September 10, 2014

MF0013 [Internal Audit and Control] Set2 Q1

Q. 1 Why Internal check is necessary? Choose an organization of your choice and find out how internal checks are put in place.

Ans:-

Internal check:-
Internal check is an important process of internal control system. Under the system of internal check, it is ensure that the job performed by one employee gets checked, automatically by another employee. No employee, alone, allowed handling transactions from beginning to end. 

Example: Please recall what happens when you visited a bank branch to encash a cheque. First, you produce the cheque to a counter, where the official concerned issued you a token and enters the token numbers on the back of the cheque and in the token book. The cheque is then send to the ledger clerk, who verify the balance in your account and makes debit entry therein. The cheque then sent to an officer, who verify your signature on the cheque with bank records, and if it tallies then he sends the cheque to the cashier to make payment. The cashier makes the payment against the token handed over to you and records it in his cash register. 

This is an excellent example of internal check. Here arrangement is such that the job of one employee is automatically checked by other. 

From the above discussion, we can summarize some characteristics of internal check: 
1. Proper segregation of duties 
2. Automatic checking of job 
3. Multiple recording of same transactions 
4. Rotation of jobs 
5. Prevention of errors and frauds 
6. Separation of custodial and recording functions. 

Let us understand the concept of internal check with a practical example of a medium sized manufacturing company regarding its purchases.
  • Purchases should be supervised by and organized by a separate department called purchase department or procurement department. The department should be headed by a qualified and trained senior officer. 
  • The department should maintain a list of approved suppliers with whom orders for making purchases are regularly placed. 
  • The purchase process should invariably be start with the placing of a requisition duly authorized by a senior official to the purchase department. 
  • Each department of the company should have a book of requisition slips bearing serial numbers. The purchase department should maintain a register of books of requisition slips issued to different departments. 
  • The purchase department should keep a separate record of requisition forms received from different departments. 
  • Upon receipt of a requisition, the purchase department should send inquiry letter to the listed suppliers for quotation of the price, fright and delivery terms. 
  • After examination of the terms quoted by suppliers, the purchase department should place an order with the supplier selected by it. It should also send copies of the order to the Accounts Department, stores department and the department which has made the requisition. In case an order has been placed with a supplier other than the one who had quoted the lowest price, the reason for the same should be recorded. 
  • The procedure relating to receipt, inspection, acceptance and transfer of the goods to concerned departments, should be clearly laid down. 
  • Receipt of goods should be recorded in the Goods Received (or Inward) Register. The person in charge of receiving the goods should prepare a Goods Received Note (or Materials Received Report) and send a copy thereof to the Accounts department and to the department upon whose requisition the good have been ordered. 
  • Goods received should be inspected to see that they are exactly as ordered. This should be dome with the assistance of the inspection department and the department which has requisitions the goods. The final inspection report should send to Accounts department. Wherever possible, goods received note and goods inspection note may be combined. 
  • Upon receipt of the suppliers invoice, the purchase (or the Accounts) department should check it with the order and the goods received/ inspection note to ensure that the rate, discount, quality and quantity of the goods are exactly as earlier agreed. 
  • After due checking, necessary particulars of the purchase should be recorded in the purchase register and the number of the purchase order should be marked on the invoice. 
  • The Accounts department should not make payment to the supplier unless the invoice has been passed for payment by an authorized person after due verification. 
  • In case any advance sum has been paid to the supplier against the order, it should be adjusted from the total amount of the bill and only the net amount should be paid to him. 
  • Goods received should also be entered in respective stores ledgers. From there, the relevant entries should be passed in the stock (bin) card. 
  • In case any goods are rejected on account of being defective or for any other reason, they should be returned to the supplier and not entered either in the stores ledger or the bin cards. 
  • For the goods returned to the suppliers, credit note should be obtained from him (against a debit note prepared in his name) failing which a debit entry should be passed in his individual account. 
  • Where only a part of the goods are returned to the supplier as being defective, the items to be entered on the bin cards or stores ledger should be those actually accepted, and the goods received note should be prepared accordingly. In such a case, either the bill is passed only for the value of goods actually accepted, or a fresh bill is demanded from the suppliers. In such a case, as also where the supplier has overcharged in respect of any of the items, a credit note may also be obtained from him. 
  • All incoming credit notes should be numbered and stamped the same way as invoices. These should also check with the advice note covering the return of rejected goods to the supplier. 

