How To Build Investor Confidence Through Good Corporate Governance

by on May 26, 2009

Julian Fisher asked:


Corporate Governance, once relegated as a nice-to-have, has never been higher on the agenda of companies than it is now. Tough new regulations have been drafted, originating in the US, to try and restore investor confidence that has been eroded not only by the volatility of the stock market but by a string of public governance failures such as those at Enron, WorldCom, Martha Stewart etc

The Sarbanes-Oxley Act (the Act), named after the two US senators who proposed the bill, is designed to restore investor confidence through the implementation of strong prescriptive measures centered around Corporate Governance.

The most important outcome of the Act is to make Directors personally and criminally liable for infringements of the Act, notably the misstatement of information within financial statements (referred to as Section 404), and roles and responsibilities of a firms Board of Directors.

Evidence of the enforcement of this Act is best illustrated by a number of high profile cases, brought to court prior to the Act’s enactment, such as the ex-CFO of Enron, Andy Fastow, who has had his assets frozen and has been indicted him on 78 federal charges of money laundering, fraud, conspiracy and obstruction of justice.

The Act affects all companies listed on any U.S. Exchange, including non-US companies, but is being adopted throughout the world by countries such as Brazil, Mexico, Canada and to a certain extent almost every other country in the world. Companies hoping to list or be acquired would also do well to adopt many of the tenets within the Act if they wish such a move to be fruitful.

Though the Act is seen by many as a knee-jerk reaction to the scandals that have plagued the markets in recent years, much of what is being recommended is just good business practice with the oversight role of a companys board and its audit committee in achieving an effective control environment being promulgated by the COSO (Committee of Sponsoring Organizations of the Treadway Commission) internal control framework. COSO details that the control environment is influenced significantly by a firms board of directors and audit committee.

Boards should, and must, be held accountable for their actions and the influence they have on the ethical behaviour of Company employees.

The Cost of Compliance

The cost of the Act to all businesses has been high. Many firms have had to increase the size of their internal audit departments to cope with the provisions of Section 404 or recruit more members to the Board to comply with the governance requirements. Key-man or Directors & Officers (or Professional Indemnity) premiums have risen between 200 and 400% to guard insurance companies and underwriters against the increased likelihood that lawsuits may be brought against Directors.

Audit fees have jumped between 15 and 30% to cover auditors costs of increasing the size of audit teams needed to perform audits with extra assurance and to guard themselves about making incorrect judgments regarding the accuracy of financial statements.

For a start up business why is this important?

Traditionally in a start up phase the direction of a company is guided by its founding fathers. In the case of BioTech companies these are usually scientists with a basic understanding of finance. In order to gain the trust of either the market or Venture Capital firms an experienced financial practitioner, such as an ACA or CPA should be sought to add credibility and to enact control over the organization. The Act stipulates the need to have an expert on the Audit Committee with an expert being defined as someone who has the knowledge and experience to give assurance over both the internal controls and financial reporting environment.

It is never too early to start enforcing controls in spending at an organization. The inability to control costs or to come up with a sound business plan has caused the downfall of many firms. Most notably this has been seen in the dot-bomb bubble where billions of dollars of Venture Capital was spent on companies who had no experience in drawing up business plans that would ever generate a profit or had no controls over how the capital raised was to be spent.

Building a Board of Directors who have industry expertise and business acumen is just good practice. Diversification of these risks will only enhance a firms ability to navigate its way to success and avoid the pitfalls that plague start up firms.

The importance of good governance

1. Reputational impact mitigants - Reputational risks in terms of ethical behavior, restatement of financial statements (and any failures caught by Venture Capital firms in their due diligence work) can adversely affect a companies valuation

2. It will easier to attract good non-executive directors if they perceive that the likelihood of loss arising from taking a position is small (as they can be legally liable for non-ethical behavior of a firm). In fact there is a severe shortage of good non executive director candidates because the potential cost to them in case of legal actions outweighs the benefits associated with the position (i.e. the salary)

3. Good governance and a disciplined approach to financial controls can save you money (especially in control of expenditure)

4. Leads to potential reduction in both audit fees and insurance premiums through changing the control mindset of an organization

5. By implementing a more formal methodology for evaluating business risks and controls will enable CEOs to run their business more efficiently and effectively whilst reducing the likelihood of operational breakdown, litigation and fraud



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Key Provisions of the Sarbanes Oxley Act

by on May 11, 2009

Singh Prahalad asked:


 

This article advises small and emerging public companies with the key provisions of the Sarbanes Oxley Act and what they need to do to ensure they are in compliance with the required provisions. In this article, we also present how Prolianze can assist the small and emerging companies with their responsibilities under the Sarbanes Oxley Act of 2002.

Key provisions of the Sarbanes Oxley Act



Section 301 – Audit Committee: This section places the responsibility of hiring and compensating the company auditors with the Audit Committee. The committee is also required to establish mechanism to receive, retain, and treatment of complaints regarding accounting, internal accounting controls, or auditing matters.

Section 302 – Responsibility for Financial Reports: CEO and CFO are required to issue a certification with their quarterly and annual report stating that the financial statements are accurate and they are not aware of any material misstatement in financial statements. The certification also requires that the CEO and CFO understand that they are responsible for establishing, maintaining and evaluating internal controls.

Section 402 – Conflicts of Interest: Prohibits, directly or indirectly, including through any subsidiary, to extend or maintain credit, to arrange for the extension of credit, or to renew an extension of credit, in the form of a personal loan to or for any director or executive officer.

Section 404 – Management’s Assessment of Internal Controls: Each public company annual report should contain an assessment, as of the end of the most recent fiscal year of the issuer, of the effectiveness of the internal control structure and procedures of the issuer for financial reporting.

Section 406 – Code of Ethics: A code of ethics is required for senior financial officers, applicable to the principal financial officer, comptroller or principal accounting officer, or persons performing similar functions.

Section 407 – Audit Committee Financial Expert: Each public company audit committee is required to have one designated financial expert. The financial expert is defined as someone who has the knowledge of US GAAP, experience with preparation and auditing of financial statements and internal accounting controls, and understands the audit committee functions.

Section 802 – Criminal Penalties for Altering Documents: This section established criminal penalties including a fine and imprisonment of up to 20 years of both. Criminal penalties may be applied to whoever knowingly alters, destroys, mutilates, conceals, covers up, falsifies, or makes a false entry in any record, document, or tangible object with the intent to destruct, alter, or falsify records in Federal investigations and bankruptcy.

Section 806 – Whistleblower Protection: This section establishes the whistleblower protection provisions to protect the employees of the publically traded companies who may report any wrongdoing to federal authorities as well as his supervisor. The section provides for civil liabilities to prevent discrimination against the whistleblower.

Section 906 – Corporate Responsibility for Financial Reports: A statement of required with the periodic reports by the CEO and CFO that information contained in the periodic report fairly presents, in all material respects, the financial condition and results of operations of the issuer.

Section 1107 – Retaliation Against Informants: This section provides for the criminal liabilities against the individuals who retaliate against the informants who provides truthful information relating to the commission or possible commission of any Federal offense to any law enforcement officer. The criminal liabilities include a fine and imprisonment of up to 10 years, or both.

