Trinity Industries: Case Study Analysis

Southern New Hampshire University

Kristina Barbacano
Organization:

In 1958 Trinity Industries was formed when two struggling propane tank companies,

Trinity Steel and Dallas Tank Company merged. W. Ray Wallace became the first CEO of the

newly formed Trinity Industries. Before becoming CEO, Wallace worked as an engineer for

Trinity Steel. After leading the company for 40 years Wallace passed the torch to his son,

Timothy Wallace who then led the company for another 20 years (O’Donnell, 2019).

What started with a merger between two struggling companies has become a market

leading provider of railcar products and services. Today Trinity employees 5,845 people in the

United States and Mexico. Among competitors in the railroad/transportation industry, Trinity sits

near the top. Notable competitors include CATX Corporation, Greenbrier Company, and

FreightCar America.

Structure:

Trinity Industries markets their railcar products and services under the name TrinityRail.

Trinity operates under two business segments; Rail Car Leasing and Management Services

Group and Rail Products Group. Along with their wholly-owned & partially owned subsidiary

TrinityRail provides rail industry services and manufacters railcars and freights. The Railcar

Leasing & Mangement Services group, provides leasing and fleet management services. Trinity

Rail & Maintanence Servicesm, Trinity Parts and Trinity Heads operate under the Rail Products

group. Trinity Heads manufactures vessels, and provides individual fabrication and other tank

car needs. Trinity parts, distributes (and manufactures) replacement parts for almost any railcar.

The Maintenance services group provides comprehensive maintenance services.

 Railcar Leasing & *Trip Rail Holdings
LLC
Management Services
*RIV 2013 Rail
Group Holdings LLC
*Provides rail industry *Trinty Industries
services Leasing Company
TrinityRail
Rail Products *Trinity Rail &
Group Maintenance Services
*Manufactures tank *Trinity Parts
railcars & freight* *Trinity Heads

The organization chart above was adapted from Trinity Industries 2021 Annual Report.

Yearly Performance

The chart below was created to compare Trinity’s yearly revenue with the 3 competitors

named above. From 2017 to 2021 Trinity saw a 36.75% decline in revenue. In comparison

GATX, Greenbrier and FreightCar America also saw revenue declines; 8.71%, 19.41% and

50.37% respectively. In 2017 Trinity’s revenues were the highest in comparison to the other

three companies. From 2018-2021, Trinity was second only to Greenbrier.

Revenue Comparison
Millions of US $
2021 2020 2019 2018 2017

Trinity Industries
$1516 $1750 $2752 $2509 $2397
Inc. (NYSE: TRN)
GATX Corp.
$1257 $1209 $1202 $1175 $1377
(NYSE: GATX)
Greenbrier Company
$1748 $2792 $3034 $2519 $2169
(NYSE: GBX)
FreightCar America
$203 $108 $230 $317 $409
(NYSE: RAIL)
Management and Culture:

From the Trinity website, we can see that they operate under 5 core values. As the

company states in their Annual Report, their goals are to promote interests of their stakeholders,

while also strengthening accountability and inspiring trust. The 5 core values are:

(1) Integrity (2) Diversity & Inclusion (3) Commitment (4) Excellence (5) Innovation

Upholding these values must start from the top down. As the President & CEO, Jean Savage is

key to the company’s success and the continued focus on their core values. While Ms. Savage

just joined Trinity in 2020, other senior management have had a long tenure with the company.

Currently the two Vice Presidents (David DelVecchio and Ian Mutswiri) have both been with the

company for a number of years. Trinity’s Board of Directors, currently has 7 members who are

elected by stockholders. They are responsible to oversee the Company, and ensure they’re

operating in a way that benefits their stockholders.

