greater than the statistics show, with the situation in Texas acute.

"I really have become convinced over the last three years or so that Texas is the prison-rape capital of the country," said Margaret Winter, a lawyer who represents two inmates who sued the prison system. "When prisoners report it, they are ignored, laughed at and often punished."

Read the whole thing.

Prison rape isn't a way to be "tough on crime." It is crime, whether perpetrated by prisoners or by guards. Because it's illegal, not a public policy, I'm a dubious about the success of an Eighth Amendment challenge. But at least these lawsuits bring some much-needed court discovery and public scrutiny.

A Thousand Words

John Paczkowski's Good Morning Silicon Valley blog is soliciting captions for this photo of Bill Gates, which left Paczkowski "slackjawed and stammering."

His favorite entries so far: "I made the screen blue ... to match my eyes"; "Hi, I'm Bill. And this is my friend, Longhorn Reduced Media Version"; "A hot new amateur every day!"; "Thanks for the brownies, Steve"; "It's not the Blue Screen of Death, it's The Blue Screen of Desire"; and "... I'm waiting for your call. Dial 1-800-LONGHORN, now."

Women Who Think, cont'd

Maybe English majors really are better at this stuff than MIT biologists. Here's Megan McArdle on the Summers flap. Here's a small sample:

4) People who are arguing that it's stupid to generalise from means or distributions to individuals...are right, but only in a trivial, irrelevant way. The particular discussion at hand revolves around the fact that there are fewer women than men in many scientific disciplines, particularly, it seems to me from the outside, the ones that involve a great deal of rather abstruse math. We are looking at a population, not an individual, and it is entirely proper--nay, necessary--to discuss group averages. That we cannot divine any individual's ability from those averages is true, but irrelevant; we're looking at the group.

Look at it this way: I am 6'2 (1.88 metres), which puts me four standard deviations from the mean height of American women--approximately one tenth of one percent of American women will be as tall as, or taller than, I am.

Could we use the average of the female population to predict that I am not 6'2? No! I am 6'2. We would get the answer wrong if we tried to use the average predictively.

Could we use the average to bet, sight unseen, on whether or not I am taller than 6'1? Yes! Only 0.3% of the female population is taller than 6'1. If you had to bet, you'd bet against it. Of course, in my case you'd be wrong--but it would still be the right way to bet.

But do we need to bet? No! We can measure me. Similarly, physicists considering female candidates have lots of other means to assess their physics ability. They don't need to look at whether or not she's female.

But if we were looking at an organisation that only hired people who were taller than 6 feet because they needed them to reach very tall shelves, most of the employees would be men. We might infer discrimination, but we'd be wrong. It's just that innate differences would produce differing results for men and women. And if I showed up and they refused to hire me because I'm a women, and women have a very low probability of being that tall, that would be discrimination, because they can look right at me and see that despite being a member of a group with a lower mean height, I myself am in fact configured like a beanstalk.

Women Who Think

The flap over Larry Summers' bravely analytical comments on why women might be scarce at the top of math and science scholarship demonstrates that political correctness is alive and well and, even more depressing, that a remarkable number of scientifically talented women are incapable of understanding plain English or the difference between general statistical patterns and individual data points. It's been a long time since female scientists did so much to advance the stereotype of women as hysterically incapable of rational analysis.

As it so often does, the WaPost distinguished itself with a more sophisticated knowledge of relevant sources than demonstrated in newspapers to the north, quoting the eminent economic historian Claudia Goldin, who knows where the statistical bodies are buried on all sorts of labor market issues:

"I left with a sense of elation at his ideas," said Claudia Goldin, a Harvard economics professor who attended the speech. "I was proud that the president of my university retains the inquisitiveness of an academic."

"Retains the inquisitiveness of an academic." Which implies that those who want to silence him do not. That's tough. And true.

I parsed the debate on sex roles in this Reason editorial.

Finding Your Calling

My latest article, in Sunday's NYT Book Review, looks at the job-hunting manual What Color Is Your Parachute? (I read the 1973, 1983, 2004, and 2005 editions.)