 

 





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SAS 70 | Overview & Analysis of Type I and Type II Audit Reports

by on May 6, 2009

Charles Denyer asked:


 

Statement on Auditing Standards No. 70, commonly known as SAS 70, is a highly recognized auditing standard put forth by the American Institute of Certified Public Accountants (AICPA). In CPA technical terms, it’s used to report on controls placed in operation (Type I audits) and tests of operating effectiveness (Type II audits). In simpler terms, it’s an audit used by auditors for examining the control environment of service organizations.

SAS 70 Type I Audits

Type I audits are looked upon as an audit done for a snapshot in time. Essentially, a service organization’s control environment is examined by auditors for a specific date in time, such as August 27, 2008. What this means is that the audit report issued for the service organization is a report on controls placed in operation for August 27, 2008. You might be asking how relevant is an entity’s control environment that is examined and attested for by a CPA firm for only that single day? Well, not too terribly relevant, and as such, SAS 70 Type I reports have limited value from a regulatory compliance perspective. They are, however, seen as an excellent stepping stone in moving towards a SAS 70 Type II audit, which actually tests controls over a state time period. Furthermore, it must be noted that SAS 70 Type I audits do not suffice for Sarbanes Oxley, as only a Type II report provides the necessary assurances for section 404 internal control requirements for user organizations. Sound a little confusing? Let me explain in detail the relationship between Sarbanes Oxley (SOX) and SAS 70 audits, which will hopefully clear up any vagueness or misunderstandings you might have.

SAS 70 and SOX

The unique relationship between SOX and SAS 70 begins with section 404. Because management must report annually on the effectiveness of internal controls, it then has an obligation to examine all controls considered vital to the organization (user organization in SAS 70 jargon) as a whole, but more importantly, to its financial reporting process. And because a large number of publicly traded companies outsource numerous critical services, these outsourcer providers, known as service organizations, are considered an integral component for purposes of financial reporting. Therefore, an in-depth, due-diligence process must be enacted to have their internal controls observed and certified. The Securities and Exchange Commission’s (SEC) Chief Accountant and the Division of Corporation Finance has stated that "In many situations, a registrant relies on a third party service provider to perform certain functions where the outsourced activity affects the initiation, authorization, recording, processing or reporting of transactions in the registrant’s financial statement. In assessing internal controls over financial reporting, management may rely on a Type 2 SAS 70 report."

SAS 70 Type II Audits

Type II audits are audits conducted over a stated time period, usually anywhere from six (6) to twelve (12) months, however, circumstances can arise where the audit is done in a shorter time period. SAS 70 Type II audits suffice for SOX regulatory requirements and are seen as effective, viable audits done on service organizations for examining their control environment. Because Type II audits actually test the worthiness of internal controls over a stated time period, these audits have wide acceptance through many industries and are looked upon as the de facto audit for examining a company’s internal controls. Type II audits can take a considerable amount of time and effort in planning and preparation. Most organizations begin with a SAS 70 Type I audit, then move towards Type II compliance in subsequent years. However, some organizations do go directly towards Type II compliance; it all depends on the circumstances that arise for service organizations.

What is a Service Organization?

Service organizations are essentially third-party outsourcing entities that provide critical services to another company. Common example of these service organizations are payroll companies, third party administrators (TPA), data centers, Software as a Service (SaaS) providers, medical claims and billing companies, fulfillment houses, along with many others.

Preparing for a SAS 70 Audit

The best way to prepare for a SAS 70 Type I or Type II audit is to undertake a SAS 70 Readiness. Any reputable CPA firm should be able to provide you with a series of sas 70 readiness questionnaire forms and templates which will help identify the scope of the audit, while giving your organization a good understanding of what the audit actually entails. Even more, sas 70 readiness questionnaire forms and templates will help your organization identify any gaps, remediation, or deficiencies that will need to be addressed and corrected before the audit commences. It’s a good example of being proactive in the audit process, ultimately allowing for a high degree of efficiency and cost effectiveness for the SAS 70 Type I or Type II audit.

If you are considering having your organizatin go through a SAS 70 Type I or Type II audit, then SAS 70 sample reports are available from the SAS 70 Resource guide.



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Internal V External Auditing; Which do you prefer?

by on May 4, 2009

Marisa Muddiman asked:


ABSTRACT

Internal and external auditing of accounting are among one of the “best jobs” listed in the newspaper. They are similar, however, they do differ in some roles and responsibilities. To discover these similarities and differences, 5 articles were read and then discussed within the body of the manuscript. As a result of this explanation, I personally have put a lot of thought into which type of auditor I would like to become. Before this I had no idea, did you?

 What is an internal auditor?

“Internal auditing is an independent, objective assurance and consulting activity designed to add value and improve an organisation’s operations. It helps an organisation accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve the effectiveness of risk management, control, and governance processes.”

An internal auditor seeks to advise management on whether its major operations have sound systems of risk management and internal controls. In other words, the internal audit function is one to ensure that the internal controls are adequate enough to maintain compliance with the policies, procedures and guidelines while being ethical. In this case, “being ethical” involves four main responsibilities of the internal auditor with the first being integrity. Internal auditors must be honest in their job as well as diligent in their work while following the law. Integrity establishes trust which provides them with the basis for reliance on their judgment. Some say that internal auditors should have integrity to make sure they are not acting in any way to discredit internal auditing as a profession.

 The second ethical responsibility that internal auditors as well as external auditors should comply with is objectivity or independence. What is meant by this is that it is important to steer clear of any activity or relationship which could obstruct one’s ability to carry out an audit with an unbiased opinion. Accepting large gifts or payments could potentially impair one’s ability to do their job professionally. Gifts and other items of the same nature should be refused for the good of the audit.

Confidentiality being the third ethical responsibility for internal auditors means that extremely important information found during the audit should not be disclosed. Internal auditors need to respect the value and ownership of information they receive and do not disclose any of it without appropriate authority unless a legal issue or a professional obligation come up forcing them to do so. Some of the information acquired during an audit can be very valuable to people outside of the company which is why confidentiality is so important.

 Finally, the fourth ethical responsibility which auditors have is competency. In this case, competency means that an auditor should only take on responsibilities in which they can apply enough knowledge, skills and experience needed to carry out the audit professionally. Internal auditors need to improve their skills over time which will help them to become more proficient in their job.

 Having a strong ethical background is very important in the profession of being an internal auditor. These four guidelines are key in having a safe, legal and successful audit.

 Some of the more important roles and responsibilities of internal auditors are:

·         Developing the annual audit plan

·         Facilitating compliance with Sarbanes Oxley 404 requirements

·         Conducting field and management interviews

·         Prepare the audit program according to GAAP

·         Preparing working papers to summarize audit findings and recommendations

·         Periodically evaluate effectiveness of internal control practices

·         Coordinate audit activities with external auditors

·         Implement an audit quality assurance system

 

What is an external auditor?

An external auditor seeks to test the underlying transactions that form the basis of the financial statements. In other words, an external auditor reviews the control procedures and many other operations as their overall evaluation of internal controls. It is expected that the auditor would identify significant weaknesses that exist and make sure that anything material in nature be reported to management and possibly to higher authority, depending on the company. They provide an opinion on the adequacy of the company’s financial statements. They review the general controls as well as the overall financial statement preparation and reporting.

