Category Archives for "Accounting and Auditing"

enterprise risk management
Dec 05

Enterprise Risk Management: Empowering Your Clients

By Harry Hall | Accounting and Auditing

Today’s article comes from my twin brother, Harry Hall. He is a certified PMP®, PMI-RMP®, and has his Associate in Risk Management (ARM-E).

Many organizations do not have an enterprise risk management (ERM) program. Therefore, these entities lack the policies and procedures to manage enterprise risks (i.e., threats and opportunities) and achieve their objectives. In this article, we’ll look at how CPAs can suggest an ERM program to their clients.

Enterprise Risk Management

Imagine that you’ve completed an audit of an organization. One way you can help your client is to provide a management letter that provides ideas to make the organization better. And one of the suggestions you can make is for them to implement an ERM program, or you can provide ways to improve the existing program. (Of course, as the auditor, you can’t make management decisions, but you can make suggestions.)

Think about it. Has one of your clients encountered a surprise event or condition in the last few years? Imagine if the client had identified and managed the risk better. That single failure may have caused your client to miss their annual objectives, resulting in weaker financial and operating positions. It’s even possible they no longer exist.

A sound ERM program can improve–and even save–your client.

What is ERM?

First, let’s define ERM. It is a program whereby an organization identifies and manages all of its risks in order to achieve its objectives. 

How does ERM differ from traditional risk management? Well, traditional risk management focuses on pure risks. These are risks where there is the possibility of loss or no loss, but no chance of gain. Hazard or insurable risks are pure risks. 

ERM includes pure risks, but also includes speculative risks. Speculative risks are risks where there is a chance of loss, no loss, or gain. So, speculative risks have the potential for gain. Examples of speculative risks include financial risks, strategic risks, and some operational risks.

So, let’s see how ERM helps businesses.

Four Benefits of ERM

There are several ways that an organization may benefit from ERM. The benefits include, but are not limited to, the following:

First, an ERM Champion can help their organization implement strategic risk management, a component of ERM. Here, we can clarify enterprise objectives and improve strategic planning, analysis, and alignment.

Second, ERM helps organizations identify risks between departments. Many departments live in siloes. And most people think solely about their department’s risk. But the actions taken by one department may impact other parts of the organization.

Third, ERM can boost collaboration. As risk owners from different departments focus on enterprise objectives together, these individuals begin to better understand other departmental processes. And these can be analyzed and improved to realize greater enterprise benefits.

Fourth, organizations with ERM programs are in a better position to meet the demands from external parties such as investors, rating agencies, and regulators.

To make this work, your client needs to leverage an ERM framework.

ERM Framework

ERM programs include risk management processes that are used throughout the enterprise. Some organizations use a framework like COSO or the ISO 31000. Others develop their own framework. In general, here are the ERM processes, regardless of the framework.

  1. Plan risk management. Define an ERM policy that guides the behavior of individuals in the organization. The ERM policy includes elements such as the risk governance structure, risk categories, ERM methodology, roles and responsibilities, risk appetite, risk tolerance, risk limits, ERM activities, ERM reports, and a glossary. This policy should be reviewed and updated each year. And the Board should approve the revisions.
  2. Identify risks. Determine the risk identification tools and techniques that will be used. For example, these could include brainstorming, interviews, checklists, and cause-and-effect diagrams.
  3. Evaluate risks. Once risks are identified, ERM stakeholders should assess the risks. Risk owners may perform qualitative and quantitative risk assessments. The risk assessments result in a prioritized risk list. The benefit: you know which risks matter most.
  4. Respond to risks. Next, risk owners develop and implement risk response plans to lessen these risks.
  5. Monitor risks. Of course, risks change over time. Threats and opportunities may (and probably will) increase or decrease. Therefore, client’s must monitor risks. Are the risks managed according to the risk appetite and risk tolerance? Are the ERM processes providing value? Are the processes economical and efficient?

As a CPA, have you ever wondered how ERM and Internal Audit differ?

ERM vs. Internal Audit

Organizations may have an ERM department or group led by an ERM Champion or Chief Risk Officer (CRO). This group facilitates the development of an ERM policy, trains employees on ERM processes, and facilitates periodic risk reviews. 

