Chapter 7 Controlling Information Systems: Introduction to Enterprise Risk Management and Internal Control : 1 Chapter 7 Controlling Information Systems: Introduction to Enterprise Risk Management and Internal Control Accounting Information Systems 7e
Ulric J. Gelinas and Richard Dull Copyright © 2008 Thomson Southwestern, a part of The Thomson Corporation. Thomson, the Star logo, and South-Western are trademarks used herein under license.
Learning Objectives : 2 Learning Objectives Summarize the eight elements of COSO’s Enterprise Risk Management—Integrated Framework.
Understand that management employs internal control systems as part of organizational and IT governance initiatives.
Describe how internal control systems assist organizations to achieve objectives and respond to risks.
Describe fraud, computer fraud, and computer abuse.
Enumerate control goals for operations and information processes.
Describe the major categories of control plans.
Organizational Governance : 3 Organizational Governance Select Objectives
Establish processes to achieve objectives
Monitor performance toward objectives
Objective Setting : 4 Objective Setting Mission, vision, purpose: e.g., to be the leading producer of household products in the regions in which we operate Strategic
objectives
e.g., to be in the
top quartile of
product sales for retailers of our products Strategy
e.g., expand production
of our top-five selling retail
products to meet increased
demand Related objectives, e.g.,
increase production of x by 15%
hire 180 qualified new staff
maintain product quality Source: Adapted from Enterprise Risk Management—Integrated Framework, Application Techniques, p. 20.
Why do we need controls? : 5 Why do we need controls? (1) to provide reasonable assurance that the goals of each business process are being achieved
(2) to mitigate the risk that the enterprise will be exposed to some type of harm, danger, or loss (including loss caused by fraud or other intentional and unintentional acts)
(3) to provide reasonable assurance that the company is in compliance with applicable legal and regulatory obligations.
Components of Enterprise Risk Management : 6 Components of Enterprise Risk Management Internal Environment – The internal environment encompasses the tone of an organization, and sets the basis for how risk is viewed and addressed by an entity’s people, including risk management philosophy and risk appetite, integrity and ethical values, and the environment in which they operate.
Objective Setting – Objectives must exist before management can identify potential events affecting their achievement. Enterprise risk management ensures that management has in place a process to set objectives and that the chosen objectives support and align with the entity’s mission and are consistent with its risk appetite.
Event Identification – Internal and external events affecting achievement of an entity’s objectives must be identified, distinguishing between risks and opportunities. Opportunities are channeled back to management’s strategy or objective-setting processes.
Risk Assessment – Risks are analyzed, considering likelihood and impact, as a basis for determining how they should be managed. Risks are assessed on an inherent and a residual basis.
Risk vs. Exposure : 7 Risk vs. Exposure Estimate the annual dollar loss that would occur (i.e., the impact) should a costly event, say a destructive fire, take place. For argument sake, say that the estimated loss is –$1,000,000.
Estimate the annual probability that the event will occur (i.e., the likelihood). Suppose the estimate is 5 percent.
Multiply item 1 by item 2 to get an initial expected gross risk (loss) of –$50,000 (–$1,000,000 × 0.05), which is the maximum amount or upper limit that should be paid for controls and the related risk reduction offered by such controls, in a given year. Next, we illustrate a recommendation plan using one corrective control, a fire insurance policy, and one preventive control, a sprinkler system.
Assume that the company would pay $1,000 annually (cost of control) for a $20,000 fire insurance policy (reduced risk exposure due to control). The estimated monetary damage remains at $1 million and expected gross risk (loss) remains at –$50,000, because there is still a 5 percent chance that a fire could occur. But, the company’s residual expected risk exposure is now –$31,000 [–$50,000 + ($20,000 – $1,000)]. Our expected loss is reduced by the amount of the insurance policy (less the cost of the policy).
Risk vs. Exposure (Cont.) : 8 Risk vs. Exposure (Cont.) Next, you recommend that the company install a sprinkler system with a 5-year annualized cost (net present value) of $10,000 each year to install and maintain (cost of control). At this point you might be tempted to say that the company’s residual expected risk just increased to –$41,000 (–$31,000 – $10,000), but wait! The sprinkler system lowered the likelihood of a damaging fire from 5 to 2 percent. In conjunction with this lower probability, the insurance company agreed to increase its coverage to $30,000 while holding the annual premium constant at $1,000.
Thus, the residual expected risk exposure is –$1,000, calculated as follows: Expected gross risk (–$20,000 or –$1,000,000 × 0.02) plus the insurance policy ($30,000) equals a gain of $10,000, but we must subtract the insurance premium ($1,000) and the sprinkler system ($10,000), leaving the residual expected risk at –$1,000.
Components of Enterprise Risk Management (Continued) : 9 Components of Enterprise Risk Management (Continued) Risk Response – Management selects risk responses – avoiding, accepting, reducing, or sharing risk – developing a set of actions to align risks with the entity’s risk tolerances and risk appetite.