Success:

In 2002 the SOX Act was signed into law. The goal of SOX was to protect investors, and

improve the accuracy and reliability of corporate disclosures (SOX Law, 2022). Publicly traded

companies, Trinity included, were well aware about the new legislation. Between 2003 and 2004

Trinity was making enormous changes to their financial reporting processes. What was initially

22 different financial reporting processes, was consolidated into one centralized process. Trinity

also replaced their 4 general ledgers with Oracle Financials. During this same time Trinity

developed the Accounting Service Center (ASC). The ASC centralized services for organization-

wide routine transactions (Schultz, 2011).

Both the ASC and Oracle projects aided in Trinity’s success in their first year of SOX

compliance. The previous projects provided insight that would otherwise have been unknown.
Not only did these projects help the company see the importance of project management, they

also identified the lack of process and control documentation company-wide (Schultz, 2011).

Having this knowledge put Trinity a ‘step ahead’ for their SOX compliance journey. Another

factor important to their success was the pilot SOX projects they conducted on 2 of their BU’s.

SOX required compliance by December 31, 2004. Despite this deadline, Trinity completed their

pilot projects in June of 2004. This gave them extra time to address and weaknesses they

identified. Prior project knowledge, pro-active compliance and dedication were at the core of

Trinity’s success in their first year of SOX compliance.

Internal Controls:

According to the Public Company Accounting Oversight Board (PCAOB), “internal

control is a process—effected by an entity’s board of directors, management, and other personnel

—designed to provide reasonable assurance regarding the achievement of objectives in the

following categories: (a) reliability of financial reporting, (b) effectiveness and efficiency of

operations, and (c) compliance with applicable laws and regulations (2010, 319.06). One internal

control framework largely used to address SOX Section 404 is COSO (Committee of Sponsoring

Organizations). PCAOB, AU 319.41 outlines 4 control activities: performance reviews,

information processing, physical controls and segregation of duties. Examples for these controls,

included in the appendix for AU 319 are as follows:

Performance reviews: Managements review of financial reports

Information processing: User access to programs or data
Physical controls: Secure facilities
Segregation of duties: One person entering transactions, while another person approves them

According to the PCOAB website, a few important internal controls are related to information

processing (centralized), physical controls and segregation of duties (AU 319.41). Developing
the ASC, and overhauling their 22 financial processing systems into one, Trinity addressed

internal controls related to information processing.

Material Weakness:

A material weakness, as defined by PCAOB is “is a deficiency, or a combination of

deficiencies, in internal control over financial reporting, such that there is a reasonable

possibility that a material misstatement of the company's annual or interim financial statements

will not be prevented or detected on a timely basis” (PCAOB, AU No.5 A7). Prior to the

December 2004 requirement for SOX compliance, Trinity was conducting their pilot study. From

this study, Trinity identified a number of gaps which were related to documenting control

activities, such as manger review of monthly or quarterly financial statements. Trinity was able

to address these gaps prior to SOX compliance, and therefore had zero

Trinity Specific:

I think the best examples specific to Trinity, and its competitors for the risk of material

weaknesses relate to their control environment. The 22 segregated financial reporting processes

would have posed a significant risk of a material weakness for Trinity. Operating 22 BU’s

separately meant Trinity had 22 control environments. Oversight responsibility would be another

example. “The majority of gaps were related to the documentation of control activities related to

management reviews of monthly/quarterly financial statements or reconciliations among various

accounts” (Schultz, 2011). If Trinity had no remedied this prior to SOX implementation these

gaps could have met the threshold for a material weakness.

PCAOB:
When determining whether there are material weaknesses relating to effective internal controls

the following standards stick out.

AS 2201.02 - “Effective internal control over financial reporting provides reasonable assurance

regarding the reliability of financial reporting and the preparation of financial statements

for external purposes.  If one or more material weaknesses exist, the company's internal

control over financial reporting cannot be considered effective”

AS 2201.69 identifies indicators of material weakness:

 Identification of fraud, whether or not material, on the part of senior management; 14/

 Restatement of previously issued financial statements to reflect the correction of a

material misstatement; 15/

 Identification by the auditor of a material misstatement of financial statements in the

current period in circumstances that indicate that the misstatement would not have been

detected by the company's internal control over financial reporting; and

 Ineffective oversight of the company's external financial reporting and internal control

over financial reporting by the company's audit committee.

