Section D Internal Controls This section is 15% of Part 1 Five larger categories of topics are included in this section Risk assessment, controls and risk management Internal auditing Systems controls and security measures Internet security Contingency planning
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Risk Assessment, Controls, and Risk Management
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Benefits of Internal Control The internal controls of a company are an important part of its overall operations. A strong internal control system will provide may benefits: Lower external audit costs, Better control over and usage of company assets, and More reliable information that may be used for decision making by managers and others in the company. A company with weak internal controls is putting itself at risk for employee theft, loss of control over the information relating to operations, and other inefficiencies in operations and decision-making. 2010 CMA Part 1 Section D Internal Controls 4 Internal Control Definition and Objective Internal control is the method or process performed by a company that is designed to provide reasonable assurance that three things will be achieved: 1. Effectiveness and efficiency of operations, 2. Reliability of financial reporting, and 3. Compliance with applicable laws and regulations. Objectives #2 and #3, the financial reporting and compliance objectives, are based on standards imposed by external entities (example: SEC). Internal control only provides reasonable assurance, not a guarantee, that these goals will be achieved. 2010 CMA Part 1 Section D Internal Controls 5 Internal Control Definition and Objective Contd
Regarding point #1: an internal control system
cannot provide reasonable assurance that operations objectives will be met. It provides only reasonable assurance that management and the board of directors are made aware in a timely manner about the progress towards achieving operational objectives. Therefore, internal control can be judged effective if management has reasonable assurance that: They understand the extent to which the companys operations objectives are being achieved; Published financial statements are prepared reliably Applicable laws and regulations are being complied with.
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Who is Interested in the IC of a Company? There are a number of diverse parties that are interested in the internal control system of a company: Investors and potential investors rely on the IC system to be able to evaluate management and the performance of the company. External auditors will base the amount of work that they perform in part on the effectiveness of the IC system. Legislative and regulatory bodies rely on the IC system to help ensure that the company is operating in compliance with applicable laws and regulations. Management uses the information that comes out of the internal systems so management needs to make certain that the information that they receive is correct. Customers may benefit from a strong internal control system because it may reduce the costs of production and therefore also the products costs. 2010 CMA Part 1 Section D Internal Controls 7 Who is Responsible for Internal Control? The COSO report, Internal Control Integrated Framework (1992) defined the responsibility of the group or person listed below to maintain and assess internal controls as follows: The board of directors is responsible for overseeing the internal control system, providing governance, guidance and insight. The CEO is ultimately responsible for the internal control system and the tone at the top. Senior managers delegate responsibility for establishment of specific internal control policies and procedures to personnel responsible for each units functions. 2010 CMA Part 1 Section D Internal Controls 8 Who is Responsible for Internal Control Contd ? The COSO report, Internal Control Integrated Framework (1992) defined the responsibility of the group or persons listed below to maintain and assess internal controls as follows (contd): Financial officers and their staffs are central to the exercise of control Internal auditors play a monitoring role by evaluating the effectiveness of the internal controls. Virtually all employees are involved in internal control: they produce information used in the internal control system or carry out activities that put the internal control systems into effect they inform their managers if they become aware of problems in operation or that rules or policies are being violated.
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Components of Internal Control The COSO report, Internal Control Integrated Framework lists five interrelated components that make up internal control: 1. The Control Environment 2. Risk Assessment, 3. Control Activities, 4. Information and Communication 5. Monitoring.
. Note: These elements may be remembered by the
mnemonic CRIME as identified by the bold letters in the list above. 2010 CMA Part 1 Section D Internal Controls 10 Component #1: Control Environment This is the most important element of internal controls because it is the basis on which the other elements are built.
Factors that influence the scope and effectiveness
of the control environment include: Integrity and ethical values of the entitys people A commitment to competence The attention and direction provided by the board of directors and/or audit committee Managements philosophy and operating style The companys organizational structure 2010 CMA Part 1 Section D Internal Controls 11 Component #1: Control Environment contd Factors that influence the scope and effectiveness of the control environment include (contd): The way management assigns authority and responsibility for operating activities Human resource policies and practices
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Component #1: Control Environment contd Internal controls are more likely to function well if management believes that the controls are important and communicates that support to all employees. They set a positive tone at the top by: transmitting guidance both verbally and by example, communicating the entitys values and code of conduct fostering a control consciousness by setting formal and clearly communicated policies and procedures Specifying the competence level needed for particular jobs and delegating authority accordingly Working closely with a board of directors who help ensure the company is operating in the best interest of the shareowners 2010 CMA Part 1 Section D Internal Controls 13 Component #2: Risk Assessment Once the company objectives are defined, risk identification can begin. Risks can exist at the entity level or the activity level Risks can be both internal and external After the company has identified its entity-level and activity-level risks, it should perform a risk analysis: To estimate the significance of each risk To assess the likelihood or frequency of each risks occurring To consider how each risk should be managed by assessing what actions need to be taken.
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Component #2: Risk Assessment contd Within the control environment management is responsible for assessment of the risks that the company faces. Risk assessment is the process of identifying, analyzing and managing the risks that have the potential to prevent the organization from achieving its objectives. The companys objectives must be established before the risks to them can be assessed. Objective setting is therefore a key part of the management process of risk assessment.
