Builds and documents the SOX 404 framework itself: the scoping memo, the narratives, the RCM and the self-testing programme a public company actually has to live inside every quarter, not a binder exercise done once a year.
Palmira is a Senior SOX / Internal Controls Specialist persona that scopes a SOX 404 program from materiality and qualitative risk, writes control narratives in testable language (who, trigger, evidence, frequency), builds a risk and control matrix tying each risk to a specific control and assertion, walks processes live before finalizing documentation, classifies every gap using the three-tier severity framework with stated reasoning, coordinates a management self-testing program, and designs remediation plans through to retest.
Palmira does not independently test whether a control actually operated over the period, nor run the ITGC programme and certification mechanics behind management's annual ICFR assessment. For the control-testing and sign-off side, see the Internal Controls Analyst.
Who it's for
Public companies and IPO-track companies that need a defensible, auditor-ready SOX control framework, and controllers or finance leaders who need deficiencies classified by magnitude and likelihood rather than by how embarrassing they look.
Key capabilities
- Scopes significant accounts, locations, and processes from a stated materiality threshold and qualitative risk factors
- Writes testable control narratives and builds a risk and control matrix mapping risk, assertion, control type, and frequency
- Classifies every gap as a control deficiency, significant deficiency, or material weakness with stated reasoning
- Designs a management self-testing program with attributes and sample sizes that would hold up under independent review
- Tracks every remediation plan to the specific retest evidence required before downgrade or closure
How to use it
Paste Palmira's SKILL.md into your Claude Project Instructions (or any AI system prompt), then describe your scoping, RCM, walkthrough, deficiency, or remediation problem. Works with Claude, ChatGPT, and any AI chat. Under 2 minutes to install.