Control Activities – Policies and procedures are established and implemented to help ensure the risk responses are effectively carried out.
Information and Communication – Relevant information is identified, captured, and communicated in a form and timeframe that enable people to carry out their responsibilities. Effective communication also occurs in a broader sense, flowing down, across, and up the entity.
Monitoring – The entirety of enterprise risk management is monitored and modifications made as necessary. Monitoring is accomplished through ongoing management activities, separate evaluations, or both.
Recent Internal Control Legislation : 10 Recent Internal Control Legislation Sarbanes-Oxley Act (SOA) of 2002
Created public company accounting oversight board
Increased accountability for company officers and board of directors
Increased white collar crime penalties
Prohibits audit firms from providing design and implementation of financial information systems
Sarbanes-Oxley Act of 2002 (SOA) : 11 Sarbanes-Oxley Act of 2002 (SOA) Section 302—CEOs and CFOs must certify quarterly and annual financial statements
Section 404—Mandates the annual report filed with the SEC include an internal control report
Outline of SOA 2002 : 12 Outline of SOA 2002
Definition of Internal Control : 13 Definition of Internal Control From SAS 78 (1995) - adopted COSO definition:
INTERNAL CONTROL is a process-effected by a an entity’s board of directors, management, and other personnel-designed to provide reasonable assurance regarding the achievement of objectives in the following categories:
Effectiveness & efficiency of operations
Reliability of financial reporting
Compliance with applicable laws & regulations.
Slide 14: 14 General Control Model
Five Interrelated Components of Internal Control : 15 Five Interrelated Components of Internal Control 1. Control environment- tone at the top
2. Risk assessment - identification/analysis of risks
3. Control activities - policies and procedures
4. Information & communication - processing of info in a form and time frame to enable people to do their jobs
5. Monitoring - process that assess quality of internal control over time
COSO Report, SOA, and SAS 94 : 16 COSO Report, SOA, and SAS 94 In the section addressing implementation of the Sarbanes Oxley Act section 404, the SEC used the COSO description of internal control.
It went on to say that management must base its evaluation of the effectiveness of its internal control system on a framework such as COSO
COSO report stresses internal control is a process
A complementary perspective on internal control is found in Statement on Auditing Standards (SAS) 94, entitled “The Effect on Information Technology on the Auditor’s Consideration of Internal Control in a Financial Statement Audit.”
This standard guides auditors in understanding the impact of IT on internal control and assessing IT-related control risks
Further, SAS 94 highlights how IT can be used to strengthen internal control, while at the same time emphasizing how IT can actually weaken some controls
Fraud and its Relationship to Control : 17 Fraud and its Relationship to Control Fraud: deliberate act or untruth intended to obtain unfair or unlawful gain.
Management charged with responsibility to prevent and/or disclose fraud
Control systems enable management to do this job
Management responsible to provide internal control system per the Foreign Corrupt Practices Act of 1977
Section 1102 of the Sarbanes-Oxley Act specifically addresses corporate fraud
Instances of fraud undermine management’s ability to convince various authorities that it is upholding its stewardship responsibility
SAS 99 : 18 SAS 99 The accounting profession too has been proactive in dealing with corporate fraud, as it has launched an anti-fraud program.
One of the manifestations of this initiative is Statement on Auditing Standards (SAS) Number 99, entitled Consideration of Fraud in a Financial Statement Audit.
SAS 99 has the same title as its predecessor, SAS 82, but the new standard is much more encompassing than the old.
For instance, SAS 99 emphasizes brainstorming fraud risks, increasing professional skepticism, using unpredictable audit test patterns, and detecting management override of internal controls.
E&Y Fraud Survey : 19 E&Y Fraud Survey About 85 % of fraud committed by company insiders
About 55% of perpetrators were management employees
More fraud in less-developed countries
About 40% of frauds are known to the public, 20% are kept confidential, and the other 40% are not yet discovered
The #1 fraud worry to executives is asset misappropriation
The #2 fraud worry to executives is computer crime
Most organizations now have formal fraud prevention policies including codes of corporate governance and employee conduct
Most useful fraud prevention techniques are internal controls, management reviews, and internal audits
2006 Report on Fraud by Assoc. of CFE : 20 2006 Report on Fraud by Assoc. of CFE Median loss $159,000
One quarter at least $1 million
Typical organization loses 5% of revenue to fraud
Detected more likely by tips than internal controls
Frauds by employees:
30% by accounting department employees
20% by upper management
Preview of some Computer Crime : 21 Preview of some Computer Crime Salami slicing - rounding
Back door – non-secured access point
Trojan horse – code in harmless looking program
Logic bomb – go off on event occurrence
Worm – network invasion
Zombie – takes over another computer
Ethics and Controls : 22 Ethics and Controls COSO report stresses ethics as part of control environment (tone at the top)
AICPA has built ethics issues into CPA exam
The Institute of Management Accountants has a code of ethics which is also tested on both the CMA and CFM exams
Internal Auditing has ethics articles
Many corporations have developed Codes of Conduct
Business Process Control Plans : 23 Business Process Control Plans Business Process Control Plans - reflect information processing policies and procedures that assist in accomplishing control goals
The Control Environment The fact that the control environment appears at the top of the hierarchy illustrates that the control environment comprises a multitude of factors that can either reinforce or mitigate the effectiveness of the pervasive and application control plans.
