INTERNAL CONTROL: SIX SMART PRECERTIFICATION STEPS in Visual Studio .NET

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INTERNAL CONTROL: SIX SMART PRECERTIFICATION STEPS
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Beginning in 2005, CEOs and CFOs will certify that their system of internal controls will provide reasonable assurance regarding the reliability of financial reporting and the preparation of the financial
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Minding the Numbers: The Audit Committee
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statements for external purposes Most companies prepared for this by hiring consultants, convening project teams, documenting and evaluating processes, and addressing control weaknesses But what happens after the project team disbands, consultants leave and the regulatory focus on Section 404 of the Sarbanes-Oxley Act gives way to other priorities How does a director know that controls continue to operate Where should a director focus his or her limited time to ensure the company s internal controls will continue to provide reasonable assurance of financial reporting reliability In addition to repeatedly challenging financial reporting and disclosure policies particularly those associated with traditional red flags the audit committee can require management to perform six best practice actions to demonstrate the existence of a strong control environment These actions are to require:
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Regular management reports communicating key control metrics Executives to identify and assess changes to key systems, processes, and people Business managers to sign off on their financial statements as accurate The identification and evaluation of material nonroutine processes Support for strong internal audit and control self assessment functions Require all employees to attest to their understanding of a code of conduct
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Step 1: Require Regular Management Reports Communicating Key Control Metrics Controls have a way of failing if no one is watching For every assertion in the financial statements, there should be an indicator, automated alert, or other procedure designed to help a manager determine how well the related control is working The indicator might be a simple factor, such as the number of days lost to injury; a metric (such as the percentage of product defects); a list that details unavailable materials; an exception report that points out threats to a system (such as when an attempt is made to circumvent system controls; or even periodic reviews and testing in which an inventory count is made or system capacity tests are performed)
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One kind of control report is a listing of all reconciliations performed, who is responsible for the reconciliation, the last time the reconciliation was completed, and the gross amount of reconciling items This should not be just cash reconciliations, but also systemto-system comparisons and physical inventory of assets to the books and records Reconciliations are a powerful detective control, and if done properly, can provide a great deal of comfort that the accounts are correct A listing of all critical controls supporting financial statement assertions should already exist if the company s preparations for complying with Section 404 are nearing completion Management should have a report prepared that lists the critical controls identified during this comprehensive review, a description of the metric that measures performance for each significant control, the frequency of measurement, the current performance of that metric, and the benchmark or targeted performance A review of this report will tell the CFO, CEO, or audit committee what is being measured, where, how often, and how well the control is working Benchmarking is a terrific management tool that can help bring perspective to this raw data There are many sources on which management can draw, both internal and external to your organization (which we delve into in 11) Since inaccurate information can be dangerous, the report should also be periodically audited either by internal audit or some other qualified person independent from those preparing the report to ensure it s reliable
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Step 2: Require Executives to Identify and Assess Changes to Key Systems, Processes, and People Change is the most significant threat to a recently completed control documentation project Change, whether to processes, people, or systems, must be monitored, evaluated and, where necessary, have action taken to ensure controls continue to operate Segregation of duties is a common and basic control lever often deployed in organizations This lever divides tasks into discrete bits so that no single person can make a transaction without the help of others This is done by separating the custody, recording, and approval functions
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