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  • Different Flavors of Leases Back On

    - by Theresa Hickman
    Given the continued interest regarding the proposed changes to Lease Accounting, I decided to write another entry on this controversial topic with colorful commentary from our resident accounting expert, Seamus Moran. Background (A History Lesson) Back in 1976, the FASB issued FAS 13, “Accounting for Leases” that permitted leases to be either an operating lease or capital (finance) lease. In substance, operating leases are a form of off-balance sheet financing. According to Seamus, operating leases date back to the launch of the Boeing 707 in the 1950s.  Because the aircraft was so much more expensive than previous aircrafts, the industry came up with the operating lease concept to accommodate these jet liners that dominated air transport.  How it worked was the bank would buy the plane and lease it to the airline.  Because the bank never controlled or flew the plane, they never placed the asset on their balance sheet, and because the airline never owned the plane, they didn’t place it on their balance sheet either. They simply treated the monthly lease payments as rental expenses on the P&L.   August 2010 Original Lease Accounting Changes In August 2010, FASB and IASB decided to overhaul lease accounting as part of their joint commitment “to insure that investors and other users of financial statements are provided useful, transparent, and complete information about leasing transactions in the financial statements.”  Some say that the current lease accounting standards are broken because it keeps assets off the balance sheet, hidden from investors’ view. The original proposal abolished operating leases and only permitted capital leases where all leases would be recorded on the balance sheet as assets and liabilities. The asset side would reflect the right to use the asset for the leased term, and the liability side would reflect the obligation to make lease payments.   Why Companies Were Freaking Out According to the SEC, the financial impact of the aforementioned lease changes was estimated to add more than $1.3 trillion of operating lease obligations to corporate balance sheets. Many companies in various industries, especially retail, are concerned because the changes are significant and will impact existing leases with no grandfather clause for existing operating leases. Of course, the banks and airlines I mentioned earlier really hate this because neither wants to report the airplane (now costing around $60 M) as an asset. Regular companies were concerned that they would have to report routine short term leases of real estate or equipment as fixed assets, even though they were really just longer term rentals.  One company we spoke to leased roadside billboards, and really did not consider them to be fixed assets in any way. Obviously, these changes would have had a profound and lasting effect on a company’s financial and real estate strategies and significantly impact its financial statements.  Financial statements would show higher depreciation and interest expense with significantly higher total assets and debt. In terms of financial metrics, they’re negatively impacted. It would raise a company’s debt-to-capital ratio to reflect the higher debt compared to equity, it would negatively impact their return-on-assets because now companies will appear more asset intensive, and it will decrease EPS, lowering shareholder ROI. Feb. 2011 Recent Update The comment period on leases closed in December 2010. The FASB and the IASB have met several times since then and published their initial responses to the input they received from the various interested parties.  They are “redeliberating” the principles involved in Lease Accounting.  Some of the issues they are looking at include: The core definition of a lease.  This will articulate principles on what is a lease and what is “not-a-lease.” One theory or supposition is that they might define a lease as the transfer of certain but not all major ownership attributes for a certain period of time.  So a year’s lease of an aircraft might be a “lease,” but a year’s lease of half a floor in an office building would be “not-a-lease.”  The ownership attributes transferred from the core owner to the user are different; the airline must maintain, paint, and do whatever it needs to do on the aircraft. However, the office renter will have strictly limited rights in respect to the rented space. The differences between a lease contract and service contract.  Even if they call them “leases” for the purpose of commercial law, a service contract might not be accounted for as a lease. The accounting to be done by the lessee.  They would define when the bank or landlord would retain the asset on their balance sheet, and perhaps by implication, when the lessor would not need to include the asset on theirs.  