Factors:

The first factor in Trinity’s success was their proactive approach to SOX compliance. The

Oracle and ASC projects helped Trinity to streamline their financial processing and created the

ASC for company-wide routine processing. Afterwards Trinity understood the importance of

approaching SOX from a project management perspective. Jake Fargas was tasked to lead the

SOX compliance project. He created a PMO as well as a steering committee to oversee the

project. Members included the CFO, CAO, internal and external auditors, KPMG and the CFO’s
of each BU. The following chart outlines the process used by Trinity (and the SOX compliance

team) to tackle their first year of SOX compliance.

Project Scoping:
Developed Classified Controls: Created action plan for
methodology/common A,B,C closing gaps
language

Created self assessment

Project Planning process Provided 4 levels of
training

Identified Completed gap- Internal audit - testing

teams/created analysis of controls
GAANT chart

Management
Documented Copmared SOX assertion
current processes complianct controls to
and controls AS-IS controls

External audit &

attestation

To begin their SOX compliance journey Trinity began by planning the project. During this

phase, the GAANT chart was created and the pilot project was conducted. Also during this

beginning phase, KPMG helped build Trinity a database application to track controls. They also

trained the documentation teams. Next the processes and controls (across all BU’s) were

identified and documented. This phase helped to identify the AS-IS state of the process and

control environment. Next the AS-IS controls were compared to what would be needed to meet

SOX compliance. The self-assessment process for Trinity was then created, which increased

accountability. Controls were classified into 3 groups; A,B and C. Once the gaps were identified,
the controls were redesigned to close any gaps. After which the steering committee provided 4

different levels of SOX training for Trinity employees and management. Next Trinity conducted

their internal audit, after which management provided their assertion of the internal controls for

Trinity. Last came the external audit conducted by E&Y which found no material weaknesses.

Bottom-Up Approach: Strengths & Weaknesses

“The focus of this project phase was to identify the AS-IS state of processes and controls

through a bottom-up analysis of the organizations work practices” (Schultze,2011). Prior to their

SOX compliance journey, Don Collum noted that Trinity had a lack of process and control

documentation and that their operations were diversified, decentralized and fragmented.

Inherently a bottom-up approach has both strengths and weaknesses. One large benefit of this

(for Trinity) was the resulting identification and documentation of processes and controls

organization wide. By starting at the process level, the project team was able to compare the

“AS-IS” controls to what they would need to be for compliance. Gaps were able to be identified,

and is many cases fixed immediately (Schultze, 2011). Albeit beneficial, the bottom-up approach

had its drawbacks for Trinity as well. Drawbacks included, the cost, resources needed and the

time it took to complete.

Bottom-Up Approach: Recommend

Trinity’s use of the bottom-up approach in year 1 was essential to their success. The

Oracle Financials and ASC initiatives highlighted the organizational lack of documentation of

processes and controls. Overcoming this was made possible by using the bottom-up approach.

Despite my belief in their compliance approach, I do have one suggestion. First, I think Trinity

could have benefited from further ‘breaking down’ the SOX compliance project teams. The

article Sustaining SOX 404: A Project Management Approach outlines two ways of structuring
the SOX compliance teams, one for centralized organizations and one for decentralized. I think

designing their project teams based on the (decentralized) model below, would have proven

beneficial. It would have allowed Trinity to focus on the specific natures/processes of each line

of business.

Sustaining SOX 404: A Project Management Approach (Wilkins & Gupta, 2007)

Bottom-Up Approach: Top-Down – compare/contrast strengths/weaknesses

Top-down and bottom-up are different approaches used for risk compliance. According

to the Public Company Accounting Oversight Board (PCAOB) the “top-down approach begins at

the financial statement level and with the auditor’s understanding of the overall risks to internal
control over financial reporting. The auditor then focuses on entity-level controls and works

down to significant accounts and disclosures and their relevant assertions. (PCAOB, n.d.)

