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Internal Control

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Internal Control

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Usama Fattah

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Internal control

over financial
reporting
Handbook

July 2023
______

frv.kpmg.us
Contents
Foreword............................................................................................................. 1

About this publication .......................................................................................... 2

1. Executive summary ...................................................................................... 4

2. Entity-level controls .................................................................................... 13

3. Risk assessment ........................................................................................ 77

4. Process understanding ............................................................................. 116

5. Process control activities .......................................................................... 168

6. Information used in controls ..................................................................... 253

7. General IT controls ................................................................................... 282

8. Service organizations ............................................................................... 325

9. Identifying and evaluating deficiencies ..................................................... 367

Appendix A ............................................................................................... 426

Appendix B ............................................................................................... 433

Appendix C ............................................................................................... 446

Appendix D ............................................................................................... 468

KPMG Financial Reporting View ..................................................................... 469

US GAAP Handbooks ..................................................................................... 470

Acknowledgments ........................................................................................... 471

© 2023 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent
member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
Internal control over financial reporting 1
Foreword

ICFR: always in the spotlight, always

work to be done
When designed appropriately and operated effectively, internal control over
financial reporting (ICFR) provides many benefits: promoting accountability,
safeguarding an entity’s assets from fraud or significant loss, maintaining
integrity of financial data and transactions, facilitating compliance with the
applicable financial reporting and statutory compliance frameworks, and
enabling information flows across the entity. Simply put, ICFR forms the bedrock
of public and investor confidence in the capital markets. Without effective ICFR,
entities risk significant financial and reputational harm.

Although the Sarbanes-Oxley Act of 2002 (SOX) is more than 20 years old,
ICFR remains in the spotlight as an essential part of an entity’s financial
reporting agenda. One reason for this is that continuous change is now the
normal state for many entities.

Change creates risks and an effective system of ICFR is needed to manage

those risks. Entities continue to implement increasingly complex systems to
support financial reporting and operating performance. Flaws in these systems –
in design or operation – can create significant financial risks. So, too, can the
march towards increased automation and involvement of specialized service
providers in business and financial reporting processes.

External factors also contribute to entities facing new and evolving risks – the
recent pandemic, international conflicts and uncertain economic environment, all
fuel the need for entities to regularly adapt their business and financial reporting
processes to manage the related risks.

So, there is always work to be done, even if you have been certifying ICFR for
years. If you are a first-time assessor of ICFR under SOX, the work is just
beginning.

In this Handbook, we discuss and illustrate the key elements of a risk-based

approach to the design, implementation and evaluation of ICFR using the
predominant framework employed in practice – the 2013 Internal Control –
Integrated Framework published by the Committee of Sponsoring Organizations
of the Treadway Commission (the COSO Framework).

We hope you find our analysis and insights useful as you start or continue your
ICFR journey and rise to the challenges of an environment where change is
constant.

KPMG LLP
Department of Professional Practice

About this publication

Management cannot satisfy its financial reporting responsibilities without strong
and effective ICFR. The purpose of this Handbook is to assist management in
understanding a risk-based approach to ICFR using the predominant framework
employed in practice – the COSO Framework.

Organization of the text

This Handbook is organized around the risk-based approach to ICFR in the
COSO Framework. Given their pervasive nature, the Handbook starts with
entity-level controls. It then moves on to risk assessment and process
understanding, both of which are integral to identifying, designing and
implementing the necessary process control activities. From there, the
Handbook moves on to information used in controls, general IT controls
(GITCs) and service organizations, all of which touch on various aspects of an
entity’s ICFR. The Handbook wraps up with identifying and evaluating
deficiencies, which may come to light at any point in the process.

While this Handbook discusses and illustrates the various aspects of a risk-
based approach to ICFR in a sequential manner, designing, implementing, and
maintaining an effective system of ICFR really is an iterative process. As
management moves through the process, it will inevitably need to revisit earlier
aspects of the process and reassess previous conclusions.

See Appendix D for a discussion of ‘What’s new’ in the Handbook as compared

with its previous version (ICFR Reference Guide) released in 2016.

COSO Framework
This Handbook makes regular references to the COSO Framework. As
discussed further in section 2.2, there are five components of ICFR under the
COSO Framework and 17 principles underlying those components. Important
characteristics of each principle are highlighted in points of focus. While the
points of focus are included in a compendium that accompanies COSO’s
Internal Control – Integrated Framework, references to the COSO Framework
in this Handbook are inclusive of that compendium as well as the separate
COSO publication with illustrative tools.

Practical tips
Seeing the COSO Framework applied in practice brings an incredible amount
of insight to bear on what the concepts really mean. In addition, as your
external auditor also may be required to opine on the effectiveness of your
entity’s ICFR, insights into working effectively with your auditor in applying this
risk-based approach are critically important. These insights are highlighted
throughout this Handbook as ‘practical tips’.

Terminology
The following terminology is used in this Handbook:
• controls include entity-level controls and control activities;

• entity-level controls are policies, procedures and structures that operate at

the entity level with an indirect relationship to financial reporting;

• control activities include process control activities and GITCs;

• process control activities mitigate a specific risk point within a business

process that could lead to a material misstatement of the entity’s financial
statements; and

• GITCs support the continued effective operation of automated process

control activities and the integrity of data and information within the entity’s
IT systems by addressing risks arising from IT.

Abbreviations
We use the following abbreviations in this Handbook:

AICPA American Institute of Certified Public Accountants

COSO Committee of Sponsoring Organizations of the Treadway
Commission
CUEC Complementary user entity control
FASB Financial Accounting Standards Board
GAAP Generally Accepted Accounting Principles
GITC General IT control
ICFR Internal control over financial reporting
PCAOB Public Company Accounting Oversight Board
PRP Process risk point
RAFIT Risk arising from IT
RDE Relevant data element
RM Risk of misstatement
RMM Risk of material misstatement
SEC Securities and Exchange Commission
SOC System and Organization Controls

1. Executive summary
This Handbook is focused on management’s ICFR journey and describes a risk-
based approach to designing, implementing and maintaining an effective system
of internal control and its evaluation. Following a risk-based approach allows
management to identify and address the areas of highest risk. Management’s
ICFR journey has many steps along the way. Each step is captured in a
separate chapter of this Handbook, and the following diagram summarizes
those steps and the related chapter numbers and titles.
2. Entity-level controls

3. Risk assessment
Materiality and scoping of significant accounts, disclosures and components of the entity

Account, disclosure, process or component determined to contain a potential risk of material misstatement

4. Process understanding
Document understanding of processes including systems utilized

Risk points in processes that could result in a material misstatement

Throughout the process, identify and evaluate deficiencies

5. Process control activities
Manual process Automated process Service organization process
control activity control activity control activity

6. Information used in controls 7. General IT controls 8. Service organizations

Identify information and RDEs Identify systems utilized – Service organization

utilized in the control consider all IT layers provides a SOC report

Yes No

Identify risks in IT layers related Manual

Internal External Independently
to process level automated control over
information information test controls at
controls review of
SOC report service
organization
or implement
For RDEs Evaluate Manual Automated own controls
understand Appropriate
relevance general IT general IT to address risk
the flow of CUECs
and control control points*
information reliability
9

from input to
use in the SOC report
Service organization No
control addresses
general IT control risk points
activity

Evaluate
relevance

Control activities or GITCs to

address input, integrity, * The control activities identified for
extraction and manipulation each data risk or risk point would
risks* (reliability) follow the guidance above based
on the type of control activity.

While a risk-based approach to designing, implementing, maintaining and

evaluating ICFR can be described in a sequential manner, if properly performed,
it is really an iterative process. Each successive step of the process is a building

block on a journey to effective ICFR and, in the case of an assessment of ICFR,

it adds to the total body of evidence considered. This cumulative body of
evidence may cause management and auditors to reassess initial conclusions
as new evidence is obtained throughout the assessment.

COSO Framework
Management and, if applicable, external auditors may be required to determine
whether the entity maintained, in all material respects, effective ICFR as of a
specified date, based on the criteria established by a suitable framework, which
is typically the Internal Control – Integrated Framework published by the
Committee of Sponsoring Organizations (COSO) of the Treadway Commission.

There are five interrelated components of internal control established in the

COSO Framework that must be present and functioning, and the five
components must operate together in an integrated manner, for an effective
system of internal controls.

• Control environment
• Risk assessment
• Control activities
• Information and communication
• Monitoring

The COSO Framework includes 17 principles that underpin each of the five
components of ICFR as fundamental concepts. The 17 principles form the basis
for designing an effective integrated system of ICFR.

Each of the five components and 17 principles is covered in more detail

throughout this Handbook.

Entity-level controls are prevalent in the following components of ICFR.

Control environment Risk assessment

The control environment includes: Risk assessment is a dynamic, iterative
• the set of standards, processes and process for:
structures that provide the basis for • identifying and analyzing risks to
carrying out ICFR; and achieving the entity's objectives;

Control environment Risk assessment

• the attitudes, awareness and actions • identifying the risks to manage; and
of those charged with governance • determining how to manage the
and management concerning the risks identified.
entity's ICFR and its importance. As part of risk assessment, management
The control environment also: considers possible changes that may
• sets the tone at the top of the entity; impede the entity's ability to achieve its
objectives. These changes can be
• influences the control present in the external environment
consciousness of its people; and and/or within the entity’s own business.
• provides the overall foundation for
the operation of other components
of the entity's ICFR.

Information and communication Monitoring activities

The information and communication Monitoring activities are required to:
component addresses: • determine whether controls are
• the importance of information designed and operating to evidence
management and continuous that the five components of internal
communication between and among control, and each related principle,
those responsible for ICFR, both are present and functioning;
internal and external; and • determine that the established
• how reliable information from both controls functioned in a manner to
internal and external sources is effectively address the current risks
needed to support the functioning of to the entity’s financial reporting
the other four components of process; and
internal control. • identify deficiencies in internal
control and communicate those
deficiencies to the parties
responsible for taking corrective
action, including those charged with
governance, as relevant.

Identifying the relevant risks to financial reporting is an essential component of

ICFR because failure to understand the likely sources of misstatements may
lead to ineffectively designed control activities, which, in turn, increases the
possibility of a material misstatement in the financial statements.

Management performs the entity’s risk assessment at various levels within the
entity by following a top-down approach that starts at the entity level and moves
down to the process level.

The following are specific activities involved in executing an effective risk

assessment.

• Consideration of materiality. Materiality involves both quantitative and

qualitative considerations, and separate materiality analyses could be
needed at the consolidated level and component level.

• Scoping of accounts and disclosures. Management identifies significant

accounts and disclosures and links them to the appropriate financial
statement assertions (e.g. completeness, existence, accuracy). This is
necessary given management’s overall objective to produce reliable
financial reporting in accordance with the relevant financial reporting
framework. Risks of misstatement to significant accounts and disclosures
require an ICFR response.

• Scoping of components. Management determines which of the entity’s

components (e.g. subsidiaries, divisions, operating units) present a risk that
the financial statements contain a material misstatement. A necessary part
of this exercise is determining component materiality.

• Identifying and assessing fraud risks. Management must assess the

potential for fraud in evaluating risks to the achievement of its objectives.
This assessment should be comprehensive, cover various levels within the
entity and involve appropriate members of management and employees.

• Consideration of changes that could impact ICFR. Management’s risk

assessment must identify changes that could significantly impact the entity’s
financial reporting and the system of internal control, assess the risks
resulting from those changes and respond to those risks.

Documentation of risk assessment often involves the creation and maintenance

of a risk and control matrix, which includes the account or disclosure, account
balance, the risk factors considered, and the significance of the risk to the
accounts, disclosures and relevant assertions, as well as linking the risks to the
controls designed to address them.

Identifying and documenting RMMs and PRPs

The PRP is the 'where' and the 'how' in the business process a misstatement
(including a misstatement due to fraud) could be introduced. The RMM is the
'what' that could be misstated. Those PRPs that could result in a material
misstatement, individually or in combination with other misstatements, require
an ICFR response.

PRPs that could result in RMMs should be documented in sufficient detail to

identify the specific condition that would allow for a material misstatement to
occur within the financial statements.

Obtaining and documenting process understanding

There are many ways management may obtain an understanding of its business
processes, but, generally, performing a walkthrough is the most comprehensive
method of doing so. In a walkthrough, a single transaction is followed from
initiation through the entity’s processes, including its information systems, until
the transaction is reflected in the entity’s financial records.

The documentation of process understanding should be of sufficient detail to

provide understanding of the flow of information through the entity’s processes
and relevant IT systems and identify the relevant RMMs and PRPs associated
with a particular process.

Additional considerations

Management also considers each of the following in its process understanding.

• Financial reporting and disclosures. Understand the period-end financial

reporting process and identify the related PRPs, including those related to
the development of financial statement disclosures.

• Estimates. Management should identify where there are estimates or

changes in estimates in their business processes. Once identified,
management determines whether there are RMMs and related PRPs
associated with the selection or application of the methods, assumptions or
data elements of the estimate.

• IT. Understanding the flow of transactions into, through and out of the
relevant IT systems and identifying the related PRPs is an integral part of
process understanding.

• Journal entries. Management obtains an understanding of business

processes all the way through the recording of journal entries and uses this
understanding to identify the RMMs and PRPs related to journal entries.

Process control activities

The crux of management’s ICFR journey is control activities. In the context of
management’s ICFR, control activities are focused on identifying the policies

and procedures established to mitigate (either directly or indirectly) RMMs in the

entity’s business processes and financial reporting process. Control activities
include process control activities and GITCs (which are addressed more in
Chapter 7). Each process control activity's objective is to mitigate an identified
PRP.

An entity’s ICFR is effective when it provides reasonable assurance that its

financial statements are reliable and prepared in accordance with the applicable
financial reporting framework. Accordingly, process control activities should be
designed and operated at a ‘would’ level of assurance – they ‘would’ (i.e.
probably will) mitigate an identified PRP and, therefore, prevent, or detect and
correct, on a timely basis, a material misstatement in the financial statements.

The following are considerations in designing a process control activity.

Control objective Nature and type of control

Frequency Judgment involved

Level of precision Investigation and resolution process

Authority and competence of the Information used in the performance

control operator of the process control activity

Given their nature, additional considerations may apply to the design and
operation of process control activities related to fraud risks, journal entries,
going concern, significant unusual transactions and related parties.

Management must monitor its process control activities and obtain evidence
necessary to support their assessment of ICFR. Management has several
different ways they may obtain this evidence, including through direct testing of
controls. Direct testing involves reperformance, inspection and/or observation of
the control together with inquiry. If it is determined through management’s direct
testing that a process control activity is ineffective in its design and/or operation,
a deficiency exists.

Information used in controls

Appropriately identifying and assessing the relevance and reliability of
information used in controls is critically important to management’s ICFR
journey. Management and others with ICFR responsibilities (such as control
operators and IT personnel) first identify the population of information
associated with a control and whether the information is external or internal,
then identify the data elements in the information that are relevant to the design
and operation of the control.

Once information used in controls is identified and the source is determined,

management assesses the information’s relevance and reliability.

Management’s evaluation of the reliability of external information considers the

information’s nature and source. Management’s evaluation of the reliability of
internal information or external information stored in the entity’s IT systems
involves understanding the flow of information and how the data risks
associated with the information’s completeness and accuracy are addressed.

Throughout the process of identifying information used in controls and

assessing its relevance and reliability, management considers whether it has
identified all such information and clearly documented its assessment of the
information’s relevance and reliability. If information used in a control is not
clearly identified and/or its relevance and reliability are not properly addressed,
the control using the information is deficient.

Before GITCs are designed and implemented, management must first

understand the IT layers within the entity’s IT system and then identify the
relevant risks arising from IT (RAFITs) within each IT layer.

• IT layers. The four layers of technology that comprise an IT system are

application, database, operating system and network. A layer of technology
is relevant to ICFR when there is one or more RAFITs within that layer of
technology that is relevant to the effective operation of automated control
activities and/or the integrity of data and information within the IT system.

• RAFITs. RAFITs represent the susceptibility of automated control activities

to ineffective design or operation, or risks to the integrity of information in
the entity’s IT systems, due to ineffective design or operation of GITCs. A
relevant RAFIT is an IT risk where there is a ‘reasonable possibility’ that the
risk could prevent the effective operation of the related automated control
activity and/or affect the integrity of data within the IT system.

• GITCs. GITCs are not expected to directly prevent, or detect and correct,
material misstatements. However, ineffective GITCs may lead to automated
control activities that don’t operate consistently and effectively, which may
lead to the automated control activities not preventing, or detecting and
correcting, a material misstatement on a timely basis. Preparing and
retaining sufficient documentation to evidence the design, implementation
and operation of the entity’s GITCs is important to demonstrating the
effectiveness of the entity’s ICFR.

Management monitors the effectiveness of GITCs designed to address relevant

RAFITs, which may result in the identification of GITC deficiencies.

• Monitoring procedures over GITCs. GITCs are included in management’s

monitoring, which may involve testing the operating effectiveness of the
control activities. If monitoring involves direct testing of GITCs, it should be
performed throughout the period.

• GITC deficiencies. If GITCs are ineffective, management may not be able

to rely on the automated control activities and/or the integrity of the
information the GITCs support, which may impact management’s
conclusions on ICFR effectiveness.

Consideration must be given to cybersecurity risks when identifying, designing

and implementing GITCs.

Depending on the nature of the services provided, a service organization is

often considered part of the user entity’s control environment. When that is the
case, the service organization becomes part of management’s ICFR journey,
which results in management needing to:

• understand the service organization’s processes;

• evaluate the nature, timing and extent of the service organization’s controls
and related testing; and
• assess deficiencies at a service organization in its evaluation of ICFR
deficiencies.

Key to performing these activities is whether the service organization provides a

SOC report to management, and if so, the nature and contents of that report.

Specific management responsibilities related to a SOC report include:

• reviewing the SOC report to determine whether it provides the entity’s

management with sufficient evidence to address risk points in the service
organization’s processes;

• implementing appropriate complimentary user entity controls as indicated in

the SOC report;

• evaluating deficiencies identified in the SOC report;

• identifying relevant information the SOC report covers or affects;

• evaluating whether the period(s) the SOC report covers is appropriate for
the entity, including performing appropriate procedures over the period
subsequent to the period addressed in the SOC report; and

• responding when a SOC report is not available or identifying ‘control gaps’

when a SOC report does not achieve the desired objectives of the entity’s
management.

Identifying and evaluating deficiencies

Control deficiencies may be discovered at any point in management’s ICFR
journey. A control deficiency exists when the design or operation of a control
does not allow management or employees, in the normal course of performing
their assigned functions, to prevent, or detect and correct, misstatements on a
timely basis.

When a control deficiency exists, a control is either missing, designed

inappropriately or not operating effectively. The existence of a control deficiency
means that there is an opportunity for a misstatement to occur, even though a
misstatement may not have occurred.

Identifying and evaluating control deficiencies may seem straightforward, but

challenges may, and often do, arise. The following six-step process may help
management to properly identify and evaluate the severity of control
deficiencies, while avoiding or properly navigating common challenges.

Identifying the internal control deficiency

Determine whether a deficiency exists and identify the deficient or
Step 1
missing control
Step 2 Understand the cause of the deficiency
Step 3 Determine whether the deficiency is indicative of other deficiencies
Evaluating the internal control deficiency
Step 4 Evaluate the severity of the deficiency individually
Evaluate the effect of compensating controls and conclude on the
Step 5
severity of the individual control deficiency
Step 6 Evaluate the severity of similar deficiencies in the aggregate

2.4.50 What are the principles in the COSO Framework related to

the control environment component of ICFR?
2.4.60 What is the importance of an entity demonstrating a
commitment to integrity and ethical values (Principle 1)?
2.4.70 What is the tone at the top?
2.4.80 Why is a consistent tone at the top important to the control
environment?
2.4.90 What drives the tone at the top?
2.4.100 How does an entity document and demonstrate the tone at
the top?
2.4.110 What is the importance of those charged with governance
demonstrating independence and exercising oversight of
ICFR (Principle 2)?
2.4.120 How is the control environment influenced by the
independence of those charged with governance?
2.4.130 What is the importance of management establishing
structure, authorities and responsibilities (Principle 3)?
2.4.140 What is the importance of an entity’s ability to attract,
develop and retain talent (Principle 4)?
2.4.150 What is the importance of holding individuals accountable for
ICFR (Principle 5)?
Examples
2.4.10 Controls that may be in place to address Principle 1
2.4.20 Controls that may be in place to address Principle 2
2.4.30 Controls that may be in place to address Principle 3
2.4.40 Controls that may be in place to address Principle 4
2.4.50 Controls that may be in place to address Principle 5
2.5 Risk assessment
Questions
2.5.10 What is the risk assessment component of ICFR?
2.5.20 What is the relevance of risk assessment to ICFR?
2.5.30 What is an entity-level risk assessment?
2.5.40 At what level within the entity is risk assessment performed?
2.5.50 How is an entity-level risk assessment typically
documented?
2.5.60 When should an entity's risk assessment process be
documented?
2.5.70 When does an entity perform its entity-level risk assessment
process?

2.5.80 What are the principles in the COSO Framework related to

the risk assessment component?
2.5.90 What is the importance of specifying objectives to identify
and assess risks (Principle 6)?
2.5.100 What is the importance of identifying risks to the
achievement of objectives across the entity and performing
an analysis on how to manage them (Principle 7)?
2.5.110 What factors does an entity consider as part of their risk
assessment to demonstrate that Principle 7 is ‘present’ and
‘functioning’?
2.5.120 What is the importance of an entity considering the potential
for fraud in assessing risks to the achievement of objectives
(Principle 8)?
2.5.130 What types of misstatements are relevant to consideration of
fraud risks?
2.5.140 What are fraud risk factors?
2.5.150 What is the step an entity takes after identifying fraud risk
factors?
2.5.160 How is materiality considered in an entity's fraud risk
assessment?
2.5.170 How are those charged with governance involved in an
entity's fraud risk assessment?
2.5.180 What is the importance of an entity identifying and assessing
changes that could impact ICFR (Principle 9)?
2.5.190 What types of changes to ICFR should be identified and
assessed as part of Principle 9?
Examples
2.5.10 Controls that may be in place to address Principle 6
2.5.20 Controls that may be in place to address Principle 7
2.5.30 Controls that may be in place to address Principle 8
2.5.40 Controls that may be in place to address Principle 9
2.6 Information and communication
Questions
2.6.10 What is the information and communication component of
ICFR?
2.6.20 What is the relevance of information and communication to
ICFR?
2.6.30 What are the principles in the COSO Framework related to
the information and communication component?

2.6.40 What is the importance of an entity obtaining or generating

and using relevant, quality information to support the
functioning of internal control (Principle 13)?
2.6.50 What is the role of IT systems in the entity's information
systems relevant to financial reporting?
2.6.60 Are general IT controls part of the information and
communication or control activities component of ICFR?
2.6.70 Are third-party service providers and business partners part
of the information and communication component of ICFR?
2.6.80 What is the difference between Principle 13 and the control
activities component of ICFR related to IT?
2.6.90 What is the importance of an organization internally
communicating information necessary to support the
functioning of internal control (Principle 14)?
2.6.100 What are management’s communication responsibilities?
2.6.110 What channels are used to internally communicate
information related to financial reporting and ICFR?
2.6.120 What is the importance of an entity communicating with
external parties regarding ICFR (Principle 15)?
2.6.130 How does an entity communicate with external parties?
Examples
2.6.10 Controls that may be in place to address Principle 13
2.6.20 Controls that may be in place to address Principle 14
2.6.30 Controls that may be in place to address Principle 15
2.7 Monitoring activities
Questions
2.7.10 What is the monitoring activities component of ICFR?
2.7.20 What is the relevance of monitoring activities to ICFR?
2.7.30 What are the principles in the COSO Framework related to
the monitoring activities component of ICFR?
2.7.40 What is the importance of an entity performing ongoing
and/or separate evaluations of their ICFR (Principle 16)?
2.7.50 How does an entity demonstrate that it has met Principle 16?
2.7.60 What are ongoing evaluations?
2.7.70 Are monitoring business performance and ongoing
monitoring activities the same?
2.7.80 What are the benefits of ongoing evaluations?
2.7.90 What are separate evaluations?
2.7.100 What parties can perform separate evaluations?

2.7.110 When might an ongoing evaluation be more appropriate than

a separate evaluation and vice versa?
2.7.120 When might an entity increase the extent of its monitoring
activities?
2.7.130 How might an entity increase the extent of its monitoring
activities?
2.7.140 Can an entity's monitoring activities be accomplished entirely
through separate evaluations?
2.7.150 Should an entity have monitoring activities over processes
and controls performed by third-party service providers?
2.7.160 How are monitoring activities different from process control
activities?
2.7.170 What is a flux analysis?
2.7.180 Can a flux analysis be a process control activity?
2.7.190 When separate evaluations are used as part of monitoring
procedures, is testing of controls performed?
2.7.200 How are entity-level controls evaluated and tested and how
does that differ from evaluating and testing control activities?
2.7.210 How are process control activities evaluated and tested as
part of monitoring activities?
2.7.220 How are general IT controls evaluated and tested as part of
monitoring activities?
2.7.230 What are examples of entity- (or group-) level monitoring
activities implemented in a multi-component or multi-location
setting?
2.7.240 Can entity-level monitoring activities be relied on to eliminate
the need to rely on or evaluate controls at the entity’s
individual locations or components?
2.7.250 To what extent can external auditors rely on the entity’s
monitoring activities?
2.7.260 What documentation standard is management held to with
respect to its monitoring activities?
2.7.270 What is the importance of an entity maintaining, tracking and
communicating deficiencies in ICFR to those parties
responsible for taking corrective action and those charged
with governance (Principle 17)?
2.7.280 How does an entity maintain, track and communicate
deficiencies in ICFR to executive management and the Audit
Committee (Principle 17)?
2.7.290 What is communicated when a control deficiency is identified
and who is it communicated to?

2.7.300 How does an entity monitor whether corrective actions to

remediate control deficiencies take place?
2.7.310 How does an entity monitor if corrective actions to remediate
a control deficiency take place in a timely manner?
Examples
2.7.10 Ongoing evaluations: KPIs
2.7.20 Ongoing evaluations: Control testing status
2.7.30 Financial statement review
2.7.40 Management meeting to assess risks
2.7.50 Communication of deficiencies and corrective actions
Key takeaways

2.1 Management’s ICFR journey

2. Entity-level controls

9. Identify and evaluate deficiencies

3. Risk assessment

4. Process understanding

5. Process control activities

6. Information used in controls 7. General IT controls 8. Service organizations

Entity-level controls represent a broad range of controls that operate at the

entity level instead of the process level. They often have an indirect relationship
to financial reporting because they are designed to operate through a top-down
approach.

The board of directors and others charged with governance play an important
role in identifying, implementing, executing and monitoring the effectiveness of
entity-level controls. Within this chapter, ‘those charged with governance’ is
used to capture the board of directors, audit committee and any others that are
charged with governance of the entity.

After discussing the basics of entity-level controls, this chapter concentrates on

those controls in the context of each internal control component (except for
process control activities, which are discussed in chapter 5) by:

• providing additional information about each component;

• highlighting the specific principles related to each component; and
• identifying and providing examples of entity-level controls related to the
principles.

Appendix A includes the COSO Framework’s points of focus, which are

important characteristics of each principle and help management to:

• design, implement and conduct an integrated system of ICFR; and

• assess whether controls responsive to each principle are designed and
operating, and therefore, the principles are present and functioning.

Abbreviations

We use the following abbreviations in this chapter.

COSO Committee of Sponsoring Organizations of the Treadway

Commission
GAAP Generally accepted accounting principles
GITC General IT control
ICFR Internal control over financial reporting
PCAOB Public Company Accounting Oversight Board

RMM Risk of material misstatement

SEC Securities and Exchange Commission
SOC System and Organization Controls

2.2 The COSO Framework

Question 2.2.10
What are the five components of ICFR?

Interpretive response: The five components of ICFR are the interrelated

elements of internal control established by the COSO Framework that must be
present and functioning for an effective integrated system of internal controls.

The table below describes each of these components further.

Control environment Risk assessment

(section 2.4) (section 2.5, chapters 3 and 4)
The control environment includes: Risk assessment is a dynamic, iterative
• the set of standards, processes and process for:
structures that provide the basis for • identifying and analyzing risks to
carrying out ICFR; and achieving the entity's objectives;
• the attitudes, awareness and actions • identifying the risks to manage; and
of those charged with governance • determining how to manage the
and management concerning the risks identified.
entity's ICFR and its importance. As part of risk assessment, management
The control environment also: considers possible changes that may
impede the entity's ability to achieve its
• sets the tone at the top of the entity;
objectives. These changes can be
• influences the control present in the external environment
consciousness of its people; and and/or within their own business.
• provides the overall foundation for
the operation of other components
of the entity's ICFR.

Information and communication Control activities

(section 2.6 and chapter 6) (chapters 5 and 7)

The information and communication Control activities are actions, governed

component addresses: by established policies and procedures,
• the importance of information that directly address financial reporting
management and continuous risks.
communication between and among Control activities are performed:
those responsible for ICFR, both • at all levels of the entity;
internal and external; and
• at various stages within business
• how reliable information from both processes relevant to ICFR; and
internal and external sources is
needed to support the functioning of • over the consistent and effective
the other four components of operation of technology relied on in
internal control. ICFR.

Monitoring activities (section 2.7)

Monitoring activities are required to:
• determine whether controls are designed and operating to evidence the five
components of internal control, and each principle associated with those
components, are present and functioning;
• determine that the established controls function in a manner to effectively address
the current risks to the entity’s financial reporting process; and
• identify deficiencies in internal control and communicate those deficiencies to the
parties responsible for taking corrective action, including those charged with
governance, as relevant.
Monitoring activities may include ongoing evaluations, separate evaluations that are
performed periodically, or a combination of both.

Question 2.2.20
Are the five components of ICFR interrelated?

Interpretive response: For a system of internal controls to be effective, each of

the five components of internal control and the related principles must be
present and functioning, and the five components must operate together in an
integrated manner.

To understand the importance of the five components operating together in an

integrated manner, think of the five components of internal control as different
parts of a house (e.g. roof, foundation, walls). Each component plays a unique
but important role contributing to an entity's overall system of ICFR. If one
component is missing or not functioning properly, the implications to an entity's
overall system of ICFR can be significant – like a house without walls or a
foundation.

Monitoring
Information and

communication

Control activities

Risk assessment

Control environment

Question 2.2.30
What are COSO principles as they relate to the five
components of ICFR?
Interpretive response: The COSO Framework includes 17 principles that
underpin each of the five components of ICFR as fundamental concepts. The 17
principles form the basis for designing an effective integrated system of ICFR.

For an ICFR system to be ‘effective,’ each of the five components, including the
principles within each component, must be present and functioning.

‘Present’ refers to the determination that components and relevant principles

exist in the design and implementation of the entity’s system of ICFR.

‘Functioning’ refers to the determination that components and relevant principles

continue to exist in the operation of the entity’s system of ICFR.

Appendix A includes the COSO Framework’s points of focus, which are

important characteristics of each principle and help management to:

• design, implement and conduct an integrated system of ICFR; and

• assess whether controls responsive to each principle are designed and
operating, and therefore, the principles are present and functioning.

Question 2.2.40
Does management need to have controls that address
each of the 17 COSO principles?
Interpretive response: Yes. The COSO Framework views all five components
and all 17 principles as relevant to an integrated system of internal controls,
irrespective of the entity or its objectives. Controls must be designed and
operating under each of the 17 principles to demonstrate that the principle has
been achieved.

Often, entities will start by taking a bottoms-up approach to map existing

controls within the entity’s process to each of the 17 principles to determine
whether there are controls under each principle. Caution should be exercised
because missing from this approach might be an overall assessment, or a top-
down evaluation, of whether the controls that have been mapped are sufficient
to demonstrate that the principle has been achieved. Typically, the number of
controls and nature of controls under each principle will vary from entity to entity
based on the nature of the business and results of the entity’s own risk
assessment.

A control deficiency exists in the entity’s system of ICFR if:

• insufficient controls exist to demonstrate that the principle has been

achieved; and/or
• controls are not designed appropriately to address the principle.

Practical tip
Due to their nature, some controls address multiple principles, even across
different components. For example, having a code of conduct and effective
communication about it via the entity’s intranet and annual compliance training
can address both:

• Principle 1 (see Question 2.4.60) because it demonstrates a commitment to

integrity and ethical values; and
• Principle 14 (see Question 2.6.90) because it shows how the commitment to
integrity and ethical values is communicated.

2.3 Entity-level controls: The basics

Question 2.3.10
What are entity-level controls?

Interpretive response: Entity-level controls describe a broad range of controls

that operate at the entity level rather than at the process level. Entity-level
controls include established policies, procedures and structures that have an
important but indirect relationship to financial reporting. This is because they are
designed to operate through a top-down approach to address the principles
under control environment, risk assessment, information and communication,
and monitoring within an entity’s overall integrated system of ICFR.

Question 2.3.20
How do entity-level controls differ from process control
activities?
Interpretive response: Process control activities (addressed in detail in chapter
5) are designed to operate at a level of precision that ‘would’ adequately
prevent, or detect and correct, misstatements on a timely basis. In contrast,
entity-level controls usually have an indirect, but still important, effect on the
likelihood that a misstatement will be prevented or detected on a timely basis –
a ‘could’ level of precision. Rather than directly mitigating a risk, entity-level
controls are typically policies, procedures, processes and structures that support
the effective operation and oversight of the entity’s system of ICFR, including
process control activities.

Entity-level controls support control activities, which include process control

activities, by facilitating the existence of:

• an environment in which control activities can operate effectively;

• a process to identify risks to financial reporting that need to be addressed by
control activities; and
• activities to monitor the effectiveness of the control activities.

Question 2.3.30
What is a ‘would’ level of assurance for a control?

Interpretive response: Process control activities operate at a ‘would’ level of

assurance. 'Would' means 'probable' in the context of designing process control
activities to prevent or detect and correct material misstatements in the entity’s
financial statements.

Process control activities, unlike entity-level controls, must be selected and

developed by an entity to directly mitigate the identified risks to the achievement
of financial reporting objectives to acceptable levels. The COSO Framework’s
objective is for the entity’s ICFR to achieve reasonable assurance – meaning
process control activities must be designed and functioning to make it ‘probable’
the entity will achieve its financial reporting objectives. Absolute assurance is
not possible due to limitations inherent in in all systems of internal control, such
as human error, judgment uncertainty and events outside management’s
control.

For a control to function properly as a process control activity, it needs to be

designed and operated in a manner to confidently support that it ‘would’ (i.e.
probably will) prevent, or detect and correct, a material misstatement in
response to the risk being addressed. Question 2.3.20 discusses how process
control activities differ from entity-level controls.

Question 2.3.40
What is a ‘could’ level of assurance for a control?

Interpretive response: Entity-level controls require at least a ‘could’ level of

assurance. ‘Could’ means ‘may’ or ‘might’ in the context of a control’s ability to
prevent or detect a material misstatement to the entity's financial statements. It
does not mean ‘probable.’

Entity-level controls typically function at the ‘could' level as they could alert an
entity to the existence of a potential error or misstatement in financial reporting;
however, they do not operate at a precise enough level of detail to provide
reasonable assurance (e.g. probable) that the financial statements will be free
from material misstatement.

For example, a monitoring control that reviews the fluctuation in consolidated

financial statement account balances year-over-year may identify an unusual
fluctuation that management investigates further. However, the act of

performing the fluctuation analysis itself does not directly address the risk as to
whether the transactions in the account were processed completely and
accurately (e.g. at the assertion level within the process).

Due to their lack of precision, entity-level controls are not likely to mitigate the
risk that the financial statements will be free from material misstatement to an
acceptable level.

Question 2.3.50
How does an entity evidence that entity-level controls
are designed and operating?
Interpretive response: Management is required to prepare and retain sufficient
documentation to:

• evidence the entity-level controls designed and implemented to achieve the

principles of each component of internal control addressed individually
and/or in combination with other controls; and

• evidence the entity-level controls are operating as intended in an integrated

manner.

Management assumes a greater responsibility for detailed documentation when

it asserts to regulators, shareholders or other third parties that the entity’s ICFR
is effective. In cases where an external auditor attests to the effectiveness of an
entity’s system of internal control, management will likely be expected to provide
the auditor with support for its assertion on the effectiveness of its ICFR.

The extent of evidence will vary based on the nature of the control. By nature,
entity-level controls often require less extensive documentation in comparison to
control activities. This is because entity-level controls operate at a higher level
of precision and are related to control components and principles generally
achieved through the establishment of policies, procedures and structures
operating at the top levels. As a result, the operation of entity-level controls can
often be evidenced through inspection and observation of published
documentation already made available to those responsible for ICFR.

However, in general, management is expected to retain documentation that

would enable someone with reasonable knowledge of the entity and financial
reporting to understand the design and operation of the control. The
documentation is also expected to show the results of operating the control,
including any further investigation required to conclude the control is designed
and operating.