External auditor’s primary purpose is to give a company feedback on the effectiveness of the internal control system by giving an opinion with four main paragraphs. First, the introductory paragraph is written to indicate that an audit has been conducted and then identifies the financial statements that the auditors examined during the audit. The second paragraph is the scope paragraph which describes the character of the work in the audit and stating that they abided by Generally Accepted Auditing Standards (GAAS). This paragraph explains that the auditors were trained and proficient, independent, exercised due professional care, planned and supervised the work, obtained a sufficient understanding of the business and its internal control system and gathered sufficient evidence. These are the general standards and standards of field work which make up GAAS.

The third paragraph is the most interesting and generally the most important paragraph. This is the opinion paragraph where all of the final audited information is explained. It is typically one long sentence explaining if the financial statements present fairly, in all material respects, the financial position of a company and the results of their operations and their cash flows for this year and preceding years. They must state that all of this is in conformity with GAAS in the USA.

The last and final paragraph of an auditor’s opinion is the internal control paragraph. This is where auditors evaluate and report on the operating effectiveness of the entity’s internal control over financial reporting. They then state that based on the criteria established in the internal control framework, they express some kind of an opinion. There are four distinct types of opinions an auditor can issue which are unqualified, qualified, adverse or a disclaimer of opinion. An unqualified opinion is the best kind of opinion a company can receive and is the last line of the opinion before the auditor’s signature.

Some of the more important roles and responsibilities of external auditors are:

·         Advise management on areas at risk once the audit is complete

·         Recommend ways to improve operations and strengthen controls

·         Protect investors from receiving incomplete, inaccurate or misleading financial information

·         Add value to the effectiveness of corporate governance

What are the main differences between internal and external auditors?

Besides the differences that were previously stated, a significant difference between internal and external auditors is that an external auditor is and external contract and not an employee of the organization being audited. Internal auditors, however, are typically employed at the organization but there are an increasing number of internal auditors from an external source.

Another main difference between the two is that external auditors look to provide an opinion on whether or not the accounts are presented fairly and show legitimate assets, debts, etc. An internal audit forms an opinion on the adequacy and effectiveness of systems of risk management and internal control. Internal auditors are mainly concerned with overall risk management and external auditors are concerned with the “final” accounts and how data is presented in those accounts.

One other difference between internal and external auditors is that unlike external auditors, internal auditors should have full and free access to the company’s audit committee, unrestricted access to the company’s records, documents, property and personnel and authority to discuss initiatives, policies and procedures regarding risk assessment, internal controls, compliance, financial reporting and governance. External auditors can have the same privileges of access as internal auditors except that external auditors need to have proper authority to do so.

What are the main similarities between internal and external auditors?

There are many similarities between internal and external auditors. Some of the main similarities are that both internal and external auditors carry out testing routines which may involve examining many transactions. Some of these testing routines are testing the internal controls of the company and a test of reasonableness for bad debts. Another similarity between the two is that they both will be worried if procedures were very poor and there was a basic ignorance of the importance of following them. A company creates controls for a reason and they should not be ignored.

Both internal and external auditors are based in a professional discipline and operate to professional standards, seek active co-operation between the two functions and are tied up during an audit with a company’s internal control system. The most important thing that internal and external auditors both do is produce formal audit reports on their activities and are both concerned with the occurrence and effect that errors have on misstating the final accounts.

What are some career opportunities for internal and external auditors?

Internal and external auditors have similar career opportunities meaning that they both “audit” companies. An internal auditor is an employee of a company and makes sure that the internal controls are running properly, however, they cannot issue an external audit report. An internal auditor’s position could potentially turn into a CFO, CEO or controller type of position.

An external auditor on the other hand works for an outside firm and audits many companies in one year. Their career opportunities could extend far beyond just working for an accounting firm. They could end up getting an offer from a client to become a full time CFO for one particular company or become their personal internal auditor.

There are many paths that can be taken with the auditing profession. It really depends what a person chooses to do once they graduate from school. The roles and responsibilities of internal and external auditors are similar in some aspects but also very different. It is clear that they are two distinct professions and each has their own unique characteristics.



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Tools For Sarbanes Oxley Compliance

by on May 27, 2009

Joe Armstrong asked:


The Sarbanes Oxley Act of 2002 (SOX) has set in place some of the toughest corporate governance standards in the world. In light of the ongoing enforcement of such accountability legislation, the need for software solutions to help organizations manage the challenges associated with Sarbanes Oxley compliance is tremendous. There are a number of points to be considered when seeking out Sarbanes Oxley software.

A good Sarbanes Oxley software solution should provide an integrated platform with specific modules designed to meet all of your SOX 302 and 404 needs. Integration points for document management, control monitoring, business intelligence and internal auditing are key. Adopting an integrated architecture reduces the time and effort involved in gathering and reporting on Sarbanes Oxley compliance, risk management, and other governance data.

Such a tool should also help organizations meet additional governance responsibilities including the standards set out in the COSO ERM framework and emerging Basel II requirements. It should identify problems, monitor process performance, assign responsibilities and prioritize action items. It goes without saying that an ideal Sarbanes Oxley software solution should be able to be customized to meet the unique needs of your organization.

Case Study: McDonald’s Corporation

New requirements for internal auditing and operational risk management demand the development of powerful solutions to address the specific needs of Sarbanes Oxley as well as broader governance requirements. This is true as much for mid-market organizations as it is for multinational corporations.

For example, McDonald’s Corporation, the fast-food giant, has been in business for 50 years and is worth a reported $19 billion. With more than 32,000 locations in 120 countries around the world, McDonald’s is perhaps the most visible corporate brand. The corporation owns nearly 30 percent of its locations directly, and employs more than 435,000 people.

As early as 2003, well before the final regulations enforcing the Sarbanes Oxley Act were written, McDonald’s executives knew they faced a tremendous challenge in complying with sections 302 and 404 of the law. Its auditors and managing executives would be busy enough just working with local business units to ensure that deadlines were met and correct data gathered. The company needed a proven IT platform to serve as a framework and repository for that crucial compliance work.

McDonald’s knew it wanted to use an industry leading, risk-based framework built on standards from the Committee of Sponsoring Organizations (COSO), since the COSO framework was already well-known and had the support of important regulatory boards such as the Public Company Accounting Oversight Board (PCAOB). The solution needed to be able to be easily bolted onto McDonald’s systems and allow SOX project managers to work immediately.

Paisley Consulting, the recognized global leader in corporate governance, enterprise risk management and audit management, offered the proven solution that McDonald’s was looking for. Risk Navigator® would let McDonald’s Global Sarbanes Oxley team load a standard set of controls into the tool, and then coordinate a global compliance effort where the core team could direct specific business units to focus on specific controls at certain times.

The Risk Navigator solution was initially phased in starting in the fall of 2003 beginning with a pilot program in Great Britain. Excel spreadsheets were used to load the global standard COSO framework into Risk Navigator for each market. Managers then used the framework to do their documentation and testing. Once the pilot proved successful, McDonald’s brought Risk Navigator into its North American and European operations. Asian operations were brought onto the system in 2005, and McDonald’s plans to include Latin American locations in late 2006.

With the global SOX team collaborating with local teams in an ongoing, sustainable effort, an estimated several hundred McDonald’s managers use Risk Navigator today in some capacity. Risk Navigator cleared a path for one of the world’s most prominent and geographically diverse businesses to comply with a complicated regulatory measure by the required deadline while empowering them to build a global repository of best practices for financial operations.

