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EXHIBIT 22 Control Systems Evaluation
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Extent of documentation
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Awareness of system/communication
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Monitoring
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Design effectiveness
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Operating effectiveness
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CHAPTER
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Control Environment
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he control environment is the control consciousness of an organization; it is the atmosphere in which people conduct their activities and carry out their control responsibilities An effective control environment is an environment in which competent people understand their responsibilities, know the limits to their authority, and are knowledgeable, mindful, and committed to doing what is right and doing it the right way; in short, they are committed to following an organization s policies and procedures and its ethical and behavioral standards The control environment encompasses both technical competence and ethical commitment; it is an intangible factor that is essential to effective internal control It is necessary to evaluate the entire organizational environment to determine if broad-based controls are working and are being followed For example, management may evaluate the design of a code of conduct by considering whether the code is comprehensive and detailed enough to guide ethical decisions It may verify that the code of conduct is sent to all personnel and that all personnel sign off on the policy This is one way to ascertain that the code is actually contributing to compliance, and this investigation allows management to evaluate the operating effectiveness of this control Another example is to consider if job descriptions are adequately designed, so that they include all relevant tasks of a position in sufficient detail Determining whether employees are aware of the job descriptions, participate in updating them, and adhere to them may provide evidence of the operating effectiveness of job descriptions
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RISK ASSESSMENT
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Risk assessment is the identification and analysis of risks associated with the achievement of operations, financial reporting, and compli49
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ance goals and objectives This, in turn, forms a basis for determining how risks should be managed Risk assessment is one of management s responsibilities and enables management to act proactively in reducing unwanted surprises Failure to consciously manage risk can result in a lack of confidence that operational, financial, and compliance goals will be achieved A risk is anything that could jeopardize the achievement of an objective Asking the following questions helps to identify risks:
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What could go wrong How could we fail What must go right for us to succeed Where are we vulnerable What assets do we need to protect Do we have liquid assets or assets with alternative uses How could someone steal from the department How could someone disrupt our operations How do we know whether we are achieving our objectives On what information do we most rely On what do we spend the most money How do we bill and collect our revenue What decisions require the most judgment What activities are most complex What activities are regulated What is our greatest legal exposure
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It is important that risk identification be comprehensive, both at the department level and at the activity or process level, for operations, financial reporting, and compliance objectives An assessment should consider both external and internal risk factors Usually, several risks can be identified for each objective Management may consider if its risk assessment includes the effects of intense competitive pressures on revenue recognition practices In evaluating the design of the risk assessment process, management may consider: the thoroughness of procedures to identify business units experiencing competitive pressures, and the likelihood of inappropriate revenue recognition practices occurring as a result; whether accounting personnel are involved in the risk assessment; and whether there are procedures for implementing follow-up control activities or monitoring
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Control Environment
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Inspecting risk assessments to determine whether relevant risks were identified, and inquiring of personnel to determine the appropriateness of follow-up actions, may provide the basis for an evaluation of operating effectiveness Management may review the policies and procedures that articulate when and how often IT risk assessments are required, as well as the planned program of risk assessments Operating effectiveness may be evaluated by examining the results of risk assessments performed, conclusions reached, and documentation of activities to mitigate risks
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Control Activities Control activities are actions supported by policies and procedures that, when carried out properly and in a timely manner, manage or reduce risks Controls can be preventive, detective, or corrective The intent of each type of control is different Preventive controls attempt to deter or prevent undesirable events from occurring They are proactive controls that help to prevent loss Examples of preventive controls are separation of duties, proper authorization, adequate documentation, and physical control over assets Detective controls, in contrast, attempt to detect undesirable acts They provide evidence that a loss has occurred, but do not prevent a loss from occurring Examples of detective controls are reviews, analyses, variance analyses, reconciliations, physical inventories, and audits Corrective controls are used to ensure that, once an error has been detected, the mistake is corrected and the accounting records are made accurate Examples of corrective controls include clearing reconciling items, reversing incorrect accounting entries, and reclassifying items that were improperly classified All three types of controls are essential to an effective internal control system From a quality standpoint, preventive controls are essential because they are proactive and emphasize quality However, detective controls play a critical role in providing evidence that the preventive controls are functioning and actually preventing losses Finally, corrective controls restore the accounting records to a state of accuracy
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