For example, consider an entity-level control related to the control environment

whereby the entity's ethics and compliance committee has established policies
and procedures to identify and address improprieties and noncompliance by
employees, third-party service providers, and other business partners. When
determining the documentation necessary to support the operation of this
control, the documentation must include evidence that there is a process for

identifying, assessing and evaluating the financial reporting implications of

noncompliance matters. In addition, documentation must exist to evidence that:

• instances of noncompliance requiring investigation were appropriately

captured;

• the severity of noncompliance matters was appropriately assessed on a

timely basis;

• the investigation into noncompliance matters was conducted in accordance

with the entity's policies based on the severity assessed; and

• the financial reporting implications of noncompliance matters were properly

evaluated by an appropriate member of the accounting and financial
reporting department on a timely basis.

Practical tip
It is important that documentation of entity-level controls is available and
sufficiently detailed to demonstrate that the entity-level controls are designed
and operating effectively. Often entity-level controls may be carried out through
meetings, either between key members of management or those charged with
governance, or both. Due to the timing and nature of these meetings, those
performing monitoring or testing may not be able to directly observe (i.e. attend)
the meetings where the entity-level controls operate. Therefore, the minutes,
agendas and materials related to the meeting are the primary evidence of the
discussions held and conclusions reached (i.e. the operation of the entity-level
control). For those materials to sufficiently evidence the operation of the control,
they should be detailed, finalized, and approved timely.

Question 2.3.60
What is considered when designing and documenting
an entity-level control?
The following table sets out the items considered when designing an entity-level
control. The considerations in the table should also be present in the
documentation (see Question 2.3.50) for each entity-level control. Some
considerations only apply to manual controls, where indicated.

Section/
Considerations Description Question
The principle the control is intended to address. 5.5
Control objective
This is achieved using control attributes.
‘Nature’ refers to whether the control is manual or 5.6
Nature and type automated.
of control ‘Type’ refers to whether the control is preventive or
detective.
The frequency with which a manual control is 5.7
Frequency
performed, which could be:

Section/
Considerations Description Question
• annually;
• quarterly;
• monthly;
• weekly;
• daily;
• recurring; or
• ad hoc.
Authority and The level of competence and authority necessary to 5.8
competence of operate a manual control (i.e. is the right person
the control performing the control?).
operator (see
Question 5.4.40)
Information used Information is usually used when performing a 2.3.70
in the manual control (e.g. system reports, manually
performance of prepared spreadsheets, queries), including the
the control relevant data elements (see Question 6.2.40).

Practical tip
Clear and concise documentation of the design of entity-level controls
(addressing the considerations in the preceding table) provides evidence to
support the achievement of the ICFR principles. Clear documentation of the
design of the entity-level control also enables management to perform separate
evaluations necessary to monitor that the ICFR principles are present and
functioning.

For example, if the design of a control is not clear in its documentation, the
control may fail to function properly if the control operator leaves the entity and
the control needs to be reassigned to a new person.

Question 2.3.70
How does the control operator consider the relevance
and reliability of information used in entity-level
controls?
Interpretive response: Prevalent throughout an entity’s system of ICFR,
information must be sufficiently relevant and reliable for use in controls. To
establish the relevance and reliability of information used in entity-level controls,
the control operator should understand the source and the nature of the
information used.

If the control operator assumes that information used in a control is relevant and
reliable without having a basis for that assumption, the information may contain
errors that could lead to incorrect conclusions about the entity-level control.

The assessment of relevance and reliability for information used should be

included in the control operator’s documentation as part of the design and
operation of the entity-level control.

Example 2.3.10
Evaluating the reliability of information used in
whistleblower hotline entity-level control
Background: On a quarterly basis, those charged with governance monitor the
calls received through the entity’s whistleblower hotline, which is operated by a
third-party operator. The individual responsible for assessing the content of calls
received through the hotline prepares a presentation to summarize calls
received for those charged with governance. The summary is supported by
reporting received from the third-party operator provided along with the
presentation.

On behalf of those charged with governance, a separate evaluation is

performed by Internal Audit at least annually to assess whether the
whistleblower hotline is operating effectively by conducting a test call and
ensuring the details of the test call are completely and accurately captured in
the third-party operator’s reporting back to those charged with governance.

Assessment: The control operator concludes within the entity-level control

documentation that the information used in the entity-level control (listing of calls
received through the whistleblower hotline presented to those charged with
governance) is:

• relevant, because the information details reports received through the

hotline during the quarter; and
• reliable, because the information is sourced from the third-party operator’s
reporting, which is monitored for completeness and accuracy.

Question 2.3.80
Is management required to test entity-level controls?

Interpretative response: Yes. Entity-level controls are tested as part of

monitoring if management determines it appropriate to perform separate
evaluations as part of their monitoring activities (see Question 2.7.200).

2.4 Control environment

Question 2.4.10
What is the control environment component of ICFR?

Interpretive response: The control environment component of ICFR is the set

of standards, processes and structures that provide the basis for carrying out
internal controls across an entity.

The control environment includes:

• the integrity and ethical values of the organization;

• the structure and oversight of those charged with governance;
• the governance, roles and responsibilities of management functions;
• the process for attracting, hiring and retaining competent individuals; and
• the rigor around performance measures and rewards to drive accountability
for performance of internal control responsibilities

Those charged with governance and management set the tone at the top
regarding the importance of internal control including the expected standards of
conduct. Management also reinforces expectations at all levels of the
organization relevant to financial reporting.

Question 2.4.20
Does the control environment encompass all levels of
an entity?
Interpretive response: Yes. The control environment underpins how ICFR is
carried out across all levels of the entity. An entity likely will need to assess the
effectiveness of the control environment at levels below the parent or corporate
level (e.g. regions, divisions, operating units, functional areas).

Question 2.4.30
Does the control environment encompass third-party
service providers?
Interpretive response: Yes. The control environment includes third-party
service providers (e.g. a third-party that provides payroll processing) and
business partners. Although the entity may rely on an outsourced service
provider to conduct business processes, policies and procedures on behalf of
the entity, management retains ultimate responsibility for ICFR effectiveness,
including the controls around risks associated with outsourced activities.
Therefore, third-party service providers must be considered in designing

effective entity-level controls to ensure principles within the control environment

are present and functioning.

Question 2.6.70 discusses further considerations for third-party service

providers in entity-level controls.

Question 2.4.40
What is the relevance of the control environment to
ICFR?
Interpretive response: Entity-level controls addressing the principles of the
control environment provide the foundation on which the other components of
ICFR are able to function properly.

Monitoring
Information and

communication
Control activities

Risk assessment

Control environment

If an entity lacks the overall governance, structure or tone at the top to promote
and manage the entity’s system of ICFR, it is more likely that deficiencies exist
in other areas of the entity’s system of ICFR.

Question 2.4.50
What are the principles in the COSO Framework
related to the control environment component of ICFR?
Interpretive response: There are five principles necessary for an effective
control environment within a system of ICFR. Designing and putting in place
controls that collectively achieve all five principles demonstrates that the control
environment is established appropriately to support the rest of the entity’s
system of ICFR.

Control environment
The organization demonstrates a commitment to integrity and ethical
Principle 1
values.

Control environment
The board of directors demonstrates independence from
Principle 2 management and exercises oversight of the development and
performance of internal control.
Management establishes, with board oversight, structures, reporting
Principle 3 lines, and appropriate authorities and responsibilities in the pursuit of
objectives.
The organization demonstrates a commitment to attract, develop, and
Principle 4
retain competent individuals in alignment with objectives.
The organization holds individuals accountable for their internal
Principle 5
control responsibilities in the pursuit of objectives.

Source: COSO Internal Control – Integrated Framework (2013).

Question 2.4.60
What is the importance of an entity demonstrating a
commitment to integrity and ethical values (Principle
1)?
Interpretive response: The effectiveness of controls cannot rise above the
integrity and ethical values of the people who create, administer and monitor
them (i.e. tone at the top).

Integrity and ethical behavior are the product of the entity's ethical and
behavioral standards or codes of conduct and how they are communicated and
reinforced in practice.

The communication of entity policies on integrity and ethical values may include
the communication of behavioral standards to personnel through policy
statements, codes of conduct and by example.

The reinforcement of entity policies on integrity and ethical values may occur
through management’s actions to eliminate or mitigate incentives or temptations
that might promote personnel to engage in dishonest, illegal or unethical acts.

Question 2.4.70
What is the tone at the top?

Interpretive response: The tone at the top of an entity comes from

management and those charged with governance leading by example in
creating and maintaining the entity's culture by developing values, a philosophy
and an operating style for the entity. An appropriate tone at the top and
throughout the organization is fundamental to the effective functioning of an
internal control system.

Question 2.4.80
Why is a consistent tone at the top important to the
control environment?
Interpretive response: A consistent tone from those charged with governance
and management (including at operating units) helps establish a common
understanding of the values, business drivers and expected behavior of
employees and partners of the entity.

Not having a consistent tone at the top to support a strong culture of internal
control undermines the awareness of risk and can lead to:

• inappropriate responses to risks;

• lack of focus and discipline around control activities that may result in
deficiencies in their design and operating effectiveness;
• lack of information and miscommunication; and
• lack of action on feedback from monitoring activities.

The consistency of the tone at the top can therefore either drive or impede
internal control; for example:

Drivers Impediments
• History of consistent ethical and • Personal indiscretions
responsible behavior by • Lack of receptiveness to bad news
management and those charged with • Unfairly balanced compensation
governance practices
• Demonstrated commitment to
addressing misconduct

These behaviors could positively or negatively affect an entity’s culture and its
employees’ conduct and integrity. Employees are likely to develop the same
attitudes about right and wrong – and about risks and controls – as those shown
by management.

Question 2.4.90
What drives the tone at the top?

Interpretive response: The tone at the top is driven by the following

characteristics of management and those charged with governance:

• operating style;
• personal conduct;
• attitudes toward risk;
• approach to making judgments (e.g. conservative versus aggressive
positions on estimates and policy choices); and
• degree of formality (e.g. potential for more informal controls in a small family
business).

Question 2.4.100
How does an entity document and demonstrate the
tone at the top?
Interpretive response: An entity often documents and demonstrates the
expectations of management and those charged with governance in the form of:

• missions and value statements;

• standards or codes of conduct;
• policies and practices; and
• operating principles, directives, guidelines and other supporting
communications.

Management and those charged with governance also demonstrate the tone at
the top through their:

• actions and decisions;

• attitudes and responses to violations and deviations; and
• informal and routine communications.

Practical tip
Tone at the top and other control environment entity-level controls are
sometimes evidenced through meetings of the Board of Directors and other
subcommittees. The minutes of these meetings should be at a detailed enough
level to provide evidence of the nature of the discussions and how the entity has
met the related principle. In addition, these minutes should be approved in a
timely manner (e.g. at the following meeting, or if meetings are sparse/annual,
via other methods).

Example 2.4.10
Controls that may be in place to address Principle 1
Principle 1: The organization demonstrates a commitment to integrity and
ethical values.

Example controls that may be in place to address Principle 1 include:

• The code of conduct defines and communicates expectations on integrity,

ethical values and compliance with laws and regulations at all levels of the
entity and key external parties.

• The ethics and compliance committee ensures all employees and key
external parties acknowledge receipt of the code of conduct and confirm
compliance status annually.

• All employees complete training on the code of conduct.

• The ethics and compliance committee establishes policies and procedures

to identify and address improprieties and noncompliance with the code of

conduct and other matters by employees, third-party service providers and

other business partners.

• The CEO's quarterly newsletter emphasizes the importance of ethics and

compliance with the code of conduct.

Question 2.4.110
What is the importance of those charged with
governance demonstrating independence and
exercising oversight of ICFR (Principle 2)?
Interpretive response: The entity's control consciousness is influenced by
those charged with governance because one of their roles is to counterbalance
pressures on management in relation to financial reporting that may arise from
market demands or remuneration schemes.

The importance of ICFR oversight responsibilities being held by those charged

with governance is recognized in codes of practice and other laws and
regulations, as well as guidance produced for their benefit.

The independence of those charged with governance is important due to their

responsibility to question and evaluate the activities of management.

Question 2.4.120
How is the control environment influenced by the
independence of those charged with governance?
Interpretive response: When independent of management, those charged with
governance provide value to the oversight of ICFR through their impartiality,
healthy skepticism and unbiased evaluation. This independence allows them to
question and scrutinize management's activities, present alternative views, and
have the courage to act in the face of obvious or suspected wrongdoing.

Example 2.4.20
Controls that may be in place to address Principle 2
Principle 2: The board of directors demonstrates independence from
management and exercises oversight of the development and performance of
internal control.

Example controls that may be in place to address Principle 2 include:

• the board of directors establishes its roles and responsibilities for the
oversight of internal control;

• the board of directors’ risk and governance committee oversees the content
and communication of the code of conduct, as well as investigation and
resolution of noncompliance;

• based on its charter, the audit committee is primarily responsible for

overseeing external financial reporting and ICFR;

• the board of directors oversees the design and effective operation of whistle
blower procedures; and

• the board of directors completes a directors and officers (D&O)

questionnaire each year, which is reviewed by the entity’s general counsel
to identify potential independence matters.

Practical tip
When an entity uses D&O questionnaires to evidence Principle 2 (independence
from management), management should consider:

• the timeliness of the questionnaire;

• the completeness of the population of individuals that fill out the

questionnaire;

• whether the questionnaire is sufficiently robust in nature to prompt

considerations of potentially uncommon relationships or other independence
matters;

• the sufficiency of the control in place to review the questionnaires; and

• the process in place to ensure that any related-party relationships identified

in the questionnaires are included on the related-party listing.

Question 2.4.130
What is the importance of management establishing
structure, authorities and responsibilities (Principle 3)?
Interpretive response: Management and those charged with governance
establish the organizational structure and reporting lines to carry out their
oversight responsibilities. Along with delegating authority and responsibility, the
structure provides accountability to management and other personnel.
Competency should be considered as part of proper application of how authority
and responsibility are delegated.

Example 2.4.30
Controls that may be in place to address Principle 3
Principle 3: Management establishes, with board oversight, structures, reporting
lines, and appropriate authorities and responsibilities in the pursuit of objectives.

Example controls that may be in place to address Principle 3 include:

• The entity uses organization charts and documented authorization policies

to establish reporting lines, and to define, assign and limit authorities and
responsibilities. This documentation is revised to respond to change as
needed and is communicated throughout the organization.

• The entity’s Operating Policies and Procedures Manual details the monetary
commitment and transaction approval authorities of management and
employees for each occurrence. Exceeding the individual transaction’s
authority requires approval from the appropriate member of higher-level
management, up to and including the CEO.

Question 2.4.140
What is the importance of an entity’s ability to attract,
develop and retain talent (Principle 4)?
Interpretive response: Effective ICFR is designed, implemented and carried
out by employees of the entity. If an entity does not have appropriate programs
and processes in place to attract, develop and retain competent individuals,
there may not be enough employees with the right level of competence and
authority (see section 5.8 for further discussion) to perform the controls as
designed. In turn, this may result in deficiencies in other components of ICFR.

Example 2.4.40
Controls that may be in place to address Principle 4
Principle 4: The organization demonstrates a commitment to attract, develop,
and retain competent individuals in alignment with objectives.

Example controls that may be in place to address Principle 4 include:

• the entity identifies the competencies needed to support effective financial

reporting and ICFR, evaluates competencies across the entity and at
external service providers, and acts to address gaps;

• the entity establishes policies to attract employees, third-party service

providers and other professionals with sufficient competencies, and
provides training to maintain and develop sufficiently competent personnel;
and

• the entity establishes contingency, and succession plans to prepare for

re-assignment of financial reporting and ICFR responsibilities in the event of
changes in leadership.

Question 2.4.150
What is the importance of holding individuals
accountable for ICFR (Principle 5)?
Interpretive response: Along with the other principles, holding individuals
accountable for their internal control responsibilities helps to enforce the entity’s
commitment to ICFR, as well as values of integrity and ethics. By connecting
internal control responsibilities to established performance measures,
management and those charged with governance reinforce the tone at the top
that ICFR is important to the entity at all levels.

Example 2.4.50
Controls that may be in place to address Principle 5
Principle 5: The organization holds individuals accountable for their internal
control responsibilities in the pursuit of objectives.

Example controls that may be in place to address Principle 5 include:

• Quarterly, the director responsible for compliance with the Sarbanes-Oxley

Act asks employees with internal control responsibilities (control operators)
to:
— confirm their accountability; and
— represent they have fulfilled their internal control responsibilities during
the quarter, highlighting any exceptions.

• The entity’s performance incentive plans establish performance measures

that:
— incorporate ICFR and ethical responsibilities;
— consider excessive pressures; and
— provide rewards or penalties, as appropriate.

• The entity’s annual employee performance reviews and employee incentive

rewards reinforce expected standards of behavior, consistent with the
entity's code of conduct, including:
— adherence to their ICFR responsibilities;
— evaluation of their competencies; and
— achievement of business goals.

2.5 Risk assessment

Question 2.5.10
What is the risk assessment component of ICFR?

Interpretive response: An entity's risk assessment process relevant to the

preparation of the financial statements includes the entity's processes to:

Assess the likelihood

Identify business
and significance of Decide what actions
risks relevant to
misstatements to take in response to
financial reporting
resulting from the those risks
objectives
risks identified

Risk assessment involves a dynamic and iterative process for identifying and
assessing risks to the achievement of objectives. Rarely in practice do entities
formally identify and assess risks on a daily basis. Risk assessment is often an
annual process or may be quarterly, depending on the entity's financial reporting
requirements. In addition, changes in the external environment or within an
entity's own business model result in the need for identification and assessment
of new risks by management and/or the reconsideration of prior risk
assessments.

Question 2.5.20
What is the relevance of risk assessment to ICFR?

Interpretive response: Risk assessment is an important component of ICFR

because it forms the basis for how management:

• identifies and analyzes risks relevant to its financial reporting objectives;

and
• determines the risks to be managed.

Failure to perform an appropriate risk assessment process may lead to:

• unidentified / unaddressed risks relevant to an entity’s financial reporting

objectives;
• ineffectively designed control activities; and
• increased possibility of a misstatement in the financial statements.

Using the house example, the risk assessment process is the blueprint or map
of the house, which is needed for the house to be appropriately designed and
built.

Monitoring

Information and

communication
Control activities

Risk assessment

Control environment

Question 2.5.30
What is an entity-level risk assessment?

Interpretive response: The entity-level risk assessment is the top level of an

entity's risk assessment process. It refers to the risk assessment performed at
the level of the consolidated entity and its components, which may be
subsidiaries, divisions or entities or business units.

The identification and assessment of ICFR-related risks at the entity level helps
ensure that the entity has identified a comprehensive population of risks to the
achievement of its financial reporting objectives. Chapter 3 provides more
information on considerations in performing an effective risk assessment, and
chapter 4 dives into process-level risk assessment, which accompanies the
entity-level risk assessment.

Question 2.5.40
At what level within the entity is risk assessment
performed?
Interpretive response: The COSO Framework makes it clear that, for purposes
of ICFR, management should perform its risk assessment at various levels
within the entity. This is a top-down approach that starts at the entity level and
moves down to the business process level to identify risks to preparing financial
statements free from material misstatement.

Question 2.5.50
How is an entity-level risk assessment typically
documented?
Interpretive response: Entities can evidence their entity-level risk assessment
in multiple ways, including through:

• a formal Business Risk Assessment that had been provided to the Risk and
Governance Committee for input and approval, which includes identifying,
assessing and making plans to mitigate the related operational and
compliance risks;

• analyzing business plans and associated business risks from Business Risk
Assessment meetings to identify and assess associated financial reporting
risks related to significant accounts;

• analyzing business plans and associated business risks from the Business
Risk Assessment meetings to identify and assess associated financial
reporting risks related to significant accounts;

• the ICFR Risk and Control Matrix, which is accessible to employees with
ICFR roles; and

• the annual plan and financial forecast, that had been provided to the Board
for input and approval.

Proper documentation of the process-level risk assessment discussed in

chapter 4, in conjunction with documentation of the entity-level risk assessment
discussed in this chapter and chapter 3, is necessary to evidence the risk
assessment component of COSO is present and functioning.

Question 2.5.60
When should an entity's risk assessment process be
documented?
Interpretive response: Because much of the risk assessment process takes
place in meetings and discussions – including senior levels of management and
those charged with governance – timely documentation of the risk assessment
activities undertaken by the entity and their results helps demonstrate an
effective assessment of the entity's ICFR.

Question 2.5.70
When does an entity perform its entity-level risk
assessment process?
Interpretive response: Risk assessment at the entity level should be formally
performed, or updated, and documented at least annually.

However, an effective risk assessment process is iterative in nature. The COSO

principles within the risk assessment component of ICFR are not always
considered sequentially given the significant overlap among the principles.
Further, as an entity performs and monitors controls, management may identify
factors that require previous risk determinations to be re-evaluated. Changes in
internal or external factors may indicate a need for re-evaluation.

Question 2.5.80
What are the principles in the COSO Framework
related to the risk assessment component?
Interpretive response: The COSO Framework sets out four principles for the
risk assessment process component of ICFR. Meeting all four principles
demonstrates that controls have been designed and implemented effectively to
meet the risk assessment objectives.

Risk assessment
The organization specifies objectives with sufficient clarity to enable
Principle 6
the identification and assessment of risks relating to objectives.
The organization identifies risks to the achievement of its objectives
Principle 7 across the entity and analyzes risks as a basis for determining how
the risks should be managed.
The organization considers the potential for fraud in assessing risks
Principle 8
to the achievement of objectives.
The organization identifies and assesses changes that could
Principle 9
significantly impact the system of internal control.

Source: COSO Internal Control – Integrated Framework (2013).

Question 2.5.90
What is the importance of specifying objectives to
identify and assess risks (Principle 6)?
Interpretive response: An entity must set its objectives first because it is the
basis on which risk assessment is performed. Once the objectives have been
set, the risks to achieve those objectives can be ascertained.

In the context of financial reporting objectives, typically the objective of ICFR is

to provide reasonable assurance regarding the reliability of an entity’s financial
reporting for external purposes in accordance with US GAAP (or other relevant
accounting framework).

Without clear objectives, risk assessment activities will likely be inefficient and
are likely to result in deficiencies in other components of internal control.

Example 2.5.10
Controls that may be in place to address Principle 6
Principle 6: The organization specifies objectives with sufficient clarity to enable
the identification and assessment of risks relating to objectives.

Example controls that may be in place to address Principle 6 include:

• The entity specifies financial reporting and ICFR objectives that are
consistent with US GAAP and SEC regulations, reflect the entity's activities
and consider materiality.

• The entity's accounting policies for all financial statement accounts,

underlying transactions and disclosures are:
— maintained by the Financial Reporting Manager responsible for SEC
reporting; and
— reviewed and approved by the Corporate Controller and CFO.

• Management assesses materiality at the consolidated financial statement

level at the beginning of the fiscal year, and again as necessary if the
entity's business changes (e.g. the results of operations and financial
position change significantly).

• The entity monitors compliance with laws and regulations that could
potentially have a significant effect on financial reporting in the event of
noncompliance.

Question 2.5.100
What is the importance of identifying risks to the
achievement of objectives across the entity and
performing an analysis on how to manage them
(Principle 7)?
Interpretive response: Once the objective is clearly defined, an entity may
proceed with its risk assessment process at all levels to identify a complete
population of risks that could jeopardize the achievement of the objective.

Once a complete population of risks is identified, the next step is to analyze the
population to design and put in place appropriate control activities responsive to
the risks.

If the risk assessment process is not detailed enough or performed at all

relevant levels of the organization, management may fail to identify control
activities to address all risks that could jeopardize the achievement of the stated
objective.

Additionally, if risks are not properly analyzed and understood by management,

the control activities designed and put in place may fail to mitigate the identified
risks, or alternatively could result in inefficiencies in the performance of control
activities.

Chapter 3 provides detailed guidance on completing a risk assessment at the

entity level, while chapter 4 dives into performing an effective and efficient
process-level risk assessment.

Question 2.5.110
What factors does an entity consider as part of their risk
assessment to demonstrate that Principle 7 is ‘present’
and ‘functioning’?
Principle 7: The organization identifies risks to the achievement of its objectives
across the entity and analyzes risks as a basis for determining how the risks
should be managed.

Interpretive response: To demonstrate that Principle 7 is ‘present’ and

‘functioning,’ an entity considers both internal and external risk factors, as well
as sources of risk. For example, an entity considers those risk factors that affect
the entity's ability to initiate, authorize, process and record transactions and
other adjustments that are reflected in the financial statements.

Chapters 3 and 4 provide more examples of internal and external risk factors
that an entity may consider as part of the risk assessment process.

Example 2.5.20
Controls that may be in place to address Principle 7
Principle 7: The organization identifies risks to the achievement of its objectives
across the entity and analyzes risks as a basis for determining how the risks
should be managed.

Examples of controls that may be in place to address Principle 7 include:

• The Finance Group identifies, analyzes and assesses the significance of

financial reporting risks across the entity, and how it will manage those
risks. This assessment is documented in an ICFR Risk and Control Matrix
available to employees with ICFR roles.

• Internal Audit performs an annual risk assessment to develop the internal

audit plan. The risk assessment is updated periodically to address any
emerging risks.

• The Director of Financial Reporting reviews scoping material, risk

assessments, and other supporting ICFR material completed by the entity’s
operating units to obtain a full population of risks at the entity and determine
how the entity will respond to those risks.

Question 2.5.120
What is the importance of an entity considering the
potential for fraud in assessing risks to the achievement
of objectives (Principle 8)?
Interpretive response: Considering fraud in the risk assessment process is
important because every entity faces some risk of fraud from within.

Specific to ICFR, management’s financial statements could be materially

misstated due to error or fraud. As shown by major corporate fraud scandals in
nearly every decade of the past century, fraud can have a significant negative
effect on an entity's financial reporting process, the reliability of its financial
statements and investor confidence.

The very nature of fraud makes it difficult to detect. It can also evolve and
change over time, which makes fraud prevention or detection even more
difficult. These difficulties elevate the significance of fraud risk to a level
deserving of its own COSO principle, making it clear that an appropriate risk
assessment process should specifically consider the vulnerability of the entity to
fraudulent activity. The SEC also requires the assessment of fraud risks.

To achieve this principle, management makes an informed assessment of

specific areas where fraud might exist (see Question 2.5.140) and then further
analyzes the likelihood of occurrence and potential effect.

Question 2.5.130
What types of misstatements are relevant to
consideration of fraud risks?
Interpretive response: Two basic types of misstatements are relevant when
considering fraud risks.

Fraudulent financial reporting

Description How it's accomplished
Intentional • Manipulating, falsifying or altering accounting records or
misstatements or supporting documentation
omissions of amounts • Misrepresenting or intentionally omitting events,
or disclosures transactions or other significant information from the
designed to deceive financial statements
financial statement
users • Intentionally misapplying accounting policies or principles

Misappropriation of assets
Description How it's accomplished
Theft of an entity's • Embezzling receipts
assets, causing the • Stealing assets
financial statements
to be misstated • Causing an entity to pay for goods or services that have
not been received and may be accompanied by false or

Misappropriation of assets
Description How it's accomplished
misleading records or documents, possibly created by
circumventing controls

Question 2.5.140
What are fraud risk factors?

Interpretive response: Fraud risk factors include a broad range of specific

events and conditions observed or identified that promote or foster an
environment where fraud could occur. Understanding these factors helps
identify where fraud risks may exist.

Identifying fraud risk factors does not necessarily mean that fraud exists or will
eventually occur. But there are three categories of fraud risk factors often
present in circumstances in which fraud exists, which make up the fraud
triangle.

Incentive/
Pressure
Why someone
might commit fraud

Fraud

Attitude/
Rationalization Opportunity
The state of mind The ‘setting’ that
that helps justify helps someone
committing fraud commit fraud

An example of each category of fraud risk factor is included in the following

table.

Category of fraud
risk factor Example

Incentive or An employee may be in financial distress (internal

pressure incentive), or management may be under extreme pressure
to meet financial targets (external incentive). These

Category of fraud
risk factor Example
situations can be a catalyst for committing fraud and could
be internal or external to the entity or the person committing
the fraud.
Deficiencies in entity-level controls or poorly designed
Opportunity control activities can make it easier (or present the
opportunity) for an individual to carry out fraud.
Management's attitude that the entity will meet its targets at
Attitude or
all costs, or an employee justifying the fraud by claiming it
rationalization
doesn't really harm anybody.

See Appendix B for example fraud risk factors.

Question 2.5.150
What is the step an entity takes after identifying fraud
risk factors?
Interpretive response: Once an entity identifies fraud risk factors, it evaluates
whether the identified fraud risk factors, individually or in combination, indicate
that a fraud risk is present. These identified fraud risks then require an
appropriate control activities response, which is discussed in chapter 5.

Question 2.5.160
How is materiality considered in an entity's fraud risk
assessment?
Interpretive response: When identifying and evaluating risks of fraud in the
entity's financial reporting process, and designing and evaluating relevant anti-
fraud controls, the entity considers the quantitative materiality of any potential
misstatements and the qualitative effects of the fraud.

Risks of fraud generally demand careful consideration and response, even if the
misstatements that could arise because of those fraud risks are lower than the
quantitative measure of materiality. Section 3.3 discusses materiality.

Qualitative considerations that an entity may consider as part of its fraud risk
assessment include:

• intent to achieve a particular outcome;

• involvement in the fraud by members of senior management; and
• questions about the pervasiveness of the fraud and its effect on the
reliability of the entire set of financial statements.

Question 2.5.170
How are those charged with governance involved in an
entity's fraud risk assessment?
Interpretive response: The COSO Framework emphasizes the importance of
those charged with governance overseeing the fraud risk assessment process.
This is particularly important when it comes to the risk of management override
of controls. In line with the COSO Framework, those charged with governance
challenge management, depending on the circumstances, when performing this
oversight.

For example, based on the results of the entity's risk assessment process, those
charged with governances might exercise its oversight role by, on a periodic
basis:

• selecting a sample of significant accounting estimates in the financial

statements; and
• reviewing and challenging management's key judgments in these estimates.

Those charged with governance might perform similar oversight for the
accounting and financial reporting of significant unusual transactions and other
matters that may be prone to bias and override of controls.

Example 2.5.30
Controls that may be in place to address Principle 8
Principle 8: The organization considers the potential for fraud in assessing risks
to the achievement of objectives.

Examples of controls that may be in place to address Principle 8 include:

• Internal Audit performs an annual risk assessment that includes

consideration of fraud risks;

• the legal department reviews all proposed related-party transactions over a

threshold, which are then presented to and approved by the board of
directors; and

• General counsel reports all matters to the board of directors, including any
issues reported to the whistleblower hotline and the actions taken.

Question 2.5.180
What is the importance of an entity identifying and
assessing changes that could impact ICFR (Principle
9)?
Interpretive response: When changes occur at an entity (or to the environment
the entity operates in), it can have an impact on ICFR. Unidentified changes can

result in risks not being properly identified and addressed by internal controls.
Many material weaknesses in ICFR are rooted in circumstances where changes
occurred, but the ICFR implications were not identified or thoroughly
considered.

Question 2.5.190
What types of changes to ICFR should be identified and
assessed as part of Principle 9?
Principle 9: The organization identifies and assesses changes that could
significantly impact the system of internal control.

Interpretive response: An entity must identify and assess changes that could
significantly impact its system of internal control. The COSO Framework
provides examples of such changes, including:

• changes in the external environment (e.g. regulatory, economic or physical

environment);
• changes in the business model (e.g. new accounts/transactions, change in
delivery of services, significant acquisitions/dispositions); and
• changes in leadership (e.g. significant personnel changes).

Section 3.7 discusses changes to ICFR in more detail.

Example 2.5.40
Controls that may be in place to address Principle 9
Principle 9: The organization identifies and assesses changes that could
significantly impact the system of internal control.

Examples of controls that may be in place to address Principle 9 include:

• Internal Audit performs an annual risk assessment, which includes

identifying and assessing changes to risks;
• on a quarterly basis, control certifications are sent to all process owners to
confirm controls are in place and operating effectively;
• management performs a risk assessment on newly acquired businesses
and updates the overall entity’s risk assessment; and
• a disclosure committee meeting is held quarterly to discuss any significant
developments or changes during the period.

2.6 Information and communication

Question 2.6.10
What is the information and communication component
of ICFR?
Interpretive response: The scope of the information and communication
component of ICFR is broad. It generally comprises people, business
processes, activities, transactions, information/data elements and IT.

An information system may be located at the entity, its service organization or

both. It is used to generate relevant and quality information used in executing
the entity's business and financial reporting objectives. For example, an
information system can be used to produce and sell an entity’s products and
services and/or measure and record the entity’s performance.

Communication, both internal and external, delivers the information the entity
needs to carry out day-to-day controls. Communication also helps staff
understand their internal control responsibilities and how they help achieve the
entity's objectives.

Information focuses on the aspects of an entity's information system relevant to

financial reporting and ICFR. Even with that narrow focus, this often includes
obtaining an understanding of both:

• how information flows from:

— the initiation and authorization of individual transactions; and
— the occurrence of other events and conditions relevant to financial
reporting.

• how those transactions and other events and conditions are reported in the
financial statements and related disclosures.

Question 2.6.20
What is the relevance of information and
communication to ICFR?
Interpretive response: An entity's ICFR uses information and communication
to achieve its ICFR objectives across all ICFR components. Continuing with the
house example, information and communication are the walls and pipes of the
house.

Monitoring

Information and

communication
Control activities

Risk assessment

Control environment

Information and communication touch all the components and act as a conduit
for interaction between the components and throughout the entity.

The entity's ICFR could be ineffective if control operators don't receive

complete, accurate, appropriate and timely information from both external and
internal sources.

Communication is pervasive to the effective operation of an entity's overall

ICFR. Consider the following two examples.

• Communication of accounting policies – If an entity has written

accounting policies, but does not communicate them consistently across
affected employees, those responsible for financial reporting may not
appropriately account for transactions in accordance with the applicable
financial reporting framework.

• Communication about a legal contingency – If the entity does not have

processes and controls in place to facilitate communication between its
legal and accounting departments about a legal contingency, a higher risk of
material misstatement might exist in this area.

These examples capture the critical importance of having processes and

controls in place to support effective communication about financial reporting
matters.

Question 2.6.30
What are the principles in the COSO Framework
related to the information and communication
component?
Interpretive response: The COSO Framework sets out three principles for the
information and communication component of ICFR. Meeting all three principles
demonstrates that controls have been designed and implemented effectively to
satisfy the information and communication objectives.

Information and communication

The organization obtains or generates and uses relevant, quality
Principle 13
information to support the functioning of internal control.
The organization internally communicates information, including
Principle 14 objectives and responsibilities for internal control, necessary to
support the functioning of internal control.
The organization communicates with external parties regarding
Principle 15
matters affecting the functioning of internal control.

Source: COSO Internal Control – Integrated Framework (2013).

Question 2.6.40
What is the importance of an entity obtaining or
generating and using relevant, quality information to
support the functioning of internal control (Principle
13)?
Interpretive response: It is important for an entity to obtain or generate and
use relevant, quality information to support the functioning of internal control
because doing so affects management's ability to:

• make appropriate decisions in managing and controlling the entity's

activities; and
• prepare reliable financial reports.

Obtaining or generating and using inaccurate or incomplete data, and

information derived from such data, could result in potentially erroneous
judgments, estimates, or other management decisions.

Question 2.6.50
What is the role of IT systems in the entity's information
systems relevant to financial reporting?
Interpretive response: In today's technology-focused economy, using IT
systems, including enterprise resource planning systems, has become
commonplace. Entities often use IT systems extensively to create, share and
transfer information (i.e. their information systems) and in business processes to
help them:

• manage and operate their business;

• maintain their financial records; and
• report financial results both internally and externally.

To enhance efficiency and effectiveness, entities may choose to automate

certain functions within business processes using IT systems, including process
control activities to address risks.

Automation may be particularly common when processing and reporting larger

volumes of transactions. In some cases, it may not be feasible to process and
aggregate information or data elements without using IT systems.

Question 2.6.60
Are general IT controls part of the information and
communication or control activities component of
ICFR?
Interpretive response: No. General IT controls are part of the control activities
component of ICFR, which are discussed further in chapter 7.

Question 2.6.70
Are third-party service providers and business partners
part of the information and communication component
of ICFR?
Interpretive response: It depends. Because an entity's information system is
not limited by legal boundaries, third-party service providers (e.g. a third party
that provides payroll processing) and business partners contracted by that entity
may be part of its information systems. Whether that is the case depends on the
nature of the processes and activities the third-party service provider (or service
organization) or business partner performs.

A service organization is part of the entity's information system when the

processes and activities they perform:

• are part of the entity's accounting and reporting processes; or

• have an indirect effect on those processes (e.g. when a service organization
performs IT processes and activities that mitigate risks arising from IT).

Chapter 8 provides detailed discussion of service organizations.

Question 2.6.80
What is the difference between Principle 13 and the
control activities component of ICFR related to IT?
Principle 13: The organization obtains or generates and uses relevant, quality
information to support the functioning of internal control.

Interpretive response: Principle 13 is a broadly written concept. In the context

of a financial statement audit or an audit of ICFR (an integrated audit), controls
over the quality of information reported in the financial statements are part of the
control activities component of ICFR. Chapter 6 provides detailed discussion on
control activities over information used in financial reporting.

In contrast, controls addressing the quality of information used throughout the

entity – including other COSO components – that does not appear in the
financial statements but supports the effective design and implementation of
ICFR are part of the information and communication component of ICFR.

Example 2.6.10
Controls that may be in place to address Principle 13
Principle 13: The organization obtains or generates and uses relevant, quality
information to support the functioning of internal control.