Internal Audit ensures that the risk controls are working as designed within the organization and makes recommendations for improvement where there are internal control deficiencies. (Traditionally, internal auditors have focused on accounting processes. Their role is expanding into other areas such as ERM.)

So, how does ERM and Internal Audit work together? First, the ERM Champion engages Internal Audit when developing the ERM policy. Second, Internal Audit uses the ERM risk register as input into the annual audit plan. Think about it – wouldn’t it be great to see the most significant enterprise threats and opportunities as Internal Audit develops the audit plan? Third, Internal Audit inspects the ERM processes, in addition to other organizational processes, to ensure they are efficient and economical.

Audit Management Letter Suggestion: ERM Program

In your next audit, think about the risk management practices in the organization.  

Does your client have a written ERM policy? Are the risk processes being performed consistently throughout the enterprise? How are risks being identified and assessed? Does the enterprise risk register include financial risks, strategic risks, operational risks, and other risks? Has the risk appetite and risk tolerance been defined and communicated to the Board, management, and risk owners?

At the conclusion of your audit, consider including ERM recommendations in your management letter. Doing so might save your client a great deal of pain–and you’ll add value to your audit.

Harry Hall

Guest Author

Harry Hall, the Project Risk Coach, is a speaker, teacher, author, and blogger. He has implemented project management offices (PMOs) and enterprise risk management (ERM) programs in the financial, healthcare, and agricultural industries. Harry is a graduate of the University of Georgia and is a certified PMP®, PMI-RMP®, and has his Associate in Risk Management (ARM-E).

Excuses for unnecessary workpapers
Nov 29

Seven Excuses for Unnecessary Audit Work Papers

By Charles Hall | Auditing

Unnecessary audit work papers create clutter and potential legal problems.

I see two problems in most work paper files:

(1) Too much documentation, and
(2) Too little documentation

I have written an article titled: Audit Documentation: If It’s Not Documented, It’s Not Done. Since I’ve already addressed the too little documentation issue, I’ll now speak to the other problem: too much documentation.

unnecessary audit work papers

Unnecessary Audit Work Papers

Over the last thirty-five years, I have reviewed audit files for CPA firms and have commonly asked this question: Why is this work paper in the file?

Here are a seven answers I’ve received.

1. It was there last year.

But is it relevant this year? Resist the temptation to mindlessly bring forward work papers from the prior year. Performing a proper audit entails risk assessment (e.g., walkthroughs, analytics), planning (i.e., creating an audit plan), and execution (i.e., carrying out the audit plan). Likewise, compilations and reviews should reflect current year planning and performance.

2. The client gave it to me.

Inexperienced auditors tend to put everything given to them in the file. Some auditors believe “if the client gave it to me, it must be important.” But this is not necessarily true. Every work paper needs a purpose.

3. I may need it next year.

Then save it for next year—somewhere other than in the current file. If the information does not provide current year engagement evidence, then it does not belong in the file.

Consider creating a file for next year and placing next year’s information in that file. Or create a folder in the current year file titled: Next year’s work papers. Then move this section to next year’s file as you close the engagement.

4. I might need it this year.

Before going paperless (back in the prehistoric days when we moved work papers with hand trucks ), I kept a manila folder titled: File 13. The physical folder was my hang-on-to-it-in-case-I-need-it repository.

Since my files are now paperless, I create an electronic folder titled Recycle Bin that sits at the bottom of my file. If I receive information that is not relevant to the current year (but there is a chance I will need it), I move it to the recycle bin, and when I am wrapping up the engagement, I dispose of the folder.

5. It’s an earlier version of a work paper.

Move earlier versions of work papers to your recycle bin—or delete them.

6. I need it for my tax work.

Then it belongs in the tax file (unless it’s related to your attest work – e.g., deferred taxes).

7. We always do this.

But why is it being done this year? Maybe a fraud was missed ten years ago and the partner said, from now on we will…

Are these procedures still relevant?

The test of details, substantive analytics, and test of controls should be in response to the current year audit risk assessment and planning.

Reducing Legal Exposure

The most important reason for minimizing work paper content is to reduce your legal exposure. Excess work papers may provide ammunition to an opposing attorney: “Mr. Hall, here’s a work paper from your own audit file that reveals fraud was occurring, and you didn’t see it?” (So don’t, for example, leave the full general ledger in your work papers.)