Summation

Keeping up with complex regulations such as the Sarbanes Oxley Act and sustaining those compliance activities with constrained time and resources is a daunting task for even the most visible businesses. If you’re looking for a more efficient alternative to first-generation Sarbanes Oxley compliance software, spreadsheets and other manual approaches to Sarbanes Oxley, Paisley Consulting can help.



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5 Years and Counting: Impact of Sarbanes-oxley

by on May 21, 2009

Joseph N. Gaudio asked:


5 Years and Counting: Impact of Sarbanes-Oxley

Background

In order to better understand the issues and impact of Sarbanes-Oxley, it is critical to understand the reasons for its implementation. Elaborate, complex fraudulent accounting scandals of the late 90’s and early 21st century have a direct correlation to poorly implemented and enforced internal controls. Since the enactment of the Sarbanes-Oxley legislation, companies have had to be even more cognizant of their controls in order to provide the necessary assurances that both their internal and external outputs (e.g. financial statements) to stakeholders are accurate and reliable.

Founding Fathers of Accounting Scandals

Enron, WorldCom and Arthur Anderson represent the dark side of the accounting profession. These tales of greed, dishonesty and malfeasance have shaken the confidence of the investing public and in the public accounting profession, the protector against such evil, fraudulent activities. It is seemingly entertaining to hear the hierarchy of these multi-national corporations (MNC) defend their wrongdoings. For example, take into consideration the following excerpt that appeared in USAToday from the testimony of Jeffery Skilling, the former Chief Executive Officer (CEO) of Enron:

Boxer: Wait a minute, you have to be an accountant to know that a company could never use its own stock to generate a gain or avoid a loss in an income statement? What was your education, Mr. Skilling? I know I read it was pretty good.

Skilling: A master’s in business administration.

Boxer: A master’s in business administration, and yet you didn’t know this simple fact, is that correct? …Where did you go to school?

Skilling: Harvard Business School.

Boxer: In Harvard Business School you did not know this, is that correct?

Skilling’s rationale is simply irrational because it ignores a basic accounting principle. Consequently, situations such as this, which cost investors hundreds of millions of dollars, needed to be addressed. Thus, the Sarbanes-Oxley Act of 2002 was meant to restore the public’s confidence in the accounting profession, safeguard against internal control failures, and deter the possibility of future accounting scandals.

Compliance Costs

While Sarbanes-Oxley provides investors with higher quality information, there has been controversy on whether the benefits exceed the rather burdensome compliance costs. However, in a recent survey, 83% of companies believe that spending on compliance costs will be relatively the same or even less than last year (Papini 11).

According to Paul Larsen, an equity strategist at the Chicago Morning Star, ”compliance costs are going to decrease as the years pass because there is usually one big upfront technology cost made in the first year, and then costs are more maintenance-related the following years.” Further, software is being developed and companies are now moving toward automated controls which should bring costs down and reduce human error (Papini 11).

Section 806

One area of fundamental weakness within the Sarbanes-Oxley legislation is Section 806 dealing with the whistleblower provisions. Under this act, civil liability can be imposed on employers who take retaliatory action on other fellow employees who come forward with information about actual or potential corporate fraud involving their employer (eapdlaw.com).

Theoretically, if effectively implemented this law could be extremely advantageous in combating fraud from the source and protecting ethical employees. However, several structural areas of the law are flawed and allow it to be exploited. One weakness is the very stringent ninety (90) day statute of limitations. In the first 3 years of the laws’ existence, roughly one-third of employees who lost at the ALJ level did so because they did not satisfy the statute of limitations (Moberly 2). While legally correct, this decision ignores the substance and the spirit of the law. In addition, failure to meet the statute of limitations forces judges to disregard the materiality of the claim and the tribulations of the employee.

Another area of weakness of Section 803 is its reliance on OSHA investigations to determine employer retaliation. OSHA’s mission statement clearly states that their mission is to assure the safety and health of America’s workers by setting and enforcing standards; providing training, outreach, and education; establishing partnerships; and encouraging continual improvement in workplace safety and health (osha.gov). This broad statement fails to encompass the spectrum of employer retaliation and how it applies to the accounting profession. OSHA’s general purpose and resourcefulness do not match the requirements for successful enforcement and implementation of Section 803. This problem is most evident by OSHA’s mere 3.6% success rate for employees in the first 3 years of SOX (Moberly 1). The system would adequately function if the investigative responsibilities were given to an agency more familiar with fraudulent accounting practices such as the SEC (Moberly 4).

Section 404

Section 404 is largely regarded as another weakness within the Sarbanes-Oxley Act, which results in an enormous corporate compliance expense. Fortunately, for accounting firms, the audit fees represent a large portion of that increased cost (Pomeroy 1).

Due to the more stringent requirements, adverse opinions are being reported more frequently. In the first year of SOX compliance, 16% of filers were given an adverse opinion. On the positive side, in the following year that number went down to 10% which proves that despite the extra costs, auditors are finding material misstatements and reporting more precise information. The following is a breakdown of the most common areas of misstatement (Section 404: Where the Weaknesses Are).

Areas of Failure 2005* 2004*

Tax Accruals/Deferrals 34.5% 32.0%

Revenue Recognition 28.4% 31.3%

Inventory/Vendor Cost of Sales 23.7% 27.4%

Fixed Intangible Assets 16.0% 18.6%

Leases or Contingencies 9.3% 16.8%

Cash Flows 8.8% 8.8%

Consolidation 6.7% 9.0%

*numbers do not add up to 100% because data allows for multiple material weaknesses.

Source: AuditAnalytics.com

Another positive of Section 404 is that costs are going down! In a recent survey of 172 companies, 2006 compliance costs for Section 404 declined 23% and are continuing to decline (SOX 404 Costs Drop).

So what have we learned?

Overall, Sarbanes-Oxley has had an overwhelmingly positive, albeit burdensome, impact on the accounting profession. The industry is expanding and more jobs are being created. Furthermore, accounting firms are producing more credible, accurate and reliable financial statements to meet the stern reporting requirements. On top of that, appropriate measures are being taken to prevent future debacles and scandals thus fulfilling the accountant’s superpower of protecting the investing public and restoring faith in the profession.

Sarbanes-Oxley’s negative impact is minimal and consists of compliance costs that will decrease in time and can be absorbed through technological advances. Even Section 806, despite its deficiencies, positively affects employees and is useful in preventing fraud. Obviously, Sarbanes-Oxley has some flaws, however if Congress selectively and intelligently amends certain weaknesses the overall long-term positive impact drastically exceeds the pitfalls.



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Outsourcing Sox – Best Options

by on May 15, 2009

Asha Jacob asked:


 SOX - An Overview

It is mandatory for all US public companies to adhere to the Sarbanes-Oxley Act (SOX) introduced in the country in July 2002. The primary objective of the Act is to regulate financial practice and corporate governance and restore investor confidence in response to major financial scandals involving Enron, WorldCom and others. But public companies are already grumbling about the costs of abiding with the Act’s requirements.

The Japanese government similarly, promulgated a law in June 2006, known as J-SOX in order to prevent accounting frauds by public companies and to safeguard investor interest. This will be in force for all fiscal years starting from April 1, 2008. Drawn up on the same lines as the US-SOX, companies listed in Japan and operating in other countries as subsidiary companies have to adhere to J-SOX compliance.

Weighty Regulations

The most contentious part of SOX is Section 404, which requires management and the external auditor to report on the adequacy of the company’s internal control over financial reporting (ICFR). This is the most expensive aspect of the legislation for companies to implement, as tremendous effort goes into documenting and testing important financial, manual and automated controls. Additionally, the Sarbanes-Oxley Act states that all business records, including electronic records and electronic messages, must be saved for "not less than five years."