Examples of controls that may be in place to address Principle 13 include:

• Management prepares an inventory of information required to support

financial reporting and ICFR, which is maintained on the entity’s information
repository, and updates the inventory of information as changes occur.

• Management retains external specialists to consult with on legal, financial

and tax matters where the entity does not maintain in-house expertise.

• Management subscribes to multiple sources of information, including

industry and regulatory publications, and finance personnel evaluate the
information monthly.

• Senior finance personnel meet monthly with management and personnel in

other areas of the business to gather information on business events and
trends.

Question 2.6.90
What is the importance of an organization internally
communicating information necessary to support the
functioning of internal control (Principle 14)?
Interpretive response: Communication is important to an entity's overall ICFR
because it is how an entity internally shares the information necessary to
support the functioning of ICFR. A lack of effective internal communication may
result in a misunderstanding of individual roles and responsibilities for ICFR and
how those roles and responsibilities impact the achievement of the entity's
objectives. In addition, a lack of communication between management and
those charged with governance may result in those charged with governance
not receiving information needed to exercise its oversight responsibility.

Question 2.6.100
What are management’s communication
responsibilities?
Interpretive response: Management’s communication responsibilities include:

• establishing a process to make sure that complete, accurate and

appropriate information is made available on a timely basis to control
operators;

• enabling inbound communication from external parties to support its system

of internal control; and

• establishing expectations of control operators to:

— be aware of significant internal control matters that may impact other
functions, operating units or divisions; and
— communicate their observations up, down and across the entity.

Significant matters management expects control operators to communicate

around the entity include:

• instances of weak or deteriorating internal controls;

• absence of key controls; and
• non-adherence to established controls.

Management’s communication about ICFR should result in personnel

understanding how their roles, responsibilities and actions relate to the work of
others in the entity and how they may affect the achievement of effective ICFR.

Question 2.6.110
What channels are used to internally communicate
information related to financial reporting and ICFR?
Interpretive response: An entity may use a variety of different channels to
communicate information internally about its objectives, policies and
procedures, and control requirements related to financial reporting, as well as
information necessary for the effective operation of ICFR. Examples of these
channels include:

• departmental vision and mission objective signs posted in high-traffic areas

or on the entity's website;
• accounting and finance internal meetings or conferences to discuss internal
control matters and accounting policy changes;
• public display of the code of conduct;
• an anonymous hotline where employees can report fraud or ethical matters;
• regular entity-wide emails, newsletters, conference calls, webcasts or
meetings about updates on internal control matters;
• senior finance and executive management visits to plants, sales offices,
major customers and other locations;

• periodic internal reporting packages that contain key financial and non-
financial information; and
• departmental and executive meetings that exchange information about
activities and decisions in parts of the business that could affect others.

Practical tip
Ensuring there is communication to the field/employees is important and can
include whistleblower hotlines. However, there should also be evidence of
employees being made aware of the hotline and a distinct policy in place on
how to handle any integrity claims, including how they are communicated to
those charged with governance.

Example 2.6.20
Controls that may be in place to address Principle 14
Principle 14: The organization internally communicates information, including
objectives and responsibilities for internal control, necessary to support the
functioning of internal control.

Examples of controls that may be in place to address Principle 14 include:

• Monthly management meetings are held to provide a forum for

communication of information affecting financial reporting and related ICFR.

• The annual internal audit plan is reviewed by management and the Audit
Committee. Quarterly, progress against the plan and/or changes to the plan
are provided to both management and the Audit Committee.

• The Board of Directors establishes a board charter that defines the

guidelines for information to be shared with the board of directors,
responsibilities for communication, and the method of communication.

Question 2.6.120
What is the importance of an entity communicating with
external parties regarding ICFR (Principle 15)?
Interpretive response: With open external communication channels, important
information concerning the entity’s objectives may be provided to shareholders
or other owners, business partners, customers, regulators, financial analysts,
government entities and other external parties. Management’s communication
to external parties sends a message about the importance of internal control in
the organization by demonstrating open lines of communication. Communication
to external suppliers and customers supports the entity’s ability to maintain an
appropriate control environment.

Question 2.6.130
How does an entity communicate with external parties?

Interpretive response: An entity can communicate with external parties about

matters affecting the functioning of internal control in a variety of different ways.
Examples include:

• code of conduct or business relationship agreements with external

suppliers;

• promoting to external suppliers and service providers the anonymous

hotline to report fraud or ethical matters;

• service agreements with external service providers;

• policies surrounding regulatory compliance and assignment of oversight for

such compliance to qualified individuals within the organization; and

• establishment of a Disclosure Committee to review documents to be filed

with the SEC or other external parties to ensure appropriate disclosure of
relevant information.

Example 2.6.30
Controls that may be in place to address Principle 15
Principle 15: The organization communicates with external parties regarding
matters affecting the functioning of internal control.

Examples of controls that may be in place to address Principle 15 include:

• the entity has a process to enable communication of information regarding

regulatory compliance that affects external reporting objectives;
• earnings and press releases are prepared by management and are
reviewed by the CEO before release; and
• the disclosure committee reviews and approves all documents to be filed
with the SEC or other external parties.

2.7 Monitoring activities

Question 2.7.10
What is the monitoring activities component of ICFR?

Interpretive response: Monitoring activities help ascertain whether each of the

ICFR components, including the principles within each component, is present
and functioning as intended.

Management’s monitoring activities over ICFR involve assessing the

effectiveness of internal control performance over time and taking necessary
remedial actions. Assessing the effectiveness of internal controls may be
performed through ongoing activities, separate evaluations or a combination of
the two.

Question 2.7.20
What is the relevance of monitoring activities to ICFR?

Interpretive response: Continuing with the house example, monitoring

activities are like the roof of the house. They oversee and protect the other ICFR
components. Without effective monitoring, management does not have a basis
to rely on their own ICFR.

Monitoring
Information and

communication

Control activities

Risk assessment

Control environment

Management’s monitoring processes and controls continually check the other

ICFR components to identify issues and determine what needs attention.
Effective monitoring helps management identify changes to ICFR needed to
prevent or detect, on a timely basis, future errors in the financial statements.

The goal of monitoring activities is to determine both that ICFR operated and
operated effectively. Monitoring also includes evaluating the severity of
identified deficiencies and communicating deficiencies to the appropriate
parties.

Question 2.7.30
What are the principles in the COSO Framework
related to the monitoring activities component of ICFR?
Interpretive response: The COSO Framework sets out two principles for the
monitoring activities component of ICFR. Meeting both principles demonstrates
that controls have been designed and are operating effectively to meet the
objectives of the monitoring activities component.

Monitoring activities
The organization selects, develops, and performs ongoing and/or
Principle 16 separate evaluations to ascertain whether the components of internal
control are present and functioning.
The organization evaluates and communicates internal control
deficiencies in a timely manner to those parties responsible for taking
Principle 17
corrective action, including senior management and the board of
directors, as appropriate.

Source: COSO Internal Control – Integrated Framework (2013).

Question 2.7.40
What is the importance of an entity performing ongoing
and/or separate evaluations of their ICFR (Principle
16)?
Interpretive response: Monitoring activities are selected, developed and
performed to ascertain whether each component continues to be present and
functioning, or if change is needed. Monitoring activities provide valuable input
for management to use when determining whether the system of internal control
continues to be relevant and can address new risks.

Question 2.7.50
How does an entity demonstrate that it has met
Principle 16?
Principle 16: The organization selects, develops, and performs ongoing and/or
separate evaluations to ascertain whether the components of internal control
are present and functioning.

Interpretive response: Demonstrating that the entity has met Principle 16

requires implementing procedures to determine that:

• a control has been performed; and

• the control has been performed effectively.

Effective performance of a control is relevant when determining which

monitoring method to use, and who should perform the monitoring.

An entity’s evidence of the operating effectiveness of controls comes from

monitoring activities, which include:

• ongoing monitoring (what the COSO Framework calls ‘ongoing evaluation’);

• direct tests of controls (what the COSO Framework calls ‘separate
evaluations’); or
• a combination of both.

Question 2.7.60
What are ongoing evaluations?

Interpretive response: Ongoing evaluations are built into the routine

operations of the entity and performed in real time. They are often built into
management’s normal recurring activities (including regular management and
supervisory activities) and provide information about the operation of controls.

Ongoing evaluations either monitor business performance or the effective

operation of other controls to identify unusual trends that may indicate control
deficiencies.

Example 2.7.10
Ongoing evaluations: KPIs
Within the sales process, management monitors several key performance
indicators (KPIs) on a daily, weekly and monthly basis. The KPIs include:

• the quantity of products shipped by day and by warehouse location;

• days sales outstanding at the end of each week; and
• analysis of accounts receivable agreed over 120 days.

The KPIs are designed to provide a timely indication of unexpected or

anomalous changes or events within the entity’s sales process and are added
as a process-level monitoring activity to the entity’s annual monitoring plan.

In addition, quarterly business reviews are completed and obtained from

component locations. These reviews analyze KPIs and certain other financial
statement captions compared to budget.

Example 2.7.20
Ongoing evaluations: Control testing status
Management maintains a status listing of the monitoring activities over all
controls. This status listing includes:

• the control description;

• the control operator;
• status of testing;
• identified deficiencies; and
• remediation plan and status.

The status listing is reviewed by management on a weekly basis for them to

assist in actioning any testing or remediation necessary. It is then presented to
those charged with governance on a quarterly basis.

Question 2.7.70
Are monitoring business performance and ongoing
monitoring activities the same?
Interpretive response: No. Monitoring business performance and ongoing
monitoring activities are not the same, although their purposes may overlap.

Monitoring business performance establishes whether the entity's business

performance (or that of its components) is meeting the objectives or
expectations set by management or third parties. Such objectives or
expectations can be expressed in the form of forecasts, budgets or prior-period
normal results that serve as a benchmark for evaluating the current-period
actual results.

An example of monitoring trends in business performance is observing KPIs –

such as the analysis of accounts receivable aged over 120 days – and following
up on unexpected trends. While an unexpected trend in the aging of accounts
receivable may not be a result of a breakdown in internal controls, it represents
a trigger for management to look more closely at their processes for:

• credit sales, and

• accounts receivable collection.

Although their investigation may identify breakdowns in relevant control

activities in one or more of these processes, that is not the intended purpose.
Monitoring activities are performed to ascertain whether each of the five
components of internal control, including controls within each component, is
present and functioning, and to take necessary remedial actions on a timely
basis.

Question 2.7.80
What are the benefits of ongoing evaluations?

Interpretive response: There are several benefits associated with ongoing

evaluations, particularly:

• routine execution and continuous operation as part of the entity's everyday

business processes;
• focus on relationships and inconsistencies that are most important to
management and other stakeholders; and
• real-time identification of issues allowing for a timelier response by
management.

Question 2.7.90
What are separate evaluations?

Interpretive response: Separate evaluations involve objective management

personnel, internal audit and/or external parties (and others) periodically
conducting testing to monitor the effectiveness of internal controls.

Question 2.7.100
What parties can perform separate evaluations?

Interpretive response: Various parties can perform separate evaluations as set

out in the following table, each with differing degrees of objectivity and
independence.

Evaluator Description
Performed by internal auditors, whether in-house or
outsourced, that perform separate evaluations either as part of
Internal audit
their regular duties or at the specific request of senior
management or those charged with governance.
Performed by other internal or external objective reviewers,
Objective parties
such as a compliance team, IT security specialists or
other than internal
consultants. Generally consistent objectivity and competence
audit
of internal audit.
Performed by personnel from different functions or
Cross-functional
departments that are independent of the process and controls
personnel
being evaluated.

Evaluator Description
Performed by the personnel responsible for operation of the
Self-assessments control. Least objective as performed by the control operator
themselves.

Question 2.7.110
When might an ongoing evaluation be more appropriate
than a separate evaluation and vice versa?
Interpretive response: One type of evaluation may be more appropriate in
certain circumstances. The following table lists circumstances that may indicate
whether an ongoing or separate evaluation is more appropriate.

Ongoing evaluation Separate evaluation

Lower risk in the execution of the control Higher risk in the execution of the control
or in the related account or disclosure or in the related account
Less judgment in executing the control More judgment in executing the control
No history of errors in the related account History of errors in the related account or
or disclosure disclosure
No changes to the process or design of Changes that may affect the way
the control information is processed or the design of
the control (e.g. an acquisition, changes
in economic conditions)
No expectation from management for An expectation from management for
external auditors to rely on the work of external auditors to rely on the work of
others relative to the control others relative to this control

Question 2.7.120
When might an entity increase the extent of its
monitoring activities?
Interpretive response: An increase in the extent of monitoring activities may be
warranted when:

• management assesses the risk associated with a control as higher;

• there is an increase in the risk of material misstatement of the entity's

financial statements related to a particular significant account or disclosure,
or the related process; or

• the particular area of the entity's financial reporting process:

— has been historically prone to errors;
— is complex;

— is exposed to higher risk of material misstatements (RMMs) due to error

or fraud; and
— involves a significant degree of judgment.

Question 2.7.130
How might an entity increase the extent of its
monitoring activities?
Interpretive response: An entity can increase the extent of its monitoring
activities through the following actions, among others:

• using more objective monitoring personnel, which might include:

— moving away from self-assessments and towards monitoring activities
performed by personnel from other functions or departments who are
independent of the process and controls being monitored;
— instituting evaluations performed by internal audit or other objective
evaluators;

• changing or extending the period of time covered by the monitoring

activities; or

• supplementing or replacing ongoing evaluations with periodic direct testing

of the underlying controls to:
— corroborate evidence from ongoing monitoring activities; and
— evaluate how effectively the underlying controls operate and whether
they continue to adequately address financial reporting risks.

Question 2.7.140
Can an entity's monitoring activities be accomplished
entirely through separate evaluations?
Interpretive response: Yes. An entity can accomplish its monitoring activities
entirely through separate evaluations. However, an entity can identify internal
control issues more quickly through ongoing evaluations.

Management should consider the rate of change in the business and the
significance of risks so that it determines the appropriate mix of both ongoing
and/or separate evaluations.

Question 2.7.150
Should an entity have monitoring activities over
processes and controls performed by third-party service
providers?
Interpretive response: Yes. As a general rule, although management may
outsource a process to a third-party service provider, they may not outsource
their responsibility for the results of the service provider's work.

When the entity uses third-party service providers, management still monitors
whether controls performed by those service providers have been appropriately
designed and implemented and are operating effectively.

Such monitoring may be accomplished by performing one or both of the

following:

• Separate evaluations, such as:

— reviewing a SOC 1® – Type II report (if such a report is available for the
service provider); or
— directly testing controls in place at the service organization.

• Ongoing evaluations, such as reviewing output provided by the service

organization for outliers that may indicate its controls have not been
appropriately designed or are not operating effectively.

Chapter 8 provides detailed discussion about the involvement of service

organizations in ICFR.

Question 2.7.160
How are monitoring activities different from process
control activities?
Interpretive response: As it relates to ICFR, monitoring controls, consistent
with most entity-level controls, provide a ‘could’ level of assurance (see
Question 2.3.40), whereas process control activities provide a ‘would’ level of
assurance (see Question 2.3.30). Additionally, monitoring activities have a
different purpose from that of process control activities, as detailed in the table
below:

Purpose of monitoring activities Purpose of process control activities

• Evaluate the effectiveness of control • Respond directly to mitigate a
activities and other components of specific risk within a process
ICFR and identify deficiencies timely. relevant to financial reporting.
• Monitor operations to identify unusual
trends or anomalies that may warrant
further investigation.

Purpose of monitoring activities Purpose of process control activities

• Analyze root cause of deficiencies.
• Design and implement effective
remediation plan.

• ‘Could’ identify errors themselves, but • Designed with sufficient precision

that is not the primary purpose of such that the control, if designed
their design and operation. and operating effectively, ‘would’
prevent, or detect and correct, errors
in financial reporting.

Example 2.7.30
Financial statement review
A review of the financial statements performed as a monitoring control may
identify an unusual change in the entity’s balance of fixed assets between
periods that, on further investigation, is attributable to a deficiency in the design
of the entity’s process control activity to address the accuracy of the accounting
for fixed asset additions. Although the entity-level control in this instance
detected a misstatement, it alone is not operating at an appropriate level of
precision to replace the need for a process control activity directly responsive to
the risk that additions are accounted for inaccurately. Said another way, the
financial statement review ‘could’ detect an error but does not operate at a level
of precision (‘would’ level of assurance) to mitigate the risk identified to an
appropriately low level.

Question 2.7.170
What is a flux analysis?

Interpretive response: A flux analysis is a monitoring activity whereby

management understands and investigates changes in account balances within
the balance sheet and income statement across two periods.

A flux analysis may compare:

• actual account balances for the current period to actual account balances
from the prior period (e.g. actual results from the current month to the
previous month); or

• account balances for the current period to a budget or forecast for the
current period (e.g. actual results from the current month to the budget for
the month).

Question 2.7.180
Can a flux analysis be a process control activity?

Interpretive response: Typically, no. A flux analysis is best classified as a

monitoring activity as it usually has a different purpose than a process control
activity and is not designed at the level of precision necessary to mitigate risks
identified at the process level.

If the flux analysis directly addresses a specific risk at the process level and is
designed at a level of precision that would prevent or detect a material
misstatement, it could function as a process control activity. However, this is
rare as it is difficult to design a flux analysis to achieve the precision required in
a process control activity. Flux analyses are typically performed over amounts at
a higher level of aggregation, which may be at an appropriate level of precision
for a monitoring control (e.g. require investigation of all changes over a low
dollar threshold). But it is often impractical to perform and document the control
at the level of detail required to effectively evidence all the activity driving the
fluctuation due to the existence of offsetting activity between and among
accounts underlying the amount at the aggregate level. There are also other
items to consider including, but not limited to:

• the reliability of the information used, specifically when budgets or forecasts

are used;
• the risk that there should be fluctuation and there isn’t; and
• the risk that outliers identified are ‘explained away’ and errors are not
properly identified and resolved.

As such, care should be exercised when asserting that a flux analysis is a

process control activity.

Question 2.7.190
When separate evaluations are used as part of
monitoring procedures, is testing of controls performed?
Interpretive response: Yes. Management, usually with the assistance of
internal audit, performs testing of their internal controls, including entity-level
controls, process control activities and GITCs.

Question 2.7.200
How are entity-level controls evaluated and tested and
how does that differ from evaluating and testing control
activities?
Background: Entity-level controls include standards, processes, structures,
communications and other activities the entity undertakes to help management

carry out ICFR across the organization. By contrast, a process control activity
directly addresses process risk points arising from business processes that
account for the entity’s transactions. Given their nature, entity-level controls are
evaluated and tested differently from control activities.

Interpretive response: Testing entity-level controls means testing the ‘set of

standards, processes and structures’ rather than specific control activities. Also,
because of the indirect nature of entity-level controls, an assessment of the
effectiveness of the controls often requires qualitative considerations.

When entity-level controls are policies, procedures, processes and structures,

and there are no discrete instances of procedures being performed (similar to
control activities), the procedures performed to test the effectiveness might
include:

• inquiring of management and those charged with governance regarding the

policies, procedures, processes and structures in place at the entity;
• inspecting documentation evidencing that the policies, procedures,
processes and structures exist; and
• observing the policies, procedures and processes being performed by
management or those charged with governance.

Inquiry alone is not sufficient to evidence the controls are present and
functioning.

Certain entity-level controls may incorporate discrete instances of procedures

being performed, similar to control activities, such as when employees are
required to re-affirm compliance with the code of conduct on an annual basis.

For entity-level controls with discrete instances of procedures being performed,

the effectiveness of these procedures is tested in a manner similar to testing
control activities. This includes ensuring there is a complete population from
which to select a sample to test and testing discrete instances of the operation
of the control. The number of items to test would be based on the population
and the risk associated with the control.

Practical tip
For entity-level controls, maintaining proper and complete evidence is important,
especially for testing purposes. For an entity-level control that operates on a
recurring basis, the ability to establish a complete population is important, as is
maintaining evidence of the control’s operation. For example, for an entity-level
control where all employees are required to sign a code of conduct each year, a
complete listing of all employees throughout the year needs to be available, as
well as a documented understanding of how that listing is determined to be
complete. In addition, the signed copies of the code of conduct for all employees
needs to be maintained and available.

Example 2.7.40
Management meeting to assess risks
Consider entity-level controls related to risk assessment whereby key members
of the finance and accounting department meet to identify, analyze and assess
the significance of financial reporting risks across the entity and how the entity
will manage those risks. When testing this control, evidence is obtained to
conclude whether the entity has a process for identifying, assessing and making
plans to address financial reporting risks. This could be accomplished through
inquiries of those who attended the meeting combined with review of:

• the meeting invites to establish the appropriate parties were included in the
meeting;
• the materials provided to the meeting participants to establish the purpose
and content of the meeting; and
• the minutes of the meeting to establish the discussions held and the
conclusions reached during the meeting.

The combination of these testing methods would support that the entity-level
control was in place and operating effectively.

Question 2.7.210
How are process control activities evaluated and tested
as part of monitoring activities?
Interpretive response: See section 5.18.

Question 2.7.220
How are general IT controls evaluated and tested as
part of monitoring activities?
Interpretive response: See section 7.4.

Question 2.7.230
What are examples of entity- (or group-) level
monitoring activities implemented in a multi-component
or multi-location setting?
Interpretive response: Most entities with multiple components or locations
perform various types of reviews or other evaluations at the consolidated entity-
level, which are targeted at the financial, operating, or control performance of
the individual components or locations. Examples of such consolidated entity-
level reviews may include:

• regular meetings between group and location or component management to

discuss business developments and to review performance;

• monitoring the locations’ or components’ operations and their financial

results, including regular reporting routines, against budgets or forecasts,
and taking appropriate action;

• monitoring the timeliness and assessment of the accuracy and

completeness of financial information received from locations or
components; and

• monitoring controls, including activities of the internal audit function and self-
assessment programs.

Question 2.7.240
Can entity-level monitoring activities be relied on to
eliminate the need to rely on or evaluate controls at the
entity’s individual locations or components?
Interpretive response: Typically, no. These consolidated entity‑level reviews
often do not represent control activities, but rather are designed as monitoring
activities. Their objective is to identify unusual trends or anomalies in business
or operating performance that may indicate possible breakdowns in process
control activities at the location or component level. The reviews are not
designed to operate at a level of precision that would, by themselves, sufficiently
address the risk of material misstatements of the group financial statements. As
monitoring activities, these consolidated entity-level reviews alone will not be
sufficient to address the risk of material misstatement at the location or
component level.

To eliminate the need for reliance on and evaluation of controls at a specific

location or component of the entity, the reviews performed at the consolidated
entity level need to represent control activities. For this to be the case, the
reviews at the consolidated entity level need to be designed and operated with
an appropriate ‘would’ level of precision. The level of precision needed provides
confidence to both management and external auditors that the reviews would
prevent or detect, on a timely basis, a misstatement that could arise at the
location or component and be material to the entity’s consolidated financial
statements. The materiality of the individual misstatement and the aggregate of
misstatements are both considered for purposes of assessing materiality. It can
be difficult to perform the control at a precise enough level due to the
aggregation level used, as well as the ability to identify and resolve outliers and
not just ‘explain them away.’

When the consolidated entity-level reviews are not or cannot be converted from
monitoring activities to process control activities, management should design
and implement relevant process control activities at the individual locations or
components of the entity. For this purpose, management includes the locations
or components that either individually, or when aggregated with others, include
a more-than-remote risk of material misstatement of the group financial

statements (see chapter 3 for discussion of scoping the ICFR risk assessment
in a multi-location or group entity situation). Management and external auditors
should then evaluate the design and operating effectiveness of the controls in
place.

While the consolidated entity-level reviews that are designed as monitoring

activities typically are not sufficient to eliminate the need for reliance on and
testing of controls at individual components or locations of the entity, such
monitoring activities would address Principle 16. In addition, such monitoring
controls, if appropriately designed and operating effectively, may allow
management and external auditors to reduce (but not eliminate) the testing of
other controls, including those controls that operate at individual components or
locations. In the case of entities with multiple homogenous locations, effective
monitoring controls may also allow management and auditors to reduce the
number of locations at which testing of process control activities needs to be
performed.

Question 2.7.250
To what extent can external auditors rely on the entity’s
monitoring activities?
Interpretive response: It depends. The degree of reliance on monitoring
activities by external auditors in their audit of an entity’s ICFR is governed by the
applicable auditing standards. Paragraph 39 of PCAOB Auditing Standard (AS)
2201 states that in an audit of ICFR, “the auditor should test those controls that
are important to the auditor’s conclusion about whether the company’s controls
sufficiently address the assessed risk of misstatement to each relevant
assertion.”

There is a direct focus in the ICFR audit on control activities that mitigate the
risk of misstatement to specific assertions over significant accounts and
disclosures. Because of this, it will be rare that an external auditor will be able to
obtain sufficient evidence of the design and operating effectiveness of these
control activities by testing only the monitoring activities operating over the
control activities. However, as stated in paragraph 40 of PCAOB AS 2201,
“there might be more than one control that addresses the assessed risk of
misstatement to a particular relevant assertion.” In some situations, a monitoring
control may represent an important element of a larger suite of controls
designed to address an assertion-level risk and, in such situations, the
monitoring activity would need to be evaluated and documented together with
the related control activities.

External auditors’ ability to rely on management’s monitoring activities is

particularly limited when it comes to ongoing evaluations (see Question 2.7.60).
This is because ongoing evaluations are rarely performed by independent
objective evaluators and do not directly test the underlying controls, but rather
look for indicators of their deficiency.

Considering the characteristics of some of these monitoring activities and the

requirements of the auditing standards, external auditors’ reliance on the work

of others is usually limited to the direct testing performed by internal auditors

over low risk, routine controls. When an external auditor relies on the work of
others, they will have to sufficiently reperform the work to determine that it can,
in fact, be relied upon.

Generally, whenever management does not monitor the controls by direct

testing, auditors will not be able to rely on management’s work.

Question 2.7.260
What documentation standard is management held to
with respect to its monitoring activities?
Interpretive response: Management must keep documented evidence of the
effectiveness of controls, including the monitoring activities performed.

Regardless of whether the entity has chosen to monitor through ongoing or

separate evaluations, the documentation of monitoring activities should be
sufficient to:

• enable a prudent official to understand the nature, timing and extent of the
monitoring activities performed; and
• provide sufficient information to be able to conclude on the appropriateness
of design and operating effectiveness of the monitoring activities.

Documentation of the monitoring of the control activities will likely be more

robust than the monitoring of the other ICFR components. A reasonable level of
documentation is always necessary to meet the ‘prudent official’ principle of
documentation and for management to assert that each of the ICFR
components and related principles are present and functioning.

Appropriate documentation of management’s monitoring activities is also critical

to the external auditors’ ability to test these activities and obtain evidence of the
entity’s compliance with the requirements of Principle 8 (see Question 2.5.120).

Question 2.7.270
What is the importance of an entity maintaining,
tracking and communicating deficiencies in ICFR to
those parties responsible for taking corrective action
and those charged with governance (Principle 17)?
Interpretive response: Communication of deficiencies in ICFR to the
appropriate parties allows for the appropriate levels to oversee the effectiveness
and timeliness of remediation.

In monitoring that the components of ICFR are present and functioning, it is not
uncommon for an entity to identify shortcomings in the design and operation of
internal controls for a variety of reasons. When deficiencies are identified, it is
important that each deficiency is tracked and communicated to the appropriate

parties so that remedial actions may be performed and overseen to support the
effective design and operation of ICFR on a go-forward basis.

Question 2.7.280
How does an entity maintain, track and communicate
deficiencies in ICFR to executive management and the
Audit Committee (Principle 17)?
Interpretive response: An entity typically has a process in place to maintain,
track, and communicate deficiencies in ICFR to executive management and the
Audit Committee that is part of assessing the results of its monitoring activities.
This process will vary depending on the entity's circumstances; however, it will
probably contain a variation of the following steps.

Step 1 Determine whether a deficiency in ICFR exists

Step 2 Perform a root cause analysis of the deficiency

Step 3 Determine whether the deficiency indicates other deficiencies

Step 4 Evaluate the severity of the deficiency individually

Step 5 Evaluate the effect of compensating controls, if applicable

Step 6 Evaluate the severity of similar deficiencies in the aggregate

The results of the entity's process of identifying and evaluating a control

deficiency assists in the development and initiation of remedial actions.

Chapter 9 includes further discussion on identifying and evaluating control

deficiencies.

Question 2.7.290
What is communicated when a control deficiency is
identified and who is it communicated to?
Interpretive response: Deficiencies are communicated to parties responsible
for taking corrective action. All control deficiencies are also communicated to the
external auditor and to at least one level of management above the control
operator. Deficiencies may be reported to senior management and those
charged with governance, depending on the reporting criteria as established by
regulators, standard-setting bodies, or the entity, as appropriate.

Management of an SEC registrant also discloses material changes to ICFR in

Item 4 of their SEC filings.

Practical tip
External auditors are required to report all significant deficiencies and material
weaknesses to those charged with governance; therefore, management
generally will, at a minimum, report these matters as well.

Question 2.7.300
How does an entity monitor whether corrective actions
to remediate control deficiencies take place?
Interpretive response: Once an entity has identified and assessed a control
deficiency, it puts in place processes to:

• determine what corrective actions are necessary to remediate the control

deficiency; and
• monitor whether the corrective actions have taken place in a timely manner.

Typically, the individuals responsible for monitoring whether corrective actions

have taken place in a timely manner are different from the individuals
responsible for determining and implementing the corrective actions.

Question 2.7.310
How does an entity monitor if corrective actions to
remediate a control deficiency take place in a timely
manner?
Interpretive response: The status of corrective actions – i.e. remediation status
– is often discussed with senior management. This may occur as part of a
periodic ICFR-focused steering committee meeting. Management also
discusses the remediation status of significant deficiencies and material
weaknesses with the audit committee as part of periodic audit committee
meetings.

When corrective actions have not taken place in a timely manner, the entity may
put additional monitoring activities in place until the corrective actions have been
implemented.

Further, Principle 5 requires the entity to hold individuals accountable for their
internal control responsibilities, which includes responsibilities related to
corrective actions necessary to remediate control deficiencies (see Question
2.4.150).

Example 2.7.50
Communication of deficiencies and corrective actions
Internal Audit maintains a control deficiency report that is updated with any new
deficiencies identified or when remediation activities are tested and completed.

Internal Audit has biweekly meetings with management where control

deficiencies are communicated to management and remediation plans are
discussed. The process or control owner develops a remediation plan including
a timeline for remediation and subsequently remits to the Internal Audit
department for review and approval.

Internal Audit performs a follow up process to verify remediation has occurred in

accordance with the approved timeline. Testing is performed to ensure that the
control is operating effectively after remediation.

Internal Audit presents the control deficiency status report to the Audit
Committee on a quarterly basis.

Key takeaways

• Assessment of the control environment component of ICFR should be

performed across the entity and at all levels, as well as third-party service
providers and other external business partners.

• Risk assessment involves a dynamic and iterative process for identifying

and assessing risks to the achievement of objectives and is performed at
least annually by management.

• Both the SEC and the COSO Framework require the assessment of fraud
risk.

• Risk assessment considers changes that could have an impact on ICFR.

Many material weaknesses in ICFR are rooted in circumstances where
changes occurred but the ICFR implications were not identified or
thoroughly considered.

• Management’s risk assessment should be documented on a timely basis

and be comprehensive in nature.

• Entities should establish processes for identifying information needs across

the entity and communicating the necessary information appropriately and
on a timely basis. Failure to communicate the relevant information to the
appropriate person(s) may result in a material weakness if it effects the
financial statements.

• Effective monitoring allows management to determine whether controls

within each of the five components of ICFR are operating as intended and to
determine what needs to be changed to prevent future errors. In obtaining
objective evidence to support their monitoring, management should
determine the appropriate mix of both ongoing and/or separate evaluations.

3. Risk assessment
Detailed contents
3.1 Management’s ICFR journey
3.2 Identifying and assessing risks
Questions
3.2.10 Why is risk assessment necessary?
3.2.20 At what level is an entity's risk assessment performed?
3.2.30 Are there certain activities or matters that should be
considered as part of the entity’s risk assessment process?
3.2.40 How does management perform risk assessment relative to
an entity’s ability to continue as a going concern?
3.2.50 What are the key activities involved in entity-level and
process-level risk assessments?
3.2.60 Can ERM suffice for entity-level risk assessment?
3.2.70 Are IT systems included in management’s risk assessment?
3.2.80 How does management execute an entity-level risk
assessment?
3.2.90 How is the significance of potential risks evaluated?
3.2.100 When a potential RMM is identified, what is management’s
response?
3.2.110 When does an entity perform and document its risk
assessment process?
3.2.120 Who should perform and review the risk assessment?
Examples
3.2.10 Risks related to safeguarding of assets and authorization of
receipts and expenditures
3.2.20 Management’s risk assessment process and audit
committee review
3.3 Consideration of materiality
Questions
3.3.10 Why is materiality important in management’s design of an
effective system of ICFR?
3.3.20 Is a materiality analysis solely quantitative?
3.3.30 Is materiality considered only at the consolidated entity
level?

3.4 Scoping of accounts and disclosures

Questions
3.4.10 Is risk assessment performed at the assertion level?
3.4.20 What is a significant account or disclosure?
3.4.30 How are significant accounts and disclosures aggregated or
disaggregated?
3.4.40 What is risk tolerance and how is it considered when
defining significant accounts?
3.4.50 What actions should management consider taking to fulfill
their ICFR-related responsibilities related to non-GAAP
financial measures?
Examples
3.4.10 Considering qualitative factors when identifying significant
accounts
3.4.20 Disaggregation and aggregation in defining significant
accounts
3.5 Scoping of components
Questions
3.5.10 Which of the components of the group are deemed in scope
for purposes of management’s ICFR assessment?
3.5.20 Can an entity-level analytical review control be sufficient to
mitigate risks in an individual component or aggregated
components of an entity?
3.5.30 Are newly acquired businesses subject to management’s
assessment of ICFR?
3.5.40 Are disposal groups included in management’s scoping of
components?
3.5.50 What should the entity consider for components that are
financially insignificant?
3.5.60 Is aggregation risk considered when determining whether a
component is in scope (or out of scope)?
3.5.70 What are factors to be considered in determining component
materiality?
3.5.80 Should management document the scoping of its accounts,
processes and components performed as part of risk
assessment?
3.6 Identifying and assessing fraud risks
Questions
3.6.10 Are all entities required to consider fraud risks in their risk
assessment?
3.6.20 How is a fraud risk assessment performed?

3.6.30 How are fraud risk factors identified?

3.6.40 How does an entity consider fraud risk factors in identifying
fraud risks?
3.6.50 How does management define and document assertion-level
fraud risks?
3.6.60 How is materiality considered in an entity’s fraud risk
assessment?
3.6.70 How are those charged with governance involved in an
entity’s fraud risk assessment?
Examples
3.6.10 Revenue-related fraud risks and related controls
3.6.20 Refresh of the entity’s fraud risk assessment process
3.7 Consideration of changes to ICFR
Questions
3.7.10 Are changes to ICFR required to be evaluated?
3.7.20 What types of changes to ICFR are required to be
evaluated?
3.7.30 How much of the ICFR process does a change in risk
assessment impact?
3.7.40 How often should changes to ICFR be evaluated?
Examples
3.7.10 Entity-wide events with financial reporting risks and ICFR
impact
3.7.20 Change in business model – entity’s investment policy
3.7.30 Change in external environment – COVID-19
3.7.40 Change in external environment – Russia-Ukraine war
3.7.50 Change in external environment – climate risks
3.7.60 Changes at an entity and their effect on ICFR
Key takeaways

3.1 Management’s ICFR journey

Management’s ICFR journey for each financial reporting cycle requires the
performance of risk assessment – a dynamic and iterative process for
identifying and assessing risks to the achievement of objectives.

2. Entity-level controls

9. Identify and evaluate deficiencies

3. Risk assessment
Materiality and scoping of significant accounts, disclosures and components of the entity

Account, disclosure, process or component determined to contain a potential risk of material misstatement

4. Process understanding

5. Process control activities

6. Information used in controls 7. General IT controls 8. Service organizations

While an entity’s risk assessment process starts early in the financial reporting
cycle, it requires a reassessment of initial conclusions based on evidence
obtained throughout the financial reporting cycle. As stated by the Chief
Accountant of the Securities and Exchange Commission, when business risks
change, a robust, iterative risk assessment process and strong entity- and
process-level controls are essential to transparent and high-quality financial
reporting 1.

This chapter provides an overall view on the process management uses to

identify and assess risks, as well as specific activities involved when executing
an effective risk assessment.

Identifying and assessing risks (see section 3.2)

Identifying the relevant risks to financial reporting is an essential component of ICFR
because failure to understand the likely sources of misstatements may lead to
ineffectively designed control activities, which in turn increases the possibility of a
material misstatement in the financial statements.
Management performs the entity’s risk assessment at various levels within the entity
by following a top-down approach starting at the entity level and moving down to the
process level.

Consideration of materiality (see section 3.3)

Materiality involves both quantitative and qualitative considerations. Separate
materiality analyses could be needed at the consolidated level and component level.

1
Paul Munter, SEC Chief Accountant, The Importance of a Comprehensive Risk Assessment by
Auditors and Management, August 2023.