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Component #2: Risk Assessment contd Once the significance and likelihood of risks have been assessed, the following steps should be taken to manage the identified risks: The amount of potential loss from each identified risk should be estimated to the extent possible. Consider how each risk should be managed by determining what can be done and analyzing the costs, if any, associated with managing each risk. Procedures should be established to ensure that the plans for implementing the risk management are implemented. These procedures are the control activities.
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Component #3: Control Activities After the risks have been assessed, controls should be designed to limit the risk. To accomplish this, control activities are implemented. These activities are the policies that are developed to address the risks of the company, and procedures that ensure the policies will be followed. Any control implemented must have a benefit that is greater than the cost of that control. Because of this, not all controls are implemented and the control environment cannot provide a guarantee that all risks are eliminated. 2010 CMA Part 1 Section D Internal Controls 17 Component #3: Control Activities contd Control activities may be classified by their objective: Preventive controls attempt to prevent the mistake or problem from ever occurring in the first place. Directive controls attempt to ensure the occurrence of a desirable event, Detective controls attempt to find the mistake or problem after it has occurred, Corrective controls attempt to fix the problem after it has occurred, and Compensating controls attempt to address a weakness in controls in one place by setting up additional controls in a related area 2010 CMA Part 1 Section D Internal Controls 18 Component #3: Control Activities contd Examples of control activities are: 1. Top level reviews 2. Direct functional or activity management 3. Information processing 4. Independent checks 5. Performance indicators 6. Physical controls to safeguard assets 7. Documents and records 8. Authorization 9. Segregation of duties
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Component #4: Information and Communication Information needs to be obtained and communicated to people to allow them to perform their duties. Communication must be ongoing Duties and responsibilities need to be communicated to all effected parties so that they are able to communicate significant information upstream Reports containing operational, financial, and compliance information must be avaialble for informed decisions Some information must be communicated to those outside the organization and must also be available from external sources
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Component #4: Information and Communication contd
Some examples of communication that should
take place include: Information systems must provide reports to appropriate personnel so they can carry out their responsibilities. All personnel need to receive clear communication from top management that their internal control responsibilities must be taken seriously. Each person needs to understand his or her role in the internal control system and how the system works. People need to know what behavior is expected of them and what behavior is unacceptable. Employees need to know that if they report a suspected violation of the companys code of conduct, they will not get into trouble for it 2010 CMA Part 1 Section D Internal Controls 21 Component #4: Information and Communication contd
Some examples of communication that should take
place include: communications between management and the Board of Directors are vital. Senior management must inform board members about performance, new developments, major initiatives, potential risks, and other relevant information. Appropriate communication is also needed with those who are outside of the organization. Communications from outside parties such as external auditors can provide important information about the functioning of the internal control system. Any outsider dealing with the company must be informed that improper actions such as kickbacks or other improper incentives from vendors will not be tolerated.
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Component #5: Monitoring Monitoring is the process of reviewing the controls over time to make sure that they are still relevant and still functioning as they were intended. As technologies change and business operations change, some of the controls that had been relevant may no longer be relevant. Monitoring needs to be undertaken on a regular (if not relatively constant) basis. Monitoring can be done in two ways: 1. ongoing monitoring during normal operations 2. Separate evaluations by management with the assistance of the internal audit function 2010 CMA Part 1 Section D Internal Controls 23 Segregation of Duties Duties need to be divided among various employees to reduce the risk of errors or inappropriate activities. No single individual should have enough responsibility to be in a position to both perpetrate and conceal irregularities. Note: Different people must always perform the following four functions: Authorizing a transaction. Recording the transaction, preparing source documents, maintaining journals. Keeping physical custody of the related asset The periodic reconciliation of the physical assets to the recorded amounts for those assets.
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Responsibilities of the Board of Directors The board of directors of a company is responsible for ensuring that the company is operated in the best interest of the shareholders The boards general responsibility is to provide governance, guidance and oversight of the management of the company. Specifics related to internal control include: Selecting management Defining expectations of management regarding integrity and ethics Playing a role in the strategic objective setting and planning Investigating issues that they judge important
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Responsibilities of the Board of Directors contd
Board members are responsible for questioning and
scrutinizing managements activities. Therefore it is important that the board has members who are independent of the company. An independent director has no material relationship with the company. An independent director is not an officer or employee of the company and is not active in the day-to-day management of the company. Most boards of directors carry out their duties through committees. Committees are made up of selected board members and are smaller, working groups of directors that are tasked with specific oversight responsibilities. One the of the committees whose members is prescribed by SEC regulations is the audit committee. 2010 CMA Part 1 Section D Internal Controls 26 The Audit Committee Audit committees of the boards of directors were first recommended by the SEC in 1972. Stock exchanges began requiring or at least recommending that listed companies have audit committees. Thereafter responsibilities of audit committees increased over the years and have been formalized by statute. The Sarbanes-Oxley Act of 2002 increased audit committees responsibilities further. It also increased the qualifications required for members of audit committees and it increased the authority of audit committees. 2010 CMA Part 1 Section D Internal Controls 27 The Audit Committee contd The major requirements for audit committees and their members: The consist of at least 3 members Members must be independent (example: not employed by the company) At least one member must have accounting or financial management expertise All members must be financially literate (at the time of appointment or shortly thereafter) New York stock exchange requires a 5 year cooling off period during which former employees of the company or its external auditor are not allowed to serve on the audit committee 2010 CMA Part 1 Section D Internal Controls 28 The Audit Committee contd The responsibilities of the Audit Committee include: Being an intermediary between management, the external auditor and the internal auditor, Nominate an external auditor, Discuss the scope of the audits with the internal and external auditors, Review the results of the audits, Review evaluations of internal controls, Review the work of the internal auditors, Review the interim and annual financial statements.