So if the finance house keeps the airplane or office on their balance sheet, the tenant doesn’t need to.  I’m not sure that I can draw the opposite conclusion where the finance house doesn’t report but the tenant must. The difference, if any, between a financing lease and other leases, and the implications to the accounting. The present value calculation when renewable terms exist. They have reduced the circumstances in which one must look at the renewable terms of a lease in calculating the present value.  In most circumstances, you will use the lease term rather than the potential renewable term. Their latest discussion this past week with the contents of the discussion was not available at the time of me writing this entry.  For more details, the results of the discussions are posted on both the FASB and the IASB websites. Implied Software Changes Whatever the final rules turn out to be, all ERP systems, such as Oracle E-Business Suite, PeopleSoft Enterprise, JD Edwards, and Oracle Hyperion will need to change their software to accommodate the new rules. The following lists some changes that might have to be made to accounting software depending on what the final standards will be in June 2011: Lease tracking may require modifications with tracking of additional lease details that might require a centralized repository to maintain Accounting may need to be modified as there are many changes to how capital leases and the new “other than finance” leases are accounted for both on the lessee and lessor side.  For example, valuation, amortization, and disclosure will be considerably different requiring different types of data to be captured. Companies may need to modify their chart of accounts depending on how they want to track leases, which could then impact financial reporting and consolidation Business processes may require changes which could then impact internal controls Software applications may need to perform more advanced computations on leases Reports and KPIs may need to reflect new operating metrics Hold Onto Your Seats           Before you redo all your lease agreements and call your software vendors asking when the changes to the software will be made, remember that the rules are not finalized yet, and from appearances, will not reflect the proposals in the exposure draft.  Not only are there objections to putting the operating lease assets on anyone’s balance sheet, there are lots of objections to subjectivity and the data required for the valuation.  According to Seamus, there is huge opposition from New York bankers, the airlines, the EU, the Communist Party of China (since it impacts their exporting business), and Republicans (hearing complaints from small and large businesses). Even if everyone can agree on the proposed changes, 2013 might be the earliest that companies would need to change how they report leases. The Boards will finish their deliberations in April, May or June 2011.  As we’ve seen with other Exposure Drafts, if the changes are minor and the principles met the General Acceptance consensus criteria, the Standard could be finalized at that time.  However, if substantial changes are made, a fresh exposure draft, comment period, and review period might be involved, too. Seamus added an interesting perspective. Even if the proposed changes do pass, don’t you think our customers, such as Boeing, GE Capital, United Airlines, etc. will be clever enough to come up with a new kind of financing arrangement that complies with the new accounting? How about the large retail customers, such as Best Buy and Macerich? Don’t you think they might simply cut deals around retail locations with new contracts that prevent their leases from being capital leases? Instead of blindly adapting the software to meet the principles outlined in the final standard, our software needs to accommodate how businesses will respond to the new rules. We cannot know our customers’ responses until the rules are finalized. Oracle is aware of the potential changes and is staying abreast of the developments through our domain expertise staff, our relationship with customers, our market awareness, and, of course, our relationships with the Big 4. This is part of our normal process with respect to worldwide regulatory compliance. Oracle products have been IFRS and GAAP compliant for years and we will continue to maintain those standards going forward.

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  • Toorcon14

    - by danx
