Financial Reporting Controls Integrity (FDICIA / SOX / COSO)
Banks with assets in excess of $1 billion as well as SEC-registered banks reaching a certain market capitalization level are subject to FDICIA and/or SOX financial reporting controls rules. Best-practice methodology is now guided by COSO 2013 (Committee of Sponsoring Organizations).
Over the five past years, The Navis Group has assisted 45+ institutions that are either reaching the relevant compliance threshold(s) or those institutions that are moving “old-school” approaches forward to best-practice compliance. Interestingly, in the latter case, we have found that banks had largely over scoped and therefore over tested the old FDICIA matrices, adding unnecessarily to the audit department’s schedule or budget.
We had developed an Excel-based approach, meeting the financial statement component synchronization recommended as part of the COSO methodology. Additionally, we have created a Word-based narrative that addresses COSO’s 17 principles and 87 focus points. Our approach now largely represents ”consensus” based on the number of institutions and external audit firms contributing to the effort. We have migrated the Excel version to Smartsheet to leverage Smartsheet’s work-flows and time and date stamps documenting certification.
Strategic Planning – Management / Board Retreats – Banks & Credit Unions
Strategic planning is an integral component of an institution’s planning, direction and growth. The Navis Group regularly facilitates strategic planning sessions / retreats with a unique focus on organizational planning. Our "7-Year-Horizon" has helped management teams and boards get past the myopia of the traditional 3-year plan.
We work with client institutions to guide the pre-planning process, facilitate a board retreat and strategic planning session, and assist with the writing of the plan and its many components, demographics, metrics, financials, goals and objectives.
Back-office Efficiency Studies
Our financial reporting controls work often leads to efficiency analysis projects. We have been involved with detailed analysis of deposit operations, loan operations, e-commerce operations, retail operations and audit/risk department complexities.
Interestingly, our risk and systems work has occasionally placed one of us in a position to fill a gap, or bridge a transition when personnel exit an institution, leaving key officer-level positions vacant. In past years, we have served as interim CFO or Controller, CRO, and CIO, “filling the seat” and assisting with the executive search, interview, vetting, hire, and transition.
Commercial Loan Origination System Search & Decisioning
Commercial Loan Origination Systems (LOS) are quickly maturing, offering work-flows, documentation tools, and data linkage making the work of commercial loan departments smarter and more productive. Navis has developed a standard RFP and methodology as we have gotten to know the “players” in the LOS space. We stand ready to manage your search and decision.
Enterprise Risk Strategies
Enterprise risk management (ERM) is an evolving challenge for a methodical, disciplined and holistic approach to all-things-risk within a financial institution. This discipline still lacks much in the way of formal regulatory guidance, even though ERM has been identified as a key focus of the regulatory agencies.
The Navis Group is one of the early pioneers in this area, having worked with many institutions on a myriad of ERM issues and approaches. Our work aims to help clients to make ERM an efficient value-adding effort.
Projects have included organizational architecture decisions; i.e. risk’s “place” in the orgchart. We have also assisted with risk committee charters, risk appetite statements, committee composition and meeting content, as well as board and management education. In one instance, we served as interim CRO while the Risk Department built out, and in many instances, we are a regular contributor to client risk committee meetings.
David B. Sidon: Gloucester, Massachusetts
The Navis Group was founded in 2003 by David Sidon, CPA. The Company is a New England based banking consulting group specializing in SOX/FDICIA/COSO, strategic planning, back-office efficiencies, business continuity tabletop testing, organizational architecture, and enterprise risk management.
Financial reporting controls integrity based on COSO guidance with respect to FDICIA/SOX requirements has been the key concentration for Mr. Sidon over the past decade, with more than 40 such projects completed, and with about half of those leading to the annual management of the COSO compliance effort. The COSO work has become the signature aspect of Navis’ branding and identity. Strategic planning is another element of concentration for Mr. Sidon, annually facilitating management and Board retreats and crafting the strategic planning documents emanating from those sessions.
Mr. Sidon is also recognized in the industry for his business continuity tabletop exercises. He has conducted full-day, full-immersion business continuity exercises for many banking associations including Massachusetts, Connecticut, New York, Maryland and Kentucky. Participants have survived hurricanes, ice storms, wide-scale electrical outages, pandemics and cyber attacks. At the individual bank level, tornadoes, fires, chemical spills, electrical outages, cyber breaches and terrorist threats have been played out. The exercises are part consulting; part improv theatre.