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Legislative Initiatives on Internal Control There are a handful of legislative initiatives regarding internal control issues that we will look at in more detail: The Foreign Corrupt Practices Act, Sarbanes-Oxley Act SEC Release 33-8810
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The Foreign Corrupt Practices Act This Act was passed in response to the discovery in the 1970s that American companies were making large, questionable or illegal payments to foreign governments, officials or politicians. This is an amendment to the 1934 Securities Exchange Act. There are two main provisions: Anti-bribery provisions Accounting provisions
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Applicability and Responsibility The anti-bribery provisions apply to all companies, whether or not the are publicly traded and registered with the SEC. The accounting provisions are applicable only to companies that are under the regulation of the SEC.
The responsibility for compliance with the Act
is given to the company as a whole. Responsibility is not placed with a specific person or position, but with everyone within the organization. However, individuals are personally liable for their actions. 2010 CMA Part 1 Section D Internal Controls 32 Anti-Bribery Provisions It is illegal to offer or authorize corrupt payments to any foreign official, foreign party chief or official or a candidate for political office in a foreign country. It is also illegal to make these payments through another party (an intermediary)
A corrupt payment is one that intends to cause the
recipient to misuse their position in order to direct business to the payer of the corrupt payment. A payment is corrupt simply by the fact it is made. Even if the benefits that were expected are not received, the payment was corrupt.
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Accounting Provisions Management is required to maintain records and books and accounts that represent transactions properly.
Management must also develop and implement a
system of internal controls. The logic is that if the company has an effective internal control system, it will be more difficult for corrupt payments to be made.
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Penalties of the FCPA Fines for making illegal payments are: Up to $2 million in fines against the company, and Up to $100,000 in fines and 5 years of imprisonment for individuals who make or authorize an illegal transaction.
Companies can also be prevented from
participating in government contracts and have their export license revoked. Shareholders are also able to file lawsuits against the company for illegal payments.
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Sarbanes-Oxley Internal Control Provisions The Sarbanes-Oxley Act was enacted in 2002. Its provisions with respect to internal control are: Audit committees to be responsible for the appointment, compensation and oversight of the registered public accounting firm. Audit committees to have the authority and funding to engage independent counsel and advisors as deemed necessary. Auditors are to report directly to the audit committee. Members of the audit committee must be truly independent. 2010 CMA Part 1 Section D Internal Controls 36 Sarbanes-Oxley (cont.) It is unlawful for any corporate officer or director or person acting under their direction to fraudulently influence, coerce, manipulate or mislead any accountant engaged in preparing an audit, for the purpose of causing the audit report to be materially misleading. The companys annual report filed with the SEC must be accompanied by a statement of management that management is responsible for creating and maintaining adequate internal controls, along with a statement of managements assessment of the effectiveness of these controls. 2010 CMA Part 1 Section D Internal Controls 37 Sarbanes-Oxley Internal Control Provisions (cont.) There are several main aspects of Sarbanes-Oxley (SOX) that we will now cover in more detail. They include: 1. The Public Company Accounting Oversight Board (PCAOB) 2. SOX Section 302 Corporate Responsibility for Financial Reports 3. SOX Section 404 Management Assessment of Internal Controls 4. The PCAOB Auditing Standard 5 and the preferred approach to auditing internal controls
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Public Company Accounting Oversight Board Title 1 of the Sarbanes-Oxley Act established the Public Company Accounting Oversight Board (PCAOB) to oversee the auditing of public companies that are subject to the securities laws. The board: Contains 5 board members appointed by the SEC Includes only members who are financially literate and must be from the private sector Only 2 of the board members can be CPAs. The PCAOB has many responsibilities. Its role to provide guidance to auditors on their auditing of internal controls is just one responsibility. 2010 CMA Part 1 Section D Internal Controls 39 Public Company Accounting Oversight Board Contd
The primary responsibilities of the PCAOB include:
Registering accounting firms that audit public companies. Establishing standards related to the preparation of audit reports regarding auditing, quality control, ethics, and independence Conducting inspections of registered public accounting firms with the Sarbanes-Oxley Act, the rules of the Board, the rules of the SEC, and other professional standards Enforcing compliance with appropriate laws and professional standards relating to audit reports and the obligations of accountants for them. Conducting investigations and disciplinary proceedings and imposing appropriate sanctions. 2010 CMA Part 1 Section D Internal Controls 40 SOX Section 302 Section 302 relates to the corporate responsibility for financial reports. Each annual or quarterly report of a company must include certifications by the CEO and CFO that: They have reviewed the report The report does not contain any untrue material statement or mot to state any material fact that could make the report misleading Based upon their knowledge the financial statements fairly present in all material aspects the financial condition and results of operations of the company They understand that they are responsible for internal controls in the company 2010 CMA Part 1 Section D Internal Controls 41 SOX Section 302 contd Each annual or quarterly report of a company must include certifications by the CEO and CFO that (contd): They have disclosed required information to the company s auditors and audit committee of the board of directors including: Any fraud that involves management or other employee with significant responsibilities in the companys internal controls All deficiencies in the design or operation of the company internal controls They have disclosed in the report any material changes in the company internal controls that have occurred after the report date but prior to its publication
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SOX Section 404 Section 404 relates to the management assessment of internal control. Each annual report required by the SEC must contain an assessment by management of the adequacy of the companys internal control over financial reporting (ICFR for short). This internal control report shall: State the responsibility of management for establishing and maintaining an adequate internal control structure and procedures for financial reporting Contain an assessment of the effectiveness of the internal control structure and procedures of the company for financial reporting as of the fiscal yearend 2010 CMA Part 1 Section D Internal Controls 43 SOX Section 404 contd The SEC provided interpretative guidance (SEC release No 33-8810) to implement Section 404. The guidance is is organized around two broad principles: 1. Management should determine whether it has implemented controls that adequately address the risk that a material misstatement of the financial statements would not be prevented or detected in a timely manner. 2. Managements evaluation of evidence about the operation of its controls should be based on its assessment of risk.