The penalty for non-compliance is fines, imprisonment or both. The legislation not only affects the financial side of companies but also the IT departments which are responsible for storing a company’s electronic records. Accounting and IT must work hand in hand to achieve the best possible accuracy in the implementation of SOX. Expectedly, the additional compliance costs and the increased paperwork that have come with the legislation have put companies in a tizzy.

Outsourcing – the Key

Both US SOX and J SOX involve documentation of all business activities of a company. It involves defining processes, mapping and identifying risks and controls. Fulfilling this daunting task involves diverting scarce corporate resources. The sensible option in such a scenario is to outsource these mandatory processes in order to ensure compliance in a cost effective manner and to free up resources to focus on other aspects of business.

Outsourcing companies particularly from India have jumped on to the Knowledge Process Outsourcing (KPO) bandwagon with SOX compliance related work garnering a major share in the outsourced processes. While significant cost savings is the key driver to consider India as a preferred outsourcing destination, there is no disputing the fact that companies benefit from the huge English speaking work force with superior financial and technology skills.

Udyen Jain and Associates (UJA) is an India based company of highly experienced Chartered Accountants bringing with them professional expertise and cross-disciplinary skills to the assignments they handle.

UJA is an experienced player handling ongoing SOX and J-SOX projects for clients in the US and Japan. As a part of their off shore solutions, UJA offers back office and internal audit services for SOX compliance - streamlining and automating the complex process to employ best practices to fulfill SOX regulations. Mr. Udyen Jain, founder of the company states “At Udyen Jain & Associates, our endeavor is to become your business partner and not just an offshore vendor. It makes complete business sense to offshore your firm’s internal compliance related procedures to our experienced team of financial and legal experts who will facilitate the setting up of secure, ongoing procedures and controls to meet your firm’s requirements under the Sarbanes-Oxley Act.”

A broad description of services under SOX performed by the UJA Audit team:



End to End Process Mapping (including documentation of process narratives and flow charts)

Risk Assessment based on a well defined Risk Control Matrix (RCM)

Process Walkthroughs

Test of Design & Operating Effectiveness Assessment





Spread Sheet Control Assessment

Segregation of Duty (SOD)

Gap Reporting

Remediation of Gap



Sustaining Compliance with Automation

UJA’s technical partner Leo Manage, a division of Leo Technosoft, offers efficient, cost-effective automated processes that help in mitigating risks and ensures compliance with financial regulations. Documentation of financial controls is best met by using workflow management software and enterprise planning solutions that will help companies breeze through SOX audits. Leo Manage offers a range of solutions in this category that are simple to use and easy to install.

Automating the internal audit process ensures the accuracy and consistency of financial procedures. Leo Manage’s technology driven solutions help automate everything from file transfer to document retrieval. Leo’s product offerings connect all SOX processes on a single platform making it easy to access records from any location.

Advanced tracking and reporting capability streamlines a company’s SOX requirements and permits continuous monitoring, all of which helps increase confidence within the company and among the auditors. SOX compliance history is always accessible. Emergency fixes are automatically documented and reconciled for easier audit.

Mea Manage provides integrated solutions which make it more cost-effective and easier to implement than expensive stand-alone products.

Fool-proof Security Practices

The process of taking over the parent company’s bookkeeping, accounting and tax return activities is seamlessly accomplished in a systematic manner to a fully secure and protected environment. UJA’s team synchronizes the client firm’s compliance requirements by setting up robust internal controls and processes from their offshore site at a fraction of the cost. Companies can thus meet the challenges of compliance upfront and take home significant cost savings.

Mr. Satyen Jain, Managing Director, Leo Technosoft emphasizes that outsourced back office operations are in good hands due to “an unshakable wall of physical, network, data and desktop security around the financial processes.”

For further details on how outsourcing can help you with easier SOX compliance, please contact satyen@leosys.in



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Convergence of Ifrs, US Gaap and Indian Gaap and Its Impact on Indian Companies Listing in U.s and American Companies Listing in India

by on May 9, 2009

Sunil Kewalramani asked:


Convergence of IFRS, US GAAP AND INDIAN GAAP and its impact on Indian companies listing in U.S and American companies listing in India

By  SUNIL  KEWALRAMANI

                                                                                     November 4, 2008

Consistent, comparable and understandable financial information is the lifeblood of commerce and investing. Presently, there are two sets of accounting standards that are accepted for international use–the U.S. Generally Accepted Accounting Principles (GAAP) and the International Financial Reporting Standards (IFRS) issued by the London-based International Accounting Standards Board (IASB). Foreign subsidiaries of U.S. multinationals use U.S. GAAP. Many foreign companies, attracted to listing in the U.S. have to confront various problems like compliance with U.S. GAAP and the onerous Sarbanes-Oxley Act.

In search of a new financial order: one global standard for financial reporting makes sense.  Accounting Standards in India will undergo significant change from 1st April 2011, when the IFRS (International Financial Reporting Standards) come into force as per the recent proposal of The Institute of Chartered Accountants of India.   Countries of the European Union, Australia, New Zealand and Russia have already adopted IFRSs for listed enterprises.  China has decided to adopt IFRS from 2008 and Canada from 2011.

If 2011 is the year when we would be totally aligning our standards with the IFRS, then what would happen in terms of inter-period comparisons because the numbers that would emerge after convergence to IFRS would be based on different accounting principles than those based on Indian GAAP ?.  In order to breathe meaning in the numbers and enable inter-period comparison, it is essential that similar accounting principles should have been used from one period to another. Besides, you would need IFRS-trained professionals in India for which the Institute of Chartered Accountants of India would need to impart special training to its students and members alike.

In India, the accounting standards or accounting-related requirements are issued not only by the ICAI(Institute of Chartered Accountants of India) but also by various other regulatory bodies, such as SEBI (Securities and Exchange Board of India), RBI (Reserve Bank of India) and the IRDA (Insurance Regulatory and Development Authority).  They now not only need to be consistent with each other but also with the IFRS.

The Central Government in pursuance of Section 211 of the Companies Act 1956 has issued a notification prescribing accounting standards for companies, and these standards direct us to the Accounting Standards issued by the ICAI. Since ICAI is now leaning on implementing IFRS with effect from 1st April 2011, the Government would find it essential to treat complying with IFRS as satisfactory compliance with Section 211 of the Companies Act 1956.

 

Closing the GAAP

The demise of U.S. GAAP has accelerated this decade. While the SEC currently looks to FASB to set U.S. GAAP, it is the SEC that retains ultimate responsibility. U.S. GAAP has been extensively used since the 1930s, and until recently was widely used around the world. However, its shortcomings are also well known, including approximately 200 pieces of fragmented U.S. GAAP on revenue recognition, some of which are not based on consistent concepts.

U.S. GAAP has evolved over the years to become overly complex and onerous as evidenced by the large number of countries and companies abandoning it. One recent example is

NEC Corporation, the Japanese electronics giant. NEC announced on September 21, 2007, “that it was not able to complete a U.S. GAAP-required analysis relating to software, maintenance, and service revenues.” In essence, the company said it simply cannot figure out U.S. GAAP revenue recognition rules and will stop trying, resulting in suspended trading on the NASDAQ.