What are your thoughts about removing unnecessary audit work papers?

Segregation of Duties
Nov 20

Segregation of Duties: How to Overcome

By Charles Hall | Auditing , Fraud

Segregation of duties is key to reducing fraud. But smaller entities may not be able to do so. Today, I tell you how overcome this problem, regardless of the entity’s size.

Segregation of Duties

The Environment of Fraud

Darkness is the environment of wrongdoing.

Why?

No one will see us. Or so we think.

Fraud occurs in darkness.

In J.R.R. Tolkien’s Hobbit stories, Sméagol, a young man murders another to possess a golden ring, beautiful in appearance but destructive in nature. The possession of the ring and Sméagol’s hiding of self and his precious (the ring) transforms him into a hideous creature–Gollum. I know of no better or graphic portrayal of how that which is alluring in the beginning, is destructive in the end.

Fraud opportunities have those same properties: they are alluring and harmful. And, yes, darkness is the environment where fraud happens.

What’s the solution? Transparency. It protects businesses, governments, and nonprofits.

But while we desire open and understandable processes, our businesses often have just a few employees that perform the accounting duties. And, many times, no one else understands how the system works.

It is desirable to divide accounting duties among various employees, so no one person controls the whole process. This division of responsibility creates transparency. How? By providing multiple eyes to see what’s going on.

But this segregation of duties is not always possible.

Lacking Segregation of Duties

Some people says here are three key duties that must always be separated under a good system of internal controls: (1) custody of assets, (2) record keeping or bookkeeping, and (3) authorization. I add a fourth: reconciliation. But many organizations are unable to separate these duties, usually due to a limited number of employees.

Some small organizations believe they can’t overcome this problem. But is this true? I don’t think so.

Here’s two easy steps to create greater transparency and safety when the separation of accounting duties is not possible.

1. Bank Account Transparency

First, consider this simple control: Provide all bank statements to someone other than the bookkeeper. Allow this second person to receive the bank statements before the bookkeeper. While no silver bullet, it has power.

Persons who might receive the bank statements first (before the bookkeeper) include the following:

  • A nonprofit board member
  • The mayor of a small city
  • The owner of a small business
  • The library director
  • A church leader

What is the receiver of the bank statements to do? Merely open the bank statements and review the contents for appropriateness (mainly cleared checks).

In many small entities, accounting processes are a mystery to board members or owners. Why? Only one person (the bookkeeper) understands the disbursement process, the recording of journal entries, billing and collections, and payroll.

Relying on a trusted bookkeeper is not a good thing. So how can you shine the light?

Allow a second person to see the bank statements.

Fraud decreases when the bookkeeper knows someone is watching. Suppose the bookkeeper desires to write a check to himself but realizes that a board member will see the cleared check. Is this a deterrent? You bet.

Don’t want to send the bank statements to a second person? Request that the bank provide read-only online access to the second person. And let the bookkeeper know.

Even the appearance of transparency creates (at least some) safety. Suppose the second person reviewer opens the bank statements (before providing them to the bookkeeper) and does nothing else. The perception of a review enhances safety. I am not recommending that the review not be performed. But if the bookkeeper even thinks someone is watching, fraud will lessen.

When you audit cash, see if these types of controls are in place.

Now, let’s look at the second step to overcome a lack of segregation of duties. Surprise audits.

2. Surprise Audits

Another way to create small-entity transparency is to perform surprise audits. These reviews are not opinion audits (such as those issued by CPAs). They involve random inspections of various areas such as viewing all checks clearing the May bank statement. Such a review can be contracted out to a CPA. Or they can be performed by someone in the company. For example, a board member.

Additionally, adopt a written policy stating that the surprise inspections will occur once or twice a year.

The policy could be as simple as:

Twice a year a board member (or designee other than the bookkeeper) will inspect the accounting system and related documents. The scope and details of the inspection will be at the judgment of the board member (or designee). An inspection report will be provided to the board.

Why word the policy this way? You want to make the system general enough that the bookkeeper has no idea what will be examined but distinct enough that a regular review occurs. 