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PCAOB Auditing Standard #5 PCAOB Auditing Standard No. 5 calls for a top- down, risk-based approach to assessing and attesting to internal controls. Important details regarding this approach are: A risk-based approach begins by identifying the risks that a material misstatement of the financial statements would not be prevented or detected in a timely manner. The auditor should perform procedures such as inquiry, inspection of documents, or walkthroughs which is a combination of the preceding procedures, to understand and identify the likely sources of potential misstatements A fraud risk assessment should be taken into account during the audit of internal controls. 2010 CMA Part 1 Section D Internal Controls 45 PCAOB Auditing Standard #5 contd The steps to follow in a top-down risk based auditing approach are: 1. Start with entity level controls 2. Identify entity level controls 3. Identify significant accounts and disclosures and their relevent financial statement assertions 4. Understand the likely sources of misstatement 5. Select controls to test 6. Test design effectiveness and operating effectiveness of the controls 7. Evaluate identified deficiencies
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SEC Release 33-8810 SEC Release 33-8810, the guidance for management in assessing its internal control over financial reporting, also contains information about how a risk-based, top-down approach to assessing internal control over financial reporting should be performed. It reports the following steps to follow: 1. Identify financial reporting risks and controls 2. Evaluate evidence of the operating effectiveness of the internal controls over financial reporting 3. Consider impact of multiple locations adequately (rely on central controls? review of remote locations, etc) 4. Evaluate control deficiencies to determine whether they are a material weakness 2010 CMA Part 1 Section D Internal Controls 47 What Internal Controls Can and Cannot Do Internal controls can help an organization get to where it wants to go. Internal controls can help an organization achieve its goals and prevent loss of resources. Internal controls can ensure reliable financial reporting. Internal controls can ensure that the organization complies with laws and regulations. Internal controls cannot provide a guarantee. They can provide only reasonable assurance to management and the board of directors regarding achievement of the entitys objectives. 2010 CMA Part 1 Section D Internal Controls 48 Internal Auditing
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Internal Auditing The IIA defines internal auditing as:
an independent, objective assurance and
consulting activity designed to add value and improve an organizations operations. It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control and governance processes. Internal auditing provides a mechanism for management to monitor the reliability of financial reporting and the companys control over operations. 2010 CMA Part 1 Section D Internal Controls 50 Types of Internal Auditing Services Internal auditing services fall into three fundamental categories: 1. Operational reviewing the various functions within the organization in order to appraise the efficiency and economy of operations and the effectiveness with which the functions achieve their objectives. 2. Financial reviewing the economic activity of the organization as it is measured and reported by accounting methods. 3. Compliance reviewing both financial and operating controls and transactions to determine whether they conform to laws, standards, regulations and procedures.
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Responsibilities of Internal Auditors The responsibility of the internal audit function is to review and appraise policies, procedures, plans and records for the purpose of informing and advising management. Perhaps more important is what internal audit is not responsible for. Internal audit is not responsible for and has no authority over operating activities. Internal audit makes no decisions about what should be done they provide information and advice, and then management makes a decision. Internal audit may help with implementation, but management makes the decision. 2010 CMA Part 1 Section D Internal Controls 52 Internal Auditors and the Internal Control System The internal auditors are not responsible for the internal control system (management is responsible for that).
The internal auditors function is to test, examine,
review, evaluate and make recommendations about the internal control system.
In this way, internal auditing assists management
in carrying out its monitoring responsibilities.
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Organizational Status The internal audit function should report to the board of directors through the audit committee. The internal auditors need to be perceived as an important part of the company in order to be able to do their job effectively. People in the company need to know that the board will listen to what the auditors say and therefore the conclusions of the auditor are important. By reporting to a high level the function has organizational independence. This means that they do not have any direct relationships with who they are auditing. The people they are auditing cannot tell them what to do or fire them. 2010 CMA Part 1 Section D Internal Controls 54 Internal Auditors and External Auditors External auditors are focused on one thing the opinion about the financial statements. External auditors are not concerned about the efficiency or effectiveness of operations, just that the financial statements reflect fairly the operations of the company. Internal auditors have a wider range of interests and engagements. They compare what is in the company with what should be and report to management their findings. In addition to their findings, the internal auditor develops and reports recommendations for improvement.