    Toorcon 2012 Information Security Conference San Diego, CA, http://www.toorcon.org/ Dan Anderson, October 2012 It's almost Halloween, and we all know what that means—yes, of course, it's time for another Toorcon Conference! Toorcon is an annual conference for people interested in computer security. This includes the whole range of hackers, computer hobbyists, professionals, security consultants, press, law enforcement, prosecutors, FBI, etc. We're at Toorcon 14—see earlier blogs for some of the previous Toorcon's I've attended (back to 2003). This year's "con" was held at the Westin on Broadway in downtown San Diego, California. The following are not necessarily my views—I'm just the messenger—although I could have misquoted or misparaphrased the speakers. Also, I only reviewed some of the talks, below, which I attended and interested me. MalAndroid—the Crux of Android Infections, Aditya K. Sood Programming Weird Machines with ELF Metadata, Rebecca "bx" Shapiro Privacy at the Handset: New FCC Rules?, Valkyrie Hacking Measured Boot and UEFI, Dan Griffin You Can't Buy Security: Building the Open Source InfoSec Program, Boris Sverdlik What Journalists Want: The Investigative Reporters' Perspective on Hacking, Dave Maas & Jason Leopold Accessibility and Security, Anna Shubina Stop Patching, for Stronger PCI Compliance, Adam Brand McAfee Secure & Trustmarks — a Hacker's Best Friend, Jay James & Shane MacDougall MalAndroid—the Crux of Android Infections Aditya K. Sood, IOActive, Michigan State PhD candidate Aditya talked about Android smartphone malware. There's a lot of old Android software out there—over 50% Gingerbread (2.3.x)—and most have unpatched vulnerabilities. Of 9 Android vulnerabilities, 8 have known exploits (such as the old Gingerbread Global Object Table exploit). Android protection includes sandboxing, security scanner, app permissions, and screened Android app market. The Android permission checker has fine-grain resource control, policy enforcement. Android static analysis also includes a static analysis app checker (bouncer), and a vulnerablity checker. What security problems does Android have? User-centric security, which depends on the user to grant permission and make smart decisions. But users don't care or think about malware (the're not aware, not paranoid). All they want is functionality, extensibility, mobility Android had no "proper" encryption before Android 3.0 No built-in protection against social engineering and web tricks Alternative Android app markets are unsafe. Simply visiting some markets can infect Android Aditya classified Android Malware types as: Type A—Apps. These interact with the Android app framework. For example, a fake Netflix app. Or Android Gold Dream (game), which uploads user files stealthy manner to a remote location. Type K—Kernel. Exploits underlying Linux libraries or kernel Type H—Hybrid. These use multiple layers (app framework, libraries, kernel). These are most commonly used by Android botnets, which are popular with Chinese botnet authors What are the threats from Android malware? These incude leak info (contacts), banking fraud, corporate network attacks, malware advertising, malware "Hackivism" (the promotion of social causes. For example, promiting specific leaders of the Tunisian or Iranian revolutions. Android malware is frequently "masquerated". That is, repackaged inside a legit app with malware. To avoid detection, the hidden malware is not unwrapped until runtime. The malware payload can be hidden in, for example, PNG files. Less common are Android bootkits—there's not many around. What they do is hijack the Android init framework—alteering system programs and daemons, then deletes itself. For example, the DKF Bootkit (China). Android App Problems: no code signing! all self-signed native code execution permission sandbox — all or none alternate market places no robust Android malware detection at network level delayed patch process Programming Weird Machines with ELF Metadata Rebecca "bx" Shapiro, Dartmouth College, NH https://github.com/bx/elf-bf-tools @bxsays on twitter Definitions. "ELF" is an executable file format used in linking and loading executables (on UNIX/Linux-class machines). "Weird machine" uses undocumented computation sources (I think of them as unintended virtual machines). Some examples of "weird machines" are those that: return to weird location, does SQL injection, corrupts the heap. Bx then talked about using ELF metadata as (an uintended) "weird machine". Some ELF background: A compiler takes source code and generates a ELF object file (hello.o). A static linker makes an ELF executable from the object file. A runtime linker and loader takes ELF executable and loads and relocates it in memory. The ELF file has symbols to relocate functions and variables. ELF has two relocation tables—one at link time and another one at loading time: .rela.dyn (link time) and .dynsym (dynamic table). GOT: Global Offset Table of addresses for dynamically-linked functions. PLT: Procedure Linkage Tables—works with GOT. The memory layout of a process (not the ELF file) is, in order: program (+ heap), dynamic libraries, libc, ld.so, stack (which includes the dynamic table loaded into memory) For ELF, the "weird machine" is found and exploited in the loader. ELF can be crafted for executing viruses, by tricking runtime into executing interpreted "code" in the ELF symbol table. One