In accounting and auditing, internal control is defined as a process effected by an organization's structure, work and authority flows, people and management
information systems, designed to help the organization accomplish specific goals or objectives. It is a means by which an organization's resources are directed, monitored, and measured. It plays an important role in preventing and detecting fraudand protecting the organization's resources, both physical (e.g., machinery and property) and intangible (e.g., reputation or intellectual property such as trademarks).

At the organizational level, internal control objectives relate to the reliability of
financial reporting, timely feedback on the achievement of operational or strategic goals, and compliance with laws and regulations. At the specific transaction level, internal control refers to the actions taken to achieve a specific objective (e.g., how to ensure the organization's payments to third parties are for valid services rendered.)

Internal control procedures reduce process variation, leading to more predictable outcomes. Internal control is a key element of the Foreign Corrupt Practices Act (FCPA) of 1977 and the Sarbanes–Oxley Act of 2002, which required improvements in internal control in United States public corporations. Internal controls within business entities are also referred to as operational controls.Internal controls have existed from ancient times. In Hellenistic Egypt there was a dual administration, with one set of bureaucrats charged with collecting taxes and another with supervising them. In the Republic of China, the Control one of the five branches of government, is an investigatory agency that monitors the other branchesof government.

Definitions
There are many definitions of internal control, as it affects the various constituencies (stakeholders) of an organization in various ways and at different levels of aggregation.Under the COSO Internal Control-Integrated Framework, a widely-used framework in the United States, internal control is broadly defined as 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: a) Effectiveness and efficiency of operations; b) Reliability of financial reporting; and c) Compliance with laws and regulations.

COSO defines internal control as having five components:
1. Control Environment-sets the tone for the organization, influencing the control consciousness of its people. It is the foundation for all other components of internal control.
2. Risk Assessment-the identification and analysis of relevant risks to the
achievement of objectives, forming a basis for how the risks should be managed
3. Information and Communication-systems or processes that support the
identification, capture, and exchange of information in a form and time frame that enable people to carry out their responsibilities
4. Control Activities-the policies and procedures that help ensure management
directives are carried out.
5. Monitoring-processes used to assess the quality of internal control performance over time.

The COSO definition relates to the aggregate control system of the organization, whichis composed of many individual control procedures.Discrete control procedures, or controls are defined by the SEC as: "...a specific set ofpolicies, procedures, and activities designed to meet an objective. A control may existwithin a designated function or activity in a process. A control’s impact...may be entitywideor specific to an account balance, class of transactions or application. Controlshave unique characteristics – for example, they can be: automated manual;reconciliations; segregation of duties; review and approval authorizations;safeguarding and accountability of assets; preventing or detecting error or fraud.Controls within a process may consist of financial reporting controls and operationalcontrols (that is, those designed to achieve operational objectives)."

Context
More generally, setting objectives, budgets, plans and other expectations establish criteria for control. Control itself exists to keep performance or a state of affairs within what is expected, allowed or accepted. Control built within a process is internal in nature. It takes place with a combination of interrelated components - such as social environment effecting behavior of employees, information necessary in control, and policies and procedures. Internal control structure is a plan determining how internal control consists of these elements. The concepts of corporate governance also heavily rely on the necessity of internal controls. Internal controls help ensure that processes operate as designed and that risk responses (risk treatments) in risk management are carried out. In addition, there needs to be in place circumstances ensuring that the aforementioned procedures will be performed as intended: right attitudes, integrity and competence, and monitoring by managers.