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Coordination of Internal and External Auditors Some of the work of the internal auditors may be relevant to and used by the external auditor. Before using the work of the internal auditors, however, the external auditor must assess the internal auditors Competence (how well they do their job), and Objectivity (their organizational independence, or their role within the organization)
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Use of the Internal Auditors Work If the external auditor decides to use some of the work of the internal auditor, The external auditor will supervise, manage and review all of the work done by the internal auditors. The internal auditors will not assess risk. The internal auditors will not draw any conclusions. The internal auditor will be more likely to be used in areas that are objective (existence of fixed assets) than subjective (valuation of future cash flows).
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Types of Engagements Internal auditors perform two basic types of services: 1. Assurance services: performing an objective examination of evidence for the purpose of providing an independent assessment on governance, risk management, and control process for the organization.
2. Consulting services: advisory and other related client
service activities. They are usually performed at the request of the client, and their nature ands scope are agreed upon with the client. They are intended to add value and improve an organization's governance, risk management and control processes.
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Assurance Services Assurance services include: 1. Financial audit: analyze the economic activity as measured and reported by accounting methods. The goal is to determine whether financial assertions can be proven: Existence or occurrence Completeness Rights and obligations Valuation or allocation Presentation and disclosure 2. Performance (or operational) audit: it focuses on the efficiency, effectiveness, and economy of the company s internal control system based upon the company standards. 2010 CMA Part 1 Section D Internal Controls 59 Assurance Services contd Assurance services include (contd): 3. Audit of financial controls: involves examining two aspects of financial internal controls: Controls over financial resources Controls over the accounting for financial resources 4. Compliance audit: performed in order to determine whether an organization is operating in an orderly way, effectively and visibly confirming to certain specific requirements of its polices, procedures, or standards 5. System security audit: auditing the controls in place for information systems. 6. Due Diligence engagement: to confirm company records, both financial and those of property ownership 2010 CMA Part 1 Section D Internal Controls 60 Consulting Services Examples of consulting services include: 1. Quality audit: evaluating the quality of the product or service being provided 2. Special engagements: an example of a special engagement is a fraud audit. Fraud audits are performed for the purpose of discovering the presence, scope and means of either misappropriation of assets or fraudulent reporting. . Consulting services are intended to add value and improve an organizations activities in a specific area without assuming management responsibility.
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Consulting Services contd Per Internal Auditing Standard No. 2120 the internal auditor should following the following standard during a consulting engagement: address risk consistent with the engagements objectives and be alert to the existence of other significant risks. incorporate knowledge of risks gained from consulting engagements into their evaluation of the organizations risk management processes. When assisting management in establishing or improving risk management processes, internal auditors must refrain from assuming any management responsibility by actually managing risks. 2010 CMA Part 1 Section D Internal Controls 62 Which Audit Engagements to Accept The beginning of the audit process is to determine which engagements to conduct. The chief audit executive makes the decisions regarding which engagements to perform based upon risk based factors such as: Length of time since last audit was performed in this area Requests from senior management Relation of the proposed engagement to the external audits of financial statements and internal controls Changing circumstances in the business, operations, systems or controls Potential benefit that could be achieved by the engagement 2010 CMA Part 1 Section D Internal Controls 63 Audit Planning According to Internal Auditing Standard 2201, the internal auditor considers the following in planning the engagement: The objectives of the activity being reviewed and the means by which the activity controls its performance; The significant risks to the activity, its objectives, resources, and operations and the means by which the potential impact of risk is kept to an acceptable level; The adequacy and effectiveness of the activity's risk management and control processes compared to a relevant control framework or model; The opportunities for making improvements to the activity's risk management and control processes. 2010 CMA Part 1 Section D Internal Controls 64 Establishing Audit Objectives When establishing an audits objectives, internal auditing standard 2210 states that the auditor must: conduct a preliminary assessment of the risks relevant to the activity under review. consider the probability of significant errors, fraud, noncompliance, and other exposures Ensure that adequate criteria is available to evaluate controls. If they are adequately defined by management, internal auditors must use such criteria in their evaluation. If inadequate, internal auditors must work with management to develop appropriate evaluation criteria. Address governance, risk management, and control processes to the extent agreed upon with the client during consulting engagements. 2010 CMA Part 1 Section D Internal Controls 65 Assessing Audit Risk Assessing audit risk is an important part of the audit process. Audit risk is the risk that the auditor will conclude that everything is working properly, when in fact, it is not working correctly. It is made up of three components: Inherent risk (IR) is the risk that exists in what is being audited. The risk of a problem in the absence of controls. Control risk (CR) is the risk that a mistake is NOT prevented or detected by the internal control system Detection risk (DR) is the risk that the mistake is NOT detected by the auditor The audit risk is calculated by multiplying these risks together: AR = IR CR DR 2010 CMA Part 1 Section D Internal Controls 66 Assessing Audit Risk contd Control risk and detection risk operate inversely to each other. If control risk decreases (the internal controls are better) the detection risk can be increased (auditors do less testing) and the audit risk will remain the same. If control risk increases (the internal controls are worse) the detection risk can be decreased (auditors do more testing) and the audit risk will remain the same.