Scoping of accounts and disclosures (see section 3.4)

Management identifies significant accounts and disclosures and links them to the
appropriate financial statement assertions (e.g. completeness, existence, accuracy).
This is necessary given management’s overall objective is to produce reliable financial
reporting in accordance with the relevant GAAP.
A significant account or disclosure is an account or disclosure where there is a
reasonable possibility that it could contain a misstatement that, individually or when
aggregated, has a material effect on the financial statements. The determination of
significant accounts is important because any accounts determined to be significant
require an ICFR response.

Scoping of components (see section 3.5)

Management determines which of the entity’s components (e.g. subsidiaries,
divisions, operating units) present a risk that the financial statements contain a
material misstatement. A necessary part of this exercise is determining component
materiality, which will be less than consolidated materiality – how much less depends
on the facts and circumstances.

Identifying and assessing fraud risks (see section 3.6)

Management must assess the potential for fraud in evaluating risks to the
achievement of its objectives. This assessment should be comprehensive, cover
various levels within the entity and involve appropriate members of management and
employees. Generally, the identified fraud risks should be linked to a specific financial
statement assertion or assertions.

Consideration of changes to ICFR (see section 3.7)

Management’s risk assessment must identify changes with a significant effect on
financial reporting and assess the risks resulting from those changes. Identified
changes are typically analyzed down to the process level.

Documentation of the risk assessment process often involves the creation and
maintenance of a risk and control matrix, which includes the account, account
balance, the risk factors considered, the significance of the risk to the accounts
and assertions, as well as linking risks to the internal controls designed to
address them.

Abbreviations

We use the following abbreviations in this chapter.

AICPA American Institute of Certified Public Accountants

COSO Committee of Sponsoring Organizations of the Treadway
Commission
FASB Financial Accounting Standards Board
GAAP Generally accepted accounting principles
ICFR Internal control over financial reporting
PRP Process risk point

RM Risk of misstatement
RMM Risk of material misstatement
SEC Securities and Exchange Commission

3.2 Identifying and assessing risks

Question 3.2.10
Why is risk assessment necessary?

Interpretive response: Identifying the relevant risks to financial reporting is an

essential component of ICFR because failure to understand the likely sources of
misstatements may lead to ineffectively designed control activities, which in turn
increases the possibility of a material misstatement in the financial statements.

The importance of risk assessment has also been emphasized by the SEC staff
who have stated that 2 to accomplish the objective of effective ICFR,
management must identify the risks to reliable financial reporting before
identifying controls and monitoring them for effectiveness.

Question 3.2.20
At what level is an entity's risk assessment performed?

Interpretive response: The COSO Framework makes it clear that management

should perform the entity’s risk assessment at various levels within the entity by
following a top-down approach that starts at the entity level and moves down to
the process level.

Question 3.2.30
Are there certain activities or matters that should be
considered as part of the entity’s risk assessment
process?
Interpretive response: Activities or matters that should be considered as part
of an entity’s risk assessment process include:

• safeguarding of assets (see Example 3.2.10);

• authorization of receipts and expenditures (see Example 3.2.10);

2
17 CFR Part 241 (Release No. 33-8810), Commission Guidance Regarding Management’s
Report on Internal Control Over Financial Reporting Under Section 13(a) or 15(d) of the
Securities Exchange Act of 1934, p. 9.

• an entity’s ability to continue as a going concern (see Question 3.2.40); and

• fraud (see section 3.6).

It is important that an entity’s risk assessment process is comprehensive and

results in a complete population of risks affecting ICFR. Exclusion of the above
items from an entity’s risk assessment could result in ineffective ICFR, as noted
in the examples below, if risks are not properly identified and the related
controls to address those risks are not in place and operating effectively.

Example 3.2.10
Risks related to safeguarding of assets and
authorization of receipts and expenditures
Scenario A: Unauthorized change to vendor bank account number

Facts: The Accounts Payable (A/P) Manager receives a phone call from an
individual who introduces himself as Account Manager at Supplier X. The caller
requests that Entity A change the number of the bank account to which the
payments due to Supplier X should be remitted on a going-forward basis. The
A/P Manager updates the payment information, and Entity A begins processing
payments to the bank account on file.

A month later, a representative of Supplier X contacts Entity A to complain

about missing payments for several recent deliveries. Entity A fell victim to a
fraud scheme perpetrated by an unidentified third party and lost several million
dollars.

Analysis: In this scenario, Entity A failed to safeguard its assets in violation of

the SEC’s definition of effective internal control that requires each issuer to
maintain policies and procedures that provide reasonable assurance regarding
prevention or timely detection of unauthorized use or disposition of the issuer’s
assets.

In addition, Entity A also did not comply with Principle 15 (see Question 2.6.120)
in the COSO Framework that requires entities to select appropriate methods of
communication with external parties. In this case, Entity A either did not have a
policy in place that required an ‘in writing’ submission of updated payment
information by an authorized representative of a vendor or failed to effectively
operate relevant controls under such policy. Entity A also did not have a process
in place to verify the validity of the updated payment information.

These failures in controls fall into the scope of management’s ICFR assessment
under the rules of the SEC, and the control deficiencies, as described above,
would likely represent a material weakness in Entity A’s ICFR. However, a
material weakness may not exist if Entity A can demonstrate the existence of
effective compensating controls that would have prevented, on a timely basis,
the stolen amount from becoming material to Entity A’s financial statements.

Scenario B: Unauthorized wire transfer

Facts: At the end of a busy day, the head of Entity B’s A/P Department (the A/P
Manager) receives an urgent e-mail message directing her to make an
immediate wire transfer in the amount of $50 million to a bank account identified
in the e-mail message as an account belonging to an investment advisor
assisting Entity B in a confidential business acquisition. The e-mail address
bears the name of Entity B’s CFO.

The message also urges the A/P Manager to keep the wire transfer confidential
given the nature of the underlying transaction. It also explains that the CFO is
not able to execute the wire transfer himself as he is currently boarding a plane
heading to a meeting with the investment advisor. The A/P Manager executes
the wire transfer as instructed.

The next day, the Manager follows up with the CFO to obtain written approval
for the wire transfer and is shocked to learn that the e-mail communication with
the party presumed to be the CFO was fictitious. The entity fell victim to a fraud
scheme perpetrated by an unknown third party.

Analysis: Entity B failed to exercise appropriate controls over the authorization

of its cash disbursements. It also failed to safeguard its cash in violation of the
SEC’s definition of effective internal control.

In addition, Entity B did not comply with Principle 14 (see Question 2.6.90) in the
COSO Framework that requires entities to select appropriate methods for
internal communication. In this case, Entity B either did not have a policy in
place that required appropriate supporting documentation for a significant cash
transaction or failed to effectively operate relevant controls under such a policy.

Further, the wire transfer was likely processed in violation of Principle 3 (see
Question 2.4.130) in the COSO Framework that requires entities to segregate
incompatible duties and institute requisite checks and balances from the highest
to the lowest levels of the organization. The A/P Manager should not have been
able to process such a significant wire transfer without appropriate segregated
approval and authorization.

These failures in controls fall within the scope of management’s ICFR

assessment under the rules of the SEC, and the control deficiencies, as
described above, would likely represent a material weakness in Entity B’s ICFR.
However, a material weakness may not exist if Entity B can demonstrate the
existence of effective compensating controls that would have prevented, on a
timely basis, the stolen cash amount from becoming material to Entity B’s
financial statements.

Overall observations

It would be unreasonable to expect management to be able to design,

implement and operate controls that would protect an entity from every potential
fraud scheme against the entity by internal or external parties. However, an
entity should have processes and controls in place that would reduce the risk of
a material misstatement in its financial statements due to fraud to a remote
level. Such risk should be considered in the specific circumstances of the entity
following evaluation of the relevant fraud risk factors.

Question 3.2.40
How does management perform risk assessment
relative to an entity’s ability to continue as a going
concern?
Interpretive response: Management performing the following steps during risk
assessment can adequately address the risk associated with applying Subtopic
205-40 (going concern) of the FASB’s Accounting Standards Codification.

Identify the risk of an inappropriate conclusion on

the entity’s ability to continue as a going concern
1 and the risk of inadequate financial statement
disclosures.
Risk
assessment
process For each risk identified in Step (1), implement a
process to identify and evaluate known and
reasonably knowable conditions and events that
2 are relevant to the entity’s ability to meet its
obligations as they become due during the look-
forward period.

Design and implement controls over (a) the

process used to identify and evaluate possible
ICFR going concern risks and (b) the completeness
process 3 and accuracy of the data used and
reasonableness of assumptions made in the
process (e.g. projected financial information).

Management’s assessment of going concern typically includes an analysis of

the entity’s current and forecasted financial condition and liquidity, as well as the
forecasted effect of management’s plans to mitigate conditions and events that
give rise to a going concern uncertainty, if any. Depending on facts and
circumstances, management’s assessment of going concern may lead to the
determination of a risk of material misstatement (RMM) that would require an
appropriate ICFR response.

The going concern assessment in Subtopic 205-40 requires management to

assess, as of the date of the issuance of the financial statements, an entity’s
ability to continue as a going concern and provide related disclosures. There
may be events that occur during the year, or even subsequent to year-end but
before the financial statements are issued, that may require further
consideration on whether there are conditions and events that raise ‘substantial
doubt’ about the entity’s ability to continue as a going concern, These events
and circumstances could be specific to the entity, or could be a broader
regulatory, economic, or industry matter that requires careful consideration of
rapidly changing circumstances. The risk assessment related to going concern
should extend through the issuance of the financial statements and the entity’s
controls should be designed to identify relevant events and circumstances that
could impact the entity’s ability to continue as a going concern.

Question 5.15.10 provides further discussion of controls related to going

concern.

Question 3.2.50
What are the key activities involved in entity-level and
process-level risk assessments?
This table summarizes the key activities involved in an entity’s entity-level and
process-level risk assessments.

Entity-level risk assessment Process-level risk assessment

Performed at the level of the consolidated Performed at the lowest level of an
entity and its components. entity’s risk assessment process.

• Determine materiality • Understand the flow of transactions

• Identify components with quantitative within a business process from
or qualitative significance initiation to reporting

• Identify significant accounts and • Translate the risk of misstatements

disclosures (RMs) into significant accounts and
assertions
• Consider fraud risks
• Identify the PRPs and determine
• Help ensure the entity has identified whether the PRPs result in an RMM
a comprehensive population of risks
to the achievement of its financial • Identify the controls implemented to
reporting objectives address the PRPs and related RMMs

Process-level risk assessment is covered in more detail in chapter 4.

Question 3.2.60
Can ERM suffice for entity-level risk assessment?

Interpretive response: No. However, a robust enterprise risk management

(ERM) or similar analysis performed by the entity may provide a good starting
point to performing a comprehensive risk assessment under the COSO
Framework.

Specifically, entity-level risk assessment requires incremental determinations

about whether:

• any of the identified risks in the ERM analysis have a potential ICFR
implication; or
• there are specific ICFR risks at the entity level that were not contemplated in
the broader ERM analysis.

Question 3.2.70
Are IT systems included in management’s risk
assessment?
Interpretive response: Yes. IT systems support informed decision making and
the functioning of ICFR by processing relevant, timely and quality information
from internal and external sources. IT systems are pervasive to the entity's
overall ICFR. As such, they need to be covered by management’s risk
assessment.

In addition, changes to IT systems (e.g. new systems, upgrades to an existing

system) are examples of entity-wide events that could have a related financial
reporting risk.

Chapter 7 provides more information about ICFR considerations related to IT

systems.

Question 3.2.80
How does management execute an entity-level risk
assessment?
Interpretive response: Management may perform the following steps as part of
their entity-level risk assessment.

Management uses the concept of materiality to determine what

Step 1 amounts it deems to be material to an end-user of its financial
statements. See section 3.3.

Management uses materiality and other qualitative factors to

Step 2 determine which accounts and processes contain a potential risk
of material misstatement. See section 3.4.

Management considers if the entity contains components and if

the components contain a potential RMM either for all or some
Step 3
specific accounts and processes identified in Step 2. See
section 3.5.

Question 3.2.90
How is the significance of potential risks evaluated?

Interpretive response: The significance of identified risks to reliable financial

reporting can be evaluated in many ways. The most frequently used criteria to
assess the significance of financial reporting risks are:

• the likelihood of a risk occurring;

• the pace of potential change; and
• the potential magnitude of the identified risk’s effect on the entity’s financial
statements.

Question 3.2.100
When a potential RMM is identified, what is
management’s response?
Interpretive response: Once identified and assessed as to significance, risks
to the achievement of the entity’s financial reporting objectives require an
appropriate ICFR response. Not all ICFR responses are required to be
fashioned with the same level of response – a risk of fraudulent revenue
recognition merits a more robust response than a risk of a balance sheet
classification error. But the process to respond to each identified risk is similar:

• The risks should be linked to the relevant assertions over significant

accounts and disclosures (see section 3.4 for a discussion of significant
accounts).

• The accounting literature governing the significant accounts should be

understood.

• The process for the transaction or estimate that drives the accounting
should be understood from initiation to reporting, and PRPs should be
identified (see chapter 4).

• The appropriate controls to mitigate the risks should be designed,

implemented, operated and monitored (see chapter 5).

Question 3.2.110
When does an entity perform and document its risk
assessment process?
Interpretive response: An effective risk assessment process is iterative in
nature. The four principles within the risk assessment component of the COSO
Framework (see section 2.5) are not always considered sequentially because
there is considerable overlap among the principles. Further, as an entity
performs and monitors controls, management may identify items requiring
reassessment of earlier risk determinations.

Much of the risk assessment process takes place in meetings and discussions
with senior management and those charged with governance. Timely
documentation of these and other risk assessment activities undertaken by the
entity and their results helps demonstrate an effective ICFR risk assessment
process.

Practical tip
Related to documentation of management’s risk assessment process, a better
practice is the creation and maintenance of a risk and control matrix, which
includes the account, account balance, the risk factors considered, the
significance of the risk to the accounts and assertions, as well as linking the
risks to the controls designed to address them. The matrix also includes
evidence of proper review and modification when new risks are identified.
Documentation of this review likely includes more than just evidence of a
meeting or its minutes.

Question 3.2.120
Who should perform and review the risk assessment?

Interpretive response: The risk assessment should be conducted by

appropriate levels of management to properly consider the sources and
likelihood of potential misstatements in the entity’s financial statements.
Management involved should have sufficient knowledge and understanding of
the entity’s business, its organization, operations, and processes. This may
include senior management and representatives from the entity’s finance and
accounting departments, operations, legal and compliance, human resources,
and other functional areas.

Findings and conclusions from the risk assessment process should be

presented to and reviewed by the audit committee or those charged with
governance. Doing so assists these groups in fulfilling their oversight
responsibilities regarding the entity’s development and performance of ICFR
under Principle 2 of the COSO Framework (see Question 2.4.110).

Example 3.2.20
Management’s risk assessment process and audit
committee review
Entity A is a global manufacturer of farm equipment. Its Financial Planning and
Analysis (FP&A) department is responsible for preparing the entity’s annual
financial and operating plan. In fulfilling these responsibilities, they carry out an
annual planning and risk assessment process, which involves FP&A personnel
meeting with senior management and representatives of the various functions of
the entity and all its components that are quantitatively or qualitative significant
to ICFR. They review business plans and conduct a comprehensive analysis of
risks to the achievement of established operating and financial goals.

Throughout the year, FP&A personnel monitor a number of internal and external
factors that may indicate a need for revisions to the entity’s plans and forecasts.

In conjunction with the annual planning and risk assessment process conducted
by FP&A, representatives of Entity A’s Internal Audit and Finance Management

departments meet with FP&A personnel. The meeting ensures the FP&A
process gives appropriate consideration to the risks to reliable financial
reporting in accordance with US GAAP and SEC rules and regulations. The
Internal Audit and Finance Management representatives also join FP&A
personnel in various planning and risk assessment activities (meetings,
workshops, brainstorming sessions, etc.), as considered necessary. Their
participation in these activities ensures personnel with sufficient understanding
of the entity’s financial reporting objectives are appropriately represented in the
FP&A process.

All risks identified in connection with the annual planning and risk assessment
process led by FP&A personnel are summarized in a spreadsheet and analyzed
for potential effects on the financial reporting process. Risks identified as
relevant to financial reporting are then separately analyzed to determine if they
rise to the level of an RMM. This analysis is performed by Internal Audit and
Finance Management representatives, including the entity’s CFO and
Controller. In addition, RMMs are linked to the affected significant accounts and
disclosures and the related business processes using a risk and control matrix.

Entity A’s CFO or Controller presents a summary of the identified RMMs to the
audit committee on an annual basis in connection with the committee’s review
and approval of Internal Audit’s annual testing plan. They also provide an
overview of the risk assessment process undertaken by management. In
assessing the sufficiency of the process, Audit committee members consider:

• the reasonableness of the summarized RMMs based on their understanding

of Entity A and its financial reporting process; and
• the appropriateness of management’s planned response to those risks,
including through Internal Audit’s annual testing plan.

3.3 Consideration of materiality

Question 3.3.10
Why is materiality important in management’s design of
an effective system of ICFR?
Interpretive response: Materiality is important in management’s design of an
effective system of ICFR because it focuses attention on those financial
statement amounts and disclosures that could influence the decisions of the
users of the financial statements.

Management’s ability to properly identify RMMs and controls that mitigate those
risks comes from applying the concept of materiality to the financial reporting
process and the resulting financial statements. Establishing an appropriate
materiality measure is an integral component of a focused and effective risk
assessment process.

Practical tip
Given their common purpose in establishing materiality, the materiality used by
management and external auditors generally would be within close proximity to
one another. Open and early communication with auditors on management’s
scoping and what has been deemed to be immaterial and/or not contain a
potential RMM is important for alignment on the determination of materiality.

Question 3.3.20
Is a materiality analysis solely quantitative?

Interpretive response: No. Management should consider the guidance in SEC

Staff Accounting Bulletin (SAB) Topic 1M related to materiality. Provided below
is an excerpt indicating that a materiality analysis involves more than
quantitative considerations.

Excerpt from SAB Topic 1M

…quantifying, in percentage terms, the magnitude of a misstatement is only the

beginning of an analysis of materiality; it cannot appropriately be used as a
substitute for a full analysis of all relevant considerations. Materiality concerns
the significance of an item to users of a registrant's financial statements. A
matter is "material" if there is a substantial likelihood that a reasonable person
would consider it important. In its Concepts Statement 2, Qualitative
Characteristics of Accounting Information, the FASB stated the essence of the
concept of materiality as follows:

The omission or misstatement of an item in a financial report is material

if, in the light of surrounding circumstances, the magnitude of the item is
such that it is probable that the judgment of a reasonable person relying
upon the report would have been changed or influenced by the
inclusion or correction of the item.

Question 3.3.30
Is materiality considered only at the consolidated entity
level?
Interpretive response: No. Materiality established at the consolidated entity
level corresponds with the ultimate objective of effective ICFR, defined in SEC
Regulation 13a-15(f) as “reliable financial reporting and financial statements
prepared in accordance with GAAP.” However, given the complex and
multilayered structure of many of today’s businesses, it is important for
management to ‘translate’ this consolidated entity-level objective into relevant

sub-objectives and measures of materiality at the component (e.g. division,

subsidiary, operating unit) and business process levels.

Question 3.5.70 provides further discussion of considering materiality at the

component level.

3.4 Scoping of accounts and disclosures

Question 3.4.10
Is risk assessment performed at the assertion level?

Interpretive response: Yes. The Internal Control over External Financial

Reporting: A Compendium of Approaches and Examples is a companion
document to the COSO Framework. It defines subobjectives of financial
reporting in terms of assertions over significant accounts and disclosures in the
entity’s financial statements – meaning, the overall objective is reliable financial
reporting in accordance with US GAAP. However, to achieve that objective, an
entity should determine that the relevant assertions of significant accounts and
disclosures have been met.

Financial statement assertions include:

Completeness Existence

Accuracy Valuation

Obligations and rights Presentation

Question 3.4.20
What is a significant account or disclosure?

Interpretive response: A significant account or disclosure is an account or

disclosure where there is a reasonable possibility that the account or disclosure
could contain a misstatement that, individually or when aggregated with others,
has a material effect on the financial statements. The determination of whether
an account or disclosure is significant is made without regard to the effect of
internal controls and may require judgment.

An entity decides which accounts present a risk that the financial statements
contain a material misstatement. Based on the definition of a significant
account, this analysis considers not only the individual account, but also

whether the account in combination with other accounts might give rise to a
material misstatement.

The determination of significant accounts is important because those accounts

determined to be significant will require an ICFR response. Conversely, if an
account is not significant, either individually or in the aggregate, no further ICFR
work is required for that account.

While quantitative measures are important, the identification of significant

accounts and relevant assertions also should consider qualitative factors and
the results of management’s entity-level risk assessment, including changes
that might have an effect on financial reporting.

Example 3.4.10
Considering qualitative factors when identifying
significant accounts
Scenario A: Accounts for a new strategically significant line of business

Facts: The entity is beginning a new line of business and will separately
disclose information about that line of business because it is considered a
significant part of the entity’s strategy and is touted by management to investors
and analysts.

Analysis: The revenues, costs and other accounts associated with the new line
of business may be considered ‘significant accounts’ (i.e. a material
misstatement could arise in those accounts) even if they are quantitatively less
than materiality, due to them being separately disclosed and considered
important to users of the financial statements.

Scenario B: Accounts for which the completeness assertion is relevant

Facts: Some accounts, like the litigation accrual, or assets/liabilities associated

with hedging activities, may be significant even if the current balance is less
than materiality.

Analysis: A risk exists that these accounts could be misstated by more than
materiality because material transactions or events may not be appropriately
reflected in the accounts (i.e. the completeness assertion is relevant). For
example, management has recorded a litigation accrual of $1m, which is less
than materiality ($5m), however the potential effect of the litigation is $10m.

Question 3.4.30
How are significant accounts and disclosures
aggregated or disaggregated?
Interpretive response: It depends on the facts and circumstances. As a
general principle, significant accounts and disclosures should represent classes
of transactions or balances that are subject to similar risks of error or fraud and

similar controls. Therefore, determination of significant accounts and disclosures

may require, on the one hand, disaggregation of the financial statement
captions into components representing distinct classes of transactions or
balances with varying risk profiles. On the other hand, entities may be able to
aggregate multiple general ledger accounts into one significant account or
disclosure based on the same principle.

Individual Financial
general ledger Level of disaggregation or aggregation statement
account caption

Appropriately defined significant accounts and disclosures will typically fall

somewhere in between these two limits, depending on the specific facts and
circumstances of the entity. Management considers factors such as the level of
detail disclosed in the external financial statements and organization of the
entity’s chart of accounts when defining its significant accounts and disclosures.

Practical tip
It is important for management to precisely associate the identified risks with
specific accounts or disclosures and to articulate why the controls designed and
implemented by management and included in the annual ICFR assessment are
responsive to such risks.

For example, if an entity’s significant accounts are defined too broadly (e.g. at
the financial statement caption level), the risk associated with a particular
significant account may be presumed to exist across the entire account instead
of an appropriately disaggregated portion of the account. Defining significant
accounts too broadly may require a control response more pervasive than would
otherwise be necessary.

Example 3.4.20
Disaggregation and aggregation in defining significant
accounts
Scenario A: Industrial manufacturer with two revenue streams

Facts: An industrial manufacturing entity has two material revenue streams

combined in the entity’s financial statements into one caption called ‘revenues’
with additional disclosures included in the footnotes to the financial statements.
One revenue stream relates to routine product sales while the other represents
sales from arrangements with multiple deliverables. Each revenue stream
results from a different process subject to different risks and a separate set of
controls.

Analysis: Without disaggregating the ‘revenues’ financial statement caption into

the two revenue streams previously described, management is unlikely to
identify all the different risk points that could lead to a material misstatement for
each revenue stream. Without identifying the proper risk points, management is
also unlikely to design and identify the appropriate controls. In this case, it would

be appropriate to disaggregate the revenue streams into separate significant

accounts.

Scenario B: Retailer with retail store and e-commerce sales

Facts: A national retailer with a chain of physical store locations, as well as a

large e-commerce sales platform, maintains a general ledger with separate
accounts for sales generated by each store and the e-commerce business.

The merchandise sold at all store locations is similar and all stores use the
same IT system to support their sales.

Analysis: Management aggregates all general ledger sales accounts related to

the physical store locations into one significant account because all these
general ledger accounts have a similar risk profile and are subject to a similar
set of controls.

Management identifies another significant account for sales made through the
e-commerce sales platform. Those risks include ones related to the delivery of
the entity’s merchandise to its e-commerce customers and the timing of the
related revenue recognition.

Management identified two different significant accounts for the retailer’s

revenue because each is a result of a separate process and exposed to
different risks.

Question 3.4.40
What is risk tolerance and how is it considered when
defining significant accounts?
Interpretive response: The COSO Framework introduced a concept called ‘risk
tolerance’, which is formally defined as “the acceptable level of variation in
performance relative to the achievement of objectives.” Said differently, risk
tolerance represents the amount of error or uncorrected misstatement in
relevant assertions over significant accounts and disclosures that management
is willing to accept without concluding that the financial statements are
materially misstated.

Risk tolerance for individual financial statement accounts and disclosures is

established quantitatively at a level lower than materiality for the financial
statements as a whole. Lower risk tolerance for individual accounts and
disclosures reduces the probability that uncorrected misstatements across the
various accounts and disclosures will, in the aggregate, become material to the
overall financial statements.

Question 3.4.50
What actions should management consider taking to
fulfill their ICFR-related responsibilities related to non-
GAAP financial measures?
Background: A non-GAAP measure is a financial, operating, regulatory or
statutory measure that is not determined under US GAAP. It is important to
differentiate between non-GAAP financial measures and other non-GAAP
measures. Non-GAAP financial measures reported by registrants are subject to
certain SEC rules and oversight while operating, regulatory and statutory
measures are not subject to those same rules. A non-GAAP financial measure
is a numerical measure of a registrant's historical or future financial
performance, financial position or cash flows.

Interpretive response: Management may take the following actions to fulfill

their ICFR-related responsibilities for non-GAAP financial measures:

• evaluate and document on a routine basis the registrant’s population of non-

GAAP financial measures, including:
— how the registrant’s non-GAAP financial measures are used;
— why the non-GAAP financial measures are relevant and important to
investors and other users;

• communicate and discuss the registrant’s non-GAAP financial measures

with the audit committee and senior management;
• incorporate the development and review of non-GAAP financial measures
into management’s disclosure controls and procedures; and
• establish a written policy that ensures non-GAAP financial measures are
transparent, consistent and comparable.

Most of these actions originate from recommendations of the SEC staff. The
SEC released Compliance & Disclosures Interpretations on Non-GAAP
Financial Measures in December 2022 and non-GAAP measures are discussed
regularly at the annual AICPA conference.

The SEC staff has also emphasized that audit committee members should seek
to understand management’s judgments related to the design, preparation and
presentation of non-GAAP financial measures and how those measures might
differ from other entities.

3.5 Scoping of components

Question 3.5.10
Which of the components of the group are deemed in
scope for purposes of management’s ICFR
assessment?
Interpretive response: Management determines which of the entity’s
components (e.g. subsidiaries, divisions, entities, business units) present a risk
that the financial statements contain a material misstatement. This evaluation
includes quantitative measures (i.e. the volume or dollar amount of account
balances) as well as qualitative measures (i.e. the nature of the transactions or
activity at the component). Further, this analysis considers not only the
individual component, but also whether the component in combination with other
components might give rise to a material misstatement.

The only ‘out of scope’ components (i.e. components that may be excluded from
the scope of management’s ICFR assessment) are those components for which
there is only a remote risk that the component individually, or in combination
with other insignificant components, includes a material misstatement. The term
‘remote’ has the same meaning as in Topic 450 (contingencies) of the FASB’s
Accounting Standard Codification, which indicates a future event or events is
remote when the chance of occurrence is ‘slight’. Therefore, ‘remote’ is a rather
low threshold for assessing the risk of a material misstatement of an entity’s
financial statements.

Question 3.5.20
Can an entity-level analytical review control be
sufficient to mitigate risks in an individual component or
aggregated components of an entity?
Interpretive response: It depends. Analytical reviews and comparisons of
actual results to budget are common entity-level controls exercised by
management over components of the entity (see Question 2.7.180). If such
analytical reviews are used to address RMMs in the entity’s financial
statements, they need to be performed at an appropriate level of precision,
meaning they would detect and correct a material misstatement in the
underlying accounts and balances being reviewed. The level of precision of
these controls should be documented along with evidence of their operation,
including questions followed-up on and the related answers.

There is no bright line for the size of components (individually or in the

aggregate) that an entity can address with these types of entity-level analytical
review controls because it depends on each entity’s facts and circumstances
and the design of the analytical review control.

The burden is on the entity to demonstrate that entity-level analytical review

controls operate in a manner that would prevent or detect, on a timely basis, a
material misstatement in the entity’s financial statements. However, practically
speaking, it is difficult to design, operate and evaluate entity-level analytical
review controls that are sufficient to mitigate risks in an individual component or
aggregated components of an entity.

Question 3.5.30
Are newly acquired businesses subject to
management’s assessment of ICFR?
Interpretive response: Yes, but the SEC allows for a delay in reporting on
ICFR for acquired businesses because it acknowledges management may have
insufficient time to assess the controls at the ‘as of date’ for a recently acquired
business. In such instances, management may scope out the acquired
businesses from the assessment of ICFR and make appropriate disclosures in
their annual filing. The period during which management may omit such
assessment may not extend beyond one year from the date of acquisition, nor
may such assessment be omitted from more than one annual management
report on ICFR.

However, as it relates to the processes and controls over the preliminary

acquisition accounting (‘Day 1 Accounting’) and consolidation of the acquired
business, those controls need to be designed and operating effectively by the
first public reporting date after the close of the transaction.

When designing controls over the measurement of amounts recognized in

accounting for an acquired business, management should take into
consideration the measurement uncertainty, which is affected by the degree to
which the estimate is considered to be provisional (i.e. preliminary) (see chapter
10 of KPMG Handbook, Business Combinations). However, even if provisional,
controls still need to exist over the measurement, even if less precise, given the
reporting requirements. As the acquisition accounting is finalized, controls
should become more precise.

Section 4.5 provides discussion on understanding how estimates are

determined and the identification of related risks and chapter 5 provides further
guidance on process control activities.

Question 3.5.40
Are disposal groups included in management’s scoping
of components?
Interpretive response: Yes. Management needs to:

• assess if a reasonable possibility of material misstatement exists within the

pre-divestiture activity of the disposal group in its risk assessment; and

• determine if the component includes a risk that the financial statements

contain a material misstatement.

Regardless of the timing of disposal, management's ICFR assessment includes

the entity's controls over applying accounting principles to the discontinued
operations (e.g. determining whether the planned disposal constitutes
discontinued operations under the financial reporting framework, preparing the
presentation and related disclosures for the discontinued operations).

Question 3.5.50
What should the entity consider for components that
are financially insignificant?
Interpretive response: If a component has been classified as being
quantitatively insignificant, management should consider whether the
component includes any RMMs and address the identified RMMs through ICFR.

For example, a component could be responsible for foreign exchange trading

that creates an RMM to the group, even though the component is not otherwise
of individual financial significance to the group.

Question 3.5.60
Is aggregation risk considered when determining
whether a component is in scope (or out of scope)?
Interpretive response: Yes. There is aggregation risk related to entities
comprised of multiple components (e.g. divisions, subsidiaries, operating units)
where consolidated (or group) financial statements are prepared by aggregating
financial information prepared for each component. For such entities, materiality
established at the consolidated entity level is first translated into component
materiality, or the amount of error that could be tolerated in the individual
component (e.g. division, subsidiary, operating unit) financial statements.
Component materiality is always lower than materiality established at the
consolidated entity level.

Question 3.5.70
What are factors to be considered in determining
component materiality?
Interpretive response: Component materiality for individual components
should reflect a sufficient decrease from materiality to adequately address the
aggregation risk that exists at the consolidated financial statement level. The
size of the decrease from materiality for the overall financial statements may
differ for each component and should be commensurate with the assessed
aggregation risk.

Factors that should be considered when determining the size of the decrease
from materiality include:

• the number and relative size of the components;

• the nature and extent of difference in operations, financial reporting and the
control environment at each component in the current period (e.g. different
systems, operations, financial reporting guidelines, etc. would lead to a
lower component materiality); and

• the nature and extent of accounting judgments made at the component

level.

As the number of components increases, the aggregation risk is also likely to

increase, thus necessitating an even more careful analysis and consideration of
a lower materiality for the component. The aggregation risk of component
materiality for groups consisting of a smaller number of similarly sized
components likely is lower and therefore components may have a higher
materiality. The higher the aggregation risk identified, the lower the materiality
should be for individual components.

Question 3.5.80
Should management document the scoping of its
accounts, processes and components performed as
part of risk assessment?
Interpretive response: Yes. It is important for management to document the
consideration of materiality and ICFR objectives at the entity level and the
translation of these entity-level concepts into relevant sub-objectives and
measures of risk tolerance (see Question 3.4.40) and materiality at the division,
subsidiary, operating unit and business process level. Management then uses
these materiality considerations and ICFR objectives to scope the entity’s
accounts, processes and components and document these conclusions. Timely
documentation of these considerations is key to an effective assessment of the
entity’s ICFR.

Practical tip
Scoping documentation may take the form of a memoranda on entity-level
considerations, such as materiality, and a scoping matrix presenting the
following:

• management’s determination of the relevant components of the entity;

• significant accounts and disclosures at the entity and component level;
• relevant assertions over the accounts and disclosures; and
• information on how these items link to the related business processes and
internal controls.

3.6 Identifying and assessing fraud risks

Question 3.6.10
Are all entities required to consider fraud risks in their
risk assessment?
Interpretive response: Yes. The COSO Framework requires entities to
consider the potential for fraud in assessing risks to the achievement of its
objectives.

Every business entity faces some risk of fraud from within. However, the very
nature of fraud makes it difficult to detect. It can also evolve and change over
time, which makes prevention or detection of fraud even more difficult. In
addition, as shown by major corporate fraud scandals in nearly every decade of
the past century, fraud can have a significant negative effect on an entity’s
financial reporting process, the reliability of its financial statements and investor
confidence.

Given the nature of fraud and the difficulties involved in its detection, both the
SEC staff and the COSO Framework make it clear that an appropriate risk
assessment should specifically consider the entity’s vulnerability to fraudulent
activity.

Principle 8 of the COSO Framework (see Question 2.5.120) identifies four types
of fraud that require consideration in an entity’s risk assessment process:

Type of fraud Impact

Fraudulent financial reporting May result in a misstatement in the financial
statements. See Question 2.5.130.
Misappropriation of assets May result in a misstatement in the financial
statements. See Question 2.5.130.
Corruption and other illegal acts Corruption is generally considered more of a
compliance matter but could influence the
control environment that also affects the entity's
external financial reporting objectives.
Management override of controls Management override describes action taken to
override an entity's controls for an illegitimate
purpose including personal gain or an
enhanced presentation of an entity's financial
condition or compliance status. See Question
5.14.40.

Question 3.6.20
How is a fraud risk assessment performed?

Interpretive response: As part of the fraud risk assessment process,

management and those charged with governance first look at broad programs
that detect or deter fraud. This assessment crosses over with many of the
processes, controls and programs considered in the control environment
component of ICFR (see section 2.4), such as:

• the entity’s whistleblower hotlines;

• the tone at the top and how it is communicated throughout the organization;
and
• the entity’s response when fraud or potential fraud is identified.

The SEC has highlighted the importance of the whistleblower hotline and noted
that a hotline should not just be a check the box requirement and instead should
focus on a culture that encourages whistleblowers to come forward.

These broad programs are critical to effective fraud prevention and, therefore,
are considered when determining whether fraud risk is effectively mitigated.
However, consideration of these broad programs is only the first step in
considering the risk of fraud. A robust fraud risk assessment also includes:

• identifying fraud risk factors present at various levels within the entity (see
Question 3.6.30); and
• identifying specific fraud risks at the financial statement and assertion level
(see Question 3.6.50).

Question 3.6.30
How are fraud risk factors identified?

Interpretive response: Identifying fraud risk factors involves assessing the

three categories of fraud risk factors represented in the ‘fraud risk triangle’ –
incentives and pressures, opportunity, and attitudes and rationalizations – as
illustrated in the following diagram.

Incentive/
Pressure
Why someone
might commit fraud

Fraud

Attitude/
Rationalization Opportunity
The state of mind The ‘setting’ that
that helps justify helps someone
committing fraud commit fraud

• Incentives and pressures are typically assessed by considering:

— what those incentives or pressures are (e.g. pressure to meet or exceed
analysts’ earnings expectations or to meet financial covenants required
in debt agreements; incentive to meet financial targets to earn bonuses
or increase stock value); and
— who is exposed to those incentives and pressures (e.g. management,
sales representatives, finance personnel).

An analysis of compensation plans for key individuals is likely necessary to

fully understand whether an incentive to commit fraud exists and, just as
important, where the factor might manifest itself into an assertion-level fraud
risk.

• Opportunity refers to conditions that exist that might allow employees to

commit fraud. Examples where an opportunity to commit fraud may exist
include:
— the entity’s inventory is not properly secured and therefore is subject to
theft and resale by employees; and
— the entity’s sensitive financial statement estimates can be manipulated,
resulting in a material effect on an entity’s earnings.