Thirty-five years ago, an Episcopal minister self-published 100 copies of a slim job-hunting guide and gave them away at a conference for college chaplains, many of whom were facing layoffs. Soon he was getting requests for more and more copies. Two years later, the little book had a commercial publisher, the small Ten Speed Press in Berkeley, Calif. "What Color Is Your Parachute?" has since become a classic, the "job hunter's bible," and sold more than 8 million copies. The 2005 edition, with a large grinning photo of its author, Richard N. Bolles, on the cover, was published in November. A lot has changed since the early 1970's, but not as much as we sometimes like to think. Job losses and career angst didn't start with the bursting of the tech bubble or the midlife crises of the baby boomers. Even way back when, white-collar workers, some of them highly trained technical experts, lost their jobs for reasons beyond their control. The first commercial edition of "Parachute" singled out aerospace engineers, whose profession was "being phased out of our society."

The book takes its title from the idea that sooner or later each of us is going to have to bail out of our current job, usually involuntarily, with only our enduring talents to support us: "The time to figure out where your parachute is, what color it is, and to strap it on, is now -- and not when the vocational airplane that you are presently in is on fire and diving toward the ground," Bolles wrote in the 1973 edition.

"Parachute" arrived on the scene when business practices and employee ideals and attitudes were beginning to shift. The postwar "loyalty ethic," in which workers got security in exchange for obedience, was dying. More Americans were starting to look for personal fulfillment in their work, which made them increasingly likely to change jobs, while employers were becoming more ruthlessly pragmatic about layoffs. "The view that there was loyalty between company and worker back then was also a myth," Bolles said in a 1999 interview in Fast Company magazine. "Even then," he said, "the conditions that produced the workplace realities of today were very much in place."

The article's conclusion got compressed a bit for space reasons. Here's the original:

The old work ethic preached that liking your work wasn't important. The new one preaches that enjoyment is essential, even (in Bolles's 1972 formulation) "divine radar" indicating what you should be doing. Parachute's 2005 edition includes a chapter aimed at helping readers identify the transferable skills they most enjoy using and the environments in which they find the greatest satisfaction. Its title, "When You Lose All Track of Time," suggests a purely secular reading of Parachute's search for meaningful work.

Even if you don't believe that a higher power has given you a destiny on earth, every human being has the capacity to find what psychologist Mihaly Csikszentmihaly calls "flow"--the total engagement with some sort of problem solving, from climbing mountains to writing computer programs to knitting, that causes a person to lose track of time. Flow activities give people their happiest moments, and these activities are intrinsically rewarding, regardless of any greater meaning. The point of a life-changing job hunt is to find work that provides flow.

That message makes Parachute not only practical but intellectually contrarian. Protestantism, claimed Weber, divested work of its earthly delight, making it purely a religious duty. Capitalism, he continued, "has destroyed" that delight "forever."

What Color Is Your Parachute? is an extended, market-grounded argument that Weber was wrong. A century after The Protestant Ethic and the Spirit of Capitalism was published, the best-selling book about job hunting is an explicitly Protestant guide to finding joy at work.

For more on related themes, see my 1995 review of Charles Heckscher's White-Collar Blues, this oped piece on William Whyte's The Organization Man, and this lecture on the "power of play," derived from chapter seven of The Future and Its Enemies.

When Segregation Was Modern

As the nation remembers Martin Luther King Jr., Thomas H. Garver, organizing curator of the O. Winston Link Museum, writes to to correct this old post:

I note your reference in your website to the fact that Modernism Magazine cites the O. Winston Link Museum, located in the old Norfolk and Western Railway station in Roanoke as having removed the "COLORED" sign from above its door.

Let me point out that this sign was removed decades ago when segregation on public conveyances was no longer permitted nor tolerated. The station itself was closed in 1971, with the termination of passenger service, and subsequently used for offices until it was abandoned about 20 years later. The museum does discuss the fact that the station was a segregated facility in a text and illustrative panel installed inside the museum.

From the Library of Congress, here are a couple of vintage photos of the station, which was redesigned by Raymond Loewy in 1947:



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