It is possible that companies listed in  the U.S. could be allowed to report their financial results using standards set by IASB instead.  Giving companies a choice of accounting standards might create an opportunity for forum shopping.

In India, one of the big impediments to implementation of IFRS in India is in the case of Mergers and Acquisitions where the High Court approval is required. The High Court has got the authority to stay application of accounting standards or to prescribe accounting requirements in the case of merger and amalgamation situations.  All this would deter smooth transition to IFRS in India.

Besides, deferral of VRS cost or ESOP accounting being based on intrinsic method, though a departure from IFRS is essential bearing in mind the needs and requirements of the Indian economy.

In addition, Schedule VI of the Companies Act, 1956 is also not in complete compliance with the IFRS and they need to be reconciled as well.

The RBI also prescribes accounting requirements for banks, such as accounting for derivatives or provision for non-performing assets, and these requirements of the RBI  are currently at variance with the IFRS.

Managements compensation, stock options, debt covenants, tax liability and distributable profits are all based on Indian GAAP and AS (Accounting Standards) at present. Now all the salary structure, compensation structure will have to be renegotiated by most senior employees who have variable methods of compensation. For example, the variable pay component of most TCS employees is about 30 % of the total compensation package and this variable pay being based on items of Profit/Loss Account which will be defined differently under IFRS, the entire compensation package will need to be revised.

Recently, the SEC (Securities and Exchange Commission) of the US eliminated the GAAP reconciliation requirement as a part of Form 20-F for foreign issuers. Almost simultaneously, the Commission issued a Concept Release that would enable U.S. issuers to drop GAAP and use International Financial Reporting Standards.

 

Statements of financial position, comprehensive income and cash flows

Perhaps the biggest potential change is a different look to financial statements. Although nothing has been decided, the IASB and FASB are striving to create a cohesive presentation of financial information that will likely do away with a single net income number, or “bottom-line.” Instead, the working proposal would require three separate statements: a statement of financial position, a statement of comprehensive income, and a statement of cash flows.

Companies would need to breakout in each financial statement information for business activities (including operating and investing activities), discontinued operations, financing activities, income taxes, and equity. This would result in a company classifying its assets, liabilities, and equity items into one of the prescribed categories or sections in the statement of financial position and then similarly classifying changes in assets, liabilities, and equity items in the statement of comprehensive income and the statement of cash flows. It is anticipated that the resulting standard will apply to all business entities (public and nonpublic), but not to not-for-profit organizations or defined benefit plans.

There are substantial differences between IFRS and U.S. GAAP. U.S. GAAP is largely rules-based meaning long and complex standards attempting to deal with all scenarios. Financial Accounting Standard No. 133 on derivatives is a fine example with over 800 pages of the standard and implementation issues.

On the other hand, IFRS is a principles-based accounting system, meaning it is objective-oriented allowing for more presentation freedom. Financial Accounting Standard No. 123R on share-based payments and the SEC executive compensation disclosure requirements are attempts to move toward principles-based standards.

One of the obvious benefits of accounting standards and particularly those that are adopted globally is comparability. We are heading towards, what we, in common parlance, call ‘apple-for-apple’ comparison, and not ‘apple-for-oranges’ comparison. Presumably, users of financial statements are in a better position to assess the prospects of one company versus another provided both the companies use the same set of rules to report similar transactions and events. The comparability issue was the prime reason for requiring the foreign issuers in the US to reconcile their statements to US GAAP.

SEC’S REASONS FOR ELIMINATING GAAP : It is ironical that although the purpose  of adopting IFRS is ensuring greater comparability, how does eliminating requirement of reconciliation help when most issuers in the US come there because of greater liquidity, visibility and marketing in the American capital markets. These foreign issuers would be competing with the US entities who adopt US GAAP and it would be unrealistic to expect that these foreign issuers would forego the US GAAP. In fact, they will continue to use the US GAAP because this way, they can compare their financials with the listed US entities and show how they can fetch similar market capitalization for their entities.

 

To circumvent this problem, if the SEC allows US issuers to adopt IFRS, there will be little need for convergence, and the concept of comparability would be highlighted.  The proposed move is said to be primarily intended to make it easier and cheaper for foreign companies to list on U.S. exchanges. There has been increasing concern that the competitiveness of the U.S. capital markets has been impaired by the onerous laws and additional compliance requirements put in place in the past five years – with the logical example being the Sarbanes-Oxley Act of 2002 and its Section 404 Internal Control Certification requirement. A popular example - regulators, lawmakers and other interested parties in the U.S. are concerned that domestic exchanges are losing market share in IPO listings to foreign exchanges that have “less cumbersome” listing requirements.

Is proposed elimination of U.S. GAAP reconciliation for foreign filers premature ?  Due to a variety of reasons – some of which have only gained broad attention in recent weeks – it appears the proposed elimination of the U.S. GAAP reconciliation for foreign filers may be premature. One of the main reasons regularly cited – despite the progress in recent years by the FASB and IASB on its “convergence” project – there are still too many differences between the two sets of standards and still have considerable room to converge further. A classic example of this can be found with GlaxoSmithKline plc – a foreign filer with the SEC which prepares its financial statements using IFRS. Note 41 from GSK’s 2006 Form 20-F filing provides details on the company’s reconciliation to U.S. GAAP. The footnote is a whopping 13 pages long and discloses a long list of differences in reconciling shareholders’ equity under IFRS (£9.4 billion) to shareholders’ equity under U.S. GAAP (£34.7 billion). Although GSK may be an extreme example, I believe the U.S. GAAP reconciliation provides important visibility to investors on the material differences in a foreign company’s financial results between IFRS and U.S. GAAP. Eliminating the reconciliation would prevent investors from adequately assessing a company’s performance and performing peer comparisons.

A paper titled “Principles-based accounting standards” was issued by  some of the world’s largest accounting firms including Deloitte, Ernst & Young, Pricewaterhouse Coopers, KPMG, Grand Thorton and BDO Seidman giving their overwhelming support for moving to single set of global accounting standards and specifically IFRS. They argued in the above paper that IFRS are more principles-based and in particular allow for “reasonable judgment”.

Many accounting experts argue that IFRS is of a lower quality and needs significant improvement. Certainly, the disclosures under IFRS are far less detailed than those required under US GAAP. Also, the moot point is does it make sense to allow companies to revalue property, plant and equipment considering that it is not for sale ? In addition, IFRS bans the use of LIFO flow of cost assumption as it relates to inventory. While the arguments for and against the various flow of cost assumptions are numerous, one has to submit that LIFO provides the users with information that is a better predictor of future results. Similarly, under IFRS 8, on Segment Reporting, a company can define a segment using its own discretion. Items such as segment revenue, segment asset, segment segment expense and current liabilities are left undefined. My question is how can differing definitions of what a segment is bring about comparable information for the users of financial statements. Or for that matter, useful information ?  Even in India, as per AS 17, if the case of a vertically integrated segment meets the quantitative norms for being a reportable segment, the relevant disclosures are to be made. However, IAS 14 of IFRS encourages, but does not require, the reporting of vertically integrated activities as separate segments.  According to the same IAS 14, a segment identified as a reportable segment in the immediately preceding period on satisfying the relevant 10 % threshold, shall be reportable segment in the current period also if the management judges it to be of continuing significance. (Note : The IASB has recently issued IFRS 8 on ‘Operating Segments’ which would supersede IAS 14 with effect from January 2009).