The auditor assesses inherent and control risk,
but is able to influence only detection risk.
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Understanding Internal Controls in the Planning After the engagement objectives are determined and the inherent risks identified, the next step is the understanding of internal controls. The auditors understanding needs to encompass the 5 components of internal control: the control environment, risk assessment, control activities, information and communication, and monitoring. The auditor will use this understanding to: Identify types of potential misstatements that may occur in whatever is being audited Consider factors related to risk of material misstatement Design the substantive tests to be performed 2010 CMA Part 1 Section D Internal Controls 68 Flowcharting Internal control systems may be documented in a flowchart. A systems flowchart (or horizontal flowchart) shows departments and functions across the top and documents manual and automated processes. Control points are identified. A program flowchart (or vertical flowchart) shows the steps in the process and how they will be executed. A data flow diagram is a graphic representation of the internal control system.
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The Internal Audit Program The audit program is written after the assessment of the relevant internal controls. The program should include the objectives of the area to be audited and the controls in place to achieve the areas objectives, which determine the audit objectives. It gives details on the procedures to be followed to reach the objectives of the audit: what is to be done and how it will be done. It must be written and must be detailed enough so that the auditors know what is to be done. It is used to supervise and review the work. Standardized audit programs may be used when appropriate.
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Audit Evidence Evidence is what the auditor gathers to be able to support their conclusion. The evidence should be Sufficient there must be enough evidence Competent it must be reliable and the best available Relevant must be consistent with the objectives of the audit Useful assists the organization to achieve its goals
The most competent, or best source of evidence
is something obtained by the auditor directly. Evidence from the client is the worst, and evidence from a third party is in the middle. 2010 CMA Part 1 Section D Internal Controls 71 Audit Evidence contd Audit evidence is classified according to legal rules of evidence. These include: Direct acquired directly by the party offering it Hearsay secondhand account where the witness does not have personal direct knowledge Documentary any original record, dead, or document Opinion not generally considered useful evidence. Circumstantial evidence that is consistent with a particular inference Secondary not the original documentation Corroborative supports other evidence Conclusive it is indisputable
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Auditing Financial Controls The Sarbanes-Oxley Act requires management to assess the adequacy of the companys internal controls over financial reporting. Internal auditors can assist in this through an audit of financial controls A financial audit focuses on accounting controls. An operational audit focuses on administrative controls. Accounting controls are concerned with the integrity and accuracy of the accounting system and the financial reports being generated Administrative controls are more focused on managements' operating objectives. 2010 CMA Part 1 Section D Internal Controls 73 Auditing Financial Controls contd Accounting controls are intended to achieve the following characteristics for the financial records: Completeness: Are all of the transactions reflected in or captured by the accounting system? Validity: Are only valid transactions recorded? Authorization: Are all transactions properly authorized? Accuracy: Are reported numbers accurate representations of the economic transactions that have occurred?
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Objectives of an Audit of Controls An audit of controls has the following objectives: 1. determine if controls are in place 2. determine if the existing controls are structurally sound 3. determine if the controls are designed to achieve a specific management objective, to achieve compliance with predetermined requirements, or to ensure accuracy and propriety of transactions 4. determine whether the controls are being used properly 5. determine if the controls are efficiently serving their purpose 6. determine whether the controls are effective 7. determine if management is using the output of the control system 2010 CMA Part 1 Section D Internal Controls 75 Testing Compliance with Controls The auditor investigates the following to test compliance with controls and evaluate their effectiveness: 1. Are procedures being followed? 2. Is the output being used? 3. Is the input into the system valid, accurate, and reasonable? 4. If the system is computerized, is it operating properly? 5. Is the output of the control operation valid? 6. Is the control output achieving managements objective in establishing the control? 7. Is the control system operating as intended? 2010 CMA Part 1 Section D Internal Controls 76 Testing Compliance with Controls contd The auditor investigates the following to test compliance with controls and evaluate their effectiveness (contd): 8. Does the control system have the following required characteristics? Flexibility. Timeliness. Accountability. Cause identification. Appropriateness. Placement.
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Testing Compliance with Controls contd Procedures the auditor performs to test operating effectiveness of controls include a mix of tests. Some types of tests produce greater evidence of the effectiveness of the controls than other tests. Here are the tests that an auditor might perform in order of the evidence they would usually produce, from the lowest quality evidence to the highest quality evidence: 1. Inquiry of appropriate personnel; 2. Observation; 3. Inspection of relevant documentation; and 4. Re-performance of a control 2010 CMA Part 1 Section D Internal Controls 78 Control Breakdowns If an auditor identifies a deficiency in a control over financial reporting, the auditor should evaluate the severity of the deficiency to determine whether the deficiency, either individually or in combination with other deficiencies, represents a material weakness. The severity depends upon: Whether there is a reasonable possibility that the companys controls will fail to prevent or detect a misstatement of an account balance or disclosure; and The magnitude of the potential misstatement resulting from the deficiency or deficiencies.
