CIA Part 1 - Internal Controls
CIA Part 1 - Internal Controls
Definition of Control
The IIA defines control in the Glossary:
“Any action taken by management, the
board, and other parties to manage risk
and increase the likelihood that established
objectives and goals will be achieved.
Management plans, organizes, and directs
the performance of sufficient actions to
provide reasonable assurance that
objectives and goals will be achieved.”
COSO Definition of Control
Internal controls are “designed to provide
reasonable assurance regarding the
achievement of objectives in the
following categories:
• Effectiveness and efficiency of
operations,
• Reliability of financial reporting, and
• Compliance with applicable laws and
regulations.”
Ways of Classifying Controls
1. The organizational level at which the
controls exist
2. Manual or automated
3. The type of control
1. Organization Level
Controls
A. Corporate-level (entity level) controls are
mostly manual, which include general policy
statements and values and overall monitoring
procedures.
B. Operational-level controls include both
manual and automated controls.
C. Transaction-level controls are mostly
automated, consisting of complying with
specific control procedures and making sure
financial information is accurate and
complete.
2. Manual vs. Automated
• Manual controls operate through
human intervention.
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The Sponsoring Organizations
The five sponsoring organizations are:
1. American Institute of Certified Public Accountants
(AICPA).
2. American Accounting Association (AAA).
3. Institute of Internal Auditors (IIA).
4. Institute of Management Accountants (IMA).
5. Financial Executives International (FEI).
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Components of Internal Control
There are five components that make up
internal control:
1. The control environment
2. Risk assessment
3. Control activities
4. Information and communication
5. Monitoring
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1. The Control Environment
Considered the most important element of
internal controls because it is the basis on
which the other elements are built.
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Categories of Objectives
Broad categories of objectives include:
• Operational – Relate to the achievement
of the company’s mission.
• Financial – Address the preparation of
external financial reports.
• Compliance – Adhering to all laws and
regulations.
Risk Assessment
Analyzing risks includes:
• Estimating the likelihood of the risk’s
occurrence,
• Deciding how to best manage the risk, and
• What actions can be taken to mitigate the
risk.
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Location of Risks
• External Risks include changes in
technology, changes in federal legislation,
natural disasters, economic changes, or
being defrauded, or robbed.
• Internal Risks include employee
embezzlement accompanied by falsification
of records to conceal theft; lack of compliance
with governmental regulations; or other illegal
acts by employees, such as taking a bribe.
3. Control Activities
These are the policies that are developed to
address the risks. These risks may be fraudulent
reporting or theft or conflict of interest, or
something else.
Control activities should be designed to mitigate risk,
wherever risk exposure is determined to exist, for
the purpose of protecting the organization’s ability
to achieve its objectives.
Controls that are implemented must have a benefit
that is greater than the cost of that control.
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Examples of Control Activities
• Top level review of actual performance
• Reviews by management at the functional or
activity level
• Controls to check accuracy, completeness, and
authorization
• Independent checks
• Various performance indicators
• Physical controls to safeguard assets
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Examples of Control Activities
• Documents and record protection and
authorization
• Pre-numbered documents
• Performance evaluations
• Hiring controls to ensure that qualified
personnel are hired
• Control over system modifications
• Segregation of duties
Segregation of Duties
1. Identify a function that is indispensable,
but potentially subject to abuse.
2. Divide that function into separate steps,
each of which is necessary for the function
to work, or for the power that enables that
function to be abused.
3. Assign each step (or duty) to a different
person or organization.
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Duties to be Segregated
The following duties need to be segregated
between different people:
1. The authorization of a transaction,
2. The recording (record keeping) of the
transaction,
3. Keeping physical custody of the asset, and
4. The periodic reconciliation of the records of
the asset (how much there should be) to the
actual amount of the asset (how much there is).
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Examples of Segregation of Duties
One person has authority to adjust accounts receivable,
while a different person posts payments on customer
accounts
One person is responsible for preparing the bank deposit,
while a different person reconciles the checking account.
One person has custody of cash receipts, while a different
person has the authority to authorize account write-offs.
One person authorizes issuance of purchase orders, while a
different person is responsible for recording receipt of
inventory.
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Limitations of Segregation of Duties
No system is perfect and no system can eliminate
all of the risks that a company faces.
Two reasons that risk can not be completely
eliminated are:
• Collusion
• Human judgment
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4. Information & Communication
Relevant information needs to be obtained and
communicated to people to allow them to perform their
duties.
Reports must contain information that management
needs and must be available in a timely manner.
• Communication must be on-going, both within and
between the various levels and activities of the
organization.
• Reports must be available containing operational,
financial, and compliance information needed for
informed decisions. 47
4. Information & Communication
• Supervisors must communicate duties and
responsibilities, and employees must alert
management to potential problems.
• Information must be communicated both
internally and externally.
• The system must provide way to
communicate important information to the
very top of the organization.
5. Monitoring
Monitoring is the process of reviewing the
controls over time to make sure that they
are still relevant and still functioning as
they were intended to function.
As technologies change and business
operations change, some of the controls
that had been relevant may no longer be
relevant.
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Methods of Monitoring
Monitoring can be done in two ways:
1. Ongoing monitoring during normal
operations, and
2. Separate evaluations by management with
the assistance of the internal audit function,
or some other independent specialist.
If monitoring is done regularly, there is a lesser
need for separate evaluations.
Components of Internal Control
1. The control environment
2. Risk assessment
3. Control activities
4. Information and communication
5. Monitoring
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Alternative Control
Frameworks
The CoCo Model
The CoCo model was designed by the Criteria of
Control Board of the Canadian Institute of
Chartered Accountants.
According to CoCo, control comprises “those
elements of an organization (including its
resources, systems, processes, culture,
structure and tasks) that, taken together,
support people in the achievement of the
organization’s objectives.”
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Components of CoCo Model
The model has four components:
1.Purpose
2.Commitment
3.Capability
4.Monitoring and Learning
1. Purpose
1. Objectives should be established and communicated.
2. Significant internal and external risks should be
identified and assessed.
3. Policies to support the achievement of the
organization’s objectives should be designed,
communicated and implemented.
4. Plans should be established and communicated to
assist in the achievement of objectives.
5. There should be measurable performance targets in
the objectives and plans.
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2. Commitment
6. Ethical values should be established and
practiced at all levels in the organization.
7. Human resources policies should be
consistent with the firm’s ethical values.
8. Authority, responsibility and accountability
should be clearly defined and consistent
with the organization’s objectives.
9. An atmosphere of mutual trust should be
supported through the flow of information
and communication. 58
3. Capability
10. People should have the needed knowledge, skills and
tools to support the achievement of the organization’s
objectives.
11. Communication should support the values and
achievement of objectives.
12. Sufficient and relevant information should be identified
and communicated to the appropriate party in a timely
manner.
13. Decision-making in the company should be coordinated
between departments.
14. Control activities should be designed and implemented.59
4. Monitoring and Learning
15. External and Internal environments should be monitored for
feedback on the achievement of objectives.
16. Performance should be monitored against targets and goals.
17. The assumptions used in the development of plans and
goals should be reviewed periodically.
18. Information and communication needs to be periodically
reviewed.
19. Follow-up procedures should be implemented to ensure that
the needed changes occur and are effective.
20. There should be periodic review of the effectiveness of the
control system.
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CoCo and COSO Similarity
Both COSO and CoCo emphasize soft
controls.