Roles and responsibilities in internal control
According to the COSO Framework, everyone in an organization has responsibility forinternal control to some extent. Virtually all employees produce information used inthe internal control system or take other actions needed to affect control. Also, all personnel should be responsible for communicating upward problems in operations, noncompliance with the code of conduct, or other policy violations or illegal actions.

Each major entity in corporate governance has a particular role to play:
Management: The Chief Executive Officer (the top manager) of the organization has overall responsibility for designing and implementing effective internal control. More than any other individual, the chief executive sets the "tone at the top" that affects integrity and ethics and other factors of a positive control environment. In a large company, the chief executive fulfills this duty by providing leadership and direction to senior managers and reviewing the way they're controlling the business. Senior managers, in turn, assign responsibility for establishment of more specific internal control policies and procedures to personnel responsible for the unit's functions. In a smaller entity, the influence of the chief executive, often an owner-manager, is usually more direct. In any event, in a cascading responsibility, a manager is effectively a chief executive of his or her sphere of responsibility. Of particular significance are financial officers and their staffs, whose control activities cut across, as well as up and down, the operating and other units of an enterprise.

Board of Directors: Management is accountable to the board of directors, which
provides governance, guidance and oversight. Effective board members are objective,capable and inquisitive. They also have a knowledge of the entity's activities andenvironment, and commit the time necessary to fulfill their board responsibilities.Management may be in a position to override controls and ignore or stiflecommunications from subordinates, enabling a dishonest management which intentionally misrepresents results to cover its tracks. A strong, active board, particularly when coupled with effective upward communications channels and capable financial, legal and internal audit functions, is often best able to identify and correct such a problem.Auditors: The internal auditors and external auditors of the organization also measure the effectiveness of internal control through their efforts.

They assess whether the controls are properly designed, implemented and working effectively, and make recommendations on how to improve internal control. They may also reviewInformation technology controls, which relate to the IT systems of the organization.There are laws and regulations on internal control related to financial reporting in a number of jurisdictions. In the U.S. these regulations are specifically established bySections 404 and 302 of the Sarbanes-Oxley Act. Guidance on auditing these controls is specified in PCAOB Auditing Standard No. 5 and SEC guidance, further discussed in SOX 404 top-down risk assessment. To provide reasonable assurance that internal controls involved in the financial reporting process are effective, they are tested by the external auditor (the organization's public accountants), who are required to opine on the internal controls of the company and the reliability of its financial reporting.

Limitations
Internal control can provide reasonable, not absolute, assurance that the objectives of an organization will be met. The concept of reasonable assurance implies a high degree of assurance, constrained by the costs and benefits of establishing incremental control procedures. Effective internal control implies the organization generates reliable financial reporting and substantially complies with the laws and regulations that apply to it. However, whether an organization achieves operational and strategic objectives maydepend on factors outside the enterprise, such as competition or technological innovation. These factors are outside the scope of internal control; therefore, effective internal control provides only timely information or feedback on progress towards the achievement of operational and strategic objectives, but cannot guarantee their achievement.

Describing Internal Controls
Internal controls may be described in terms of: a) the objective they pertain to; and b)the nature of the control activity itself.

Objective categorization
Internal control activities are designed to provide reasonable assurance that particularobjectives are achieved, or related progress understood. The specific target used todetermine whether a control is operating effectively is called the control objective.Control objectives fall under several detailed categories; in financial auditing, theyrelate to particular financial statement assertions, but broader frameworks arehelpful to also capture operational and compliance aspects:

1. Existence (Validity): Only valid or authorized transactions are processed (i.e., no invalid transactions).
2. Occurrence (Cutoff): Transactions occurred during the correct period or were
processed timely.
3. Completeness: All transactions are processed that should be (i.e., no omissions)
4. Valuation: Transactions are calculated using an appropriate methodology or are computationally accurate.
5. Rights & Obligations: Assets represent the rights of the company, and liabilities its obligations, as of a given date.
6. Presentation & Disclosure (Classification): Components of financial statements (or other reporting) are properly classified (by type or account) and described.
7. Reasonableness-transactions or results appears reasonable relative to other data or trends. For example, a control objective for the accounts payable function may be stated as:"Payments are made only for authorized products and services received." This is a validity objective. A typical control procedure designed to achieve this objective is: "The accounts payable system compares the purchase order, receiving record, and vendor invoice prior to authorizing payment." Multiple controls may be applicable to achieve a given control objective with a reasonable level of assurance.Management is responsible for implementing appropriate controls that apply to transactions in their areas of responsibility. Internal auditors perform their audits to evaluate whether the controls are designed and implemented effectively to address the relevant objectives.

Activity categorization
Control activities may also be explained by the type or nature of activity. These include(but are not limited to):
. Segregation of duties - separating authorization, custody, and record keeping roles of fraud or error by one person.. Authorization of transactions - review of particular transactions by an appropriate person.
. Retention of records - maintaining documentation to substantiate transactions.
. Supervision or monitoring of operations - observation or review of ongoing
operational activity.
. Physical safeguards - usage of cameras, locks, physical barriers, etc. to protect property, such as merchandise inventory.
. Top-level reviews-analysis of actual results versus organizational goals or plans, periodic and regular operational reviews, metrics, and other key performance indicators (KPIs).
. IT Security - usage of passwords, access logs, etc. to ensure access restricted to authorized personnel.
. Top level reviews-Management review of reports comparing actual performance versus plans, goals, and established objectives.
. Controls over information processing-A variety of control activities are used in
information processing. Examples include edit checks of data entered, accounting for transactions in numerical sequences, comparing file totals with control accounts, and controlling access to data, files and programs.

Control precision
Control precision describes the alignment or correlation between a particular control procedure and a given control objective or risk. A control with direct impact on the achievement of an objective (or mitigation of a risk) is said to be more precise than one with indirect impact on the objective or risk. Precision is distinct from sufficiency; that is, multiple controls with varying degrees of precision may be involved in achieving a control objective or mitigating a risk.Precision is an important factor in performing a SOX 404 top-down risk assessment.After identifying specific financial reporting material misstatement risks, management and the external auditors are required to identify and test controls that mitigate the risks. This involves making judgments regarding both precision and sufficiency of controls required to mitigate the risks.
Risks and controls may be entity-level or assertion-level under the PCAOB guidance.

Entity-level controls are identified to address entity-level risks. However, a
combination of entity-level and assertion-level controls are typically identified to
address assertion-level risks. The PCAOB set forth a three-level hierarchy for
considering the precision of entity-level controls. Later guidance by the PCAOB regarding small public firms provided several factors to consider in assessing
precision.

Fraud and internal control
Internal control plays an important role in the prevention and detection of fraud. Under the Sarbanes-Oxley Act, companies are required to perform a fraud risk assessment and assess related controls. This typically involves identifying scenarios in which theft or loss could occur and determining if existing control procedures effectively manage the risk to an acceptable level. The risk that senior management might override important financial controls to manipulate financial reporting is also a key area of focus in fraud risk assessment.

The AICPA, IIA, and ACFE also sponsored a guide published during 2008 that
includes a framework for helping organizations manage their fraud risk.
If the internal control system is implemented only to prevent fraud and comply with laws and regulations, then an important opportunity is missed. The same internal controls can also be used to systematically improve businesses, particularly in regard to effectiveness and efficiency.

Continuous Controls Monitoring
Advances in technology and data analysis have led to the development of numerous tools which can automatically evaluate the effectiveness of internal controls. Used in conjunction with continuous auditing, continuous controls monitoring provides assurance on financial information flowing through the business processes.    

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