Besides, the IASB has not yet addressed important issues such as revenue recognition and lease accounting.  Should we presume that revenue recognition is to be left to the auditor’s “reasonable judgment” and “to the best of his knowledge and belief” ?

Just like conversion to US GAAP, gave different lists; so has conversion to IFRS.  Under European Union Law, 2007 was the first year that many foreign firms listed on U.S. exchanges were required to begin using IFRS. They have experienced varied results. For example, Diamler Chrysler’ first report using IFRS increased the automaker’s tax earnings by $ 819 Million to $ 5.2 Billion, while EPS (Earnings Per Share) increased by 68 cents. Operating Profit, or Earnings before interest and taxes, dropped by $ 38 Million to $ 7.5 Billion under IFRS. The switch also reduced the loss suffered by the company’s Chrysler division—the only unit to show a loss—from $ 1.5 Billion to $ 682 Million.  The company attributed most of the above variation to the way pension obligations are booked under the IFRS. For example, retroactive pension-plan adjustments are immediately entered into the income statement under IFRS; whereas, under US GAAP, the adjustments are distributed over the remaining service period.

Fair value accounting of IFRS

One common criticism about IFRS is that it is heavily loaded in favour of fair valuation principles and these principles are very subjective and would result in significant volatility in periodic results. IFRS is fair-value driven and this often produces unrealized gains and losses. How will income tax treat these unrealized gains and losses ? Besides, can unrealized gains be distributed as dividends within the contours of Companies Act 1956 is the debatable point.

China Construction Bank, The Bank of China and The Industrial and Commercial Bank of China have launched mega-IPOs in the last couple of years.  But after decades of rapid loan growth; they, along with other Chinese banks, state investment companies, credit co-operatives, are now sitting on record Non-Performing Loans (NPLs).  The Chinese NPL market is one of the largest in the world with, according to one estimate, a total outstanding principal balance of over a trillion dollars, which is about 40% of China’s GDP. How are these NPLs to be reflected at fair value and at what point of time their diminution in value is to be recognized ?

In India, State Bank of India (SBI), ICICI Bank, Bank of Baroda (BOB) and Bank of India (BOI) are all set to book mark-to-market losses from 5 -10%.  The exposure of these banks are $ 1 Billion, $ 1.5  Billion, $ 150 Million and $ 300 Million respectively to subprime loans.  Here also, at what point of time these subprime losses are to be recorded as having crystallized ?  Are we going to allow some time for these subprime losses to recover ?  Or do we recognize them immediately on fair value principles as soon as it appears they are going sour ?  And who’s call is this finally—that of the auditor, that of the management, or of both ?

Markets in complex pieces of paper such as CDOs (Collateralized Debt Obligations) and CDSs (Credit Default Swaps) are in disarray.  If assets can be priced realistically, trading can resume.  Yet in practice, fair value accounting, appears not to be delivering on its promise to help mitigate systemic risk.  The problem seems to be arising over illiquid assets. 

The US Financial Accounting Standards Board (FASB) has introduced a “three bucket” taxonomy to categorize marks to market.

Bucket # 1 is for assets that have observable market prices.

Bucket # 2 is for less frequently traded securities that can be priced by reference to similar assets.

Bucket # 3 is for assets with unobservable inputs where value is based on management assumptions. This where the CDS (Credit Default Swaps), CDOs (Collateralized Debt Obligations) and other exotic credit market instruments would lie.  There will always be scope for friction here because company auditors, worried about their professional liability and using conservative accounting principles, may coerce management into adopting valuations close to fire sale valuations. 

This will lead to a vicious circle.  Because, if you mark down assets excessively, the solvency of the financial system could be eroded. 

An unusual situation could arise where although on a fair value basis or mark-to-market basis, there could be loss but if the loss is expected to reverse itself over the life of the insured credit derivatives, as happened in the case of the monoliner MBIA which although threw up a pre-tax loss of $ 3.5 Billion on mark-to-market basis, expected to actually incur loss of only $ 200 Million.

If my loan accounts are marked-to-market under fair value accounting, it runs a predatory risk because by means of an hostile takeover, the predator can launch an assault on my firm.  During the Latin American debt crisis of the 1980s, the world’s biggest banks would have been insolvent if their loan books had been valued realistically.  But to stave off runs on banks by uninsured wholesale depositors in the protracted period needed to rebuild bank capital, the authorities allowed loans to remain at book value on the bank balance sheets. The ICAI (Institute of Chartered Accountants of India) should make sure that it is neither behind of the curve nor ahead of the curve.  In the days of the Latin American debt crisis, provisioning against loans was progressive, permitting capital ratios to be maintained.  This policy of regulatory forbearance would theoretically be possible today.  Illiquid assets that are now flowing into the accountants’ third bucket could be kept on bank balance sheets at book value until maturity.  But forbearance carries the risk of moral hazard. Hard look needs to be given to all these issues.  The ICAI has always been very conservative in its accounting policies and this has stood it in good stead, and should be careful in adopting fair value method of accounting across-the-board and in situations.

At the end of the day, in the interests of globalization, convergence to IFRS is essential for India to align itself with the rest of the world; however the transition will not be smooth and we as members of the Chartered Accountancy profession need to put our heads together to ensure that foreign investors in our country do not get deterred by inconsistent policies and rules and regulations, which may get even more apparent as we move into the IFRS era.

Reference :

Concept Paper entitled “Convergence with IFRSs in India” issued by  the Institute of Chartered Accountants of India

Note :    Mr Sunil Kewalramani is a WHARTON BUSINESS SCHOOL MBA and CEO, GLOBAL CAPITAL ADVISORS.

EXECUTIVE SUMMARY :

A)    THE CONVERGENCE AGREEMENT BETWEEN FASB (OF USA) AND IFSB, AND BETWEEN IAS (INDIAN ACCOUNTING STANDARDS) AND IFSB is significant and will have dramatic impact of Indian companies listing in US and American companies listing in India

B)    THERE IS NO SINGLE PATH TO CONVERGENCE, but an open-minded pursuit of the highest quality guidance should result in standards that foster superior financial reporting

C)    CONVERGENCE will require changes in US, Indian, International standards as well as those of countries who are trying to implement the convergence.

D)    INTERNATIONAL STANDARDS may change to follow accounting standards in a particular country.  For example, international accounting standards resemble U.S. standards in accounting for discontinued operations.



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Internal Auditing

by on May 7, 2009

Kara Meldrum asked:


History of Internal Auditing

Internal auditing is a very respectable profession with many responsibilites.  Internal auditing can be documented and traced as far back as to about 5000 B.C.  A few civilized communites such as the Chaldaean Empire and the Babylonian Empire were the among the first to advance economically and politically and organize themselves into sovereign states.  The two empires imposed many taxes on both individuals and businesses, and therefore they established an intricate system of checks and counterchecks.  They designed internal control systems to help minimize errors and safeguard state property from taxpayers who were dishonest (Gupta). 

In the United States, internal auditing has steadily grown and evolved ever since the end of World War II.  Internal auditing today can be compared to financial auditing because of the many similarities associated with each, and “much of the theory underlying internal auditing is derived from management consulting and public accounting professions” (Internal Audit).

