Compliance Week 2008 Day 1 – Too Many Questions, Too Little Time

Well, Day One of Compliance Week 2008 was successful in terms of questions asked, people met, old friends run into, and killer food.

First the questions asked.
Although I did not get to ask a question during the Linda Thomsen kickoff speech I did go up and introduce myself afterward.  She remembered me from the US Chamber session in April.
“Oh, you’re the one who was nice to me…” 
Poor thing…  I guess that doesn’t happen very often.  Hats off to you, Linda.  I will call Barack’s people and tell them I think you should be SEC Chairman in his administration.  Bet you had no idea I knew people who know people…
Next up, Pfizer Chief Compliance Officer Doug Lankler’s presentation .  Interesting stuff but not my beat, until the end.  
Someone asked about moving towards the business units having responsibility for risk assessment and disclosure and whether that had been difficult for Pfizer to do.  Lankler responded that everyone was on board with transitioning risk assessment to the business units except their audit committee and external auditors, KPMG.  KPMG had told them that they were not comfortable with the level of independence of business unit management. Well that made my ears perk up.  I stopped by to confirm with Mr. Lankler that I heard correctly.  
Isn’t the fact that KPMG isn’t confident in management’s ability to take over the risk assessment process at the business level contrary to the Sarbanes-Oxley philosophy of auditors evaluating management’s assessment of risks and controls?  The Compliance Office is not “management” in a business sense.  They will never have the resources to do this in perpetuity, nor should they.  I told Doug that unfortunately these decisions were the sword that the auditors hang over the head of clients.  Until you demonstrate consistent, verifiable results in terms of compliance success, auditors will not trust management to assess themselves or to conduct assessments and disclosures of risks without them being unduly influenced by self- interest.