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The Director, SOX Program Management Office (PMO) leads the company’s Sarbanes-Oxley compliance program end-to-end and serves as the single accountable management owner for the design, documentation, and operating governance of Internal Control over Financial Reporting (ICFR) across both business processes and technology. The Director also owns the company’s NAIC Model Audit Rule (MAR) ICFR program for statutory financial reporting, operated as an integrated extension of SOX given the substantial overlap in controls, processes, and evidence. The role reports directly to the Controller and partners closely with the CFO, Internal Auditors, External Auditors, CIO, and the parent company’s Corporate SOX function to deliver an effective, efficient, and risk-aligned controls program in support of management’s assertions under Section 302 and 404 of Sarbanes-Oxley and Section 16 of the NAIC Annual Financial Reporting Model Regulation (Model #205).

Independent testing of controls will be performed by an independent and separate function. The Director is responsible for the program, the framework, and the partnership with control owners; the Director is not responsible for performing or directing independent testing.

This role is positioned as a function within Finance with strong governance lines into IT and business process owners.

Function

Accountability for SOX / ICFR

Process & Control Owners (Finance, Claims, Underwriting, Actuarial, IT, etc.)

Design, consistently execute, and self-attest to controls; own remediation of identified deficiencies.

SOX PMO (this role)

Owns the SOX program: scoping, risk assessment, control framework, documentation standards, deficiency aggregation, and reporting.

Internal Audit

Independent testing of ICFR and separate independent audit of test results

1. SOX Program Leadership and Strategy

• Own the annual SOX program lifecycle for the entity, including scoping, planning, execution oversight, control automation and optimization efforts, deficiency evaluation, certification support, and year-end conclusion.
• Maintain alignment with the parent company’s consolidated SOX program, including conformity with corporate methodology, scoping thresholds, and reporting cadences, while tailoring execution to the carrier’s P&C business model.
• Define and continuously improve the SOX operating model, including roles, RACI, calendar, key milestones, and intersection points with External Audit, Internal Audit, and IT.
• Drive program efficiency through control rationalization, automation, continuous controls monitoring, and AI-enabled documentation and review.

2. Risk Assessment and Scoping

• Lead the annual SOX risk assessment covering financial statement materiality, qualitative factors, fraud risk, and significant accounts and disclosures.
• Determine in-scope entities, locations, processes, applications, and service providers (including SOC reliance) using a documented, defensible methodology.
• Maintain SOX risk and control inventory, Key and non-Key designations, and accuracy of ownership, related systems and reports, etc.
• Drive continuous updates where applicable due to changes in process, system, volumes, and/or accounting guidance.  

3. Business Process ICFR Ownership

• Own the framework, documentation standards, and quality of business process flowcharts and risk-and-control matrices (RCMs).
• Partner with process owners across Finance, Actuarial, Claims, Underwriting, Premium, Reinsurance, Treasury, and Tax to ensure controls are well-designed, properly documented, and operating as intended.
• Apply heightened rigor to Management Review Controls (MRCs), addressing precision, evidenc