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The
American Institute of Certified Public Accountants (AICPA) has published
a "how-to" guide for audit committees that includes security
as one of several priority considerations. The AICPA Audit Committee
Toolkit specifies security in two key areas:
(1) Assessing significant risks and exposures,
including the extent to which insurance adequately covers exposures,
and
(2) Reviewing "the adequacy of the company's internal controls
including computerized information system controls and security."
For a copy of the Audit Committee Toolkit,
refer to the AICPA's website at http://www.aicpa.org/
Although security is included in narrative
and various checklists, the Audit Committee Toolkit is almost exclusively
focused on traditional governance roles and responsibilities. These
include independence and oversight of financial statements integrity.
Including, but not emphasising security is
consistent with the roll-out of Sarbanes-Oxley regulations and standards.
The Public Company Accounting Oversight Board (PCAOB), for example,
has narrowly defined auditing standards on internal controls. The
standard, An Audit of Internal Control Over Financial Reporting
Performed in Conjunction with an Audit of Financial Statements,
does not expand Sarbanes-Oxley attestations beyond matters closely
connected to financial statements integrity. The PCAOB's approach
suggests that, for now, internal control reviews mandated by Sarbanes-Oxley
will stick closely to financial accounting principles and not include
broader risk management concerns.
The PCAOB does, however, explicitly recognize
the validity of the internal control framework developed by the
Committee of Sponsoring Organizations (COSO) of the Treadway Commission,
which is the foundation for the AICPA's discussion on security and
enterprise risk management in the Audit Committee Toolkit. The COSO
framework expands traditional Generally Accepted Accounting Principles
(GAAP) to include greater emphasis on "people, processes, and
technology" as they affect corporate risk.
The Enterprise Risk Management Framework, which
the COSO released last year, is significant in three important areas:
* First, the Enterprise Risk Framework defines
terms, as well as roles and responsibilities, more broadly than
traditional accounting principles. Throughout the material, COSO
expands customary reporting and accounting responsibilities, which
focus narrowly on financial reporting, historical cost, and limited
non-financial disclosures. The COSO draft thus challenges exclusive
reliance on recognised accounting and financial reporting principles.
Generally Accepted Accounting Principles (GAAP) and rules developed
by the Financial Accounting Standards Board form the basis of public
company reporting responsibility.
* Second, the Enterprise Risk Framework provides
an additional auditing mechanism to assess corporate value and risk.
To date, legal and auditing communities have been reluctant to expand
Sarbanes-Oxley to more than the integrity of financial reporting.
* Third, the Enterprise Risk Framework clarifies
fiduciary roles and responsibilities in areas of risk oversight
and management. In adopting Sarbanes-Oxley, Congress narrowly links
corporate governance to financial transparency and independence
issues. Several often-cited court cases expand this statutory definition
of fiduciary responsibilities to include risk oversight for areas
such as security and regulatory compliance. If integrated into public
company auditing requirements, COSO's Enterprise Risk Framework
would further expand corporate governance expectations.
The COSO will release the final draft early
this year.
Source: Zeichner Risk Assessment
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•Date:
30th January 2004 •Region: N.America •Type:
Article •Topic:
Operational risk
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