A401 Internal Controls INTERNAL CONTROL: COSO Definition A process, effected by an entity’s board of directors, management, and other personnel, designed to provide reasonable assurance regarding the achievement of objectives in the following categories: Effectiveness & efficiency of operations Reliability of financial reporting Compliance with applicable laws & regulations COSO, 1992, p. 9 INTERNAL CONTROL: PSA 315 Definition The process designed and effected by those charged with governance, management, and other personnel to provide reasonable assurance about the achievement of the entity’s objective with regard to reliability of financial reporting, effectiveness, and efficiency of operations and compliance with applicable laws and regulations. Four Essential Concepts #1 Internal control is a process. #2 Internal control is effected by those charged with governance, management, and other personnel. #3 Internal control can be expected to provide reasonable assurance of achieving the entity’s objectives. Limitations: Cost – benefit concerns Directed at routine transactions Human error Possibility of collusion Possibility of control override Inadequacy of procedures due to changes #4 Internal control is designed to help achieve the entity’s objectives. Categories of the objectives: Effectiveness and efficiency of operations Compliance with laws and regulations Reliability of financial reporting Control categories according to business objectives Operational controls Operational controls are controls that help to reduce operational risks, or identify failures in operational systems when these occur. The nature of operational risks varies between companies, because their operations differ widely. In general terms, operational risks are risks of failures in operations due to factors such as human error, a failure in processes, a failure in systems, and so on. Compliance controls Compliance controls are concerned with making sure that an entity complies with all the requirements of relevant legislation and regulations. When regulations are specific, compliance controls often involve detailed procedures for checking that every regulation has been properly complied with, and that there is documentary evidence that the checks have been made. This is often called a boxticking approach to compliance. A box-ticking approach to compliance control is more usually associated with a rules-based approach to regulation rather than a principles-based approach. Financial controls Financial controls have been explained as internal accounting controls that are sufficient to provide reasonable assurance that: „ transactions are made only in accordance with the general or specific authorisation of management „ transactions are recorded so that financial statements can be prepared in accordance with accounting standards and generally-accepted accounting principles „ transactions are recorded so that assets can be accounted for „ access to assets is only allowed in accordance with the general or specific authorisation of management „ the accounting records for assets are compared with actual assets at reasonable intervals of time, and appropriate action is taken whenever there are found to be differences. SPAMSOAP Some years ago, a guideline of the UK Auditing Practices Board identified eight categories of internal (financial) controls, which can be remembered by the mnemonic SPAMSOAP. Segregation of Duties Where possible, duties should be divided between two or more people Physical Controls These are measures to protect assets against theft, loss or physical damage Authorization & These are controls over spending decisions and decisions to enter into transactions. Management controls Controls applied by management. An example is the system of budgeting. approval controls SPAMSOAP Some years ago, a guideline of the UK Auditing Practices Board identified eight categories of internal (financial) controls, which can be remembered by the mnemonic SPAMSOAP. Supervision Controls can be applied by supervising the work done by employees Organization Controls There should be lines of reporting from junior to senior staff Arithmetical & Examples are control total checks and bank reconciliation checks Personnel controls There should be controls over the selection and training of employees accounting controls Types of Controls In general, controls can be classified into: Directive – designed to encourage or cause a desirable outcome to be achieved Preventive – keep errors or irregularities from occurring Detective – search for and identify errors after they have occurred Corrective – designed to prevent recurrence of errors Types of Controls RISKS: UNDESIRABLE EVENTS Preventi ve Prevent ive Prevent ive Detective Detective Detective Correctiv e Correctiv e Correctiv e Directive Broad in nature Can also be classified as preventive Examples: Job descriptions Policies and procedures Trainings Laws and regulations Meetings Preventive More cost effective than detective controls Examples: Segregation of duties Authorization / approval matrix Locking your office to prevent theft Detective More expensive than preventive controls but still essential to measure the effectiveness of preventive controls Examples: Reviews and comparisons Periodic physical inventory counts Supervisory reviews Exception reports Reconciling monthly account statements Corrective Used when improper outcomes occur and are detected Usually the last recourse, but can be costly Examples: Disciplinary actions Filing suits in court Full restoration of a system backup files after evidence is found that data have been improperly altered Reflection: Observe USJR. What examples can you give for each of the three control categories? Operational controls __________________________________ Compliance controls __________________________________ Financial controls __________________________________ Internal Control System, Defined Means all the policies and procedures (internal controls) adopted by the management of an entity to assist in achieving management’s objective of ensuring, as far as practicable, the orderly and efficient conduct of its business, including adherence to management policies, the safeguarding of assets, the prevention and detection of fraud and error, the accuracy and completeness of the accounting records, and the timely preparation of reliable financial information. Components of internal control The components: Control Environment Risk Assessment Information and Communication Systems Control activities Monitoring CONTROL ENVIRONMENT Management’s & board of director’s attitude, awareness, & actions regarding internal control Captures importance of control in management’s operating style “Tone at the top” Foundation for effective internal control, providing discipline and structure. Control Environment (cont’d) Factors reflected in the control environment include: Communication and enforcement of integrity and ethical values Commitment to competence Management philosophy and operating style Active participation of those charged with governance Personnel policies and procedures Assignment of responsibility and authority Organizational structure RISK ASSESSMENT Risk assessment is the process used by companies to identify and assess the risks that the company faces, and changes in those risks. The risk assessment process involves prioritising the risks, and (if possible) putting a quantitative measurement to them. Risk assessment Business risk – the risk that the entity’s business objectives will not be attained as a result of