can inject parasitic "code" without modifying the actual ELF code portions. Think of the ELF symbol table as an "assembly language" interpreter. It has these elements: instructions: Add, move, jump if not 0 (jnz) Think of symbol table entries as "registers" symbol table value is "contents" immediate values are constants direct values are addresses (e.g., 0xdeadbeef) move instruction: is a relocation table entry add instruction: relocation table "addend" entry jnz instruction: takes multiple relocation table entries The ELF weird machine exploits the loader by relocating relocation table entries. The loader will go on forever until told to stop. It stores state on stack at "end" and uses IFUNC table entries (containing function pointer address). The ELF weird machine, called "Brainfu*k" (BF) has: 8 instructions: pointer inc, dec, inc indirect, dec indirect, jump forward, jump backward, print. Three registers - 3 registers Bx showed example BF source code that implemented a Turing machine printing "hello, world". More interesting was the next demo, where bx modified ping. Ping runs suid as root, but quickly drops privilege. BF modified the loader to disable the library function call dropping privilege, so it remained as root. Then BF modified the ping -t argument to execute the -t filename as root. It's best to show what this modified ping does with an example: $ whoami bx $ ping localhost -t backdoor.sh # executes backdoor $ whoami root $ The modified code increased from 285948 bytes to 290209 bytes. A BF tool compiles "executable" by modifying the symbol table in an existing ELF executable. The tool modifies .dynsym and .rela.dyn table, but not code or data. Privacy at the Handset: New FCC Rules? "Valkyrie" (Christie Dudley, Santa Clara Law JD candidate) Valkyrie talked about mobile handset privacy. Some background: Senator Franken (also a comedian) became alarmed about CarrierIQ, where the carriers track their customers. Franken asked the FCC to find out what obligations carriers think they have to protect privacy. The carriers' response was that they are doing just fine with self-regulation—no worries! Carriers need to collect data, such as missed calls, to maintain network quality. But carriers also sell data for marketing. Verizon sells customer data and enables this with a narrow privacy policy (only 1 month to opt out, with difficulties). The data sold is not individually identifiable and is aggregated. But Verizon recommends, as an aggregation workaround to "recollate" data to other databases to identify customers indirectly. The FCC has regulated telephone privacy since 1934 and mobile network privacy since 2007. Also, the carriers say mobile phone privacy is a FTC responsibility (not FCC). FTC is trying to improve mobile app privacy, but FTC has no authority over carrier / customer relationships. As a side note, Apple iPhones are unique as carriers have extra control over iPhones they don't have with other smartphones. As a result iPhones may be more regulated. Who are the consumer advocates? Everyone knows EFF, but EPIC (Electrnic Privacy Info Center), although more obsecure, is more relevant. What to do? Carriers must be accountable. Opt-in and opt-out at any time. Carriers need incentive to grant users control for those who want it, by holding them liable and responsible for breeches on their clock. Location information should be added current CPNI privacy protection, and require "Pen/trap" judicial order to obtain (and would still be a lower standard than 4th Amendment). Politics are on a pro-privacy swing now, with many senators and the Whitehouse. There will probably be new regulation soon, and enforcement will be a problem, but consumers will still have some benefit. Hacking Measured Boot and UEFI Dan Griffin, JWSecure, Inc., Seattle, @JWSdan Dan talked about hacking measured UEFI boot. First some terms: UEFI is a boot technology that is replacing BIOS (has whitelisting and blacklisting). UEFI protects devices against rootkits. TPM - hardware security device to store hashs and hardware-protected keys "secure boot" can control at firmware level what boot images can boot "measured boot" OS feature that tracks hashes (from BIOS, boot loader, krnel, early drivers). "remote attestation" allows remote validation and control based on policy on a remote attestation server. Microsoft pushing TPM (Windows 8 required), but Google is not. Intel TianoCore is the only open source for UEFI. Dan has Measured Boot Tool at http://mbt.codeplex.com/ with a demo where you can also view TPM data. TPM support already on enterprise-class machines. UEFI Weaknesses. UEFI toolkits are evolving rapidly, but UEFI has weaknesses: assume user is an ally trust TPM implicitly, and attached to computer hibernate file is unprotected (disk encryption protects against this) protection migrating from hardware to firmware delays in patching and whitelist updates will UEFI really be adopted by the