 

Internal Auditing

            The profession of internal auditing helps companies by advising them on how to better achieve there short-term and long-term objectives.  Internal auditors utilizing “systematic methodology for analyzing business processes or organizational problems and recommending solutions” (Internal Audit).  Internal auditors are generally employed by companies to perform their internal auditing activities which may include internal controls such as efficacy of operactions, reliability of financial reporting, deterration and investigation of fraud, safeguarding assets, and compliance with laws and regulations (Internal Audit)

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Internal Controls

            Improving internal controls is one of the main responsibilities of internal auditors.  The management of a company is in charge of internal controls within the organization, but internal auditors test the controls to make sure they are working effectively.  Internal controls can be defined as a process that is affected by the employees of the company as well as the information technology systems that are used to assist the company in achieving its objectives.  Internal controls direct, monitor, and measure a company’s resources and help detect and prevent fraud from occuring within an organization (Internal Control).

           

Risk Management

Another responsibility of internal auditors is the monitoring and evaluation of the effectiveness of the risk management process of a company.  In addition to management’s reponsibility of internal controls, they are also responsible for performing risk management activities as part of their ordinary course of business.  How an organization sets their objectives and responds to the risks associated with their objective is part of the risk management process.  Risk management is a way for companies to manage uncertainty through risk assessment.  Developing strategies to manage risk and mitigating risk by using managerial resources is also involved in risk management.  For companies, risks can usually be categorized into four groups:  strategic risks, operational risks, financial reporting risk, and legal and regulatory risks (Risk).

 

Sarbanes Oxley Act

            The Sarbanes-Oxley Act, also known as the Public Company Accounting Reform and Investor Protection Act, was implemented on July 30, 2002 by the United States Federal Government to help prevent corporate fraud scandals.  All companies, both large and small, must comply with the rules and regulations of the Sarbanes-Oxley Act.  Some cases that prompted the passing of this act were with companies such as Enron, Tyco International, and Adelphia that involved corporate and accounting fraud (Sarbanes).  The Sarbanes-Oxley Act accelerated the growth of internal auditors profession because they possessed “the skills required to help companies meet the requirements of the law” (Internal Audit).

            The Sarbanes-Oxley Act is comprised of eleven different sections for companies to reduce and eliminate fraud.  Section 302 of the act establishes internal procedures that are designed to ensure accurate financial disclosure within organizations.  The officers of companies must sign off on documents stating that they are “responsible for establishing and maintaining internal controls” (Sarbanes).  The officers certifying this also says that the internal controls designed ensure that the material information significant to the company and its subsidiaries is known to the executive officers.  In addition, section 404 of the Sarbanes-Oxley Act requres that management submit a report on the internal controls.  The internal auditor is responsible for making sure that the company follows the guidelines established under the Sarbanes-Oxley Act (Sarbanes).

 

Example

Cases such as the Enron scandal was a reason why the Sarbanes-Oxley Act was put into effect.  In as little as fifteen years, Enron grew from a little company to the seventh largest company in the country.  At its financial peak, Enron employed more than 21,000 in staff and expanded into more than forty countries.  Eventually, the company’s scam became known to the world.  Enron had been lying about profits and was accused of many “shady” dealings including concealing debts, so they didn’t show up in the company’s accounts (Enron).  If the Sarbanes-Oxley Act was being enforced at that time, the scam would never have come to be.

 

Salary

Internal auditing can be as rewarding as one makes it, depending on education and experience.  According to swz.salary.com, the median expected starting salary for an Internal Auditor I in the United states is $46,041 as of February 2008.  One’s salary can be greatly affected by factors such as employer size, industry, employee credentials, and years of experience though (Salary). 

Other Opportunities

            Everyone knows that accounting is a great subject to be knowledgable in.  Charlie Munger, vice-chairman of the diversified investment corporation, Berkshire Hathaway Corporation, once said, “You have to know accounting.  It’s the language of practical business life” (Accounting).  Knowing accounting, especially internal auditing, can be very beneficial in the advancement of one’s career. Internal auditing encompasses many different areas of internal controls and risk management of companies.  Internal auditors evaluate the adequacy and effectiveness of companies’ internal control systems and its overall performance and report back to top management.  Internal auditors are required to solve problems within the company and are constantly perfecting their skills to make sure the company runs appropriately.  Some would consider the internal auditors to be the key to the success of a company.  Because of the broad spectrum of activities internal auditing involves, it gives one the opportunity to gain knowledge in many areas of the company, and therefore gives one enough experience to expand and advance their career.  There are not only opportunities for internal auditors, but with the type of experience and knowledge gained from internal auditing, one can expand their experience to other careers as well.  Some related careers in which internal auditing experience is extremely valuable include budget analysts, cost estimators, loan officers, financial analysts, personal financial adviors, tax examiners, and even computer programmers and such to name a few (Accountants).

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Works Cited

 

“Accountants and Auditors.” U.S. Department of Labor. 18 Dec. 2007. 24 Feb. 2008

            .

“Accounting Quotes.” Woopidoo Quotations. 24 Feb. 2008    .

“Enron Scandal At-a-Glance.” BBC News. 22 Aug. 2002. 24 Feb. 2008 .

Gupta, Parveen P. “Spiraling Upward - History of Internal Auditing and the Institute of Internal

            Auditors.” Bnet. June 1991. 24 Feb. 2008 .

“Internal Audit.” Wikipedia. 24 Feb. 2008 .

“Internal Control.” Wikipedia. 24 Feb. 2008 .

“Risk Management.” Wikipedia. 24 Feb. 2008 .

“Salary Wizard.” Salary.Com. Feb. 2008. 24 Feb. 2008 .

“Sarbanes-Oxley Act.” Wikipedia. 24 Feb. 2008 .

 



Sarbanes Oxley 404

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SAS 70 | A Guide to Type I & Type II Audits

by on April 30, 2009

Charles Denyer asked:


Welcome to today’s regulatory environment, where SAS 70 Type I & Type II audits have permeated the landscape like never before. Ever since the Sarbanes Oxley (SOX) Act of 2002, SAS 70 audits have been on the upswing, and in a big way. Sure, they were used before when the SAS 70 auditing standard was introduced in 1992, but certain provisions with the SOX act, most notably, section 404, have pushed these audits into the limelight.

If you are a service organization seeking to become SAS 70 Type I or Type II compliant, then there’s alot to learn about this highly specialized auditing standard. Once you gain a strong understanding about many of the core elements of a SAS 70 audit, you will be able to make a wise, informed decision on moving forward with the audit and with the right provider for conducting the audit.

Important Points about SAS 70 audits

Scope

You will need to find out early on what the scope of the SAS 70 audit is going to be. That is, will the audit be a straightforward general controls report, or will it include certain business processes as part of the engagement. This is important because it dictates SAS 70 pricing and it also brings into play what really needs to be covered in the audit.

Pricing

Be sure to get a fee that is fixed. Thus, all audit costs, including travel and out of pocket expenses are part of the engagement. This is imperative because out of pocket, travel and other miscellaneous expenses can be very, very costly to the audit.

SAS 70 Readiness Questionnaire & Assessments

If this is the first time your organization is undertaking a SAS 70 Type I or Type II audit, then its imperative that you start on the right track-SAS 70 readiness questionnaire assessments are what you need. They help lay the groundwork for a successful SAS 70 audit while also proving invaluable for learning about any shortcomings or deficiencies in your internal controls.

You can learn more about SAS 70 audits through publications from the AICPA. Additionally, you can visit the official SAS 70 Resource Guide.



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