internal and external factors such as Technological developments Changes in operating environment New personnel New or revamped information systems Rapid growth New business models, products, or activities Corporate restructurings Expanded foreign operations New accounting pronouncements Changes in customer demands Economic changes Risk assessment: an example A manufacturing company might categorise its operational risks as: selling and markets, delivery, production, and purchasing and resources. Most of these risk categories involve more than one function or department within the company. Selling and markets is an aspect of operations that affects not just the marketing department, but also research and development, quality control and customer services, and so on. Risk assessment: a reflection If you were to assess the risks for USJR, identify at least three risk categories, preferably spread across the different company objectives. ________________________________ ________________________________ ________________________________ ________________________________ ________________________________ ________________________________ ________________________________ INFORMATION AND COMMUNICATION SYSTEMS Within a system of internal control, there must be a system for reporting to management information about risks, the effectiveness of controls, failures in control and the success of action to remove weaknesses in controls and reduce risks. The information provided needs to be timely, relevant and reliable. Information and communication systems Information system Financial reporting system Consists of the procedures and records established to initiate, record, process, and report entity transactions and to maintain accountability for the related assets, liabilities, and equity. CLASSIFY, MEASURE, SUMMARIZE, DISCLOSE Communication Involves providing an understanding of individual roles and responsibilities pertaining to internal control over financial reporting. Can be made electronically, orally, and through the actions of management. CONTROL ACTIVITIES Are the policies and procedures that help ensure that management directives are carried out. Performance Reviews Information Processing Proper authorization of transactions and activities Segregation of duties Adequate documents and records Safeguards over access to assets Independent checks on performance Physical Controls Segregation of Duties Management (authorization) Custody (transaction execution) Accounting (recording transactions) Monitoring (independent checks on performance) CONTROL ACTIVITIES Categories Preventive controls Intended to prevent misstatement Detective controls Detect misstatements that have occurred Control Activities Categories General Controls Control activities that prevent or detect irregularities for all accounting systems Policies and procedures that relate to many applications and support the functioning or application controls by helping to ensure the continued proper operation of information systems. Examples: Controls over data center and network operations; system software acquisition, change, and maintenance; access security; application system acquisition, development, maintenance Application Controls Controls that pertain to the processing of certain types of transaction. Controls that apply to the processing of individual applications. These controls help ensure that transactions occurred, are authorized, and are completely and accurately recorded and processed. Examples: Checking the arithmetical accuracy of records, maintaining and reviewing accounts and trial balances, automated controls such as edit checks of input data and numerical sequence checks, and manual follow up of exception reports. Control Activities Authorization All transactions should be authorized by responsible personnel acting within scope of prescribed authority, responsibility Specific authorization Required for each transaction Typically unusual transactions General authorization Policies, procedures for typical transactions Segregation Of Duties Optimum segregation of duties exists when collusion is necessary to circumvent controls Separate functions for Custody (transaction execution) Authorization (management) Recording (accounting) Monitoring (independent checks on performance) Design, Use Documents & Records Evidence of executed transactions Represent an audit trail Impact efficiency Designed for multiple use Prenumbered consecutively Easy to complete Access To Assets & Records Access limited to authorized personnel by Locks for physical protection Limits on employee access online Codes to authorize access Example of control activities Example of control activities Monitoring Process of assessing the quality of internal control performance over time. Involves assessing the design and operation of controls on a timely basis. Ongoing monitoring For recurring activities Separate monitoring Self-assessment performed by managers over the controls in their areas of responsibility Independent checks performed by outsiders such as internal or independent auditors. CASE ANALYSIS CASE 1 In Yaya Company, operations director Ben Janoon recently realised there had been an increase in products failing the final quality checks. These checks were carried out in the QC (quality control) laboratory, which tested finished goods products before being released for sale. The product failure rate had risen from 1% of items two years ago to 4% now, and this meant an increase of hundreds of items of output a month which were not sold on to Yaya's customers. The failed products had no value to the company once they had failed QC as the rework costs were not economic. Because the increase was gradual, it took a while for Mr Janoon to realise that the failure rate had risen. A thorough review of the main production operation revealed nothing that might explain the increased failure and so attention was focused instead on the QC laboratory. For some years, the QC laboratory at Yaya, managed by Jane Goo, had been marginalised in the company, with its two staff working in a remote laboratory well away from other employees. Operations director Ben Janoon, who designed the internal control systems in Yaya, rarely visited the QC lab because of its remote location. He never asked for information on product failure rates to be reported to him and did not understand the science involved in the QC process. He relied on the two QC staff, Jane Goo and her assistant John Zong, both of whom did have relevant scientific qualifications. The two QC staff considered themselves low paid. Whilst in theory they reported to Mr Janoon, in practice, they conducted their work with little contact with colleagues. The work was routine and involved testing products against a set of compliance standards. A single signature on a product compliance report was required to pass or fail in QC and these reports were then filed away with no-one else seeing them. It was eventually established that Jane Goo had found a local buyer to pay her directly for any of Yaya's products which had failed the QC tests. The increased failure rate had resulted from her signing products as having 'failed QC' when, in fact, they had passed. She kept the proceeds from the sales for herself, and also paid her assistant, John Zong, a proportion of the proceeds from the sale of the failed products. Required: (a) Explain the internal control deficiencies that led to the increased product failures at Yaya. (b) Propose recommendations to address the internal control deficiencies noted. end