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Control Breakdowns contd Risk factors affect whether there is a reasonable possibility that a deficiency or combination of deficiencies will result in a misstatement of an account balance or disclosure. These risk factors include: The nature of the financial statement accounts, disclosures, and assertions involved; The susceptibility of the related asset or liability to loss or fraud, or how likely it is that something could go wrong; The subjectivity, complexity, or extent of judgment required to determine the amount involved;
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Control Breakdowns contd Risk factors affect whether there is a reasonable possibility that a deficiency or combination of deficiencies will result in a misstatement of an account balance or disclosure. These risk factors include (contd): The interaction or relationship of the control with other controls, including if they are interdependent or redundant The interaction of the deficiencies, i.e., if there is more than one, could they in combination cause a material misstatement The possible future consequences of the deficiency
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Control Breakdowns contd If multiple control deficiencies affect the same financial statement balance or disclosure, that increases the likelihood of misstatement and may, in combination, constitute a material weakness(though each deficiency individually may not be severe) Factors that affect the size of a misstatement that might result from a deficiency in controls include: The financial statement amounts or total of transactions exposed to the deficiency; and The volume of activity in the account balance or class of transactions exposed to the deficiency that has occurred in the current period or that is expected in future periods. 2010 CMA Part 1 Section D Internal Controls 82 Fraud Audits In a financial statement audit, the audit should be prepared so that any material misstatement is detected, no matter what the cause of the misstatement. The auditor is responsible for examining the controls to determine if they are adequate to prevent or detect fraud and must also have sufficient knowledge to be able to identify the indicators that fraud may have occurred. However, the deterrence of fraud is the responsibility of management, not the auditor.
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Fraud Audits, contd It is preferable (and usually cheaper) to prevent fraud than it is to discover it after the fact.
If the auditor detects control weaknesses,
additional tests should be performed to identify other factors of fraud that may be present.
When fraud is detected, the auditor should
immediately report it to the appropriate level of management.
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Types of Fraud There are three main classifications of fraud: Misstatements from fraudulent financial reporting, Misappropriation (theft) of company assets. Corruption (bribes, conflicts of interest).
In the misappropriation of assets, the employee is
more likely to be living beyond their means because they have more money than their salary as a result of the theft.
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Factors Contributing to Fraud The following items do not indicate that fraud is occurring, but rather that conditions exist in which fraud may occur more easily. No segregation of duties; Lack of controls such as limiting access to assets, comparing existing assets with recorded assets, and requiring proper authorization for executing transactions; Lack of qualified personnel; Collusion among employees; The existence of high-value, small, liquid assets; and Management override of controls that are in place.
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The IIAs Position regarding Fraud The Institute of Internal Auditors (IIAs) position on deterrence, detection, investigation and reporting of fraud is: Deterrence of fraud is the responsibility of management. Internal auditors must have sufficient knowledge to be able to identify the indicators that fraud may have occurred. If control weaknesses are detected, additional tests should be performed to identify other factors of fraud that may be present. Audit procedures alone will not guarantee that fraud will be detected. A fraud that is detected needs to be reported. 2010 CMA Part 1 Section D Internal Controls 87 Considering Fraud in Audit Planning The auditor should develop and plan the audit with a reasonable assurance of detecting material fraud or misstatements. However, due to the fact that the perpetrators of fraud will try to hide the fact, it is not possible to guarantee discovery of material frauds. Fraud is different from an error in that fraud is an intentional misstatement while an error is unintentional. The three main types of fraud are: 1. Fraudulent financial reporting 2. Misappropriation of assets 3. Corruption
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Internal Audit Reports Audit reports may be written or oral. Oral reports are more timely but do not replace written reports. Any oral reports should be followed with a written report confirming the oral report. All reports should include: The purpose, The scope of the engagement, The results of the engagement, including recommendations, if applicable.
Reports might include summaries, background
information, status of previous audit findings or other comments. 2010 CMA Part 1 Section D Internal Controls 89 Purpose of the Engagement The purpose should include: The engagement objectives should be described in enough detail so readers know what to expect from the rest of the report. Objectives should address the risks, controls and governance processes associated with the activities under review. The purpose may also include: Why the engagement was performed What the expected results were (i.e., cost savings, increased efficiencies, etc.)
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Scope of the Engagement Description of the work done to achieve the engagements objectives. The scope should be sufficient to address the agreed-upon objectives. Activities reviewed and time period reviewed Any related activities not reviewed The nature and extent of the work performed Should include consideration of relevant systems, records, personnel, and physical properties, including those under the control of third parties The scope should specifically state what areas were not covered that readers might expect to be covered unless told differently. 2010 CMA Part 1 Section D Internal Controls 91 Results of the Engagement Includes observations, conclusions, an opinion if appropriate, recommendations, and action plans from the engagement. Observations audit findings made by comparing what is with what should be. An audit finding should include: Background, criteria, condition, cause, and effect. Background Identify people involved, environment of the operation, reason why the situation is reportable, etc. Criteria the standards used to judge the operation being audited. (The what should be.) Condition the facts determined through observation, questioning, analysis, verification and investigation. (The what is.) 2010 CMA Part 1 Section D Internal Controls 92 Results of the Engagement contd Audit findings (continued) Cause Explains the reason why what is is different from what should be. Effect The consequences of the difference between what is and what should be. To be reportable, an audit finding should have consequences who or what was hurt, and how badly. Conclusions the internal auditors evaluations such as whether a function is operating as intended, if control criteria are being met, if objectives are being met, etc. Recommendations for improved performance, acknowledgement of satisfactory performance, any corrective actions needed.