On the contrary the bottom-up approach begins at the control level, with the identification of the

processes. Next is the identification of the associated risks, determining the risk level and

establishing the necessary controls. Both approaches have their own strengths as well as

disadvantages. The bottom-up approach provides an in-depth look, and knowledge, of the

processes of the company. The end result is a comprehensive identification of risks. This

approach however, is labor intensive and costly for a business (Zahra & Said, 2014). The top-

down approach to risk compliance is less extensive, more specific in the identification of risks.

Only controls (related to relevant/significant) risks are documented. “The top-down, risk-based

approach results in meaningful scoping decisions that promise to be efficient and effective in

addressing real financial reporting risks” (Wilkins & Gupta, 2007).

Bottom-Up Approach: Compliance Project

In April of 2003, Trinity completed their two IT projects, the creation of the Accounting

Service Center (ASC) and the implementation of Oracle. These IT projects essentially identified

the need for Trinity to use a bottom-up approach during their first year of compliance. The lack

of process and control documentation presented a major issue in regards to SOX compliance.

Since each of Trinity’s BU’s had been operating individually, it was essential for all processes

and controls to be identified and documented. Not only was the bottom-up approach appropriate

for their first year of compliance, it was necessary. .

Bottom-Up Approach: Internal Control Structure

As the bottom-up and top-down approaches are different in their process steps, they’re

also different in the outcomes of the internal control structure. The bottom-up approach takes
processes within a business from start to finish. The processes and controls start from the bottom

and continue upward. The internal control structure – based on the bottom-up approach, will be

expansive. There will be many controls (possibly in different control environments) that are

identified and therefore become integrated with the control framework. The top-down approach

will identify entity levels controls used to mitigate risks to financial misstatements. This control

structure will be sleeker, with less controls to document and test.

Bottom-Up Approach

During their project scoping phase, Trinity, led by the KPMG team, conducted a pilot

project in two of their manufacturing BU’s. The pilot project identified key controls

(preventative, detective, manual and system) and control gaps. The project identified 32 total

control gaps; of these gaps, 24 of them were gaps related to documentation (Schultze, 2011). The

pilot project provided insight into the gaps Trinity would encounter, and provided a way to

estimate the time and labor that process and control documentation would take.

Bottom-Up Approach: Testing Processes

After the processes and controls were documented and subsequently compared to SOX

compliance, Trinity moved into their self-assessment and testing phase. The self-assessment

phase introduced the “Representative Letters’. These letters were used for management to assert

the effectiveness of the internal controls they were responsible for. This phase also included the

steering committee classifying all of the identified controls. ‘A’ controls were classified as key

controls, and essential for SOX compliance. ‘B’ controls were identified as back-up controls, and

‘C’ controls were identified as related but not imperative for SOX compliance (Schultze, 2011).

Trinity then tested all the classified controls as well as their newly created self-assessment

process. At the end of their first year Trinity has tested 2440 controls. Trinity took a proactive
approach to SOX, as they wanted to ensure their compliance. I think this motivation caused them

to test too many controls in their first year. While testing of the ‘A’ and ‘B’ controls was

necessary, I do not think the same attention/testing should have been applied to those controls

classified as “C’ controls.

Bottom-Up Approach: Most Useful

Substantive tests/procedures are used during audits to detect material misstatement at the

assertion level. From the Trinity case study, the most useful substantive audit test would be the

self-assessment test phase. The steering committee created Control Certification Letters

(Schultze, 2011). These letters served as the managers assertion over their internal controls. They

certified that the control was in use and effective. Not only did the letters do this, they also

notified Trinity when there was a change in control ownership.

Bottom-Up Approach: Results and Recommendations

Date: October, 2, 2022

To: Trinity Industries

From:

Subject: SOX Compliance Testing: Results & Recommendations

As we close out our first year of SOX compliance, I would like to thank all of you for

your hard work. E&Y concluded their external audit, and found no material weaknesses

(Schultze, 2011). This success was made possible by the time and dedication given by all of you.