• Attitudes and rationalizations is a subjective analysis that often coincides

with an evaluation of the tone at the top. However, it is not just an analysis
of whether someone has an attitude of committing fraud – such an attitude
may be difficult to detect. An analysis of attitudes and rationalizations
extends to whether key management understand the importance of
accurate financial reporting. For example, a CEO who is unduly interested in
improving financial results may either have an attitude or create a

rationalization in others that fosters an environment where fraud might be

tolerated.

In general, at least one of these fraud risk factors is present when fraud exists.
All three factors are not required to be observed or evident to conclude that a
fraud risk exists. An entity may conclude that a fraud risk exists even when only
one of the three factors is present.

The COSO Framework identifies factors that may influence the various ways
that fraud in financial reporting could occur and that should be considered in
management’s fraud risk assessment.

Fraud risk factor

Factors that may influence the occurrence of fraud category
Management bias Attitude
Degree of estimates and judgments in external reporting Opportunity
Fraud schemes and scenarios common to the industry sectors Opportunity or
and markets in which the entity operates attitude
Geographic regions where the entity does business Opportunity or
attitude
Incentives that may motivate fraudulent behavior Incentive
Nature of technology and management’s ability to manipulate Opportunity
information
Unusual or complex transactions subject to significant Opportunity or
management influence attitude
Vulnerability to management override and potential schemes to Opportunity or
circumvent existing control activities attitude

Question 3.6.40
How does an entity consider fraud risk factors in
identifying fraud risks?
Interpretive response: Once an entity identifies fraud risk factors, it evaluates
whether those factors, individually or in combination, indicate that a fraud risk is
present.

The SEC staff 3 has stated that “Management should recognize that the risk of
material misstatement due to fraud ordinarily exists in any organization,

3
17 CFR Part 241 (Release No. 33-8810), Commission Guidance Regarding Management’s
Report on Internal Control Over Financial Reporting Under Section 13(a) or 15(d) of the
Securities Exchange Act of 1934, p. 14.

regardless of size or type, and it may vary by specific location or segment and
by individual financial reporting element.

For example, one type of fraud risk that has resulted in fraudulent financial
reporting in companies of all sizes and types is the risk of improper override of
internal controls in the financial reporting process. While the identification of a
fraud risk is not necessarily an indication that a fraud has occurred, the absence
of an identified fraud is not an indication that no fraud risks exist. Rather, these
risk assessments are used in evaluating whether adequate controls have been
implemented.”

Once fraud risks have been identified, the entity designs control activities
responsive to the fraud risks, including, but not limited to, the risk of
management override of controls.

Question 3.6.50
How does management define and document
assertion-level fraud risks?
Interpretive response: Generally, the identified fraud risks should be linked to
a specific financial statement assertion or assertions. Without this link, it may be
difficult to understand what controls should be designed or selected for
evaluation to address the fraud risks.

In the unusual case where it is not possible to link the identified fraud risk to a
specific financial statement assertion, management should consider whether the
identified fraud risk is defined in an overly broad manner. If so, management
should consider the need to redefine the fraud risk. If not, and the identified
fraud risk truly has a pervasive effect on the entity’s financial statements,
management would need to develop an appropriately robust control response.

When assertion-level fraud risks are identified, the entity should be very specific
about what the risk is. For example, if there is an incentive for management to
increase revenue, specific opportunities for management to manipulate
revenue, such as the following, should be identified (see Example 3.6.10):

• posting fictitious journal entries to record additional revenue (management

override of controls);

• entering into side agreements with customers (e.g. an agreement with the
customer to take delivery of goods before they are wanted or needed with
an understanding that the goods can be returned after period-end or that the
payment terms can be extended);

• marking items as shipped in the system when they have not yet been
physically shipped; or

• manipulating estimates related to revenue (e.g. shipping transit time,

performance obligations satisfied over time).

The more specific the risk, the better the entity is going to be able to design and
monitor controls that are responsive to the risk. This risk assessment should be
documented consistent with Question 3.5.80.

Example 3.6.10
Revenue-related fraud risks and related controls
The following table includes examples of fraud risks related to revenue and
controls that may address those risks.

Fraud risks Controls1

Posting fictitious journal entries to record Review by an objective party of all
additional revenue manual journal entries posted to the
revenue account and a subledger-to-
general-ledger reconciliation
Entering into side agreements with Confirmations with customers to identify
customers side agreements, or a post-period-end
review of returns or aged receivables by
appropriate personnel specifically looking
for indicators of side agreements
Marking items as shipped in the system Sweeps of loading docks and warehouse
when they have not yet been physically facilities or comparisons of shipping
shipped terms to customer requests by
appropriate personnel
Manipulating estimates related to Review of key estimates by appropriate
revenue personnel, including comparison of key
estimates to prior periods
Note:
1. See chapter 5 for considerations related to appropriate control design.

Keep in mind that if an entity has identified an assertion-level fraud risk, it is

expected that there will be incremental effort to mitigate the risk – either
additional controls added to mitigate the risk or specific changes to the design or
operating effectiveness of existing controls. In the side agreements example
above, entity personnel are likely constantly reviewing returns and aged
receivables. But, in response to the fraud risk, the analysis should be
specifically focused on returns or aged receivables that may indicate side
agreements.

Section 4.7 discusses journal entry process understanding and identification of

risk points, section 5.13 discusses controls responding to a fraud risk and
section 5.14 discusses controls over journal entries and other adjustments.

Question 3.6.60
How is materiality considered in an entity's fraud risk
assessment?
Interpretive response: When identifying and evaluating risks of fraud in the
entity's financial reporting process and designing and evaluating relevant anti-
fraud controls, management should consider:

• the quantitative materiality of any potential misstatements; and

• the qualitative effects the fraud could have.

The objective of effective ICFR is to prevent or detect, on a timely basis, a

material misstatement due to fraud or error. Given that objective, it is important
to acknowledge that risks of fraud generally require careful consideration and
response in the form of appropriately designed controls even if the
misstatements that could arise because of those fraud risks are lower than the
quantitative measure of materiality. This is due to the qualitative considerations
related to misstatements caused by fraud in the financial statements.

Qualitative considerations that an entity may consider as part of its fraud risk
assessment include:

• intent to achieve a particular outcome, such as to meet analyst

expectations;
• involvement in the fraud by members of senior management; and
• questions about the pervasiveness of the fraud and its effect on the
reliability of the entire financial statements.

Question 3.6.70
How are those charged with governance involved in an
entity's fraud risk assessment?
Interpretive response: The COSO Framework emphasizes the importance of
those charged with governance overseeing the fraud risk assessment process.
This is particularly important when it comes to the risk of management’s override
of controls. In line with the COSO Framework, those charged with governance
challenge management, depending on the circumstances, when performing this
oversight.

For example, based on the results of the entity's risk assessment process, those
charged with governances might exercise its oversight role by, on a periodic
basis:

• selecting a sample of significant accounting estimates in the financial

statements; and
• reviewing and challenging management's key judgments in these estimates.

Example 3.6.20
Refresh of the entity’s fraud risk assessment process
Management and the Audit Committee take a fresh look at the entity’s fraud risk
assessment process. They determine that fraud risks have been historically
‘covered’ by the overall risk assessment activities conducted on an annual basis
by Internal Audit. However, after reviewing the guidance included in the COSO
Framework, management and the Audit Committee determine that to truly
achieve Principle 8 (see Question 2.5.120):

• Fraud risk assessment should be integrated with the wider enterprise risk
assessment process and conducted by the Risk Management Office.

• The process should include formal discussions with key personnel at the
entity’s corporate head office and all significant locations.

• The discussions with key personnel should consider the different types of
fraud facing the entity and the various ways that a material financial
reporting fraud could occur.

• In preparation for the discussions with key personnel, Risk Management

Office personnel should analyze the ‘fraud risk triangle’ to help identify
conditions in which fraud may occur.

• Findings from the fraud risk assessment meetings should be summarized in

minutes.

• Identified fraud risks should be documented in a Risk and Control Matrix,

evaluated for severity and linked with relevant controls.

• Results of the fraud risk assessment process should be reported to the

Audit Committee on an at least annual basis.

3.7 Consideration of changes to ICFR

Question 3.7.10
Are changes to ICFR required to be evaluated?

Interpretive response: Yes. Principle 9 of the COSO Framework (see Question

2.5.180) requires management to have controls in place to early identify and
communicate ICFR changes that have a significant effect on financial reporting,
and to assess the risks resulting from those changes. The COSO Framework
refers to such controls as an ‘early warning system’.

Question 3.7.20
What types of changes to ICFR are required to be
evaluated?
Interpretive response: Entities are required to assess the changes listed here
and consider how such changes may affect their system of ICFR.

Changes in the… Examples

External environment • New laws
• New accounting pronouncements
• New stock exchange regulations
Business model • New product launches
• Geographical expansion
• Restructuring
Leadership of the entity • New executive leadership
• Turnover in key financial reporting
positions

Example 3.7.10
Entity-wide events with financial reporting risks and
ICFR impact
The following table includes examples of entity-wide events and how they may
affect financial reporting. These changes should be evaluated to determine if
there are new PRPs that require a new or modified control response.

Event Potential impact to financial reporting

Changes in GAAP • changes in how underlying data is captured,
generated, analyzed or reported
• new RMMs
• risks related to SAB 74 disclosures
Changes in third-party • changes to the way the third-party receives and
service providers provides data
• changes to the way the third-party processes data
Changes in business • assets held for sale
strategy • triggering events for asset impairment
• change in the entity’s determination of materiality
• new or modified revenue streams
Entrance into new • unknowns related to valuation of receivables
geographic markets • new risks for safeguarding of assets in new
environment
Business combinations • purchase price accounting
• valuation of intangibles and other assets

Event Potential impact to financial reporting

Other nonroutine • approval of nonroutine transactions
transactions1 • new accounting treatment(s)
• new RMMs
Changes in organizational • change in reporting units
structure
Deterioration of the results • triggering events for potential impairment
of operations • going concern assessment
Note:
1. Examples of other nonroutine transactions include issuances of debt,
restructurings, unusual sales transactions or related party transactions.

Other changes could have an affect directly on personnel including layoffs

(RIFs), promotions, new hires and offshoring. These can all result in new control
operators performing controls, and therefore focus should be given to their
authority and competence as well as consideration of increased risks due to
constrained resources. RIFs and other layoffs also may provide a fraud risk
factor related to an increased risk of fraud due to disgruntled employees.

Example 3.7.20
Change in business model – entity’s investment policy
Facts: An entity makes a change in its investment policy when senior
management decides to invest in lower-grade securities to obtain a higher yield,
and the board of directors approves the decision.

Analysis: This change should be identified and analyzed for any potential effect
on ICFR. For example, investing in lower-grade securities may present
significant valuation risks that previous investments in cash and cash
equivalents did not – these risks will need to be understood and controlled. It is
very likely that ICFR in the area of valuation of securities will need to be
enhanced given the new risks.

Example 3.7.30
Change in external environment – COVID-19
As a result of COVID-19, entities may have been faced with new or exacerbated
risks of misstatement to the financial statements. Such risks may range from:

• more traditional risks that simply did not represent risks of material
misstatement in the previous years (such as impairment of certain long-lived
assets); to

• risks that are unique to the current environment (such as appropriate

recognition of funds received from various government assistance
programs).

In addition, remote working conditions or, at some entities, employees’ return to

their workplaces, as well as employee turnover and lack of qualified employees
in certain industries or geographic locations, may have a significant effect on
entities’ ICFR.

Example 3.7.40
Change in external environment – Russia-Ukraine war
The Russia-Ukraine war and related events are taking place at a time of global
economic uncertainty and volatility, and the effects are likely to interact with and
exacerbate current market conditions, including global demand, foreign
exchange rates, interest rates and general liquidity. These effects may be felt by
a broad range of entities with no direct exposure to Russia, Belarus or Ukraine
and may carry through to the entities’ financial statements and ICFR.

Potential direct and indirect effects of the Russia-Ukraine war may include, but
not be limited to:

Direct effects Indirect effects

• Destruction/closure/abandonment of • Rising commodity prices
facilities, which may not be • Increased raw material costs
recoverable due to act of war • Supply chain disruptions and delays
exceptions in insurance contracts. • Inflation
• Significant business interruption and • Labor shortages
lack of ability to operate due to: • Trade friction
— loss of inventory; • Uncertain financial markets
— inability to manufacture and/or
procure key materials;
— travel restrictions;
— logistics disruptions; and
unavailability of personnel.
• Sanctions, laws, regulations and
involuntary actions on the entity’s
ability to do business.
• Inability to finance operations due to
lack of access to capital or inability to
access financial instruments located
in certain countries.

Example 3.7.50
Change in external environment – climate risks
As part of the risk assessment process, an entity may need to consider the
effect of evolving climate risks, such as transition risk (e.g. changes in
operations, reduced availability of raw materials) or physical risk (e.g. loss of
information systems due to extreme weather events). Performing an effective

risk assessment includes understanding whether the related process is

designed to capture both internal and external factors that have financial
reporting implications.

Question 3.7.30
How much of the ICFR process does a change in risk
assessment impact?
Interpretive response: Risk assessment has a widespread effect – a change in
risk assessment or the process could result in a change to the PRP and
therefore necessitate a change in the process control activity. Management
should evaluate the magnitude of a change to ensure it is properly considered
and addressed as part of ICFR.

Risk assessment (materiality and scoping of

accounts) Change in scope
Chapter 3

Process understanding (identification of systems

and risk points) Change in process
Chapter 4

Controls implemented to address risk points

Change in control (automated, manual, service organization)
Chapter 5

Controls implemented over information utilized in

Change in controls
information used Chapter 6

GITCs over systems utilized in controls

Chapter 7

See section 5.17 for guidance on changes in controls.

Example 3.7.60
Changes at an entity and their effect on ICFR
This example includes three change events at an entity and the effects on the
entity’s ICFR response depending on the likelihood of the event touching ICFR
and the pace or magnitude of the change to ICFR.

Likely to result in less

Likely to result in a significant or no ICFR
Change event significant ICFR response response
Reduction in force • Large RIF spans across • Small RIF is concentrated
(RIF) the entity or within the in an area that doesn’t
finance department. handle ICFR directly.

Likely to result in less

Likely to result in a significant or no ICFR
Change event significant ICFR response response
• Potential change in • Potential or no change in
process. controls.
Entrance into new • New market is expected • Growth of new market is
geographic market to be one of high and expected to be slow and
relatively quick growth. methodical.
• Potential change in • Potential or no change in
scope. controls.
Change in a third- • Third-party service • Third-party service
party service provider handles provider handles
provider processing of 50% of processing of legal claims
revenue transactions. where the entity has
• Potential change in multiple methods to
process. determine the complete
population of legal claims.
• Potential or no change in
controls.

Practical tip
For larger changes, management may perform a change impact analysis,
including affected areas, roles, controls and processes, and highest areas of
resistance and risk. After this analysis, they can then outline a plan to address
any identified risks.

Question 3.7.40
How often should changes to ICFR be evaluated?

Interpretive response: Continuous risk assessment is critical to respond to a

changing business and control environment. Given the pace of change and how
fluid current conditions are, there is likely a need to revisit the risk assessment
determinations in some areas more than once throughout the year.

Practical tip
Having one of the following periodic controls can assist in identifying smaller
changes in controls that can ultimately have a large effect on management’s
ICFR assessment:

• Each control owner attests to whether there have been changes in controls.
• Agendas for management or other committee meetings include a standing
item to discuss and assess changes in controls.

Key takeaways

• Risk assessment is an iterative, cumulative process that requires a

reassessment of initial conclusions based on evidence obtained throughout
the assessment.

• Materiality should be determined based on those financial statement

amounts and disclosures that could influence the decisions of the users of
the financial statements.

• Management conducts risk assessment at all relevant levels within the

entity, from the consolidated entity level down to the business process level.
Appropriate members of management and other employees should be
involved in the risk assessment process.

• Management determines the components of the group that are of

quantitative or qualitative significance and their significant accounts as part
of scoping.

• Fraud risk assessment should be comprehensive, cover various levels

within the entity and involve appropriate members of management and
employees.

• Risk assessment considers changes that could have an effect on ICFR.

Identified changes are typically analyzed down to the process level.

4. Process understanding
Detailed contents
4.1 Management’s ICFR journey
4.2 Identifying the process risk points
Questions
4.2.10 What does management do after completing process
understanding?
4.2.20 What is a PRP?
4.2.30 What is the difference between an RM, an RMM and a PRP?
4.2.40 Do all PRPs require an ICFR response?
4.2.50 What factors are considered in determining if a PRP could
result in an RMM?
4.2.60 Are internal controls considered when evaluating if a PRP is
an RMM?
4.2.70 How are PRPs identified?
4.2.80 How should PRPs that lead to RMMs be documented?
Examples
4.2.10 Inventory illustration
4.2.20 Specificity and clarity of PRPs
4.2.30 Lack of specificity leads to ineffective design or assessment
of controls
4.3 Understanding the business process and performing walkthroughs
Questions
4.3.10 Is management required to gain an understanding of
business processes?
4.3.20 Is management required to document an understanding of
business processes?
4.3.30 What is included in understanding a business process?
4.3.40 How is an understanding of business processes obtained?
4.3.50 What is a walkthrough?
4.3.60 Is a walkthrough performed of the process as a whole, or
just the controls that are in place?
4.3.70 Who is responsible for understanding the business process?
4.3.80 When does management obtain an understanding of the
business process?

4.3.90 How does management evidence their process

understanding?
4.3.100 What should be documented related to process
understanding?
4.3.110 What type of questions should be asked in the walkthrough?
4.3.120 Are IT systems included in walkthroughs?
4.3.130 Does obtaining a process understanding extend to service
organizations?
4.3.140 Where does a walkthrough begin?
4.3.150 What parts of a process are included in a walkthrough?
4.3.160 How does management consider variations in processes
when performing a walkthrough?
4.3.170 How does management consider multiple physical sites
when performing a walkthrough?
4.3.180 Can control activities that were originally determined to be
homogeneous not actually be homogeneous?
4.3.190 How often is the understanding of a business process
updated?
4.3.200 How often are walkthroughs performed by management?
Examples
4.3.10 Determining the scope of a walkthrough
4.3.20 Management factors risk into the extent of procedures
performed to update the understanding of a business
process
4.4 Considerations related to period-end financial reporting, including
preparation of disclosures, in obtaining a process understanding
and identifying risk points
Questions
4.4.10 Does obtaining a process understanding apply to the period-
end financial reporting process, including preparation of
disclosures?
4.4.20 What are the processes and procedures in the period-end
financial reporting process?
4.4.30 What is included as part of the understanding of the
preparation, review and approval of the financial statements,
including disclosures?
4.4.40 How is the understanding of the preparation of financial
statement disclosures obtained?
4.4.50 Is a walkthrough of the period-end financial reporting
process the same as other business processes?

4.5 Considerations related to estimates in obtaining a process

understanding and identifying risk points
Questions
4.5.10 What is an accounting estimate?
4.5.20 How do estimates pose a risk to the financial statements?
4.5.30 What is estimation uncertainty?
4.5.40 Where does estimation uncertainty arise in accounting
estimates?
4.5.50 What is ‘subjectivity’?
4.5.60 What is ‘complexity’?
4.5.70 What is 'management bias' and how does it affect
accounting estimates?
4.5.80 What should management consider when identifying
accounting estimates within their processes?
4.5.90 What controls should the entity have over the identification
and oversight of estimates?
4.5.100 What are the primary elements of an estimate?
4.5.110 What does management understand related to the
development of estimates?
4.5.120 How are risks identified as part of estimates?
4.5.130 What are the additional inherent risk factors considered in
relation to accounting estimates?
4.5.140 What does management consider when evaluating whether
the method may give rise to an RMM for the estimate?
4.5.150 What does management consider when evaluating whether
the model may give rise to an RMM for the estimate?
4.5.160 What does management consider when evaluating whether
an assumption may give rise to an RMM for the estimate?
4.5.170 What does management consider when evaluating whether
the data may give rise to an RMM for the estimate?
4.5.180 How might management address estimation uncertainty?
4.5.190 How might the applicable financial reporting framework
affect the related disclosures regarding estimation
uncertainty?
4.5.200 What are common PRPs and controls related to whether
disclosures for accounting estimates conform to the
applicable financial reporting framework?
4.5.210 When might management use specialists or third parties
(other than specialists) in developing an accounting
estimate?

4.5.220 Are the risks for estimates different if management uses a

specialist?
4.5.230 Does the entity identify risks over data generated by a
specialist specifically for the entity’s use in an estimate?
Examples
4.5.10 Documentation of understanding of the process for
developing accounting estimates
4.5.20 Understanding elements and identifying PRPs in an estimate
4.6 IT considerations when obtaining a process understanding and
identifying risk points
Questions
4.6.10 What are IT considerations when obtaining a business
process understanding?
4.6.20 Why is understanding the overall IT environment important?
4.6.30 What is a better practice for documenting the understanding
of IT systems?
4.6.40 What is included in an ISD?
4.6.50 Is management required to identify IT risks at the process
level?
4.6.60 What effect do GITCs have on IT at the process level?
4.7 Considerations for journal entries and other adjustments while
obtaining a process understanding and identifying risk points
Questions
4.7.10 Does obtaining a process understanding apply to the journal
entry process?
4.7.20 What are potential risks associated with journal entries and
other adjustments?
4.7.30 What are the risks related to automated and manual journal
entries and other adjustments?
4.7.40 What are additional considerations related to the approval of
journal entries?
Key takeaways

4.1 Management’s ICFR journey

Obtaining an understanding of business processes and the financial reporting
process is an important part of management’s ICFR journey because it provides
the basis for management to identify and assess process risk points (PRPs) and
the related risks of material misstatement (RMMs). These activities facilitate the
identification, design and implementation of appropriate control activities to
address PRPs (see chapter 5). An inadequate understanding of a business
process and the related RMMs and PRPs often can lead to inappropriate design
and selection of controls, which in turn can result in deficiencies being identified
in the later stages of an entity’s ICFR.

2. Entity-level controls

9. Identify and evaluate deficiencies

3. Risk assessment

4. Process understanding
Document understanding of processes including systems utilized

Risk points in processes that could result in a material misstatement

5. Process control activities

6. Information used in controls 7. General IT controls 8. Service organizations

Identifying and documenting RMMs and PRPs

This chapter starts with explaining how management identifies RMMs and PRPs
(see section 4.2). An RMM is a risk that could result in a material misstatement
to the financial statements. A PRP is a point in the business process that a
misstatement could, individually or in the aggregate, yield a material
misstatement (including a misstatement due to fraud) to the financial
statements. The PRP is the 'where' and the 'how' in the business process that a
misstatement could be introduced. The RMM is the 'what' that could be
misstated.

There are many inherent risk factors in individual transactions processed

through (or in) an account or reflected in a disclosure that may be considered in
determining if a PRP could result in an RMM. Those PRPs that could result in a
material misstatement, individually or in combination with other misstatements,
require an ICFR response.

PRPs that could result in RMMs should be documented in sufficient detail to

identify the specific condition that would allow for a material misstatement to
occur within the financial statements. In addition, the documentation for each
PRP should link to a relevant financial statement assertion.

Obtaining and documenting process understanding

This chapter continues with management gaining an understanding of its

business processes and preparing/maintaining appropriate documentation of
that understanding (see section 4.3). There are many ways management may

obtain this understanding; but, generally, performing a walkthrough is the most

comprehensive method of doing so. In a walkthrough, a single transaction is
followed from initiation through the entity’s processes, including its information
systems, until the transaction is reflected in the entity’s financial records.

The documentation of process understanding should capture the flow of

information through an entity’s process and be of sufficient detail to provide
understanding of the flow of information through the entity’s processes (see
section 4.3) and relevant IT systems (see section 4.6) and identify all relevant
RMMs and PRPs associated with a particular process (see section 4.2).
Chapter 5 addresses the identification, design and implementation of control
activities to address relevant PRPs.

Considering the financial reporting process in process understanding

Management’s process understanding also includes the period-end financial

reporting process (see section 4.4). That process includes the activities an entity
performs to close the books and make post-closing adjustments when preparing
the individual financial statements (e.g. balance sheet, statement of income)
and related disclosures.

Considering estimates in process understanding

As part of its process understanding, management identifies and evaluates the

risks related to accounting estimates (see section 4.5). By their nature,
accounting estimates are subject to factors that inherently drive risks of
misstatement, such as estimation uncertainty, complexity and subjectivity.
These factors also make estimates susceptible to management bias.

As part of the ICFR framework, management should identify where there are
estimates or changes in estimates in their business processes. Once identified,
management determines whether there is an RMM associated with the selection
or application of the methods, assumptions or data.

Considering IT in process understanding

Understanding the flow of transactions into, through and out of the relevant IT
systems is an integral part of management’s process understanding (see
section 4.6). Management identifies and documents the relevant PRPs related
to IT at the assertion level where there is a reasonable possibility that they could
result in or contribute to a material misstatement. Documentation of
management’s consideration of IT in its process understanding may be
facilitated using IT System Diagrams (ISDs).

Considering journal entries in process understanding

Management obtains an understanding of business processes all the way

through the recording of journal entries and uses this understanding to identify
the RMMs and PRPs related to journal entries (see section 4.7). The potential
risks related to journal entries include the existence of the underlying
transactions, their accuracy and completeness and the potential for
management override. An understanding of the recording of journal entries also
includes consideration of any differences in the process for manual versus
automated journal entries, including authorization of manual journal entries.

Abbreviations

We use the following abbreviations in this chapter.

COSO Committee of Sponsoring Organizations of the Treadway

Commission
GAAP Generally accepted accounting principles
GITC General IT control
ICFR Internal control over financial reporting
ISD IT systems diagram
PRP Process risk point
RAFIT Risk arising from IT
RM Risk of misstatement
RMM Risk of material misstatement
SEC Securities and Exchange Commission

4.2 Identifying the process risk points

Question 4.2.10
What does management do after completing process
understanding?
Interpretive response: After obtaining an understanding of the flow of
transactions, management identifies the PRPs.

Question 4.2.20
What is a PRP?

Interpretive response: A PRP is a point in the business process that a

misstatement could, individually or in the aggregate, yield a material
misstatement (including a misstatement due to fraud) to the financial
statements. The PRP is the 'where' and the 'how' in the business process that a
misstatement could be introduced.

Every business process is likely to contain multiple PRPs. In addition, each

identified risk of material misstatement (RMM) will have at least one PRP.

Question 4.2.30
What is the difference between an RM, an RMM and a
PRP?
Interpretive response: Risk of misstatements (RMs) generally stem from the
accounting framework, so they are generally the same for similar transactions
across entities. RMs can become RMMs based on the specific factors of the
entity, including size and volume of transactions. PRPs are the specific points
where a material misstatement could be introduced by the process.

The RMM is the 'what' could be misstated, whereas the PRPs are the 'where'
and the 'how' in the process an RMM can arise.

Example 4.2.10
Inventory illustration
In the diagram below, inventory is a significant account with an RM that has
been identified as an RMM. The RM is based on the accounting standards and
has been identified as an RMM due to the size and volume of transactions at

the entity. In evaluating how the RMM could occur, the entity has identified
process specific PRPs that are addressed by process control activities.

What

Risk of material misstatement

(RMM)
Inventories are not correctly recorded at the net realizable value, when
net realizable value is lower than cost at the period end.

Where and How

Process risk point

(PRP)
Historical sales data The spreadsheet
Sales forecasts used
used in the inventory used to calculate
in the inventory
reserve calculation the inventory
reserve calculation
may not transfer reserve may be
may not adequately
completely and inappropriately
reflect market
accurately from the accessed and/or
conditions.
sales ledger. changed.

Question 4.2.40
Do all PRPs require an ICFR response?

Interpretive response: No. Only those PRPs that could result in a material
misstatement, individually or in combination with other misstatements, require
an ICFR response.

Question 4.2.50
What factors are considered in determining if a PRP
could result in an RMM?
Interpretive response: Assessing the likelihood and magnitude of potential
misstatements can help in determining if a PRP could result in an RMM. When
the likelihood of a potential misstatement is more than remote and the
magnitude is material, the PRP could result in an RMM.

The following are inherent risk factors in individual transactions processed

through an account or reflected in a disclosure, or in the account or disclosure
itself, that may be considered in determining if a PRP could result in an RMM:

• quantitative or qualitative significance, including:

— size and composition of the account;
— nature of the account or disclosure;
— existence of related-party transactions in the account;
— possibility of significant contingent liabilities arising from the activities
reflected in the account or disclosure;
— exposure to losses in the account;

• volume, complexity and homogeneity of activity;

• susceptibility to misstatement due to error or fraud;
• degree of accounting and reporting complexities;
• degree of subjectivity, including judgment in the recognition or measurement
of financial information related to the risk;
• occurrence of change(s), including changes from the prior period, in
characteristics of the account or disclosure;
• susceptibility to recent significant economic, accounting or other
developments; and
• degree of uncertainty present.

Practical tip
Management should consider underlying GAAP when determining if there are
additional RMMs within a process, particularly around infrequent and/or unusual
transactions.

Question 4.2.60
Are internal controls considered when evaluating if a
PRP is an RMM?
Interpretive response: No. The effects of internal controls are not considered
when determining if a PRP could result in an RMM.

Question 4.2.70
How are PRPs identified?

Interpretive response: A PRP is not simply a risk that the data could be
misstated. It also is not the absence of a control. Rather, a PRP is any condition
that could allow material misstatements to enter the system or cause the data to
lose its integrity. There are likely to be multiple PRPs in every business process.

PRPs also include a risk of unauthorized acquisition, use or disposition of

assets that could result in a material misstatement of the financial statements.

There are many considerations in the identification of PRPs. For example:

• how data enters an IT system;

• how data is stored within an IT system, and the ways in which it may be
accessed or transferred to another system;

• where in the process data is summarized, accumulated, subjected to

calculations or otherwise manipulated;

• whether there are manual processes that affect the data (e.g. manual
journal entries);

• when there are judgments made by management in determining whether or

not to adjust data, and in determining the amount of any necessary
adjustments; and

• how data is affected when it is summarized for inclusion in the financial

statements (e.g. top-side entries during the period-end financial reporting
process).

Question 4.2.80
How should PRPs that lead to RMMs be documented?

Interpretive response: PRPs that lead to RMMs should be documented in

sufficient detail to identify the specific condition that would allow for a material
misstatement to occur within the financial statements.

The specificity and clarity with which an identified risk is defined are key to
management’s ability to design and operate controls that are appropriately
responsive to that particular risk.

A properly defined and documented risk also is critical to the effective evaluation
of the controls by management and external auditors. Failure to define risks with
sufficient clarity often results in a missing control or a control that is not
appropriately designed to address the actual risk.

In addition, the documentation for each PRP should link to a relevant financial
statement assertion. Frequently, multiple PRPs link to the same relevant
assertion. If a PRP does not link to a relevant assertion, it is likely not a relevant
PRP for ICFR.

Example 4.2.20
Specificity and clarity of PRPs
The following are examples of common PRPs from the purchase-to-pay process
where the initial PRP lacked specificity and clarity and the revised PRP provides
sufficient specificity and clarity.

Initial Revised
Accounts Payable and accrual balances Invoices received after period-end relate
(A/P and Accruals) are incomplete. to the current period but are not accrued
for. [Completeness, Existence, and
Accuracy of A/P and Accruals]
Expenditures are overstated. Payment of duplicate vendor invoice
numbers. [Existence of Expenses]
A/P is not accurately presented in the Receivables and A/P are offset and
financial statements. inappropriately reported under a net
presentation. [Presentation of
Receivables and A/P]
Debits inappropriately exist within the A/P
subledger and are netted against the
ultimate credit recorded on the financial
statements. [Presentation of A/P]
Selling, General, and Administrative Cash disbursements are coded to
(SG&A) expenses are incomplete. incorrect general ledger accounts.
[Completeness, Existence, and Accuracy
of SG&A expenses; Completeness,
Existence, and Accuracy of PP&E]
Vendor invoices are not submitted on a
timely basis to the Accounting
Department by various corporate
departments. [Completeness of SG&A
Expenses and A/P]

In each of these examples, the initial PRP is stated very generally. This may
make it difficult to identify a specific control (or controls) that will mitigate the
risk. In addition, a generic PRP may result in a risk of management missing
relevant controls. By including more detail in the description of the risk,
management and external auditors will be in a better position to identify and
evaluate controls.

For example, the first revised PRP will put management in a better position to
properly address the timely accounting for invoices received after period-end.

Example 4.2.30
Lack of specificity leads to ineffective design or
assessment of controls
Management identifies and documents the following PRP: The statement of
cash flows is incorrect.

To address the PRP, as documented, management may choose to rely on and

evaluate the design and operating effectiveness of a control defined as
‘management’s review of the statement of cash flows.’ However, a properly
designed review of the statement of cash flows may need to do more than just
review the statement of cash flow’s ‘proof’ and tie numbers to the balance sheet.
The review may need to include consideration of many other aspects of the

statement of cash flows, such as key information about noncash transactions,

foreign currency effects and items that are required to be reported gross.

The lack of specificity in the control may lead to management’s review not
identifying issues with the cash flow statement, including (but not limited to) the
following:

• inaccurate or incomplete proof of the cash flow statement;

• inaccurate or incomplete tie-out of the numbers in the cash flow statement
to the balance sheet;
• incomplete information about noncash transactions;
• improper consideration of foreign currency effects; and
• improper reporting of amounts gross that should be reported net.

Without more detailed PRPs related to the preparation and review of the
statement of cash flows, management may not identify the right controls to
address all relevant PRPs.

This example illustrates that a heavily aggregated or overly general PRP may
lead management to design a control, or external auditors to select a control for
evaluation, that appears to address the PRP when, in actuality, the control only
addresses a portion (or none) of the potential for misstatement (i.e. the PRP).

4.3 Understanding the business process and

performing walkthroughs

Question 4.3.10
Is management required to gain an understanding of
business processes?
Interpretive response: Yes. An aspect of Principle 7 of the COSO Framework
(see Question 2.5.100) requires understanding the business process activities
and the flow of data from initiation to reporting. That aspect of Principle 7 is so
critical to ICFR that it warrants its own chapter in this Handbook.

Obtaining an understanding of business processes as well as the financial

reporting process provides important information used in identifying and
assessing RMMs and where they can occur within the process – the PRPs.
Management then designs appropriate control activities to address the identified
PRPs.

For example, a thorough understanding of the revenue process helps

management identify and understand:

• each type of revenue stream;

• where in the process there is reliance on IT systems; and
• related estimates in the process.

Inadequate understanding of a business process and the related PRPs often

can lead to inappropriate design and selection of controls, which in turn can
result in deficiencies being identified in the later stages of the ICFR assessment
process.

As business processes are owned and operated by management, it is generally

acknowledged that the business process is ‘understood by management.’
However, the knowledge of a business process, especially in larger or more
complex entities, can be spread between a few to dozens of individuals who
know only their part of the process. This is particularly true in processes with
complex IT systems, estimates or transaction flows.

Complex business processes involving multiple individuals knowledgeable only

about their part of the process can lead to the inappropriate identification of
risks, which then leads to controls that are not properly designed to address
RMMs. Discussion of understanding the process throughout this Handbook is
focused on the centralization of that understanding by individuals that are
performing risk assessment and designing controls to address identified PRPs.

Question 4.3.20
Is management required to document an understanding
of business processes?
Interpretive response: Yes. As part of the COSO Framework, management is
required to develop and maintain documentation of their business processes as
part of their ICFR.

Effective documentation of business processes assists in:

• creating standards and expectations of performance and conduct;

• operating the process on a consistent basis;
• identifying PRPs;
• identifying estimates and related risks;
• capturing the design of internal controls;
• communicating the who, what, when, where and why of internal control
execution;
• communicating processes to external auditors; and
• retaining knowledge.

Question 4.3.30
What is included in understanding a business process?

Interpretive response: When management obtains an understanding of a

business process, they specifically understand:

• how the transactions are initiated, and how information about the
transactions is recorded, processed, incorporated in the general ledger and
reported in the financial statements;

• how information about events and conditions, other than transactions, is

captured, processed and disclosed in the financial statements;

• which accounting records, specific accounts in the financial statements and

other supporting records are involved in the business process, as well as
how the information flows through IT system;

• which estimates are relevant to the business process; and

• which of the entity's resources, including the IT environment, are relevant to

the business process.

Question 4.3.40
How is an understanding of business processes
obtained?
Interpretive response: There are many ways an entity may obtain an
understanding of a business process, including interviewing people who are
involved in the process. Generally, a walkthrough is in the most comprehensive
method for obtaining that understanding because following a transaction
through the process validates what is described in an interview.

Question 4.3.50
What is a walkthrough?

Interpretive response: In a walkthrough, a single transaction is followed from

initiation through the entity’s processes, including its information systems, until
the transaction is reflected in the entity’s financial records. The person
performing the walkthrough uses the same documents and technology used by
those performing the process. It is important to follow the flow of information (or
transaction data) by inspecting key documents, reports and third-party
deliverables within the process.