Pervasive control plans also relate to a multitude of goals and processes
Like the control environment, they provide a climate or set of surrounding conditions in which the various business processes operate.
They are broad in scope and apply equally to all business processes, hence they pervade all systems.
Business process control plans relate to those controls particular to a specific process or subsystem, such as billing or cash receipts, or to a particular technology used to process the data.
Slide 24: 24
Business Process Control Goals : 25 Business Process Control Goals Control Goals - ends to be obtained
Control goals of operations processes
Control goals of information processes
Control Goals of the Operations Process : 26 Control Goals of the Operations Process Ensure effectiveness of operations
Ensure efficient employment of resources
Ensure security of resources
Control Goals of Operations Process : 27 Control Goals of Operations Process Ensure effectiveness of operations (including compliance)
A measure of success in meeting one or more operations process goals which reflect the criteria used to judge the effectiveness of various business processes
Ex. Deposit cash receipts on the day received
Ensure efficient employment of resources
A measure of the productivity of the resources applied to achieve a set of goals
Ex. What is the cost of people, computers, and other resources to deposit cash on the day received
Ensure security of resources
Protecting an organization’s resources from loss, destruction, disclosure, copying, sale, or other misuse
Ex. Are cash and information resources available when required?
Are they put to authorized use?
Control Goals of the Information Process : 28 Control Goals of the Information Process For business event inputs, ensure
Input validity
Input completeness
Input accuracy
For master data, ensure
update completeness
update accuracy
Control Goals of Information Process : 29 Control Goals of Information Process Input validity
Input data approved and represent actual economic events and objects
Ex. Are all cash receipts input into the process supported by customer payments
Input completeness
Requires that all valid events or objects be captured and entered into the system
Ex. Are all valid customer payments captured on a customer remittance advice (RA) and entered into the process?
Input Accuracy
Requires that events be correctly captured and entered into the system
Ex. Is correct payment amount and customer number on the RA?
Ex. Is the correct payment amount and customer number keyed into the system?
Control Goals of Information Process : 30 Control Goals of Information Process Update completeness
Requires all events entered into the computer are reflected in their respective master data
Ex. Are all input cash receipts recorded in the AR master data?
Update accuracy
Requires that data entered into a computer are reflected correctly in their respective master data
Ex. Are all input cash receipts correctly recorded in the AR master data?
Lenox Company Systems Flowchart : 31 Lenox Company Systems Flowchart
Control Goals for the Lenox Cash Receipts Process : 32 Control Goals for the Lenox Cash Receipts Process
Other Classifications of Control Plans : 33 Other Classifications of Control Plans Preventive Controls: Issue is prevented from occurring – cash receipts are immediately deposited to avoid loss
Detective Controls: Issue is discovered – unauthorized disbursement is discovered during reconciliation
Corrective Controls: issue is corrected – erroneous data is entered in the system and reported on an error and summary report; a clerk re-enters the data
Gelinas and Dull Working Definition of IC: Key Points : 34 Gelinas and Dull Working Definition of IC: Key Points A system of internal control is not an end in itself. Rather, it is a means to an end—the end of attaining process objectives
Internal control itself is a system. Therefore, like any system it must
(1) have clearly defined goals and
(2) consist of interrelated components that act in concert to achieve those goals.
We can also say that internal control is a process
Establishing a viable internal control system is management’s responsibility.
The strength of any internal control system is largely a function of the people who operate it.
Internal control cannot be expected to provide absolute, 100% assurance that the organization will reach its objectives. Rather, the operative phrase is that it should provide reasonable assurance
Internal control is not free; controls should be built in and cost effective
Gelinas and Dull Working Definition of IC : 35 Gelinas and Dull Working Definition of IC INTERNAL CONTROL is a process-effected by a an entity’s board of directors, management, and other personnel-designed to provide reasonable assurance regarding the achievement of objectives in the following categories:
Effectiveness & efficiency of operations
Reliability of reporting
Compliance with applicable laws & regulations.
Chapter Important Points : 36 Chapter Important Points Need for controls
ERM components
COSO components
Definition of controls
Need to avoid fraud
Pervasive versus process controls
Process control goals (operations and information)
Preventive, detective, and corrective controls