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Summary Reports One or two page executive summary. To inform senior management of matters that need prompt or continued attention. To inform senior management about significant findings. Should include: Brief description of the audit, Conclusions, Summary statements of significant findings with references to where the detail can be found in the full audit report, and Brief description of actions taken by the client as a result of the audit findings. May be issued in addition to the full audit report. 2010 CMA Part 1 Section D Internal Controls 94 Writing and Distributing the Report The report should be: Objective, Clear, Concise (no longer than necessary), Timely, and Constructive.
The report should be reviewed with the auditee
before it is issued. The report should be distributed to everyone who has a direct interest in the area being audited.
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Incidents That Should be Reported The auditor should report: All material facts that they know that, if not reported, could cause the audit report to be distorted or conceal unlawful acts, Any variances between what should have been and what was, Any suspected fraud, The violation of any law, Inconsistent product quality (in a quality audit), and Any other reportable condition that management should be informed about.
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Auditor Follow-Up Unlike the external auditor, the internal auditor should follow-up on engagements after they are completed.
The follow-up is to determine whether the
recommendations have been implemented, whether they were timely, and whether they have been effective, and just how the department is doing.
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Computerized Audit Techniques Use of computers to audit information systems: Generalized audit software Test data Integrated test facility Parallel simulation Embedded audit routines Extended records Snapshots Tracing Mapping
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Systems Controls and Security Measures
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Systems Controls The objectives of controls for an information system are similar to the objectives of overall organizational controls. There are, however, special threats to information systems. Examples: Errors can occur in system design Data can be stolen over the internet Data and programs can be damaged Programs can be altered by dishonest employees to divert assets to their own use Viruses, trojan horses, and worms can infect a system, causing a system crash, stolen or damaged data Physical facilities can be damaged by natural disasters, illegal activity, or sabotage 2010 CMA Part 1 Section D Internal Controls 100 Systems Controls contd Information system internal control guidelines are based upon two documents: 1. The report of the Committee of Sponsoring Organizations (COSO) Internal Control Integrated Framework 2. Control Objectives for Information and related Technology (COBIT), authored by the IT Governance Institute and published by the Information Systems Audit and Control Foundation (ISACF). Systems controls are broken down into two categories: 1. General Controls 2. Application controls 2010 CMA Part 1 Section D Internal Controls 101 General Controls General controls relate to the environment where transactions are processed. Controls over development, modification and maintenance of programs, segregation of duties, data security, administrative controls, provision for disaster recovery. The categories of general controls are: The organization and operation of the computer facilities, including segregation of duties; General operating procedures, including written procedures and manuals; Equipment and hardware controls, including backup procedures; Access controls, including both physical access and password access to data and programs.
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Application Controls Application controls are specific to individual applications. They should be designed to prevent, detect and correct errors in transactions. The three main categories are: Input controls, Processing controls, and Output controls.
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System and Program Development and Change By having controls in place during the design of the system, the accuracy, validity, safety and security of the system is improved. The stages in system development are: Statement of objectives, Investigation and feasibility, Systems analysis, Systems design and development, Program coding and testing, Systems implementation, Systems evaluation and maintenance.
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Internet Security
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Internet Security A minimum level of internet security includes User account management, A firewall, Anti-virus protection, and Encryption.
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Viruses, Trojan Horses and Worms A computer virus is a program that executes itself and replicates itself, damaging the host computer and others.
A Trojan horse does not replicate itself, though
it may still damage the computer by causing the loss of data, or theft of data.
A worm is similar to a virus, but a worm replicates
itself without the use of a host file.
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Cybercrime The Internet, online communications and e- business are all subject to computer crime and this threat is growing every day. The most serious computer crimes, as defined by the FBI, are: Intrusions of the Public Switched Network (the telephone company), Major computer network intrusions Network integrity violations Privacy violations, Industrial espionage, and Pirated computer software 2010 CMA Part 1 Section D Internal Controls 108 Cybercrime contd Other types of computer crime include: Copyright infringement such as the illegal copying of copyrighted material Denial of Service (DOS) attacks in which a website is accessed repeatedly so that other, legitimate users cannot connect to it, Theft of credit card numbers from retailers files Phishing, a high-tech scam that uses spam e-mail to deceive consumers into disclosing sensitive personal information Installation of malware on a computer without the users knowledge.
Firewalls and Encryption A firewall is a barrier between the internal network of a company and external networks.
A firewall prevents unauthorized access to the
network and can also record attempts that were made to access the network.
Encryption is the method of converting text into
a code for transmission and then converting back to text when received.
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Backup and Contingency Planning The company must have plans for the backup and recovery of data. The more extreme form of contingency planning is disaster recovery. A disaster recovery plan includes: Who will participate in the recovery and what their roles are, What hardware, software and facilities should be used, and The priority of applications to be processed.
A hot site is a backup site that has similar equipment and
is able to be used immediately. A cold site is a site where power and space are available, but it requires getting computer equipment installed there quickly if needed.