Question 4.3.60
Is a walkthrough performed of the process as a whole,
or just the controls that are in place?
Interpretive response: A walkthrough is performed of the process as a whole,
and not just the individual control activities within the process. A walkthrough is
about understanding the process, which is not the same as identifying RMMs

and process control activities to mitigate those RMMs. However, the two are
interrelated because understanding the process will lead to identifying RMMs
and mitigating process control activities.

Concentrating the walkthrough procedures on just the previously identified

controls ignores the possibility that additional RMMs exist between the identified
points of control. If these RMMs are not identified, relevant controls are not
designed and operated to mitigate those RMMs.

Practical tip
Management may find it helpful to ensure all relevant process and control
owners are included in the applicable process walkthrough. This helps ensure
that the walkthrough includes the entire process, rather than just the individual
controls that are the responsibility of the specific control owner that participates
in the walkthrough.

Question 4.3.70
Who is responsible for understanding the business
process?
Interpretive response: The responsibility for obtaining an appropriate
understanding of each relevant business process, the flow of information and
PRPs belongs to the entity’s management. That responsibility cannot be
delegated to the external auditors. In fact, it may be impossible for the external
auditors to properly identify and evaluate risks of misstatement of the financial
statements and the related mitigating controls if management’s own risk
assessment process or documentation is missing or deficient.

Practical tip
Scheduling a joint walkthrough that includes management and the entity’s
external auditors may reduce the amount of time and effort incurred by process
and control owners. In addition, ensuring all relevant parties are included in the
walkthrough may reduce the number of follow-up questions and/or requests for
additional documentation after the walkthrough is completed. Management may
consider selecting a relevant transaction and asking for the supporting
documentation in advance of the walkthrough to prepare their questions ahead
of time and help ensure a thorough understanding is obtained.

Question 4.3.80
When does management obtain an understanding of
the business process?
Interpretive response: Management obtains an understanding of business
processes and the flow of transactions related to processes with likely RMMs
early in the ICFR assessment process.

New information may come to light as the ICFR assessment process progresses
throughout the relevant reporting period. If this happens, it may be necessary to
revisit the preliminary determination of processes requiring a walkthrough. If
additional potential RMMs are identified, it is then necessary to obtain an
understanding of the related PRPs and whether there are process control
activities in place to address those risks.

Similarly, during the ICFR assessment process, previously unidentified risks

within a business process may come to light. If this happens, management may
be required to supplement their understanding of the process and design and
implement additional process controls to address the newly identified risks.

Business processes and the transaction flows are susceptible to change during
the relevant reporting period. Such a change may occur after the initial
understanding of the processes and transaction flows is obtained by
management and the external auditors. For example, the entity may undergo a
restructuring, experience turnover in personnel, implement new IT systems or
reassign certain control responsibilities. When major changes occur, it is
necessary for management to update its understanding of relevant business
processes and any risks and controls that might have been affected by the
changes. (See Question 4.3.190)

Question 4.3.90
How does management evidence their process
understanding?
Interpretive response: Generally, flowcharting is the most effective manner for
management to document their understanding of business processes, the flow
of transactions, the relevant risks, and process control activities. Flowcharts, or
flowcharts supplemented by a brief narrative, can substantially reduce or even
eliminate the need for long, detailed process descriptions. The flowchart
provides a condensed picture, while the narrative provides more detail and
supplemental information. They can also help the entity comply with the
objectives of Principles 7 and 10 of the COSO Framework (see Questions
2.5.100 and 5.2.50, respectively).

A flowchart graphically depicts steps and/or activities in a process, as well as

key inputs and outputs. The purpose of a flowchart is to help identify the PRPs
and the process control activities in place to address them. A flowchart does not
need to be overly complex. Judgment is required to determine how much detail
to include in a flowchart.

Practical tip
Narratives that are too long and detailed can make it more difficult to understand
the end-to-end process. Using both a flowchart and a concise narrative can be
the most effective way to document management’s understanding of a business
process.

Question 4.3.100
What should be documented related to process
understanding?
Interpretive response: The documentation of process understanding should
capture the flow of information through an entity’s process and be of sufficient
detail to help management and the external auditors execute the following steps
in the ICFR assessment process.

Step 1 Understand the flow of information through the entity’s process

Identify relevant IT systems through use of a flowchart or an ISD and

Step 2
understand the flow of information through IT systems

Step 3 Identify all relevant PRPs associated with a particular process

Identify all relevant process control activities that address the relevant
Step 4
PRPs

As discussed in Question 4.3.90, management’s documentation may take the

form of a narrative or a flowchart, or a combination of the two.

Question 4.3.110
What type of questions should be asked in the
walkthrough?
Interpretive response: At points within a process where important processing
activities occur, the person performing the walkthrough places themself in the
role of the process owners and control operators and asks the entity’s personnel
to explain what is required by the entity’s prescribed procedures and controls.

Obtaining this explanation, combined with performing the other walkthrough

procedures:

• allows management and external auditors to understand the process and

identify:
— important activities within the process;
— potential opportunities for misstatement;
— points at which a necessary control is missing or designed ineffectively;

• allows management and external auditors to understand the types of

transactions handled by the process, particularly when the probing
questions go beyond the narrow focus of the transaction used as the basis
for the walkthrough; and

• may help identify indicators of fraud.

To corroborate information at various points in the walkthrough, the person

executing the walkthrough might ask entity personnel to:

• describe their understanding of previous and successive steps in the

process or control activities;

• demonstrate how they perform the activity or process control activity;

• describe what they are looking for to determine if there is an error (rather
than simply asking them if they perform listed procedures and controls);

• explain what they do when they find an error;

• explain what kinds of errors they have found, what happened as a result of
finding the errors, and how the errors were resolved;

• describe whether they have ever been asked to override the activity or
controls and, if so, to describe the situation; and

• explain whether the transaction and the related process being discussed are
typical of all transactions that flow through the process or whether other
transactions follow a different process.

Question 4.3.120
Are IT systems included in walkthroughs?

Interpretive response: Yes. To fully understand the flow of transactions, it is

necessary to understand how data enters an IT system, and is stored,
processed and accumulated for use in the operation of controls and preparation
of financial statements. It also is necessary to understand how data associated
with the transactions flows through IT systems, including which applications,
databases and other system components accept, maintain, manipulate and
move the data. In other words, it is important to follow the transaction selected
through the relevant IT systems, not around them.

Section 4.6 provides further discussion of IT specific considerations when

performing a walkthrough.

Practical tip
A better practice is for relevant IT personnel to be part of the walkthroughs of
business processes to ensure that a thorough understanding of the relevant IT
systems is obtained. This includes understanding the software or applications
being used, the relevant network, database and application layers, and the
related GITCs.

Question 4.3.130
Does obtaining a process understanding extend to
service organizations?
Interpretive response: Yes. More and more entities use and depend on
services provided by service organizations, and the COSO Framework
recognizes this trend. It explicitly states that its goal is to address the extended
business model of today’s organizations – the entity itself, plus all service
providers and other business partners who support the entity’s control
objectives.

The COSO Framework specifies that all relevant principles of internal control
should be applied across that extended business model. Similarly, the SEC staff
has stated that management’s annual report on ICFR cannot be limited in its
scope to exclude processes and controls performed by service providers
engaged by the entity.

If services obtained from a third-party organization are part of the entity’s

financial reporting process, those services are part of the entity’s ICFR.
Management should consider the risks associated with the transactions
processed by the service organization and the controls performed by them (and
the entity itself) to manage those risks and determine how those controls affect
the entity’s ICFR.

The extent to which management addresses each service organization in their

assessment of the effectiveness of ICFR (including obtaining an understanding
of the business processes affected by the service organization and identifying
the relevant risks and controls) depends on several factors, including:

• the significance of the transactions or information processed by the service

organization to the entity’s financial statements;

• the risk of material misstatement due to error or fraud associated with the
business activities performed by the service organization;

• the nature and complexity of the services provided by the service

organization and whether they are unique to the entity or highly
standardized and used extensively by many;

• the extent of the delegation of authority to the service organization;

• the extent to which the entity’s processes and controls interact with those of
the service organization and whether the entity has controls in place that
can independently ensure that the objectives of effective ICFR are met; and

• the extent to which the entity depends on the internal controls of the service
organization operating effectively.

Chapter 8 provides further discussion of service organizations’ involvement in

ICFR.

Question 4.3.140
Where does a walkthrough begin?

Interpretive response: A walkthrough begins where the transaction begins – in

other words, where the transaction is initiated. For example, a walkthrough for
the sales process begins where the customer submits an order.

Question 4.3.150
What parts of a process are included in a walkthrough?

Interpretive response: An understanding of the business process and the flow

of transactions from initiation to reporting should be obtained for each relevant
assertion of each significant account and disclosure that could cause the
financial statements to be materially misstated. This includes how the
transactions are initiated, authorized, processed and recorded.

For example, management would not just perform a walkthrough over the
portion of the process related to the existence of inventory but would also need
to include the portion of the process related to the accuracy and valuation of
inventory, which could be a different part of the process.

Obtaining an understanding of the business process and flow of transactions

from beginning to end is required for both routine processes, such as sales or
procurement, as well as for significant unusual transactions, such as business
combinations or impairment of goodwill, that could cause the financial
statements to be materially misstated.

In addition, one business process may include several significant accounts and
disclosures. For example, a revenue process for a commercial enterprise may
cover not only revenue, but likely also cover such accounts as deferred
revenue, accounts receivable and sales returns.

Question 4.3.160
How does management consider variations in
processes when performing a walkthrough?
Interpretive response: There may be many different variations within a
process, such as different revenue streams, order entry methods, payment
methods or delivery methods. When determining whether the objectives of a
walkthrough may be achieved through selection of a single transaction (versus
multiple transactions), management considers whether any unique PRPs exist.

Management also considers the various data elements that may be used to
determine the relevant assertions over the significant accounts associated with
the business process that is the subject of the walkthrough. Various data

elements may source from different places within and outside the entity and
may require selection of multiple transactions within a process to achieve the
objectives of an effective walkthrough.

The following example includes different scenarios where variations in the

process effect the nature and extent of walkthroughs performed.

Example 4.3.10
Determining the scope of a walkthrough
Scenario 1: Purchasing process

Before performing a walkthrough related to the purchasing process, the internal

audit manager considers how best to perform the walkthrough and what
pertinent questions to ask of the process owners. She considers the risks
inherent in the purchasing process and decides to choose a transaction that
was already recorded in the general ledger. She follows that transaction through
the following process by inspecting documentation and inquiring of various
employees who participated in the processing of the transaction.

Purchase order Vendor invoice

Purchase
request → creation and → Goods received → recorded in
approval general ledger

The following is a list of relevant questions posed to the process owners.

• What happens next in the process?

• Where does the information come from?

• Does the information always come to you the same way?

• Has anyone ever asked you to handle the transaction in a different manner?

• Are there differences in the way you process a purchase order depending
on the item purchased? For example, do you process a purchase order for
inventory different from one for office supplies?

• Who decides which general ledger accounts the transactions should be

recorded in?

• Have you ever found an error, and if so, what did you do to address the
error?

By asking these questions, the internal audit manager determines that there are
different processes (and, therefore, likely different opportunities for
misstatement) depending on what the entity is purchasing. She also determines
that there are occasions when (for legitimate reasons) similar transactions go
through different processes. Therefore, she identifies the need to walk through
various iterations of the process to fully understand the different ways that
transactions are processed. Only by performing this expanded walkthrough
could she identify all relevant PRPs.

Scenario 2: Retail and online sales processes

A retailer sells a product on its website and through several retail locations. It is
unclear whether both types of transactions go through the same or different
processes, which may affect the PRPs to be addressed. In this case, it would be
appropriate to select both an internet sales transaction and a retail location
sales transaction for which to perform walkthroughs and follow each transaction
until the two processes merge.

Scenario 3: Bank account origination process

A commercial bank offers a customer multiple options for initiating a transaction,

such as a customer deposit account. This account can be opened by a
customer through the bank’s website, at a bank branch location or through the
US mail. Regardless of the option the customer chooses, the bank receives the
same information and processes that information in the same manner. Because
there are no unique PRPs related to the different ways a customer deposit
account may be opened, following a single transaction through the account
origination process might achieve the objective of performing a walkthrough of
that process.

Question 4.3.170
How does management consider multiple physical sites
when performing a walkthrough?
Interpretive response: An entity may have multiple physical sites (e.g.
warehouses or retail locations), which is not to be confused with multiple
subsidiaries. These sites may or may not have control activities that are
homogenous and/or centrally controlled and operated.

Homogeneous

Locations may have homogeneous control activities across multiple physical

sites when there are consistent related IT systems and similar processes, PRPs
and RMMs. They are also subject to the same entity-level controls. Careful
consideration should be given in determining whether control activities at
locations are homogeneous.

If multiple physical sites’ control activities are determined to be homogeneous, it

may be possible to conclude that walkthroughs at each location are
unnecessary after considering:

• the effectiveness of the entity’s risk assessment and monitoring processes;

• the effectiveness of entity-level controls developed by management in

response to its risk assessment;

• the assessment of risk of controls failing in the process;

• the results of other procedures performed by management or internal audit

relevant to the locations including compliance assessments and operational
audits; and

• the knowledge obtained in the previous year’s process understanding,

including the nature and extent of any deficiencies within ICFR.

In most instances, it may be necessary to perform a walkthrough or other

procedures at multiple physical sites to support the assertion that the control
activities at the locations are in fact homogeneous. Determining homogeneity is
a matter of judgment and requires careful consideration of the relevant facts and
circumstances.

Centrally controlled

Multiple physical sites have control activities that are centrally controlled if
transactions and related control activities for these sites are processed centrally
based on information provided by each site.

If multiple physical sites are determined to have control activities that are
centrally controlled, it may be most effective to perform a walkthrough at the
central location. Based on the walkthrough, management determines whether
the process at the central location sufficiently addresses the relevant risks at the
individual physical sites.

Neither homogeneous nor centrally controlled

In the case of multiple physical sites where control activities are neither
homogeneous nor centrally controlled, walkthroughs may need to be performed
at each site that (individually or when aggregated with others) gives rise to the
risk of a material misstatement of the entity’s financial statements.

Question 4.3.180
Can control activities that were originally determined to
be homogeneous not actually be homogeneous?
Interpretive response: At various points during the ICFR assessment,
evidence may arise that suggests that control activities originally determined to
be homogeneous may not actually be homogeneous. Such evidence may
include:

• business understanding obtained in the current year that indicates that the
processes and related controls are not consistently designed;

• differences in the design of controls at locations selected for direct testing

as part of monitoring activities;

• deficiencies in the operating effectiveness at only one or some of the

locations selected for direct testing as part of monitoring activities that are
determined to be isolated to those locations; or

• indications from other sources (e.g. Internal Audit site visits that were not
ICFR related) that the design of controls may be different or operating
ineffectively at locations not selected for testing.

When contrary evidence arises, management considers whether more evidence

is needed to affirm or disaffirm the original conclusion that the control activities
are homogeneous.

Once sufficient evidence has been obtained, if management ultimately

concludes the control activities are not homogeneous, the assessment of control
activities at the individual locations may need to be reconsidered to determine if
control activities at those locations are appropriately designed and operated. If
exceptions are identified at a location(s), management should reconsider if the
determination of homogeneity remains appropriate for all locations, not just the
location(s) with the exception.

Question 4.3.190
How often is the understanding of a business process
updated?
Interpretive response: On an annual basis, management should ensure that
they sufficiently:

• consider potential changes in the process, including the introduction of new

IT systems or information, a change in the business environment or a
change in key personnel; and

• update the process understanding and related documentation (e.g.

flowcharts, narratives).

Various events and conditions that are relevant to the entity when preparing its
financial statements may indicate that RMMs exist in a process or changes have
occurred in the process. For example, a breach of loan covenants (event) may
affect the presentation of the loans in the financial statements and require
additional disclosures. For another example, changes in income tax laws or
rates that affect the recognition and measurement of income taxes (condition)
may indicate that RMMs exist when the entity applies the new tax laws or rates.

Many material weaknesses in ICFR originate from an inadequate risk

assessment process to identify changes in a process. Processes change over
time due to a variety of factors including changes in personnel, changes in the
way transactions are processed, and changes in technology. As these changes
occur, new PRPs may arise. If the new PRPs are not identified and managed
through relevant controls on a timely basis, they may lead to undetected errors
in the entity’s financial reporting.

Even slight changes made to business processes over time, if they are not
understood and assessed on a timely basis, can render the existing suite of
controls (in the aggregate) inadequate and lead to a material weakness in the
entity’s ICFR.

As illustrated in Example 4.3.20, management may establish a policy and

parameters in determining the extent of procedures necessary to update their
understanding of a business process.

Example 4.3.20
Management factors risk into the extent of procedures
performed to update the understanding of a business
process
A manufacturing entity determines that it will classify each process (e.g. sales
order process, treasury process) into categories based on the types of
transactions performed, the degree of change from the prior year, the degree of
judgment involved in the process, and the importance of the related significant
accounts to the financial statements.

For processes related to sales and inventory that are believed to have a higher
risk of changes in the processes, management decides to perform a
walkthrough each year to update their understanding of the processes,
determine the PRPs, and confirm that the controls in place are still appropriately
designed and operating effectively.

For processes related to fixed assets, cash and prepaid expenses, management
decides to perform an annual evaluation to determine whether any external or
internal influences might have caused changes to the processes or presented
new PRPs. If they determine that there are no such changes, a walkthrough is
performed every two years instead of every year. Management documents the
key inquiries made of process owners to corroborate their understanding and
conclusion.

Question 4.3.200
How often are walkthroughs performed by
management?
Interpretive response: As illustrated in Example 4.3.20, there may be some
business processes for which management performs the walkthroughs on an
annual basis due to higher risks of error or fraud present in those processes
and/or the changes made to those processes. In contrast, there may be other
business processes for which management performs the walkthrough every few
years due to the insignificant nature of the risks related to those processes and
management’s determination that the processes were unchanged in the last
year.

If a walkthrough is not performed over a business process by management, a

robust assessment is crucial to determine there are no changes in the process
that would affect the determination or PRPs and necessitate new or modified
controls. Considerations in determining whether a walkthrough should be
performed in the current year include:

• there is a significant change to the entity's process in the current period as

compared to the prior period;
• a change in accounting standard or accounting policy that affects the
process;
• new control owner(s) or turnover of control operator(s) in the process;

• a history of audit misstatements in the process;

• a history of control deficiencies in the process;
• the process contains a higher risk of error or fraud; and/or
• the process to record a significant unusual transaction.

4.4 Considerations related to period-end financial

reporting, including preparation of disclosures, in
obtaining a process understanding and identifying
risk points

Question 4.4.10
Does obtaining a process understanding apply to the
period-end financial reporting process, including
preparation of disclosures?
Interpretive response: Yes. The period-end financial reporting process is a
critical process that exists for all entities. The period-end financial reporting
process includes the activities an entity performs to close the books and make
post-closing adjustments when preparing the individual financial statements
(e.g. balance sheet, statement of income) and related disclosures (collectively
referred to as the financial statements). This process generally operates after
the business processes and related process control activities designed to record
individual transactions have been executed.

The period-end financial reporting process is the last process to occur before
the financial statements are issued. Therefore, it is important for the entity to
have well designed and effective period-end financial reporting controls as
errors or fraud in the period-end financial reporting process may override
effective control activities that occur throughout the entity's other processes.

Question 4.4.20
What are the processes and procedures in the period-
end financial reporting process?
Interpretive response: The process starts with the general ledger that is used
to record the accumulation of transactions from all business processes. The
process ends when the entity issues or reports its final financial statements. The
period-end financial reporting process includes:

• the consolidation process (if applicable);

• foreign currency translation (if applicable);
• selection and application of accounting policies or principles;

• initiating, authorizing, recording and processing of journal entries and other

adjustments (see section 4.7); and
• preparation, review and approval of individual financial statements and
related disclosures (see Question 4.4.40).

Question 4.4.30
What is included as part of the understanding of the
preparation, review and approval of the financial
statements, including disclosures?
Interpretive response: Understanding should include, among others, the
process of preparing the current and comparative period financial statements,
identifying financial statement disclosure requirements (e.g. earnings per share),
identifying and assessing reportable segments, identifying non-routine
transactions requiring disclosure in the notes to the financial statements,
preparing financial statement disclosures, assessing going concern
assumptions, and identifying and assessing the impact of any subsequent
events.

Question 4.4.40
How is the understanding of the preparation of financial
statement disclosures obtained?
Interpretive response: Obtaining an understanding of the process to prepare
financial statement disclosures typically straddles both business processes and
the period-end financial reporting process.

Financial statement disclosures usually use information that flows through the
underlying business processes (e.g. sales information that will be needed to
prepare the revenue disclosures required by ASC 606). As such, obtaining an
understanding of the information, the PRPs related to the input, integrity and
extraction or manipulation of the information and the related controls is best
integrated with the understanding of the related business process. At the same
time, inclusion of the information into the financial statements in the form and
content prescribed by the accounting standards (e.g. revenue disaggregated
into categories that depict how revenue and cash flows are affected by
economic factors) typically requires further analysis, breakdown or aggregation
of the data. This may be part of the period-end financial reporting process that
has incremental PRPs from the underlying business process.

Question 4.4.50
Is a walkthrough of the period-end financial reporting
process the same as other business processes?
Interpretive response: No. For most business processes, a walkthrough
involves following a 'single transaction' from initiation to the recording of the
transaction in the entity's transaction processing systems. However, a
walkthrough of the period-end financial reporting process and its sub-processes
will not necessarily involve following a 'single transaction' through the process in
the same way, because the period-end financial reporting process involves the
entering of transactions into the entity's general ledger and consolidation
systems and the reporting of the accumulation of transactions in the financial
statements, including related disclosures.

Therefore, a walkthrough of the period-end financial reporting process follows

the flow of data from the general ledger and consolidation systems to the
consolidated financial statements and related disclosures for a particular
financial reporting period.

Practical tip
To understand the complete flow of information, it may be effective to confirm
management’s understanding by looking at the final financial statements,
including disclosures, and tracing the consolidated information back to the
respective information sources.

4.5 Considerations related to estimates in obtaining a

process understanding and identifying risk points

Question 4.5.10
What is an accounting estimate?

Interpretive response: An accounting estimate (or ‘estimate’) is a

measurement or recognition in the financial statements of (or a decision to not
recognize) an account, disclosure, transaction or event that generally involves
subjective assumptions and estimation uncertainty.

Accounting estimates vary widely in nature and management makes them when
monetary amounts cannot be directly observed.

Question 4.5.20
How do estimates pose a risk to the financial
statements?
Interpretive response: By their nature, accounting estimates, and their
elements, are subject to factors that inherently drive risks of misstatement, such
as estimation uncertainty, complexity and subjectivity. These same factors also
make estimates susceptible to management bias.

Estimates can vary in their degree of complexity but can involve complex
processes and methods.

Question 4.5.30
What is estimation uncertainty?

Interpretive response: Estimation uncertainty is the susceptibility of an

accounting estimate and related disclosures to an inherent lack of precision in
measurement. Estimation uncertainty is an inherent risk factor and arises when
there are constraints on the availability of knowledge (or data) necessary to
develop an estimate, which limits the precision of an estimate.

As estimation uncertainty increases, so too does the risk of material

misstatement to the financial statements.

'Estimation uncertainty' is also referred to as 'measurement uncertainty.'

Question 4.5.40
Where does estimation uncertainty arise in accounting
estimates?
Interpretive response: Estimation uncertainty is commonly associated with the
assumptions used to develop an accounting estimate; however, the other
elements of an accounting estimate can also give rise to estimation uncertainty.

For example, there may be subjectivity or judgement in determining an

appropriate method/model to use in determining an accounting estimate,
leading to estimation uncertainty. There also may be subjectivity and judgement
in selecting a data set or deciding if it is appropriate for certain data to be
excluded from the population, which can lead to estimation uncertainty.

Estimation uncertainty can also be related to an accounting estimate through

the aggregate effect of the uncertainty that arises through the individual
elements.

Question 4.5.50
What is ‘subjectivity’?

Interpretive response: Subjectivity is the quality of being based on or

influenced by personal feelings, tastes or opinions. In accounting estimates,
subjectivity is an inherent risk factor and reflects the inherent limitations around
the knowledge or data reasonably available related to an accounting estimate.

As subjectivity increases, so does the risk of material misstatement to the

financial statements.

In some cases, the applicable financial reporting framework reduces the

subjectivity by providing requirements for making the judgment (e.g. the
minimum amount within a range is recorded for a loss contingency when no
amount within a range is a better estimate than any other amount).

Management judgment is generally necessary in determining the

appropriateness of the elements used to make an accounting estimate, which
can lead to management bias. As subjectivity increases, so does the
susceptibility of the elements to management bias.

Question 4.5.60
What is ‘complexity’?

Interpretive response: Complexity is the quality of being intricate or

complicated. In accounting estimates, complexity is an inherent risk factor and
stems from how an accounting estimate is made.

As complexity increases, so too does the risk of material misstatement to the

financial statements.

Question 4.5.70
What is 'management bias' and how does it affect
accounting estimates?
Interpretive response: Management bias can be thought of as a lack of
neutrality by management in preparing an accounting estimate. Management
bias is considered with the selection of the various elements of an estimate, as it
relates to an estimate, and the aggregate of all accounting estimates.

Management bias can be unintentional, or it can be intentional (fraud).

Question 4.5.80
What should management consider when identifying
accounting estimates within their processes?
Interpretive response: As part of obtaining an understanding of a business
process, management should identify if there are estimates or changes in
estimates. This includes consideration of:

• the entity's transactions or other events and conditions that may give rise to
the need for, or changes in, accounting estimates to be recognized or
disclosed in the financial statements, including conditions that affect the
recoverability of assets;

• the requirements of the applicable financial reporting framework related to

accounting estimates (including the recognition criteria, measurement
bases, and the related presentation and disclosure requirements) and how
they apply in the context of the nature and circumstances of the entity and
its environment; and

• regulatory factors relevant to the entity's accounting estimates, including,

when applicable, regulatory frameworks.

Management should have processes and controls in place to identify those

transactions, events and conditions that may give rise to the need for
accounting estimates to be recognized or disclosed in the financial statements.

Question 4.5.90
What controls should the entity have over the
identification and oversight of estimates?
Interpretive response: The entity should have entity-level controls in place
related to estimates that address:

• how the entity's board of directors exercises oversight over management's

process for making accounting estimates;

• how management identifies the need for, and applies, specialized skills or
knowledge related to accounting estimates, including with respect to the use
of a specialist and other qualified external information sources (e.g. a pricing
service for information used to price investment securities); and

• how the entity's risk assessment process identifies and addresses risks
related to accounting estimates, including susceptibility to management bias
and fraud.

See chapter 2 for further considerations for entity-level controls.

Question 4.5.100
What are the primary elements of an estimate?

Interpretive response: Estimates have three primary elements.

Methods Assumptions Data

A method is a Assumptions represent Data is equivalent to
measurement technique judgments, decisions or ‘information.’ Accordingly,
used by management or assessments made in data may be comprised
management’s specialist areas that involve a of multiple ‘data
to make an accounting degree of subjectivity or elements.’ In the case of
estimate in accordance uncertainty. Assumptions accounting estimates,
with the relevant that are important to the data elements may be
measurement basis. A recognition or used as either a direct
method may include measurement of the input to the method or
application of a model or estimate are referred to model or in developing an
models. as ‘significant assumption.
assumptions.’

As noted in Question 4.3.10, Principle 7 of the COSO Framework requires

understanding the business process activities and the flow of data from initiation
to reporting. When a business process contains an estimate, the understanding
of the business process activities includes obtaining an understanding of each
of the elements of the estimate.

Obtaining an understanding of each of the elements of the estimate provides

important information used in identifying and assessing RMMs and the related
PRPs within the estimate. Management then designs appropriate control
activities to address the identified PRPs.

Question 4.5.110
What does management understand related to the
development of estimates?
Interpretive response: When a business process involves an estimate,
management should understand the process of how an estimate is developed
including:

• how the relevant methods, assumptions, or data are identified, the sources
of the relevant methods, assumptions and data (including IT systems and IT
layers), and how changes that are appropriate in the context of the
applicable financial reporting framework to the relevant methods,
assumptions or data are identified;

• how the entity:

— selects, or designs and applies the methods used, including the use of
models;

— selects the assumptions to be used, including consideration of

alternatives, and identifies relevant assumptions; and
— selects the data to be used;

• how and when a retrospective review of the estimate is performed and how
the entity responds to the results of the retrospective review;

• the degree of estimation uncertainty, including if there is a range of possible

measurement outcomes;

• how the estimation uncertainty is addressed, including selecting a point

estimate and related disclosures for inclusion in the financial statements;

• how the entity identifies when to use and apply specialized skills or
knowledge related to accounting estimates; and

• how the entity analyzes the sensitivity of its relevant assumptions to change
for critical accounting estimates.

This will assist management in determining where there are PRPs within the
estimate that require a controls response.

Example 4.5.10
Documentation of understanding of the process for
developing accounting estimates
Management may choose to include a diagram of the method/model,
assumptions and data that are used to develop an accounting estimate similar
to the following.

General Estimate model

External ledger
publication
Assumption 1
General Manual Excel Data element 1
ledger spreadsheet 1
Data element 2
Manual
Competitor JE
information
Assumption 2
General ledger Manual Excel Data element 3
spreadsheet 2 General
ledger
Dbase

A diagram can help summarize the key aspects of how management develops
and records an accounting estimate.

Question 4.5.120
How are risks identified as part of estimates?

Interpretive response: Once management obtains a granular understanding of

how the estimate is developed (see Question 4.5.110), the following steps
should be performed to identify the risks related to the process to determine an
estimate.

Identify the method and model used to measure the estimate. There
Step 1 may be multiple methods and models used to develop an estimate that
management may consider when selecting a point estimate or range.

Identify the population of assumptions that are used to measure the

Step 2
estimate.

Identify the population of data that is used to measure the estimate –

Step 3 including data that is used directly in the method and data that is used
as an assumption or to develop an assumption.

Consider the quantitative and qualitative inherent risk factors and other
risks (see Question 4.5.130), and whether the process to determine the
Step 4 estimate gives rise to an RMM. When doing so, consider the
contribution of risk that each element contributes to the RMM for the
estimate, individually and in combination with other elements.

Identify the PRPs for each method and model, assumption or data
Step 5
element where an RMM was identified.

For more complex estimates like business combinations, this process can take
time and likely will result in the identification of many elements and PRPs.

Once all PRPs are identified, management designs process controls activities to
address the PRPs and GITCs to address any related risks arising from IT
(RAFITs). The design of the process control activities (see chapter 5) and
GITCs (see chapter 7) related to estimates follow the same criteria as other
control activities.

Practical tip
To assist in designing control activities around estimates and ensuring that all
identified PRPs associated with the elements individually and in combination
with one another are identified and that related control activities are designed
and implemented, management may use a template or spreadsheet to perform
the steps above to identify the population of elements, those elements that
result in an RMM and the related PRPs, and then map the PRPs to the related
control activities.

Example 4.5.20
Understanding elements and identifying PRPs in an
estimate
Steps 1-3: Management uses the straight-line method for the estimation of
depreciation expense and identifies the following individual elements within the
estimate.

Primary element Method, assumption or data element

Method/model Straight-line method / Automatically calculated in the
Oracle Fixed Asset System
Assumption Useful life
Residual value
Data Cost of asset
In-service period
Asset classification
In-service date

Step 4: Management considers the contribution of risk that each of the above
elements contributes to the RMM for the estimate, individually and in
combination with other elements. For purposes of our example, management
determines that there is an RMM associated with the application of the methods,
assumption and data when used in the model.

Step 5: One of the PRPs management identifies is the following: The Fixed
Asset system is not configured to accurately calculate depreciation expense.

Management ensures that appropriately designed controls are in place and

operating to address the PRP.

Question 4.5.130
What are the additional inherent risk factors considered
in relation to accounting estimates?
Interpretive response: Management evaluates additional risk factors when
determining if there is a RMM associated with an accounting estimate, which
include:

• the complexity of the process for developing the accounting estimate;

• the number and complexity of methods and relevant assumptions

associated with the process;

• the degree of subjectivity associated with the methods, relevant

assumptions, and data;

• the degree of uncertainty associated with the future occurrence or outcome

of events and conditions underlying the relevant assumptions;

• if forecasts are important to the estimate, the length of the forecast period
and degree of uncertainty about trends affecting the forecast; and

• the degree of subjectivity associated with the selection of management's

point estimate and related disclosures for inclusion in the financial
statements.

Question 4.5.140
What does management consider when evaluating
whether the method may give rise to an RMM for the
estimate?
Interpretive response: When evaluating whether the method may give rise to
an RMM for the estimate, individually or in combination with the other elements,
management considers the degree of complexity, subjectivity and estimation
uncertainty associated with the method. There is a risk that the method selected
is inappropriate.

Management should consider the following questions.

• Is the method appropriate to use for measurement under the applicable

financial reporting framework (individually and in combination with the other
elements used)?

• If the method used is not prescribed by the applicable financial reporting

framework, is the method typically used for determining the estimate for the
industry or business that the entity operates?

• If neither of the above, is the method reasonable to use under the facts and
circumstances?

• Does the method rely on IT systems, and if so, what are the applicable IT
system layers and how do they apply to the method?

• What are the assumptions and data used in the method? See Questions
4.5.160 and 4.5.170.

• What is the frequency at which an estimate is calculated, e.g. annually,

every quarter, every quarter on a one-month lag, one-week lag?

• Is a service organization used, and if so, how does it affect the method?

• Does management use a specialist or third party (other than a specialist) to

develop or select the method?

Management should also consider the following questions that may help when
identifying bias or fraud risks factors.

• Are there alternative methods and were they considered, if available?

• Are judgments about which method(s) to use consistently applied?

• If the method has changed from the method used in the prior period, is the
basis for change reasonable given the facts and circumstances, timely
made, and appropriate to use for measurement?

• Are adjustments made to the output of the model appropriate and supported
by sufficiently relevant and reliable information (see chapter 6)?

• Is there is a lag period between the calculation of an estimate and the

reporting date in the applicable financial reporting framework?

Careful consideration of the above questions can help management identify the
PRPs where an RMM associated with the selection of the method used in
developing an estimate may occur. Key decisions about the selection of the
method(s) and controls that address the risks should be documented.

For example, there are alternative methods available to management for

determining the fair value of a reporting unit in a goodwill impairment analysis.
There is a point in the process where management selects which of these
methods to use, e.g. an income and/or market approach and how to weight
them if multiple methods are used. Accordingly, the selection of the method(s)
may give rise to an RMM given the different options that are available and the
judgments that must be applied in deciding which method(s) are appropriate to
use.

Question 4.5.150
What does management consider when evaluating
whether the model may give rise to an RMM for the
estimate?
Interpretive response: When evaluating whether the model may give rise to an
RMM for the estimate, management considers the degree of complexity
associated with the application of the methods, assumptions and data when
used in the model. There is a risk that the application is inappropriate.

Management should consider the following questions.

• Is the calculation of the estimate in accordance with the method selected?

• Is the calculation mathematically accurate?
• Has the integrity of the assumptions and data been maintained when used
in the model?

Careful consideration of the above questions can help management identify the
PRPs where an RMM associated with the application of the methods,
assumptions and data when used in the model may occur. Key information
about the application and controls that address the risks should be documented.

Continuing with the goodwill impairment analysis example, management has

selected the discounted cash flow (DCF) income approach (the method) to

develop the fair value of its reporting units. Application of the DCF method is
performed using Microsoft Excel (the model). There is a point in the process
where management inputs the assumptions and data into the Excel
spreadsheet(s) either manually or automatically and the DCF is calculated
based on the formulas that have been inserted into the cells within the
spreadsheet(s). Accordingly, the input of the relevant assumptions and data into
the Excel spreadsheet(s), the integrity of the assumptions and data when used
in the various formulas and the mathematical accuracy of the calculation(s) may
give rise to an RMM (e.g. the assumptions and data could be transposed when
entered, the formulas could be inconsistent with the DCF method and/or the
formulas could contain errors).

Question 4.5.160
What does management consider when evaluating
whether an assumption may give rise to an RMM for
the estimate?
Interpretive response: When evaluating whether an assumption may give rise
to an RMM for the estimate, individually or in combination with the other
elements, management considers the degree of complexity, subjectivity and
estimation uncertainty associated with the assumption. There is a risk that the
assumption selected is inappropriate.

Management should consider the following questions.

• Is the assumption appropriate/reasonable to use for measurement under the

applicable financial reporting framework (individually and in combination
with the other elements used)?

• If dependent on management’s intent and ability, is the assumption

consistent with the following factors?
— the entity's history of carrying out its stated intentions;
— the entity's written plans or other relevant documentation, such as
budgets or minutes;
— the entity's stated reasons for choosing a particular course of action;
— the entity's ability to carry out a particular course of action, which
includes consideration of whether:

• the entity has the financial resources and other means to carry out
the action;
• legal, regulatory or contractual restrictions could affect the entity's
ability to carry out the action; and
• the entity's plans require the action of third parties and, if so,
whether those parties are committed to those actions?

• Is the assumption consistent with other sources of information, including:

— relevant industry, regulatory, and other external factors, including
economic conditions;
— the entity's objectives, strategies and related business risks;

— existing market information; and

— historical or recent experience, considering changes in conditions and
events affecting the entity?

• If used in other estimates, is the assumption consistent or otherwise

supported?