Surprise Audit Ideas

Here are some surprise audit ideas:

  • Inspect all cleared checks that clear a particular month for appropriate payees and signatures and endorsements
  • Agree all receipts to the deposit slip for three different time periods
  • Review all journal entries made in a two week period and request an explanation for each
  • Inspect two bank reconciliations for appropriateness
  • Review one monthly budget to actual report (look for unusual variances)
  • Request a report of all new vendors added in the last six months and review for appropriateness

The reviewer may not perform all of the procedures and can perform just one. What is done is not as important as the fact that something is done. In other words, the primary purpose of the surprise audit is to make the bookkeeper think twice about whether he or she can steal and not get caught.

I will say it again. Having multiple people involved reduces the threat of fraud.

Segregation of Duties Summary

In summary, the beauty of these two procedures (bank account transparency and surprise audits) is they are straightforward and cheap to implement. Even so, they are powerful. So shine the light.

What other procedures do you recommend?

For more information about preventing fraud, check out my book: The Little Book of Local Government Fraud Prevention.

management override of internal controls
Nov 11

Management Override of Internal Controls

By Charles Hall | Auditing , Fraud , Risk Assessment

Management can override internal controls, resulting in fraudulent financial reporting. Below I provide four ways that management can do so and how you can audit for these potential threats. 

Controls can be overridden, even when properly designed and operating. Accounting personnel usually comply with the wishes of management either out of loyalty or fear. So if a trusted C.E.O. asks the accounting staff to perform questionable actions, they will sometimes comply because they trust the leader. Alternatively, management can threaten accounting personnel with the loss of their jobs if they don’t comply. Either way, management gets what it wants by overriding internal controls. 

Management Override of Internal Controls

Here are a few ways that management can override controls:

  1. Booking journal entries to inflate profits or cover up theft
  2. Using significant transactions outside the normal course of business to dress up the financial statements
  3. Manipulating estimates 
  4. Transferring company cash to their personal accounts 

Auditors consider management override in all audits (or at least, they should). Why? Because it’s always possible. That's why audit standards require that we respond to the risk of management override in all audits. 

First, let’s consider how management overrides controls with journal entries.

1. Journal Entry Fraud

Think about the WorldCom fraud. Expenses were capitalized to inflate profits. Income statement amounts were moved to the balance sheet with questionable entries. Once the fraud was discovered, the internal auditors were told the billion-dollar entries were based on what management wanted. The entries were not in accordance with generally accepted accounting principles. And why was this done? To increase stock prices. Management owned shares of WorldCom, so they profited from the climbing stock values. The fraud led to prison sentences and the demise of the company, all because of management override. 

Journal entries are an easy way to override controls. Consider this scenario: Management meets at year-end, and they have not met their goals; so they manipulate earnings by recording nonexistent receivables and revenues, or they record revenues before they are earned. For example, management accrues $10 million in fake revenue, or they book January revenues in December. 

Journal Entry Testing

Auditors should test journal entries for potential fraud, but how? First, understand the normal process for making journal entries: who makes them, when are they made, and how. Also, inquire about journal entry controls and consider any fraud incentives, such as bonuses related to profits. Then think about where fraudulent entries might be made and test those areas. Fraudulent journal entries are often made at year-end, so make sure you test those. Here are some additional journal entry test ideas:

  • Examine entries made to seldom-used accounts
  • Review consolidating entries (also known as top-side entries)
  • Test entries made at unusual hours (e.g., during the night) 
  • Vet entries made by persons that don’t normally make journal entries
  • Look at suspense account entries
  • Review round-dollar entries (e.g., $100,000)
  • Test entries made to unusual accounts

You don’t need to perform all of the above tests, just the ones that are higher risk in light of journal entry controls and fraud incentives. Data mining software can be helpful in vetting journal entries. For example, you can search for journal entries made by unauthorized persons. Just extract all journal entries from the general ledger and group them by persons making the entries; thereafter, scan the list for unauthorized persons. 

Fraudulent journal entries are not the only way to override controls. The books can be cooked with related party transactions. 

2. Funny Business

Sometimes, as an auditor, you’ll see funny transactions. No, I don’t mean they are amusing. I mean they are unusual. Management can alter profits with transactions outside the normal course of business, and these are often related party transactions. 