mainstream (smartphone hardware support, bank support, apathetic consumer support) You Can't Buy Security: Building the Open Source InfoSec Program Boris Sverdlik, ISDPodcast.com co-host Boris talked about problems typical with current security audits. "IT Security" is an oxymoron—IT exists to enable buiness, uptime, utilization, reporting, but don't care about security—IT has conflict of interest. There's no Magic Bullet ("blinky box"), no one-size-fits-all solution (e.g., Intrusion Detection Systems (IDSs)). Regulations don't make you secure. The cloud is not secure (because of shared data and admin access). Defense and pen testing is not sexy. Auditors are not solution (security not a checklist)—what's needed is experience and adaptability—need soft skills. Step 1: First thing is to Google and learn the company end-to-end before you start. Get to know the management team (not IT team), meet as many people as you can. Don't use arbitrary values such as CISSP scores. Quantitive risk assessment is a myth (e.g. AV*EF-SLE). Learn different Business Units, legal/regulatory obligations, learn the business and where the money is made, verify company is protected from script kiddies (easy), learn sensitive information (IP, internal use only), and start with low-hanging fruit (customer service reps and social engineering). Step 2: Policies. Keep policies short and relevant. Generic SANS "security" boilerplate policies don't make sense and are not followed. Focus on acceptable use, data usage, communications, physical security. Step 3: Implementation: keep it simple stupid. Open source, although useful, is not free (implementation cost). Access controls with authentication & authorization for local and remote access. MS Windows has it, otherwise use OpenLDAP, OpenIAM, etc. Application security Everyone tries to reinvent the wheel—use existing static analysis tools. Review high-risk apps and major revisions. Don't run different risk level apps on same system. Assume host/client compromised and use app-level security control. Network security VLAN != segregated because there's too many workarounds. Use explicit firwall rules, active and passive network monitoring (snort is free), disallow end user access to production environment, have a proxy instead of direct Internet access. Also, SSL certificates are not good two-factor auth and SSL does not mean "safe." Operational Controls Have change, patch, asset, & vulnerability management (OSSI is free). For change management, always review code before pushing to production For logging, have centralized security logging for business-critical systems, separate security logging from administrative/IT logging, and lock down log (as it has everything). Monitor with OSSIM (open source). Use intrusion detection, but not just to fulfill a checkbox: build rules from a whitelist perspective (snort). OSSEC has 95% of what you need. Vulnerability management is a QA function when done right: OpenVas and Seccubus are free. Security awareness The reality is users will always click everything. Build real awareness, not compliance driven checkbox, and have it integrated into the culture. Pen test by crowd sourcing—test with logging COSSP http://www.cossp.org/ - Comprehensive Open Source Security Project What Journalists Want: The Investigative Reporters' Perspective on Hacking Dave Maas, San Diego CityBeat Jason Leopold, Truthout.org The difference between hackers and investigative journalists: For hackers, the motivation varies, but method is same, technological specialties. For investigative journalists, it's about one thing—The Story, and they need broad info-gathering skills. J-School in 60 Seconds: Generic formula: Person or issue of pubic interest, new info, or angle. Generic criteria: proximity, prominence, timeliness, human interest, oddity, or consequence. Media awareness of hackers and trends: journalists becoming extremely aware of hackers with congressional debates (privacy, data breaches), demand for data-mining Journalists, use of coding and web development for Journalists, and Journalists busted for hacking (Murdock). Info gathering by investigative journalists include Public records laws. Federal Freedom of Information Act (FOIA) is good, but slow. California Public Records Act is a lot stronger. FOIA takes forever because of foot-dragging—it helps to be specific. Often need to sue (especially FBI). CPRA is faster, and requests can be vague. Dumps and leaks (a la Wikileaks) Journalists want: leads, protecting ourselves, our sources, and adapting tools for news gathering (Google hacking). Anonomity is important to whistleblowers. They want no digital footprint left behind (e.g., email, web log). They don't trust encryption, want to feel safe and secure. Whistleblower laws are very weak—there's no upside for whistleblowers—they have to be very passionate to do it. Accessibility and Security or: How I Learned to Stop Worrying and Love the Halting