• Does the assumption rely on IT systems, and if so, what are the applicable
IT system layers and how do they apply to the assumption?

• Is a service organization used, and if so, how does it affect the assumption?

• Does management use a specialist or third party (other than a specialist) to

develop or select the assumption?

• What data is used to derive the assumption? See Question 4.5.170.

Management should also consider the following questions that may help when
identifying bias or fraud risks factors.

• Are there alternative assumptions and were they considered, if available?

• Were judgments about which assumption(s) to use consistently applied?

• If the assumption was changed from that used in the prior period, what was
the basis for change and is it reasonable given the facts and circumstances,
made timely, and appropriate to use for measurement)?

• Is the assumption sensitive to variation?

• Does the assumption involve unobservable data or adjustments to

observable data?

• Does the assumption rely on the entity's intent or ability to carry out specific
course of action?

Careful consideration of the above questions can help management identify the
PRPs where an RMM associated with the selection of an assumption used in
developing an estimate may occur. Key decisions about the selection of the
assumption(s) and controls that address the risks should be documented.

Continuing with the goodwill impairment analysis example, when determining

the fair value of its reporting units using the DCF model, there is a point in the
process where management estimates the future cash flows for a certain
discrete projection period. Accordingly, the selection of the revenue growth
assumption for a particular reporting unit, among other assumptions, may give
rise to an RMM, e.g. the revenue growth assumption could be inconsistent with
the same assumption when used in other estimates for the entity, it could be
inconsistent with management’s intent and ability for operating the reporting
unit, or it could be inconsistent with recent conditions or events affecting the
reporting unit.

Question 4.5.170
What does management consider when evaluating
whether the data may give rise to an RMM for the
estimate?
Interpretive response: When evaluating whether the data may give rise to an
RMM for the estimate, individually or in combination with the other elements,
management considers the degree of complexity, subjectivity and estimation
uncertainty associated with the data. There is a risk that the data selected is
inappropriate.

Management should consider the following questions.

• How are the data and data elements used, including what is the source of
the data?

• Is the data appropriately understood or interpreted by management?

• Is the data sufficiently relevant (i.e. sufficiently precise and detailed), to use
for measurement under the applicable financial reporting framework
(individually and in combination with the other elements used)?

• Is the data sufficiently reliable, which includes:

— If internal data, is it complete and accurate?
— If external and not a source document, is it from a reputable, qualified,
and objective source?

• Does the data rely on IT systems, and if so, what are the applicable IT
system layers and how do they apply to the data?

• Is a service organization used to develop or select the data, and if so, how
does it affect the data?

• Does management use a specialist or third party (other than a specialist) to

develop or select the data?

Management should also consider the following questions that help when
identifying bias or fraud risks factors.

• Is there alternative data and was it considered, if available?

• Were judgments about which data to use consistently applied?

• If the data was changed from that used in the prior period, what was the
basis for change and is it reasonable given the facts and circumstances,
made timely, and appropriate to use for measurement?

Careful consideration of the above questions can help management identify the
PRPs where an RMM associated with the data used in developing an estimate
may occur. Key decisions about the selection of the data and controls that
address the risks should be documented.

Continuing with the goodwill impairment analysis example, when determining

the fair value of its reporting units using the DCF method, there is a point in the

process where management must decide which data to use either directly in the
method or in an assumption. Accordingly, the selection of the carrying value of
the reporting unit, among other data, may give rise to an RMM, e.g. the carrying
value of the reporting unit could have nonoperating assets or liabilities reflected
in the carrying amount of the reporting unit, or equity method investments that
would result in adjustments to the fair value of the reporting unit.

Question 4.5.180
How might management address estimation
uncertainty?
Interpretive response: Management addresses estimation uncertainty by
developing controls over the:

• selection of an appropriate point estimate; and

• ensuring appropriate disclosures are made in their financial statements
regarding estimation uncertainty.

The point estimate is the amount selected by management for recognition or

disclosure in the financial statements.

Said another way, the point estimate is the output of management's process to
record or disclose an estimate in the financial statements after all data and
assumptions have been selected and applied to the method/model, including
any adjustments to the output method/model. This process includes
management considering where estimation uncertainty, subjectivity and/or
complexity affects the elements of an estimate and the resulting range of
measurement outcomes.

To select a point estimate, management may:

• record the output of a model directly in the financial statements; or

• before recording the point estimate in the financial statements:
— adjust the output of the model;
— weight the outputs of multiple models; or
— select from within a range of possible outcomes.

As part of addressing estimation uncertainty, management considers the range

of possible outcomes, as well as other specific matters and designs controls to
address and consider these matters, such as:

• alternative methods, relevant assumptions or sources of relevant data that

are appropriate in the context of the applicable financial reporting
framework;

• possible alternative outcomes, e.g. performing a sensitivity analysis to

determine the effect of changes in the data or assumptions on an
accounting estimate; and

• the outcome of accounting estimates made in previous periods, responding

to differences.

Question 4.5.190
How might the applicable financial reporting framework
affect the related disclosures regarding estimation
uncertainty?
Interpretive response: The applicable financial reporting framework may
prescribe disclosures or disclosure objectives related to accounting estimates
that:

• describe the amount as an estimate;

• explain the nature and limitations of the process for making an estimate,
including the variability in reasonably possible outcomes;

• describe significant accounting policies related to an accounting estimate;

• describe significant or critical judgments, including significant forward-

looking assumptions or other sources of estimation uncertainty;

• describe the method of estimation used, including any applicable model and
the basis for its selection; and

• describe the information that has been obtained from models, or from other
calculations used to determine estimates recognized or disclosed in the
financial statements, including information relating to the underlying data
and assumptions used in those models.

Depending on the circumstances, relevant accounting policies may include

matters such as the specific principles, bases, conventions, rules and practices
applied in preparing and presenting accounting estimates in the financial
statements. In certain circumstances, additional disclosures beyond those
explicitly required by the financial reporting framework may be necessary to
achieve fair presentation, or in the case of a compliance framework, for the
financial statements not to be misleading.

Management should have controls properly designed to ensure estimates are

properly disclosed based on the applicable financial reporting framework.

Question 4.5.200
What are common PRPs and controls related to
whether disclosures for accounting estimates conform
to the applicable financial reporting framework?
Interpretive response: PRPs related to whether disclosures for accounting
estimates conform to the applicable financial reporting framework are entity
specific; however, given the nature of the risk, PRPs may include:

• management has not taken the appropriate steps to understand the

required disclosures;
• management’s understanding of the disclosure requirements is incorrect;

• management has not taken the appropriate steps to make the disclosures;
and
• how management made the disclosures is incorrect.

To address the related PRPs, the entity may have a control that evaluates the
disclosure requirements for an accounting estimate to determine what
disclosures are required under the financial reporting framework. Additionally,
the entity may have a control that reviews the disclosures individually and, in the
aggregate, to validate that the disclosures are accurate, complete and fairly
presented in accordance with the financial reporting framework.

Question 4.5.210
When might management use specialists or third
parties (other than specialists) in developing an
accounting estimate?
Interpretive response: Management may choose to involve specialists or third
parties (other than specialists) when they lack the knowledge or skills
necessary, especially when:

• the matter requiring estimation is very specialized;

• the financial reporting framework requires a method/model that is very
technical by nature; or
• the transaction or event requiring an accounting estimate doesn’t occur
frequently or is unusual.

Question 4.5.220
Are the risks for estimates different if management uses
a specialist?
Interpretive response: No. When management uses a specialist in the
development of an estimate, there is no difference in how risks are identified or
controls are developed to address the risks.

For example, with a business combination, management may provide historical

customer data to a specialist for them to develop an attrition rate. The specialist
will perform modifications to the data and then will calculate the attrition rate
based on that data. In addition, they will use the attrition rate in the calculation of
fair value. Management is responsible for the completeness and accuracy of the
data being used in the attrition rate calculation, including the risks related to the
manipulation and the calculation of the attrition rate. Management is also
responsible for the attrition rate that was developed being properly transferred
into the fair value calculation, the method used to calculate the attrition rate and
the mathematical accuracy of the calculation.

Practical tip
Whenever a new estimate is developed, such as a business combination
estimate, management should develop appropriate control activities during the
process as opposed to trying to put control activities in place after the estimate’s
development, with a focus on the completeness and accuracy of the information
used.

Question 4.5.230
Does the entity identify risks over data generated by a
specialist specifically for the entity’s use in an estimate?
Interpretive response: Yes. Data generated by specialists for the entity’s use
in an estimate is generally calculated using external or internal information
provided by management. For example, mortality tables created specifically for
an entity typically use historical entity-specific data. As it is developed
specifically for the entity’s use, it is considered internal information (see
Question 6.4.10). Therefore, to address the reliability of the mortality tables, the
completeness and accuracy of the information used in the model to create the
table, as well as the end user computing risk in the model (i.e. mathematical
accuracy, manipulation risk) need to be addressed. In some cases,
management can obtain the models and calculations to have control activities
over these risks. However, in other cases a specialist’s model is proprietary.
Even when this is the case, management is still required to determine the
completeness and accuracy of the data.

This discussion is relevant to information developed by both internal and

external specialists. For example, if the entity’s own engineering department
calculates an estimated cost to rebuild a building as part of a fair value estimate,
the risks around the data, assumptions and the model used would need to be
considered and addressed consistent with an estimate developed by the entity’s
accounting department or by an external valuation specialist hired by the entity.

Practical tip
Other individuals in the entity with specific knowledge and expertise may assist
the accounting team with developing an estimate used in financial reporting.
These individuals typically are unfamiliar with the requirements for controls. As
such, management should ensure that process control activities are being
performed and the appropriate documentation is retained to evidence the design
and effective operation of the process control activities (consistent with chapter
5) and the use of information in those controls.

4.6 IT considerations when obtaining a process

understanding and identifying risk points

Question 4.6.10
What are IT considerations when obtaining a business
process understanding?
Interpretive response: IT considerations include understanding:

• the overall IT environment and risks that may exist at the entity level; and
• the flow of transactions through each relevant financial statement process,
including through IT systems.

Question 4.6.20
Why is understanding the overall IT environment
important?
Interpretive response: It is important to understand the overall IT environment
to properly identify IT risks at the process level. This is because flowcharts or
narratives that document the flow of information through a particular process are
activity-based. As a result, they often do not fully articulate the multiple layers of
IT embedded in the process, or the controls management has in place to
address the risks, including the completeness and accuracy of relevant data
elements flowing through the process.

Question 4.6.30
What is a better practice for documenting the
understanding of IT systems?
Interpretive response: An understanding of IT systems used by the entity,
including how information flows into, through, and out of the relevant IT
systems, may be facilitated using IT System Diagrams (ISDs).

ISDs are not flowcharts; rather, they are diagrams that depict the different layers
of an entity’s IT environment. ISDs show relevant applications, databases,
operating systems and other network infrastructure. In addition, they will often
show how service organization systems interact with the entity’s internal IT
systems.

The ISD is a diagram of the IT systems and a framework by which management

and the external auditors can ensure they understand IT adequately when they
walk through a business process to identify relevant PRPs. See Example
7.2.20.

Question 4.6.40
What is included in an ISD?

Interpretive response: The ISD considers the application, the database that
stores the data and the underlying operating systems, including IT components.
There may be additional components relevant to the ICFR assessment, such as
scripts, interfaces and customized application programming interfaces.

Each aspect of the ISD is important for purposes of management and the
external auditors:

• obtaining an adequate understanding of the business processes that rely on

IT;

• identifying relevant PRPs; and

• informing their judgment when it comes to identifying the relevant GITCs

that support the automated controls that are relied on in the ICFR
assessment to mitigate PRPs identified within each business process.

Question 4.6.50
Is management required to identify IT risks at the
process level?
Interpretive response: Yes. Understanding the way IT is used in the process
and identifying and addressing IT risks is not optional.

The entity must identify and document the relevant PRPs in the process at the
assertion level where there is a reasonable possibility that these PRPs could
result in or contribute to a material misstatement. This includes the PRPs
related to IT. Failure to sufficiently understand IT risks is a deficiency that needs
to be evaluated for severity and could result in a material weakness.

Walkthroughs and other procedures can provide an understanding of how IT

affects the entity’s flow of information and allows management and the external
auditors to consider IT risks (e.g. a PRP related to the data as it flows through
the IT system) when identifying likely sources of misstatement. There is a
potential PRP related to the completeness and accuracy of data whenever:

• data enters the system;

• data is stored and can be accessed in the system or a database;
• data is moved from one system to another; and
• data is summarized, accumulated or subjected to calculations.

When performing walkthroughs, there is no requirement to review the IT

system/application code. Ordinarily, the walkthrough can be completed by
interviewing the relevant process owners, inspecting system documentation,
and tracing a transaction through the process. However, because there is often
complexity involved with IT infrastructure, both management and the external

auditors should seek assistance from someone with the proper IT skill set when
planning and/or executing walkthroughs of processes that rely on IT.

Chapter 7 provides further discussion of IT control activities.

Question 4.6.60
What effect do GITCs have on IT at the process level?

Interpretive response: The effectiveness of GITCs has a pervasive effect on

automated controls or manual controls that rely on information from IT systems
at the process and transaction level, and within entity-level controls. Because of
this, it is important to consider GITCs when assessing IT risks.

Chapter 7 provides further discussion of IT control activities.

4.7 Considerations for journal entries and other

adjustments while obtaining a process
understanding and identifying risk points

Question 4.7.10
Does obtaining a process understanding apply to the
journal entry process?
Interpretive response: Yes. Management should understand business
processes all the way through the recording of journal entries.

Question 4.7.20
What are potential risks associated with journal entries
and other adjustments?
Interpretive response: The following table captures potential risks associated
with journal entries and related questions for management in understanding the
process of recording journal entries and identifying related PRPs that require
controls that are appropriately designed and operated.

Potential risks Questions for management

The existence of transactions underlying How does management ensure that each
journal entries and other adjustments automated and manual journal entry and
other adjustment represents a valid
transaction that is appropriately

Potential risks Questions for management

supported (i.e. what is management’s
process for obtaining appropriate
approval of journal entries)?
The accuracy of journal entries and other How does management ensure that each
adjustments automated and manual journal entry and
other adjustment is recorded for the
appropriate amounts and to the
appropriate general ledger accounts or
financial statement line items?
The completeness of journal entries and How does management ensure that all
other adjustments automated and manual journal entries
and other adjustments that should be
recorded are recorded and are recorded
in the correct period?
Management override of journal entries How does management ensure that all
and other adjustments relevant automated and manual journal
entries and other adjustments that have
been posted have been appropriately
approved and/or reviewed?

Section 5.14 discusses control considerations related to the risks associated

with journal entries and other adjustments.

Question 4.7.30
What are the risks related to automated and manual
journal entries and other adjustments?
Automated journal entries

For automated journal entries, routine financial transactions can be initiated,

authorized and accumulated via automated IT applications and posted through
automated journal entries from subsystems to the general ledger. The risks
generally relate to the proper transfer of journal entries between systems and
the configuration of the IT application to post complete and accurate amounts
during the appropriate period to the appropriate general ledger accounts.

Manual journal entries

Manual journal entries, which are initiated by an individual and manually entered
into the system, or which at any point in the process may be modified or
otherwise impacted by human intervention, would generally have an increased
risk of misstatement related to management override risk and completeness,
existence and accuracy risks.

Identifying all manual journal entries may be challenging and involves a detailed
understanding of the IT applications involved in the journal entry process.
Management should obtain an understanding of the sources of journal entries,
how the system processes and posts journal entries, and the capability for
manual changes to be made to journal entries during or after the posting

process. For example, in an automated journal entry process, is it possible that

manual changes could be made to the entry either during or after the posting
process without being subject to additional review?

How an entity defines manual journal entries may also impact the relevant
controls in place to address management override. For example, some IT
applications are highly configurable such that many different types, sources,
system users or transactions may involve manual intervention, and a simple or
static definition of ‘manual’ may not be sufficient to identify all such journal
entries. In this case, identifying the manual entries may require recurring
monitoring and revision throughout the period.

Other adjustments

Other adjustments are adjustments to amounts reported in the financial

statements that are not reflected in formal journal entries. For example, they
may be reflected in consolidating adjustments, report combinations or
reclassifications. Other adjustments may give rise to management override risk
as well as completeness, existence and accuracy risks.

Question 4.7.40
What are additional considerations related to the
approval of journal entries?
Interpretive response: When obtaining an understanding of the IT
environment, management should consider who has access to post a journal
entry, and whether approval of the journal entry is enforced within the IT system,
manually obtained outside of the IT system, or through some combination of the
two. Provided next are three common IT scenarios for approving journal entries.

Automated approval: Park and post

A park and post system restricts access to prepare and approve journal entries
and requires authorized approval before posting. If operating effectively, this
system typically offers the strongest control to address the risk of management
override that journal entries are posted that have not been approved and/or
reviewed before posting.

For this system, management needs to understand and assess whether access
controls are in place to restrict access to separately prepare and approve
journal entries. When evaluating this control, management considers whether
the IT system is configured to prevent a preparer from approving their own
journal entry and restrict edits to the entry after it has been approved.

Manual review and approval before posting: System restricts preparer and
approver from posting

In this scenario, all manual journal entries are subject to a control involving
review and approval by an individual who is separate from the preparer before
posting the entry in the system.

Compared to a park and post system, there may be a greater risk of

management override that journal entries are posted that have not been
reviewed and approved. However, systematically restricting posting access to
individual(s) other than the preparer and reviewer/approver, such as a data
entry clerk who is segregated from the preparer and reviewer/approver, may
help mitigate the risk.

When evaluating the sufficiency of controls under this scenario, management

considers the following questions.

• Is the poster independent of the preparer and reviewer?

• Does the poster validate that the journal entry was approved before
posting?
• Are access controls operating effectively to segregate access to prepare,
review/approve and post journal entries?

Manual review and approval before posting: System does not restrict
preparer and approver from posting

Similar to the previous scenario, all manual journal entries are subject to a
control involving review and approval by an individual who is separate from the
preparer before posting the entry in the system. However, a preparer or
reviewer/approver has access to post journal entries. Therefore, a risk exists
that an entry is posted that has not been subject to the review/approval control.

This scenario is riskier than the previous two scenarios, giving rise to the
following additional considerations.

• Absent automated access controls, does the entity have policies to

manually enforce segregation of duties between the preparer and
reviewer/approver, and the reviewer/approver and poster?

• How does management address the risk that the journal entry
review/approval has been circumvented?

• How does management know the population of journal entries subject to the
manual review control is complete?

Key takeaways

• The understanding of a business process should cover the entire process,

from initiation through recording in the financial statements, to identify all
PRPs that may lead to the identification of key controls that address RMMs.

• While the period-end financial reporting process operates after business

processes have been executed, understanding the process to prepare
financial statement disclosures typically straddles both business processes
and the period-end financial reporting process. Obtaining an understanding
of the information used in disclosures is best integrated with the
understanding of the related business process.

• When a business process includes an estimate, management’s

understanding of the process includes each of the elements of the estimate
and identification of the related PRPs.

• Management should ensure that obtaining a process understanding

includes identification of IT systems, as well as any information that is used
in the process.

• Flowcharts are the best way to evidence process understanding and the
flow of information, as well as document identification of PRPs and the key
controls that address them.

• Management should ensure they consider any changes to the business

process and update their process understanding at least annually, and
whenever key changes occur.

• Business process understanding should include journal entries, including

potential risks and approval considerations, to ensure accurate and
complete financial records and mitigate the risk of management override.

5. Process control activities

Detailed contents
5.1 Management’s ICFR journey
5.2 Control activities component of ICFR
Questions
5.2.10 What is the control activities component of ICFR?
5.2.20 What is the relevance of the control activities component of
ICFR?
5.2.30 What are the principles in the COSO Framework related to
the control activities component of ICFR?
5.2.40 How do control activities interact with the other components
of ICFR?
5.2.50 What is the importance of an entity selecting and developing
control activities that contribute to the mitigation of risks to
acceptable levels (Principle 10)?
5.2.60 How does an entity demonstrate that it has met Principle 10?
5.2.70 What is the importance of an entity selecting and developing
GITCs (Principle 11)?
5.2.80 What are GITCs?
5.2.90 How does an entity demonstrate that it has met Principle 11?
5.2.100 What is the importance of an entity deploying control
activities through policies that establish what is expected and
in procedures that put those policies into action (Principle
12)?
5.2.110 How does an entity demonstrate that it has met Principle 12?
5.3 Process control activities
Questions
5.3.10 What are process control activities?
5.3.20 What is a 'would' level of assurance?
5.3.30 What is the difference between a process control activity and
a process?
5.3.40 Why does management differentiate process activities from
control activities?
5.3.50 Could two or more process control activities address the
same PRP?
5.3.60 Can one process control activity address multiple PRPs?
5.3.70 Does management identify PRPs related to activities at a
service organization?

Example
5.3.10 ‘Could’ vs ‘would’ level of assurance provided by controls
5.4 Design, documentation, and implementation of relevant process
control activities
Questions
5.4.10 When is a process control activity properly designed?
5.4.20 What does ‘implementation’ of a process control activity
mean?
5.4.30 What is considered when designing a process control
activity?
5.4.40 What is a control operator?
5.5 Designing and documenting a control: Control objective
Questions
5.5.10 How are controls designed to achieve the control objective?
5.5.20 What are control attributes?
5.5.30 Do all controls have attributes?
5.5.40 Are all parts of a control considered control attributes?
5.5.50 What level of detail is needed in identifying and documenting
control attributes?
5.5.60 What does ‘sufficiently detailed’ mean as it relates to
identifying and documenting control attributes?
5.5.70 How should management document how the design of a
control addresses its objective?
Examples
5.5.10 Defining reasonableness in the context of the control
attribute
5.5.20 Identifying and documenting control attributes – review of a
fixed assets reconciliation
5.5.30 Identifying and documenting control attributes – review of a
physical inventory reconciliation
5.5.40 Identifying and documenting control attributes – review of
goodwill revenue forecast
5.6 Designing and documenting a control: Nature and type
Questions
5.6.10 What is the 'nature' of a control?
5.6.20 What are manual controls?
5.6.30 What are automated controls?
5.6.40 How do IT systems perform automated controls?

5.6.50 Are manual or automated controls more suitable to address

certain control objectives?
5.6.60 Are there any additional risks to consider when designing
and implementing manual controls?
5.6.70 Can a manual control have an automated component?
5.6.80 Are there additional considerations when designing and
documenting a process control activity that is automated?
5.6.90 What are the different categories of automated process
control activities?
5.6.100 What are the different types of controls?
5.6.110 What are preventive controls?
5.6.120 What are detective controls?
Example
5.6.10 Separate manual and automated control activities
5.7 Designing and documenting a manual control: Frequency
Questions
5.7.10 What is the frequency of a manual control?
5.7.20 Can a control be performed on an ad-hoc basis?
5.7.30 What's the relationship between frequency and achieving the
control objective?
Examples
5.7.10 Frequency of a process control activity in relation to its
objective
5.7.20 Frequency of a process control activity in relation to its
precision
5.8 Designing and documenting a manual control: Competence and
authority
Questions
5.8.10 What does it mean for a control operator to have ‘authority’?
5.8.20 How is the control operator’s authority assessed?
5.8.30 Why is a control operator’s competence important?
5.8.40 When is the competence of a control operator considered
and how is it assessed?
5.8.50 How are authority and competence considered when there
are multiple control operators?
5.8.60 How is the authority and competence of the control operator
affected when a control involves judgment and complexity?
5.8.70 Can management use a third-party or a specialist as a
control operator?

5.8.80 Can management use a service organization as a control

operator?
Examples
5.8.10 Authority of a control operator
5.8.20 Competence of a control operator
5.9 Designing and documenting a manual control activity: Judgment
Questions
5.9.10 What challenges arise when a control attribute involves
judgment?
5.9.20 How is it determined if a control activity involves judgment?
5.9.30 Do all control activities involve judgment?
5.9.40 Are there different considerations related to judgment when
the control activity is associated with an estimate?
Examples
5.9.10 Identifying judgment in a control activity – margin analysis
5.9.20 Identifying judgment in a control activity – fixed asset
reconciliation
5.10 Designing and documenting a control activity: Precision
Questions
5.10.10 What is precision in the context of a process control activity?
5.10.20 Is precision considered for all process control activities?
5.10.30 What are the primary factors used in determining the level of
precision for a process control activity?
5.10.40 What if a process control activity is not sufficiently precise?
5.10.50 How is the development of expectations evidenced?
5.10.60 What are criteria for investigation?
5.10.70 Why is it important to establish criteria for investigation when
designing a control activity?
5.10.80 Are the criteria for investigation of a control activity
documented?
5.10.90 How are precision and criteria for investigation applied in the
operation of a control?
5.10.100 What is a threshold?
5.10.110 What are quantitative thresholds?
5.10.120 What are ‘pre-defined’ and ‘variable’ quantitative thresholds?
5.10.130 What are qualitative thresholds?
5.10.140 What are management review controls and how is their
precision considered?

Examples
5.10.10 Determination of precision – review of purchases
5.10.20 Determination of precision – purchase order price
comparison
5.10.30 Control attributes that involve expectations
5.10.40 Qualitative thresholds
5.11 Designing and documenting a manual control activity:
Investigation and resolution
Questions
5.11.10 What is an outlier?
5.11.20 Is an outlier a misstatement?
5.11.30 How are outliers identified?
5.11.40 Are all outliers investigated?
5.11.50 Are all outliers resolved?
5.11.60 What should be documented related to the identification and
resolution of outliers?
5.11.70 What if no outliers are identified in the performance of a
control activity?
Examples
5.11.10 Fixed asset reconciliation – identification of outliers
5.11.20 Fixed asset reconciliation – investigation of outliers
5.11.30 Fixed asset reconciliation – resolution of outliers
5.12 Designing and documenting a manual process control activity:
Information
5.13 Controls responding to a fraud risk
Questions
5.13.10 Is it necessary to design control activities to address fraud
risks?
5.13.20 What is an anti-fraud control?
5.13.30 What activities generally require anti-fraud controls?
5.13.40 What are control activities that address the risk of
misappropriation of assets?
5.14 Controls responding to a risk related to journal entries and other
adjustments
Questions
5.14.10 How are risks related to journal entries and other
adjustments considered when designing control activities?

5.14.20 What types of control activities can address the risk of

completeness associated with journal entries and other
adjustments?
5.14.30 What types of control activities can address the risk of
existence and accuracy associated with journal entries and
other adjustments?
5.14.40 What is the risk of management override of controls?
5.14.50 How is the risk of management override addressed?
5.14.60 What types of control activities can address the risk of
management override associated with journal entries and
other adjustments?
5.14.70 Can other indirect control activities address journal entry
risks?
5.15 Controls responding to going concern, significant unusual
transactions, and related parties
Questions
5.15.10 Are there special considerations for control activities over the
risk related to an entity’s ability to continue as a going
concern?
5.15.20 What are significant unusual transactions?
5.15.30 What kind of controls over SUTs does management need to
have in place?
5.15.40 Why are there special considerations for controls related to
SUTs?
5.15.50 Are there special considerations for controls over related
party relationships and transactions?
5.15.60 What are examples of controls that may be in place to
address the completeness of related parties?
5.15.70 When management asserts a transaction occurred at arm’s
length, what terms of the transaction is that assertion
referring to?
5.15.80 What controls can management design and operate to
address the risk of an inappropriate assertion that a related
party transaction is at arm’s length?
5.16 Controls executed on a sample basis
Questions
5.16.10 Can controls be designed to be executed on a sample
basis?
5.16.20 When might it be appropriate to design controls to operate
on a sample basis?
5.16.30 What method is used to select the sample size to be used in
a control?

5.16.40 What other factors should management consider when

designing a control that operates on a sample basis?
5.16.50 Can a sampling control be used to address completeness?
Example
5.16.10 Evaluating whether a control that operates on a sample
basis is appropriate for an inventory count
5.17 Considerations when there are changes to controls
Questions
5.17.10 What is considered a change in a control?
5.17.20 What is the impact of a change in a control?
5.17.30 What are the impacts of a change in the control operator?
5.17.40 Does a change in the PRP addressed by a process control
activity require a change in the control?
5.18 Monitoring procedures over process control activities
5.18.10 Is testing of process control activities performed as part of
monitoring procedures?
5.18.20 What is included in the direct testing of process control
activities?
5.18.30 What is the timing of direct testing of process control
activities?
5.18.40 What is the extent of direct testing performed over a control
activity?
5.18.50 What evaluation strategies can be used in direct testing
process control activities?
5.18.60 What evidence is maintained for the operation of process
control activities to enable the performance of monitoring
activities?
5.18.70 Is management required to test all control activities each
year if using the direct testing approach?
Key takeaways

5.1 Management’s ICFR journey

Control activities in the context of management’s ICFR are focused on
identifying the policies and procedures established to mitigate (either directly or
indirectly) risks of material misstatements (RMMs) in the entity’s business
processes and the period-end financial reporting process. While all parts of
management’s ICFR journey are important, the proper selection and
development of control activities is vital to effective ICFR. See section 5.2 for
more information. This chapter begins with an overview of the Control activities
component of ICFR, which includes process control activities and GITCs. The
focus of the chapter is process control activities. GITCs are addressed in
chapter 7.

2. Entity-level controls

9. Identify and evaluate deficiencies

3. Risk assessment

4. Process understanding

5. Process control activities

Manual process Automated process Service organization process
control activity control activity control activity

6. Information used in controls 7. General IT controls 8. Service organizations

Each process control activity's objective is to mitigate a specific risk within a

business process that could lead to a material misstatement of the entity's
financial statements. We call that risk a process risk point (PRP).

An entity’s ICFR is effective when it provides reasonable assurance that its

financial statements are reliable and prepared in accordance with the applicable
financial reporting framework. Accordingly, process control activities should be
designed and operated at a ‘would’ level of assurance – they ‘would’ (i.e.
probably will) mitigate an identified PRP and, therefore, prevent, or detect and
correct on a timely basis, a material misstatement in the financial statements.
See section 5.3 for more information.

The following considerations in designing a process control activity are a central

focus of this chapter.

Consideration Description
The objective of a process control activity is the risk it is intended
to mitigate - i.e. the relevant PRPs the control activity addresses.
Control objective All other considerations involved in designing a process control
activity are driven by this objective. See section 5.5 for more
information.
'Nature' refers to whether the process control activity is manual
Nature and type or automated. 'Type' refers to whether the process control
of control activity is preventive or detective. See section 5.6 for more
information.

Consideration Description
An important consideration in determining the appropriate
frequency of the control’s operation (e.g. annually, daily,
Frequency
recurring, ad hoc) is whether it would achieve its objective in a
timely manner. See section 5.7 for more information.
If the control operator does not have the requisite authority and
Authority and
competence to operate (and, if necessary, correct the results of)
competence of
a manual process control activity, the control cannot achieve its
the control
objective (i.e. it would be ineffective). See section 5.8 for more
operator
information.
A process control activity must consider the judgment and
Judgment subjectivity involved in achieving its objective and setting the
involved appropriate parameters for identifying and evaluating outliers.
See section 5.9 for more information.
The level of precision is essentially the size of a potential
misstatement the control activity would prevent, or detect and
Level of correct on a timely basis, when it operates effectively. A control
precision is deemed to be sufficiently precise when the operation would
prevent or detect a material misstatement. See section 5.10 for
more information.
A manual process control activity should include appropriately
Investigation and
designed and documented steps performed by the control
resolution
operator to investigate and resolve outliers. See section 5.11 for
process
more information.
Information is usually used when performing a manual process
Information used control activity (e.g. system reports, manually prepared
in the spreadsheets, queries). Assessing the relevance and reliability of
performance of this information is critically important to ICFR, because controls
the process that rely on information cannot achieve the control objective and
control activity address the related PRP if the information is not relevant and
reliable. See chapter 6 for more information.

Given their nature, additional considerations may apply to the design and
operation of process control activities related to the following:

• fraud risks, such as the misappropriation of assets, fraudulent financial

reporting, corruption and other illegal acts, and management override of
controls (see section 5.13 for more information);

• journal entries and other adjustments, which may be used as part of

management’s override of controls (see section 5.14 for additional
information); and

• going concern, significant unusual transactions and related parties,

such as considerations related to:
— forecasts used in management’s going concern assessment;
— the potential for management to be incentivized to achieve a specific
accounting treatment for a significant unusual transaction; and

— identifying related parties, transactions with related parties and whether

such transactions occur on an arm’s length basis (see section 5.15 for
more information).

This chapter also discusses whether controls can be executed on a sample

basis (see section 5.16) and how changes in controls affect an entity’s ICFR
(see section 5.17).

This chapter ends with discussion on how the effectiveness of process control
activities is monitored by the entity, including the use of direct testing involving
reperformance, inspection and/or observation of the control together with inquiry
(see section 5.18). If it is determined that a process control activity is ineffective
in its design and/or operation, management concludes a deficiency exists and
performs the necessary evaluation and remediation activities (see chapter 9).

While the focus of this chapter is on process control activities, there are multiple
concepts discussed that are applicable for entity-level controls and GITCs as
well. The following terminology is used in this Handbook:

• controls include entity-level controls and control activities; and

• control activities include process control activities and GITCs.

Abbreviations

We use the following abbreviations in this chapter.

COSO Committee of Sponsoring Organizations of the Treadway

Commission
CUEC Complementary user entity control
GITC General IT control
ICFR Internal control over financial reporting
PCAOB Public Company Accounting Oversight Board
PRP Process risk point
RAFIT Risk arising from IT
RMM Risk of material misstatement
SEC Securities and Exchange Commission
SOC System and Organization Controls

5.2 Control activities component of ICFR

Question 5.2.10
What is the control activities component of ICFR?

Interpretive response: Per the COSO Framework: “Control activities are the
actions established through policies and procedures that help ensure that
management's directives to mitigate risks to the achievement of objectives are
carried out. Control activities are performed at all levels of the entity and at
various stages within business processes, and over the technology
environment.”

Question 5.2.20
What is the relevance of the control activities
component of ICFR?
Interpretive response: The control activities component of ICFR is relevant
because, per the COSO Framework: “control activities serve as mechanisms for
managing the achievement of an entity’s objectives and are part of the process
by which objectives are achieved.” The control activities performed in this
component of ICFR mitigate the identified RMMs.

Monitoring
Information and

communication

Control activities

Risk assessment

Control environment

See chapter 2 for discussion of the other ICFR components.

Question 5.2.30
What are the principles in the COSO Framework
related to the control activities component of ICFR?
Interpretive response: There are three principles necessary for an effective
control activities component of ICFR. Meeting all three principles demonstrates
that controls have been designed and implemented effectively to meet their
objectives.

Control activities
The organization selects and develops control activities that
Principle 10 contribute to the mitigation of risks to the achievement of objectives to
acceptable levels.
The organization selects and develops general control activities over
Principle 11
technology to support the achievement of objectives.
The organization deploys control activities through policies that
Principle 12 establish what is expected and in procedures that put policies into
action.

Source: COSO Internal Control – Integrated Framework (2013).

Question 5.2.40
How do control activities interact with the other
components of ICFR?
Interpretive response: Control activities complement the other components of
ICFR. For example:

• proper design and implementation of control activities are supported by an

effective risk assessment (see chapter 3);

• determining that the control activities operate as intended is supported by

monitoring (see section 2.7);

• providing control operators with the information to properly operate control

activities is supported by appropriate levels of information and
communication (see section 2.6 and chapter 6); and

• a robust control environment lays the foundation for an effective system of

ICFR (including control activities) (see section 2.4).

Question 5.2.50
What is the importance of an entity selecting and
developing control activities that contribute to the
mitigation of risks to acceptable levels (Principle 10)?
Interpretive response: Per the COSO Framework, “control activities help to
ensure that risk responses that address and mitigate risks are carried out.” The
proper selection and development of process control activities is vital in
ensuring that RMMs are properly mitigated.

Question 5.2.60
How does an entity demonstrate that it has met
Principle 10?
Principle 10: The organization selects and develops control activities that
contribute to the mitigation of risks to the achievement of objectives to
acceptable levels.

Interpretive response: Demonstrating that the entity has met Principle 10

requires the following:

• proper risk assessment (see chapter 3);

• proper identification of relevant business processes that require control

activities (see chapter 3) and obtaining an understanding of those
processes (see chapter 4);

• consideration of entity-specific factors and characteristics that create risks to

the achievement of objectives, including the environment, complexity,
nature, and scope of the entity’s operations, which are embedded in the
entity’s risk assessment (see chapter 3), process understanding (see
chapter 4) and design of controls (this chapter); and

• proper design of process control activities to respond to identified PRPs

(see Question 5.3.10), including a mix of control activity types and
considering the level of the entity at which the control is applied, as well as
appropriate segregation of duties.

An effective way to demonstrate the proper design of a process control activity

is through a detailed reconciliation of its attributes to each aspect of the related
PRP(s) to demonstrate that the risks are addressed by the control. Design of
process control activities is covered concurrently with Principle 12 in section 5.4.

Question 5.2.70
What is the importance of an entity selecting and
developing GITCs (Principle 11)?
Interpretive response: The reliability of technology within business processes,
including automated process control activities, depends on the selection,
development, and deployment of effective GITCs. GITCs support proper
deployment of IT systems, as well as proper continued operation of those
systems. GITCs also address integrity risk for information used in control
activities.

Question 5.2.80
What are GITCs?