Throughout the year, we monitored 2485 controls, tested 2440 and identified 327 testing gaps.

As we look towards our second year of compliance, our goal should be to move away from a
bottom-up approach, towards a top-down approach. Implementing a risk-based (top-down)

approach for compliance in future years, will reduce cost, the number controls identified and

tested, as well as internal/external testing hours. We will focus on those controls/processes that

pose the greatest risk, as opposed to approaching all on the same level.

It has been wonderful working with all of you. Your hard work and dedication paved the way for

our successful year one of compliance.

SOX-Related Expenses: Further Reduce

The first year of SOX compliance was costly for Trinity. In 2004 Trinity’s SOX testing

cost them $2.5 million. Efforts can be made to further reduce these compliance costs for Trinity.

The first was mentioned previously, the adoption of a top-down approach. This will reduce the

number of key controls, thereby reducing controls needing to be tested, as well as the costs.

According to the pilot project (Highway safety and Tank-barge) showed a large amount of

manual controls. Transferring manual controls to system controls will also reduce costs for

Trinity. Currently, Trinity is utilizing three different versions of BPCS (Schultze, 2011). By

combining these 3 separate versions of BPCS into one single software, Trinity could further

reduce their SOX compliance costs. Since the beginning of their SOX compliance journey,

Trinity has been able to reduce the number of controls tested year after year. If they were able to

continually slim down controls (while still maintaining reliable, accurate information) it would

reduce the cost associated with internal and external testing.

SOX-Related Expenses: Major Sources of Cost

Major sources of cost in Trinity’s compliance and maintenance testing relate to the

documentation of processes and controls, the testing hours completed both internally and

externally and prior IT projects, Oracle and ASC.

SOX-Related Expenses: Rank

First, in terms of cost would be the Oracle and ASC projects. The Oracle initiative cost

Trinity $28 million, although it was estimated to have saved Trinity $.5 million annually in

compliance expenses (Schultze, 2011). Next would be the testing hours conducted both

internally and externally. In 2004, 3000 internal hours of testing and 25,000 hours of external

testing were conducted. This enormous amount of testing hours cost Trinity $2.5 million. Last is

the identification and documentation of all of Trinity’s processes and controls.

SOX-Related Expenses:

Among many choices, Trinity chose Oracle for their software system. Two alternatives to

Oracle are SAP and Microsoft Dynamics. The table below outline the pros and cons of each

option.

Pros Cons
- Seamless integration
- High implementation
- Extensive
cost
Oracle customization options
- Interface isn’t user
- Enables automation of
friendly
processes
- Not user friendly
- Highly scalable - Recurring
SAP - Intuitive, consistent & maintenance costs
well integrated - Limited configuration
option
- Lowest
implementation
cost/short - Difficult or
implementation impossible to
timeline integrate with other
Microsoft Dynamics
- Easily integrated with software
other Microsoft - Long installation time
products
- Multi-lingual/support
multiple currencies
SOX-Related Expenses: Defense

Oracle, Microsoft Dynamics and SAP all offer software systems, each bearing their own

individual characteristics. After researching the alternatives, I believe Trinity made the correct

choice in implementing Oracle. Two specific reasons stand behind this decision. Trinity operates

22 different BU’s in 5 lines of business. In order to meet the specific needs of each BU, while

also working for the organization as a whole, customization is key. Oracle provides extensive

customizable options (Team, 2021). Along with this, Oracle is able to seamlessly integrate with

other software platforms. As Trinity continues in their SOX compliance journey the need for

automated processes and controls will only grow. A highlighted feature of Oracle is the ability to

automate processes.