Problem Anna Shubina, Dartmouth College Anna talked about how accessibility and security are related. Accessibility of digital content (not real world accessibility). mostly refers to blind users and screenreaders, for our purpose. Accessibility is about parsing documents, as are many security issues. "Rich" executable content causes accessibility to fail, and often causes security to fail. For example MS Word has executable format—it's not a document exchange format—more dangerous than PDF or HTML. Accessibility is often the first and maybe only sanity check with parsing. They have no choice because someone may want to read what you write. Google, for example, is very particular about web browser you use and are bad at supporting other browsers. Uses JavaScript instead of links, often requiring mouseover to display content. PDF is a security nightmare. Executible format, embedded flash, JavaScript, etc. 15 million lines of code. Google Chrome doesn't handle PDF correctly, causing several security bugs. PDF has an accessibility checker and PDF tagging, to help with accessibility. But no PDF checker checks for incorrect tags, untagged content, or validates lists or tables. None check executable content at all. The "Halting Problem" is: can one decide whether a program will ever stop? The answer, in general, is no (Rice's theorem). The same holds true for accessibility checkers. Language-theoretic Security says complicated data formats are hard to parse and cannot be solved due to the Halting Problem. W3C Web Accessibility Guidelines: "Perceivable, Operable, Understandable, Robust" Not much help though, except for "Robust", but here's some gems: * all information should be parsable (paraphrasing) * if not parsable, cannot be converted to alternate formats * maximize compatibility in new document formats Executible webpages are bad for security and accessibility. They say it's for a better web experience. But is it necessary to stuff web pages with JavaScript for a better experience? A good example is The Drudge Report—it has hand-written HTML with no JavaScript, yet drives a lot of web traffic due to good content. A bad example is Google News—hidden scrollbars, guessing user input. Solutions: Accessibility and security problems come from same source Expose "better user experience" myth Keep your corner of Internet parsable Remember "Halting Problem"—recognize false solutions (checking and verifying tools) Stop Patching, for Stronger PCI Compliance Adam Brand, protiviti @adamrbrand, http://www.picfun.com/ Adam talked about PCI compliance for retail sales. Take an example: for PCI compliance, 50% of Brian's time (a IT guy), 960 hours/year was spent patching POSs in 850 restaurants. Often applying some patches make no sense (like fixing a browser vulnerability on a server). "Scanner worship" is overuse of vulnerability scanners—it gives a warm and fuzzy and it's simple (red or green results—fix reds). Scanners give a false sense of security. In reality, breeches from missing patches are uncommon—more common problems are: default passwords, cleartext authentication, misconfiguration (firewall ports open). Patching Myths: Myth 1: install within 30 days of patch release (but PCI §6.1 allows a "risk-based approach" instead). Myth 2: vendor decides what's critical (also PCI §6.1). But §6.2 requires user ranking of vulnerabilities instead. Myth 3: scan and rescan until it passes. But PCI §11.2.1b says this applies only to high-risk vulnerabilities. Adam says good recommendations come from NIST 800-40. Instead use sane patching and focus on what's really important. From NIST 800-40: Proactive: Use a proactive vulnerability management process: use change control, configuration management, monitor file integrity. Monitor: start with NVD and other vulnerability alerts, not scanner results. Evaluate: public-facing system? workstation? internal server? (risk rank) Decide:on action and timeline Test: pre-test patches (stability, functionality, rollback) for change control Install: notify, change control, tickets McAfee Secure & Trustmarks — a Hacker's Best Friend Jay James, Shane MacDougall, Tactical Intelligence Inc., Canada "McAfee Secure Trustmark" is a website seal marketed by McAfee. A website gets this badge if they pass their remote scanning. The problem is a removal of trustmarks act as flags that you're vulnerable. Easy to view status change by viewing McAfee list on website or on Google. "Secure TrustGuard" is similar to McAfee. Jay and Shane wrote Perl scripts to gather sites from McAfee and search engines. If their certification image changes to a 1x1 pixel image, then they are longer certified. Their scripts take deltas of scans to see what changed daily. The bottom line is change in TrustGuard status is a flag for hackers to attack your site. Entire idea of seals is silly—you're raising a flag saying if you're vulnerable.

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