For example, Burning Fire, an audit client, is owned by Don Jackson. Mr. Jackson also owns another business, Placid Lake. As you are auditing Burning Fire, you see it received a check for $10 million dollars from Placid Lake. So you ask for transaction support, but there is little. The CFO says the payment was made for “prior services rendered,” but it doesn’t ring true. This could be fraud and is an example of a transaction outside the normal course of business. Why would a company record such an entry? Possibly to bolster Burning Fire’s financial statements. When you see such a transaction, consider whether a fraud incentive is present. For example, do loan covenants require certain financial ratios and does this transaction bring them into compliance? 

Next, we look at how management can juice up profits by manipulating estimates. 

management override of internal controls

3. Manipulating Estimates

Auditing standards require a retrospective review of estimates as a risk assessment procedure. Why? Because management can manipulate estimates to inflate earnings and assets. Auditing standards call such tendencies bias, a sign that fraudulent financial reporting might exist. That’s why auditors review prior estimates and related results. 

For instance, suppose a company has a policy of reserving 90% of receivables that are ninety days or older. If at year-end the greater-than-ninety-days bucket contains $1,000,000, management can increase earnings $400,000 by lowering the reserve to 50%. What an easy way to increase net income! 

Retrospective Review of Estimates

So, how does an auditor perform a retrospective review of an allowance for uncollectible accounts? Compare the year-end reserve with that of the last two or three years. If the reserve decreases, ask why. There might be legitimate reasons for the decline. But if there is no reasonable basis for the smaller allowance, bias could be present. Note such changes in your risk assessment summary. For example, in the accounts receivable section, you might say: The allowance for uncollectible accounts appears to have decreased without a reasonable basis. Why? Because you’ve identified a fraud risk that deserves attention. 

Complex estimates are easier to manipulate without detection than simple ones. Why? Because intricate estimates are harder to understand, and complexity creates a smokescreen, making bias more difficult to spot. As an example, consider pension plan assumptions and estimates. Very complex. And changes in the assumptions can dramatically affect the balance sheet and net income. 

Now, let's look at how to document your retrospective review. 

Documenting Your Retrospective Review

Document your retrospective review. How? List the current and prior year estimates and explain the basis for each. Also, examine the results of the prior year estimates. For example, compare the current year bad debts with the prior year uncollectible allowance. Additionally, consider including incentives for manipulating profits such as bonuses. 

Label the workpaper Retrospective Review of Estimates to communicate its purpose. Also, consider adding purpose and conclusion statements such as:

  • Purpose of workpaper: To perform a retrospective review of estimates to see if bias is present.
  • Conclusion: While the allowance estimate is higher in the current year, the judgments and assumptions are the same. It does not appear that bias is present. All other prior year estimates appear reasonable. 

Other conclusion examples follow:

  • Conclusion: The rate of return used in computing the pension liability increased by 1%. The increase does not appear to be warranted given the mix of investments and past history. Bias appears to be present and is noted in the risk assessment summary form (in the payroll and benefits section).
  • Conclusion: Based on our review of the economic lives of assets in the prior year depreciation schedule, no bias is noted.
  • Conclusion: We reviewed bad debt write-offs in the current year and compared them to the uncollectible allowance in the prior year. No management bias is noted.

Is there another way that management might override controls? Yes, sometimes management requires accounting personnel to transfer company cash to personal bank accounts. 

4. Transferring Company Cash to Personal Accounts

Years ago I audited a hospital in Alabama. The C.E.O. would sometimes go to Panama City Beach, and while there, direct his accounting staff to wire funds to his personal account—and they did. Why? The threat of losing their jobs. Some management personnel, especially those with muscle, can intimidate the accounting employees into doing the unbelievable. I’ve seen this happen and once the C.E.O. is called out, he pretends to know nothing about the prior conversations with accounting.  

Management Override of Internal Controls

In your future audits, consider that management override of internal controls is always a possibility.

So don't allow yourself to believe that management is too honest to commit fraud. (A personal friend of mine just went to jail for stealing $3.5 million; he was part of the company's management team. I've known him for twenty years, so I was stunned to hear this.) Conduct your audits to detect material misstatements, including fraud--even if you've known the management team for many years. 

>