Including freelance consulting work from 1998 to 2003, David has provided consulting services to more than 100 different institutions. The key descriptive word in that last sentence is “different”. Banks may all use checks that are rectangular in shape, but, after that, people, cultures, systems, geography, and complexity all contribute to a rich diversity institution to institution.
Personally, his credentials include a Bachelors degree in Business Administration (Merrimack College, as part of their initial co-op class), a CPA license, and a Masters degree in Finance from Bentley. After 13 tax seasons in public accounting and a brief dabble in private industry as a CFO, Mr. Sidon’s banking career commenced in 1985 as a young director at Gloucester Cooperative Bank. After starting out as the mortgage department (small bank - many hats - one man department) he eventually spent the last three years of his ten year tenure as CEO. In 1996, Mr. Sidon joined a larger commercial bank, Gloucester Bank & Trust, as CIO, running a three bank data center. After the BankNorth signs were installed on the GB&T building in 1998, his consulting career was launched; just in time for Y2K.
David managed Y2K readiness and testing projects for numerous New England banks, but also included work as far away as Guam. One of the interesting aspects of Y2K planning was that investment in banking technology was either escalated or delayed around that fateful and, as it turned out, uneventful date. System searches and implementation project management followed in the early years of the new century.
Mr. Sidon led a team that attempted to form, open and capitalize a de novo bank from late 2001 through June 2003, and although all approvals were attained, capital in the post 9/11 market recession was not adequately available.
On July 1, 2003, The Navis Group was born, soon moving into the newly emerging ERM (risk) disciplines, inclusive of technology and information security (GLBA) risks. He has assisted numerous client banks with risk programs, committee charters, risk appetite statements and risk metrics, regularly serving as a contributing member of client banks’ Risk Committees.
In addition to working with client institutions, Mr. Sidon has worked with the Massachusetts Bankers Association and Connecticut Bankers Association on various programs. For MBA, he facilitates a series of CFO forums and Risk Manager Forums. For CBA, as a faculty member of the Connecticut School for Financial Management, he instructs a risk class and serves as the driver of the financial simulation model underlying the school’s capstone resident session. For many associations, he has presented and facilitated ERM sessions and provided COSO-related education...
Kevin W. Nunes: Gloucester, Massachusetts
email@example.com / 978-423-7296
After graduating from Salem State College in 1984 with an accounting degree, Kevin joined the “Big 8” accounting firm of Arthur Andersen & Co., spending time in both the audit and tax divisions before leaving to join a division of ITT/The Hartford Group in Boston as a financial and reinsurance analyst. In 1991, Kevin joined Gloucester Bank & Trust Company (GB&T), where, along the way to becoming the bank’s CFO/Treasurer, he also ran the in-house operations center and was head of human resources. In 1996, Dave Sidon joined GB&T to develop its in-house systems processing excess capacity into a data center serving other financial institutions, beginning a long-standing association with Kevin that continues to this day.
In 2001, Kevin re-connected with David Sidon to become part of the core management team and the initial investor group for the formation of a de novo bank – Navis Bank – on Cape Ann, the precursor to the formation of the Navis Group in 2003. Kevin’s specific banking experience includes asset/liability management and liquidity planning, development of financial models for strategic planning and balance sheet modeling, bank regulatory compliance and investment portfolio management. As well his experience with forensic accounting and his background in audit and as a financial analyst lends itself to the work Navis Group does for its client banks, especially with respect to the FDICIA/SOX/COSO work that has become a mainstay of the practice
In 2001, Kevin re-connected with David Sidon to become part of the core management team and the initial investor group for the formation of a de novo bank – Navis Bank – on Cape Ann, the precursor to the formation of the Navis Group in 2003.
Kevin’s specific banking experience includes asset/liability management and liquidity planning, development of financial models for strategic planning and balance sheet modeling, bank regulatory compliance and investment portfolio management. As well his experience with forensic accounting and his background in audit and as a financial analyst lends itself to the work Navis Group does for its client banks, especially with respect to the FDICIA/SOX/COSO work that has become a mainstay of the practice