IFRS: Change

“A change in accounting principle results when an entity adopts a generally accepted

accounting principle different from the one it used previously” (Hall & Aldridge, 2007). The U.S

GAAP is based on a set of rules/standards, while IFRS is based on principles. GAAP are a

specific set of rules that U.S companies must follow. On the other hand, IFRS are guidelines, not

rules. IFRS are meant to provide the companies with base of guidelines, rather than dictate (with

rules) how financial statements should be prepared (Schmidt, In the U.S. companies must adhere

to GAAP. GAAP provide companies with a set of rules that must be followed. On the other

hand, IFRS are not rules, they are guidelines. Rather than

A switch from U.S. GAAP to IFRS would have far reaching impacts for any business. Dealing

with the Implications of Accounting Change highlights that changes will need to be made to the

organizations systems, processes and controls and business practices. There will be changes to

data calculations and other financial measures. How financial reports are created, and the data
included in them will also need to be changed. To ensure compliance with new IFRS standards,

the business processes will need to be examined and changed accordingly. Since there will be

changes in processes, the related controls will also need to be changed.

IFRS: Improve

As stated above, a change in accounting standard will inevitably require changes to the

internal controls. During their SOX compliance journey, Trinity documented their AS-IS

processes and controls to compare to the requirements in SOX. The same process will need to be

taken for a move to IFRS. Initially Trinity will need to identify any processes that will be

affected. Once any new processes have been identified, the corresponding control will need to be

examined. The principle-based nature of IFRS may also require Trinity (or any company) to

strengthen their control environment to account for any “judgement” based decisions.

IFRS: Standards

Numerous standards, or differences between U.S GAAP and IFRS will have an impact

for Trinity. Two differences between GAAP and IFRS relate to inventory. Under IFRS the last-

in, first-out (LIFO) method is prohibited, rather the first-in, first-out method is used. GAAP

allows for the LIFO method; which allows companies to sell their most recent inventory if it

would increase profits to do so. The measurement of inventory is also different between the two.

Under GAAP inventory is measured at the lower of cost or market value. In contrast IFRS

considers the lower of cost or net realizable value (Deloitte, 2007). Another difference is related

to accounting for fixed assets. U.S. GAAP uses the cost model for valuation of fixed assets, IFRS

however, allows for a revaluation model (which GAAP prohibits). The revaluation method bases

fixed asset value on the date of evaluation (Fosbre et al., 2009). Research and Development

(R&D) will also change if there is a switch to IFRS. Currently under U.S GAAP, research and
development costs are expensed as they are incurred. IFRS accounts for research costs and

development costs separately. Research costs are expensed as they are incurred, whereas

development costs are capitalized (Fosbre et al., 2009). IFRS and U.S GAAP also account for

revenue differently. U.S GAAP recognizes revenue when the process has been completed, and

related expenses have been recorded. IFRS on the other hand, recognizes revenue when the sale

occurs (Fosbre et al., 2009).

IFRS: Role

Governance Infrastructure:

During 2006, Trinity realized that they needed to move past SOX as a project, and

instead implement a governance process (Schultze, 2011). This governance process would be

essential for the implementation of IFRS. We’ve learned that compliance projects begin with the

‘tone at the top’. There will need to be an organizational acceptance of the changes. Utilizing the

governance infrastructures (in place) from their SOX compliance project, Trinity can create the

environment and organizational tone needed to successfully complete a transition to IFRS.

IT Infrastructure:

According to the Trinity case study, the IFRS changes would ultimately be implemented

by the businesses AIS, and therefore would be an IT forward project. Included in Trinity’s IT

infrastructure are Oracle, AIS and BPCS. All IT software will need to be evaluated and adjusted

to accommodate the changes. While the IT department can address the technical aspects of

change, they will need to work closely with accounting to ensure compliance with IFRS

standards.

Process Infrastructure:
 A company’s process infrastructure essentially refers to the company’s entire workflow,

from start to finish. “Such a foundation encompasses all services, capital equipment, resources

and facilities that are required and essential for a company to successfully exist and operate

(What is process infrastructure, n.d.). In order to make the change to IFRS all organization

processes will need to be examined.

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