Manager, SOX 404 Compliance

Reports To: AVP, Financial Reporting

Department: Accounting

Location/Schedule: Hybrid – Chicago, IL

Classification: Full-Time / Exempt

Who We Are:

Old Republic is a leading specialty insurer that operates diverse property & casualty and title insurance companies. Founded in 1923 and a member of the Fortune 500, we are a leader in underwriting and risk management services for business partners across the United States and Canada. Our specialized operating companies are experts in their fields, enabling us to provide tailored solutions that set us apart.

Position Overview:

The Manager, SOX 404 Compliance will be a key contributor in leading the organization's Sarbanes–Oxley (SOX) Section 404 compliance program, ensuring the effectiveness of internal controls over financial reporting (ICFR), with a strong focus on insurance-specific processes including reserves, premium revenue, reinsurance, investments, and systems (general ledger, claims, reinsurance, and policy administration). This role partners with finance, accounting, IT, and internal/external auditors to design, implement, and continuously improve the control environment, maintaining a robust, compliant framework aligned with NAIC, SEC, and PCAOB requirements.

Essential Job Functions:

• Lead the end-to-end SOX 404 compliance program, including scoping, quarterly SOX
• certifications, and assessing deficiencies.
• Tailor SOX scope to insurance-specific financial reporting risks (e.g. loss reserves, premium
• recognition, DAC, investment valuations).
• Serve as the primary point of contact for external auditors, internal auditors, and operating
• companies regarding SOX compliance.
• Oversee the annual SOX risk assessment and scoping process, including identification of
• significant accounts, disclosures, and key controls.
• Internal Controls Oversight
• Design, evaluate, and enhance internal controls over financial reporting (ICFR) across key
• insurance processes to ensure effectiveness and efficiency.
• Claims and loss reserves (including actuarial estimates and judgments), premium billing, and revenue recognition
• Reinsurance accounting and recoverables, statutory vs. GAAP reporting differences
• Investment accounting (fixed income, equities, alternatives)
• Systems, including general ledger, claims, reinsurance, and policy administration, and data integrity
• Evaluate control deficiencies to determine severity (deficiency, significant deficiency, or material weakness) and aggregation risk.
• Oversee SOX compliance for IT general controls (ITGCs) and key automated controls across general ledger, claims, reinsurance, and policy administration systems.
• Ensure controls over data flows, interfaces, and reports used in actuarial and financial reporting processes.
• Partner with IT and data governance teams to address system changes, access controls, and cybersecurity/artificial intelligence considerations impacting ICFR.
• Partner with Accounting, Finance, IT, Legal, Actuarial, Reinsurance, Investments, and Operations to ensure alignment on control design and execution.
• Provide guidance and training to control owners and stakeholders on SOX requirements and
• best practices.
• Collaborate with Internal Audit to align SOX efforts with broader audit strategies.
• Identify opportunities to streamline SOX processes and enhance efficiency through automation and standardization.
• Drive continuous improvement initiatives, including adoption of technology tools (e.g., GRC
• platforms).
• Support integration of SOX controls into digital transformation initiatives (e.g., policy administration system upgrades, claims platforms).
• Ensure SOX compliance aligns with broader insurance regulatory frameworks, including NAIC, Model Audit Rule (MAR), statutory reporting, and state insurance regulations.
• Support coordination between SOX reporting and statutory audit requirements.
• Prepare SOX status updates, risk assessments, and deficiency reports for senior leadership and audit committees.
• Ensure compliance with regulatory requirements, including SEC and PCAOB expectations.
• Maintain strong governance over SOX documentation and evidence retention.

Qualifications:

• Bachelor's degree in accounting, Finance, or related field (CPA or equivalent strongly preferred).
• 8+ years of experience in SOX compliance, internal audit, or public accounting (Big 4 experience preferred).
• Minimum 3 years of experience within the insurance industry (life, P&C, or reinsurance preferred).
• Strong understanding of both GAAP and Statutory (NAIC SAP) accounting requirements.
• Strong understanding of SOX 404 requirements, COSO framework, and internal control concepts.
• Deep knowledge of financial reporting processes and risks.
• Experience with ITGCs and automated controls.
• Familiarity with ERP systems and insurance platforms (e.g. Guidewire, Duck Creek) and Workiva Controls Management or equivalent platform preferred.
• Experience with flowchart tools and building flowcharts.
• Proven ability to lead cross-functional teams and manage multiple priorities.
• Strong analytical, problem-solving, and decision-making skills.
• Demonstrated project management skills to prioritize tasks and achieve deadlines.
• Excellent communication and stakeholder management abilities.
• High level of integrity and professionalism.

Preferred Qualifications

• Experience managing SOX programs in a public company environment.
• Experience with NAIC Model Audit Rule (MAR) compliance.
• Prior experience interacting with external auditors and regulatory bodies.
• Certification such as CPA, CIA, or CISA.

ORI is an Equal Opportunity Employer. ORI provides equal employment opportunities to all employees and applicants for employment and prohibits discrimination and harassment of any type without regard to race, color, religion, age, sex, national origin, disability status, genetics, protected veteran status, sexual orientation, gender identity or expression, or any other characteristic protected by federal, state or local laws.

This policy applies to all terms and conditions of employment, including recruiting, hiring, placement, promotion, termination, layoff, recall, transfer, leaves of absence, compensation and training.