Interpretive response: GITCs are control activities over the entity's IT

processes that support the continued effective operation of the IT environment,
including:

• the continued effective operation of automated control activities; and

• the integrity of data and information within the entity's IT systems.

The entity’s IT processes manage:

• access to programs and data;

• program changes;
• program acquisition and development; and
• computer operations.

The IT environment encompasses the IT systems the entity uses as part of its
financial reporting and business processes, including the layers of technology
(application, database, operating system and network), the IT processes and
the IT organization.

GITCs are not expected to directly prevent, or detect and correct, material
misstatements on a timely basis. However, ineffective GITCs may lead to
automated process control activities that don't operate consistently and
effectively, and therefore might not prevent, or detect and correct on a timely
basis, a material misstatement on a timely basis.

Chapter 7 provides more information about GITCs and related concepts.

Question 5.2.90
How does an entity demonstrate that it has met
Principle 11?
Principle 11: The organization selects and develops general control activities
over technology to support the achievement of objectives.

Interpretive response: Demonstrating that the entity has met Principle 11

requires:

• proper identification of integrity risks for information used in controls (see

Question 6.4.110);
• proper identification of relevant IT layers and risks arising from IT (RAFITs)
for automated process control activities (see section 7.2); and
• proper design and operation of GITCs to respond to the identified RAFITs
(see section 7.3).

Question 5.2.100
What is the importance of an entity deploying control
activities through policies that establish what is
expected and in procedures that put those policies into
action (Principle 12)?
Interpretive response: Control activities are built into business processes and
employees' day-to-day activities, which occurs through:

• the policies that communicate expectations as part of the control activities;

and
• the relevant procedures that put those policies into action.

The policies establish the responsibility and accountability for control activities
with management (or other designated personnel) of the business unit or
function in which the relevant risks reside. Deployment of the policies outlines
the timing, process for corrective action and competence of the personnel who
perform the control activities. The policies are important to guide the
performance of control activities throughout the entity.

Question 5.2.110
How does an entity demonstrate that it has met
Principle 12?
Principle 12: The organization deploys control activities through policies that
establish what is expected and in procedures that put policies into action.

Interpretive response: Demonstrating that the entity has met Principle 12

requires proper documentation of policies, procedures and operation of controls.
The documentation, at a minimum, should clearly identify:

• the individuals responsible for each process and executing each relevant
control;
• the specific procedures the control operator is expected to perform in
executing the control; and
• how outliers identified in the performance of the control are to be
investigated and resolved.

5.3 Process control activities

Question 5.3.10
What are process control activities?

Interpretive response: Process control activities directly support the actions to

mitigate transaction processing risks in an entity's business processes. Each
process control activity's objective is to mitigate a specific risk within a business
process that could lead to a material misstatement of the entity's financial
statements. We call that risk a process risk point (PRP). Accordingly, process
control activities are designed and operated at a ‘would’ level of assurance (see
Question 5.3.20).

Question 5.3.20
What is a 'would' level of assurance?

Interpretive response: For a control to function properly as a process control

activity, it needs to be designed and operated in a manner to confidently support
that it ‘would’ (i.e. probably will) prevent, or detect and correct on a timely basis,
a material misstatement in response to the risk being addressed.

Unlike entity-level controls (see Question 2.3.20) that operate at a ‘could’ level
of precision (see Question 2.3.40), process control activities are selected and
developed by an entity to directly mitigate the identified risks to the achievement
of financial reporting objectives to acceptable levels. An entity’s ICFR is
effective when it provides reasonable assurance (i.e. a high level of assurance)
regarding the reliability of the financial statements and their preparation in
accordance with the applicable financial reporting framework – meaning process
control activities must be designed and functioning to make it ‘probable’ the
entity will achieve its financial reporting objectives. Absolute assurance is not
possible due to limitations inherent in all systems of internal control, such as
human error, judgment uncertainty, and events outside management’s control.

Example 5.3.10
‘Could’ vs ‘would’ level of assurance provided by
controls
Scenario

Management has identified a PRP where invoices from vendors are not properly
reconciled with other purchasing documentation prior to recording in the entity’s
ERP system, resulting in invoices being processed for which the purchase price
or quantity does not agree to the purchase order and/or receiving document.
This PRP is related to the risk of material misstatement that the operating
expense account is not complete or accurate.

To address the PRP, management is considering whether to implement the

following two controls:

• control A: a monitoring control that reviews fluctuations in the operating

expense account balances year over year to identify unusual fluctuations
that may warrant further investigation; and

• control B: a preventive control whereby the entity’s ERP system performs,

prior to recording the expense and/or making payment, a three-way match
between the purchase order, invoice, and receiving document with a
threshold of tolerance for potential discrepancies defined by management.
Any discrepancies above the threshold are flagged by the system and
investigated and resolved through a separate manual control activity (see
Question 5.6.70) before the vendor invoice is processed and recorded.

Analysis

Due to the level of aggregation at which control A is designed to operate

(fluctuations in the balance of the entire operating expense account), the design
of the control does not support that it ‘would’ (i.e. probably will) identify,
investigate and resolve discrepancies between vendor invoices, purchase
orders and receiving documents. The control ‘could’ identify such issues but that
is not the appropriate level of assurance to serve as a process control activity
and address the identified PRP. Control A could, however, be an appropriate
entity-level control that, for example, monitors the effectiveness of process
control activities within the purchasing process (see Question 2.3.20).

On the other hand, control B, which is designed to operate systematically at the

individual transaction level, is designed in a manner that ‘would’ prevent a
material misstatement resulting from the incorrect recording of purchase
transactions when the vendor invoice does not agree to the purchase order or
the receiving document. The design of control B directly addresses the identified
PRP and, therefore, mitigates the risk that the transactions in the operating
expense account are not processed completely and accurately (i.e. at the
assertion level within the process).

Question 5.3.30
What is the difference between a process control
activity and a process?
Interpretive response: Management should think about the process as the
actual steps necessary to record an amount in the financial records in
accordance with the applicable financial reporting framework. In contrast,
process control activities are the specific actions taken along the way to mitigate
risks introduced during the process. Said differently, processes are ‘how’ an
entity records transactions and process control activities are the different checks
performed throughout the process to prevent or detect misstatements that could
occur along the way. Process control activities can be manual or automated.

Question 5.3.40
Why does management differentiate process activities
from control activities?
Interpretive response: Understanding the difference between activities that
introduce risks and those that mitigate risks is a key first step to understanding
the process and flow of transactions.

Blurring the lines or misunderstanding the distinction between process activities

and control activities hinders the proper understanding of the process and flow
of transactions. A lack of proper understanding of the process could lead to
insufficient identification of the related PRPs that require a control response or
misunderstanding of whether a process control activity addresses the related
risk. Process control activities can be designed appropriately only when the
risks created by the process activities that they are designed to mitigate are
clearly understood and articulated.

Consider the following example of the relationship between process activities

and control activities.

Control activities to address the identified

Process activities PRP risk
Customers place Customers The entity's ERP system compares the open
their purchase could exceed receivables from the customer plus the
orders electronically. their submitted purchase order amount to the
These orders are established established customer credit limit.
captured in the credit limit. If the total amount of open receivables and
entity's ERP system purchase orders exceeds the credit limit, the
and are processed purchase order is not processed further.
for fulfilment. Manual follow-up is performed for each
unprocessed purchase order.

Question 5.3.50
Could two or more process control activities address
the same PRP?
Interpretive response: Yes. Multiple process control activities can address the
same PRP. This can occur where there are both preventive and detective
controls in a process over the same PRP.

Question 5.3.60
Can one process control activity address multiple
PRPs?
Interpretive response: Yes. One process control activity can address multiple
PRPs when that activity is designed to adequately address each PRP. However,
management should carefully evaluate how the process control activity
responds to each PRP and clearly capture how it is designed to address each
PRP.

For example, an entity may have a process control activity that includes the
comprehensive review of:

• the presentation of the cash flows statement in accordance with a cash

flows checklist; and
• the reconciliation of balances to supporting documentation.

The entity may have designed this control to address the following PRPs.

• The cash flows statement is not mathematically accurate.

• Cash payments and receipts related to debt are not completely and
accurately entered in the cash flows workbook, presented gross, or
classified as financing activities.

• Cash payments for investments in property, plant and equipment are not
completely and accurately entered in the cash flows workbook or classified
as investing activities.

This control activity may be appropriately designed to address each PRP if the
cash flows checklist includes specific steps requiring the control operator to
recalculate the mathematical accuracy of the statement, agree the reported
balances of debt cash transactions to supporting documentation and evaluate
whether they are properly presented on a gross basis and classified as
financing activities, and agreeing payments for investments in property, plant
and equipment as presented in the cash flows statement to supporting
documentation and verifying they are classified as investing activities.

Question 5.3.70
Does management identify PRPs related to activities at
a service organization?
Interpretive response: It depends. If the process activities at a service
organization are part of the entity’s ICFR (see Question 8.2.30), then
management is responsible for understanding the process and identifying PRPs
within the process. This allows management to properly consider whether the
service organization has appropriate process control activities in place to
mitigate the PRPs. Management also identifies PRPs and related controls,
including complementary user entity controls (CUEC), around the relevant
handoffs of data between the entity and the service organization.

Management may also implement process control activities at the entity to

address PRPs related to the process activities carried out by the service
organization. This may be necessary when process control activities at the
service organization that are necessary to address the identified PRPs are
missing, are not appropriately designed, or do not operate effectively.

Chapter 8 provides further information on service organizations and ICFR.

5.4 Design, documentation, and implementation of

relevant process control activities

Question 5.4.10
When is a process control activity properly designed?

Interpretive response: A properly designed process control activity is capable

of effectively preventing, or detecting and correcting on a timely basis, material
misstatements, either individually or in combination with other process control
activities.

A properly designed process control activity is effective when it:

• satisfies the entity's control objectives by addressing the PRPs it is intended

to address; and
• operates at a level of precision that 'would' prevent, or detect and correct on
a timely basis, a material misstatement.

Question 5.4.20
What does ‘implementation’ of a process control activity
mean?
Interpretive response: The ‘implementation’ of a process control activity
means that the control exists, and the entity is using it. It can also be used
interchangeably with ‘operation’, meaning the continued operation of a control
activity.

Question 5.4.30
What is considered when designing a process control
activity?
Interpretive response: This table sets out and describes the items considered
when designing a process control activity. The considerations in the table
should also be present in the documentation of each process control activity.
Some considerations only apply to manual process control activities, where
indicated. See Question 2.3.60 for the considerations for entity-level controls
and Question 7.3.30 for the considerations for GITCs.

Consideration Description Section

The risks, including fraud risks, the control is intended
to mitigate - i.e. the relevant PRPs the process
Control objective 5.5
control activity addresses. This is achieved using
control attributes.
'Nature' refers to whether the process control activity
Nature and type is manual or automated.
5.6
of control 'Type' refers to whether the process control activity is
preventive or detective.
The frequency with which a manual process control
activity is performed, which could be:
• annually;
• quarterly;
Frequency • monthly; 5.7
• weekly;
• daily;
• recurring; or
• ad hoc.
Authority and The level of competence and authority necessary to
competence of operate a manual process control activity (i.e. is the
the control right person performing the control activity?). 5.8
operator (see
Question 5.4.40)
The subjectivity involved in determining whether
Judgment something is an outlier and/or whether that outlier is
5.9
involved correct/reasonable in operating a manual process
control activity.

Consideration Description Section

Level of The level of precision, including the criteria/thresholds
5.10
precision for investigation, used to identify outliers.
Investigation and The documented steps performed by the control
resolution operator to investigate and resolve outliers identified 5.11
process in operation of a manual process control activity.
Information used The information used when performing the manual
in the process control activity (e.g. system reports, manually
5.12
performance of prepared spreadsheets, queries), including the
the control relevant data elements (see Question 6.2.40).

If it is determined that a process control activity is ineffective in its design and/or

implementation, management should:

• conclude that there is a deficiency;

• evaluate the control deficiency (see chapter 9); and
• remediate the control deficiency or identify a compensating control activity
(see section 9.6).

Question 5.4.40
What is a control operator?

Interpretive response: The control operator is a term used to describe who or

what performs the control. In a manual control, the control operator is the
individual who performs the control. In an automated control, the control
operator is the IT system.

5.5 Designing and documenting a control: Control

objective

Question 5.5.10
How are controls designed to achieve the control
objective?
Interpretive response: To effectively design a control to achieve the control
objective(s), the control should include specific attributes directly responsive to
the objective(s). These attributes should be clearly documented as part of the
control’s design documentation. All controls have at least one control attribute.

A control’s objectives are different depending on the type of control.

Type of control Objective

To address a principle of COSO,
Entity-level control individually or with other entity-level
controls (see chapter 2).
To mitigate a relevant PRP that relates to
Process control activity
a relevant RMM (this chapter).
GITC To mitigate a RAFIT (see chapter 7).

Question 5.5.20
What are control attributes?

Interpretive response: Control attributes are the specific procedures performed

by the control operator that make up the control. Control attributes are the parts
of the control that address its objective.

Question 5.5.30
Do all controls have attributes?

Interpretive response: Yes. All controls have at least one attribute. Depending
on how a control is defined by the entity, it may have more than one attribute.

Question 5.5.40
Are all parts of a control considered control attributes?

Interpretive response: No. Control attributes do not include steps that are part
of the ‘process’, but not part of the control. For example, if the control operator
reconciling A to B is important to achieving the control objective, then that step
is a control attribute. If, on the other hand, saving the completed reconciliation to
a particular file folder is not important to achieving the control objective, then
that step is not a control attribute.

Question 5.5.50
What level of detail is needed in identifying and
documenting control attributes?
Interpretive response: Control attributes need to be sufficiently detailed for the
control operator to understand what is expected of them in executing the control
and for a third party (e.g. external auditor) to be able to reperform the control
attributes.

Question 5.5.60
What does ‘sufficiently detailed’ mean as it relates to
identifying and documenting control attributes?
Interpretive response: ‘Sufficiently detailed’ means the control attributes are
described in specific terms that align with the actual procedures or steps in the
control that the control operator performs. What is expected of the control
operator should be clearly described in the control attribute. Vague language
should be avoided.

For example, words like ‘reasonable’ or ‘appropriate’ do not provide a sufficient

level of detail, nor does simply indicating that the control operator performs a
‘review.’ Instead, control attributes should articulate how the control operator
judges whether something is ‘reasonable’ or ‘appropriate’ or what specific
conditions the control operator contemplates or evaluates when performing a
‘review.’

Practical tip
When documenting the design of controls that require a control operator to
review something and make an evaluation, avoid using the term ‘review’ in
describing the control. This will help identify the specific steps or attributes the
control operator is expected to perform in executing the control.

In addition, when considering whether a control attribute is sufficiently detailed,

management may want to ask themselves the following question: “If another
person needed to perform this control in the absence of the current control
operator, would they know exactly what to do, what criteria/thresholds to apply
to identify items that may require further investigation, and how to resolve such
items in order to achieve the control’s objective?”

Example 5.5.10
Defining reasonableness in the context of the control
attribute
Scenario

Management has documented the following process control activity: A

reconciliation of the construction-in-progress (CIP) detail to the fixed asset
rollforward is performed and evaluated monthly.

As part of documenting the design of this process control activity, management

has identified the following control attribute:

The control operator evaluates the reconciliation for reasonableness.

Analysis

The attribute identified by management is unclear about how the control

operator determines whether each reconciling item is reasonable. Consider the
following modification to this attribute:

The control operator evaluates whether:

• each item on the manual listing of CIP additions was properly capitalized; and
• each item continues to represent CIP or if it was placed into service.

With the modified attributes, it is easier to understand what the control operator
is looking for in determining reasonableness.

Example 5.5.20
Identifying and documenting control attributes – review
of a fixed assets reconciliation
Scenario

Management has documented the following process control activity: On a

quarterly basis, the control operator reviews the reconciliation of the fixed assets
subledger to the general ledger.

Analysis

Although this process control activity appears to be a straightforward

reconciliation review, it contains several attributes that should be separately
identified when documenting the design of the control. Doing so facilitates
consideration of how each part of the process control activity addresses the
identified PRP(s).

Breaking apart the process control activity above and focusing on avoiding
using the word ‘review’ may result in identifying the following attributes to be
performed.

Attribute 1: The control operator agrees the fixed asset subledger amount to the fixed
asset reconciliation.

Attribute 2: The control operator agrees the fixed asset general ledger amount to the
fixed asset reconciliation.

Attribute 3: The control operator recalculates any differences between the general
ledger amounts and the subledger amounts.

Attribute 4: The control operator ensures all outliers have been identified (e.g.
differences greater than $10,000) and determines if they have been appropriately
resolved by the preparer of the reconciliation.

Example 5.5.30
Identifying and documenting control attributes – review
of a physical inventory reconciliation
Scenario

Management has documented the following process control activity: A physical

inventory reconciliation is reviewed each month by the plant controller.

Analysis

Similar to Example 5.5.20, there may be several attributes associated with this
control that should be separately identified when documenting the control’s
design, such as the following.

Attribute 1: The control operator agrees quantities per the final physical inventory
count sheets to the reconciliation. (Other process control activities operate over the
physical inventory observation, resulting in the final count sheets.)

Attribute 2: The control operator agrees the pre-adjustment subledger balance to the
reconciliation.

Attribute 3: The control operator checks that, for any inventory item with a count
difference greater than $5,000, a second count was performed per the count sheets.

Attribute 4: The control operator agrees the result of the reconciliation to the
adjusting journal entry and checks that the quantities in the post-adjustment subledger
agree to the count sheets.

Example 5.5.40
Identifying and documenting control attributes – review
of goodwill revenue forecast
Management has documented the following process control activity:
Management reviews the revenue forecast used in the assessment of goodwill
impairment for a reporting unit.

Analysis

This process control activity description is unclear about exactly what the control
operator is reviewing, how the review is performed, what information is used in
the review, and how any outliers are identified. Another individual performing
this same process control activity would be unlikely to perform the same
procedures and come to the same conclusions given this vague control
description. Controls that involve judgment typically involve more attributes as
well as multiple sources of information (see section 5.12 for further
consideration of information used in controls). In addition, the controls may
require various levels of precision, which are identified in the documentation of
the individual attributes.

To facilitate consistent operation of the process control activity at the ‘would’

level of precision (see Question 5.3.20), management documents the following
detailed attributes and focuses on avoiding the use of the word ‘review’.

Attribute 1: The control operator agrees the historical data presented on the forecast
spreadsheet to the prior year financial statements (i.e. the control operator validates
the completeness and accuracy of data used in the operation of the control activity by
agreeing it to its source).

Attribute 2: The control operator sets an expectation for Year 1 revenue growth
based on examining the following internal and external information:
• 3-year historical growth for the entity’s peer group;
• 12-month prospective growth forecast for the entity’s peer group (when available);
• industry analysts’ 12-month revenue forecast; and
• the internal sales group’s revenue goals by product line, and a comparison of past
sales goals with actual sales results.

Attribute 3: The control operator sets an expectation for Years 2-5 revenue growth
based on examining the following internal and external information:
• 5-year historical entity-specific and industry-specific growth trends;
• the internal sales group’s revenue goals by product line; and
• a comparison of past sales goals with actual sales results.

Attribute 4: The control operator compares the revenue growth forecast for the
terminal value to the 10-year average rate of inflation and investigates and resolves
differences greater than 0.5 percentage point.

Attribute 5: The control operator compares the actual forecast for each of the periods
listed with the expectation and investigates outliers that differ by more than $10 million
or 1.5% of the expectation. Outliers are investigated and resolved with persuasive
supporting evidence or adjustment to the forecast.

Question 5.5.70
How should management document how the design of
a control addresses its objective?
Interpretive response: When documenting the design of a control,
management should include a link between the attributes of the control and the
PRPs they are addressing. This supports the design of the control addressing
the relevant PRPs and assists with writing the attributes in sufficient detail to
clearly evidence how the attribute is addressing the risk.

When writing attributes, it is important to achieve the right balance between too
much information and not enough information. The attribute(s) should guide the
control operator through the steps involved in performing the process control
activity. Start by writing out the steps the control operator is expected to
complete as they perform the control. Then, remove any parts that do not apply
to the control’s performance, including those related to the ‘process’ and not the
control.

When considering whether an attribute is sufficiently detailed, consider asking

the following question: If another person needed to perform this control in the
absence of the current control operator, would they know exactly what to do,
what criteria/thresholds to apply to identify items that may require further
investigation, and how to resolve such items to achieve the control’s objective?

A best practice to evidence how controls address the control objective is a risk
and controls matrix that links:

• the RMM;
• the underlying PRPs that can lead to the RMM; and
• the specific process control activities and attributes that address the PRPs.

This matrix can be shared with external auditors for alignment on the population
of identified risks and related controls. Management can also use flowcharts
(see Question 4.3.90) to evidence the link of PRPs to the process control
activities.

5.6 Designing and documenting a control: Nature and

type

Question 5.6.10
What is the 'nature' of a control?

Interpretive response: The 'nature' of a control refers to whether the control is

manual or automated.

Question 5.6.20
What are manual controls?

Interpretive response: Manual controls are controls performed by people.

Question 5.6.30
What are automated controls?

Interpretive response: Automated controls are controls performed by an IT

system. Automated controls are executed (e.g. extending prices on invoices,
performing edit checks) the same way until:

• the program logic (including the tables, files or other permanent data used
by the control) is changed; or
• the automated control is otherwise overridden.

Question 5.6.40
How do IT systems perform automated controls?

Interpretive response: IT systems perform automated controls using system

configurations that apply business logic governing data input, processing and
output. These configurations may be programmed into any of the layers of
technology that comprise an IT system (see Question 7.2.10).

Question 5.6.50
Are manual or automated controls more suitable to
address certain control objectives?
Interpretive response: Yes. The following diagram captures factors that may
point to either an automated or manual control being more suitable to address a
specific control objective.

Automated Manual
Control Control

• No judgment or discretion are • Judgment and discretion are

necessary. necessary.

• High volume of recurring • Large, unusual or non-recurring

transactions. transactions.

• Situations where errors are • Changing circumstances where

easy to define. a control response outside the
scope of an existing automated
control is necessary.

• Circumstances where errors are

difficult to define, anticipate or
predict.

• Monitoring the effectiveness of

automated controls.

Question 5.6.60
Are there any additional risks to consider when
designing and implementing manual controls?
Interpretive response: Manual controls may be less reliable than automated
controls because they can be more easily bypassed, ignored or overridden.
They are also more prone to human error and simple mistakes. Management
cannot assume that a manual control will be applied consistently each time it is
performed.

Question 5.6.70
Can a manual control have an automated component?

Interpretive response: No. Manual controls often rely on or use the output of a
separate automated control. While these activities might seem to be only one
control, they are two distinct controls addressing different objectives.

Example 5.6.10
Separate manual and automated control activities
Scenario

Data is flowing from one system to another, and an automated process control
activity is in place to ensure the completeness and accuracy of the data transfer.
If a data transfer fails, a control operator is sent a notification of the failure, and
the control operator investigates the error and resolves it.

Analysis

There is an automated process control activity that addresses the PRP that data
is not completely and accurately transferred from one system to another.

There is a separate manual process control activity that addresses the PRP that
failures in the data transfer are not properly investigated and resolved, resulting
in the data not being completely and accurately transferred.

Question 5.6.80
Are there additional considerations when designing and
documenting a process control activity that is
automated?
Interpretive response: Yes. When a process control activity is automated,
management needs to identify and respond to RAFITs by:

• identifying the relevant layers of technology that the automated process

control activity relies on and determining what RAFITs within each of those
layers could impact effective operation of the automated process control
activity; and

• identifying and evaluating the design and implementation of relevant GITCs

that address the RAFITs.

Like with manual process control activities, documenting the level of precision
when the control is designed to identify outliers is also important (see Question
5.10.10).

Chapter 7 provides further discussion of RAFITs and GITCs.

Practical tip
If an automated process control activity does not have effective GITCs that
address the identified RAFITs, the automated process control activity cannot be
relied on to operate effectively. GITCs are vital to the effective operation of
automated process control activities, which makes identifying the relevant IT
layers and the related GITCs vital to effective ICFR.

Question 5.6.90
What are the different categories of automated process
control activities?
Interpretive response: The following table lists examples of different
categories of common automated process control activities and example
controls for each category. However, there may be additional types of
automated process control activities that do not fall in the categories listed.

Category Example
• Access to change credit limits in the IT system is
restricted only to those in the credit department, and
those in the credit department do not have access to
System access create a sales order or ship an order.
control activities,
including those
• Access to approve claim payments between $10,000
and $25,000 is restricted to the Claims Payment
enforcing segregation
Supervisor.
of duties
• Access to open and close periods within the general
ledger IT system is restricted to the Finance System
Admin Group.

• The system is configured to approve invoices that

match the invoice to the purchase order and the goods
shipped. Unmatched invoices are flagged for
resolution (3-way match control).
• The system is configured to apply customer payments
to the appropriate customer account.
• The system is configured to completely and accurately
calculate interest credited based on policy plan codes.
• The system is configured to prevent unbalanced
journal entries.
System configuration
control activities • The system is configured to validate premium codes
assigned to policies based on the policy type.
• The system is configured to assign accounts
receivable transactions completely and accurately to
an aging bucket based on the invoice due date.
• The system is configured to completely and accurately
report suspended purchase orders because of a
customer exceeding their credit limit.
• The system is configured to completely and accurately
accumulate and report transactions based on product
type.

• The system is configured to produce an error when the

number of records processed does not agree to the
number of records shown in the interface file header
Interface control record.
activities
• The system is configured to add general ledger
account codes completely and accurately to
transactions based on interface mapping rules.

Category Example
• The system is configured to produce an error log of
interfaced transactions that could not be processed
due to missing data elements.

Question 5.6.100
What are the different types of controls?

Interpretive response: Controls are either preventive or detective. It is

important for entities to have a mix of both types.

Question 5.6.110
What are preventive controls?

Interpretive response: Preventive controls are proactive. They help reduce the
risk of errors or fraud before they occur.

An example of a preventive control is an automated process control activity that

requires an expenditure to be approved before posting and payment.

Question 5.6.120
What are detective controls?

Interpretive response: Detective controls identify errors or fraud after they

have occurred.

An example of a detective control is a manual process control activity where a

control operator reviews all expenditures at the end of the month and verifies
that they were approved before posting and payment.

Practical tip
Preventive controls generally are considered stronger than detective controls
because they stop the fraud or error from occurring. Management should
consider which type of control is more appropriate when designing controls to
address their objective.

5.7 Designing and documenting a manual control:

Frequency

Question 5.7.10
What is the frequency of a manual control?

Interpretive response: Frequency relates to how often a manual control is

performed. For example, a manual control could be performed:

• annually;
• quarterly;
• monthly;
• weekly;
• daily;
• on a recurring basis (e.g. performed multiple times per day); or
• ad-hoc (e.g. when a certain type of transaction or activity occurs).

Annual, quarterly, monthly, weekly, and daily controls are referred to as 'periodic
controls.'

Question 5.7.20
Can a control be performed on an ad-hoc basis?

Interpretive response: Yes. A control may be performed only when a certain

type of transaction or activity occurs. An example of an ad-hoc control is a
process control activity to evaluate the appropriateness of accounting for new
debt agreements when they occur.

Certain compensating controls (see section 9.6) may also be designed to

operate on an ad-hoc basis to address the same objective (i.e. same PRP for
process control activities) as a deficient control.

Question 5.7.30
What's the relationship between frequency and
achieving the control objective?
Interpretive response: The appropriate frequency of a control's performance is
considered in relation to the control objective. The precision of a control
increases when the frequency and consistency of its performance increases.

When management evaluates whether a control is appropriately designed, they

should ask: Does the control operate at a frequency that would achieve its

objective in a timely manner? For a process control activity, the frequency

should result in the prevention or detection of a material misstatement on a
timely basis.

Management should document the frequency of the control’s operation and how
that frequency achieves the control objective.

One aspect of the control objective that may influence the frequency of the
control’s operation is whether the control relates primarily to income statement
accounts or balance sheet accounts.

• Income statement accounts. Such accounts are reported on a cumulative

basis, which should be reflected in the frequency of the control’s operation
along with the nature of the risk the control is addressing. For example, a
recurring control over the approval of expenditures properly addresses the
magnitude of expenditures and responds to the cumulative nature of
recognizing the expenditures in the income statement.

• Balance sheet accounts. Such accounts are reported at a point-in-time,

which should be reflected in the frequency of the control’s operation (at least
as of period end) along with the nature of the risk the control is addressing.
While a control may be focused on a balance sheet account, it may also
support the related income statement accounts, which should be reflected in
the frequency of the control’s operation. Two contrasting examples follow.
— Management implements an annual inventory count. This may be an
appropriate frequency due to the existence of other controls over the
movement of inventory throughout the period that reduce the risk
surrounding the one-time performance of the count.
— Management implements a monthly control over accounts receivable.
This may be an appropriate frequency due to the risks related to
accounts receivable, the nature of the control also supporting revenue
accounts and the allowance for credit losses, and the need to identify
outliers on a timely basis.

Example 5.7.10
Frequency of a process control activity in relation to its
objective
Scenario

An entity has a process control activity to detect improper access to a folder with
information used in the preparation of financial statements. However, the
process control activity only operates annually.

Analysis

The frequency of the process control activity may not be sufficient to meet the
control objective as it may not detect improper access in a timely enough
manner to prevent the potential manipulation of the information and a
misstatement in the financial statements.

Example 5.7.20
Frequency of a process control activity in relation to its
precision
Scenario

On an annual basis, the CFO reviews the entity’s marketing expenses for
completeness, existence and accuracy. The designed precision of that review is
equal to the risk tolerance (see Question 3.4.40) established for the marketing
expense account.

Analysis

Assuming the entity reports its financial results only once a year, the review
control is sufficiently precise as the maximum error in the marketing expense
account that the control might ‘miss,’ if effectively executed, would be limited to
the risk tolerance established for the account. However, if the same review
control operated at the same level of precision four times a year using quarterly
marketing expense information, there would be a risk of ‘missing’ an error in the
annual financial statements as large as four times the established risk tolerance.
Therefore, the quarterly review control should be designed with a greater level
of precision than the annual review. In this example, it would be more
appropriate for the CFO’s quarterly review to involve a level of precision that is
one quarter of the established risk tolerance for the marketing expense account.

5.8 Designing and documenting a manual control:

Competence and authority

Question 5.8.10
What does it mean for a control operator to have
‘authority’?
Interpretive response: In a system of internal control, the authority of a control
operator (see Question 5.4.40) relates to their ability to sufficiently challenge
process owners and, where necessary, correct the process outcomes. When a
control operator does not have the authority within the organization to enforce
the control’s operation or correct its results, the control cannot achieve its
objective and, therefore, is ineffective.

Question 5.8.20
How is the control operator’s authority assessed?

Interpretive response: Authority of the control operator is assessed by

obtaining an understanding of the entity’s organizational structure. The control
operator must have the ability to sufficiently challenge process owners in a way
that would influence their behavior.

Example 5.8.10
Authority of a control operator
Scenario

Accounting Associate reviews and authorizes all journal entries posted each
month. Certain journal entries are posted by Accounting Associate's supervisor
and other supervisors.

Analysis

Based on the entity's structure, Accounting Associate does not have the right
level of authority to sufficiently challenge the legitimacy of a journal entry
because they wouldn't be able to challenge a supervisor about a questionable
journal entry posted by that supervisor. Therefore, the process control activity is
not designed effectively to address the PRP.

Question 5.8.30
Why is a control operator’s competence important?

Interpretive response: Competence relates to the abilities, knowledge or skills

that enable a person to effectively perform their job responsibilities. The
competence of a person performing a control may either support or limit the
control's effectiveness. When a control operator does not have the necessary
abilities, knowledge or skills to perform the control activity the way it was
designed, the control may not be able to achieve its objective.

Question 5.8.40
When is the competence of a control operator
considered and how is it assessed?
Interpretive response: Competence of the control operator is considered when
designing a control and identifying the control operator.

Management should consider a variety of factors in assessing a potential control

operator’s competence, including their:

• educational level;
• prior experience with the subject matter of the control;
• prior work results (e.g. any deficiencies or misstatements in prior periods
related to their areas of responsibility); and
• qualifications, licensing, membership in a professional body and other forms
of external recognition.

Management should also consider the relevance of the control operator's

capabilities to the control's subject matter, and whether there are circumstances
that may threaten the control operator's objectivity.

Example 5.8.20
Competence of a control operator
Scenario

The Tax Department prepares the entity's income tax provision and identified
specific PRPs related to the entity’s valuation allowance. When designing a
control to address the PRPs, management determined to require a member of
the Accounting Department outside of the Tax Department to perform specific
procedures over the valuation allowance analyses prepared by the Tax
Department.

Management identified that the Director of Accounting is a CPA with experience

in both preparing and auditing tax provisions while working for a public
accounting firm. Further, the Director of Accounting has been employed with the
entity for a number of years and participates in the monthly management
meetings where information relevant to risks related to the recoverability of the
entity’s deferred tax assets is discussed.

Analysis

Management concludes that the Director of Accounting possesses the

competence to perform the control over the entity’s valuation allowance
analysis.

Question 5.8.50
How are authority and competence considered when
there are multiple control operators?
Interpretive response: It depends on whether each of the multiple control
operators are performing the control or the multiple control operators are
performing the control as a group.

When there are multiple control operators (e.g. a homogeneous control

performed in multiple locations), all the control operators should have the
necessary authority and competence to effectively perform the control.

When there are multiple control operators performing the control as a committee
or a group, the aggregation of the group members should have the necessary
authority and competence to effectively perform the control. In this situation,
there may be different perspectives and experiences among the multiple control
operators that, collectively, result in the appropriate competence and authority to
effectively perform the control.

Practical tip
When the control operators have consistent roles/titles, management can
consider and review the job, experience and education requirements of the
related job description for that role/title to assist in assessing the authority and
competence of the group of control operators.

Question 5.8.60
How is the authority and competence of the control
operator affected when a control involves judgment and
complexity?
Interpretive response: As the level of judgment required by, and/or complexity
of, a manual control increases, so does the level of authority and competence
needed of the control operator. The greater the degree of judgment and
complexity, the greater the control operator's knowledge, skills and experience
must be to effectively perform the control.

Practical tip
The root cause of deficiencies in complex controls or controls involving
judgment is often related to the control operator not having the appropriate
competence or authority to perform the control activity. This could include the
control operator not having the appropriate experience or not being privy to
information and decisions made within the business to appropriately identify
outliers. It could also include the control operator not having the right authority to
address any identified outliers.

Critical to the appropriate design of a control is whether the control operator has
the appropriate experience and awareness of relevant information and decisions
within the entity that may affect the control’s performance. When there are
changes in control operators due to layoffs, business combinations and
turnover, management should pay close attention to how those changes affect
the operation of complex controls and controls involving judgment.

Question 5.8.70
Can management use a third-party or a specialist as a
control operator?
Interpretive response: Yes. In some cases, management may use a third party
to assist with financial reporting functions, including performing controls.

For example, a smaller entity with limited accounting and financial reporting
personnel may engage an external party to operate a control. Also, an entity
may not have internal resources with the technical expertise to effectively
execute controls over a particular area of accounting or financial reporting (e.g.
complex tax transactions, derivative accounting). As a result, the entity may
retain an external party to assist with process and control activities in those
areas.

When a third-party or specialist is used as a control operator, management

retains responsibility for:

• supervising the third party or specialist; and

• understanding and evaluating the third party's or specialist’s work in
designing, implementing and operating the control.

If management uses a third-party, including a specialist who is not employed by

the entity, to operate a control, they should document their consideration of the
third-party’s competence by considering:

• the knowledge, skill, and ability of the third party; and

• the nature and complexity of the area that the third party was asked to
address.

Question 5.8.80
Can management use a service organization as a
control operator?
Interpretive response: Yes. In many cases, management may use a service
organization to assist with certain of the entity’s processes and functions.

For example, many entities outsource their payroll function to service providers.
When a process or function is outsourced to a service organization,
management remains responsible for that process or function. To carry out that
responsibility, management may either:

• rely on the service organization to maintain relevant controls to prevent or

detect material misstatements; or
• design and implement their own controls at the entity that prevent or detect
material misstatements.

If management is relying on a service organization to perform controls and

receives a SOC 1 Type II report from the service organization (see Question
8.4.30), management does not need to separately consider the authority and
competence of the control operators at the service organization. The authority

and competence of the service organization’s control operators is evaluated by

its service auditor in connection with issuing the SOC 1 Type II report. However,
any communicated exceptions identified in the service auditor’s report related to
the authority or competence of the control operators at the service organization
should be evaluated by management.
If management tests the controls at the service organization or implements their
own controls at the entity related to the processes and functions performed by
service organization, then the authority and competence of the control operators
need to be assessed by management.

Chapter 8 provides in-depth discussion about management’s responsibilities

over service organizations.

5.9 Designing and documenting a manual control

activity: Judgment

Question 5.9.10
What challenges arise when a control attribute involves
judgment?
Interpretive response: When judgment is involved in a control attribute, it
introduces challenges in elaborating on:

• the subjectivity involved in the control attribute; and

• the ‘triggers’ embedded in the judgmental element that may lead to the
identification and investigation of outliers.

Control activities involving judgment are often used in complex areas with the
potential for a higher RMM, which may increase the amount of evidence needed
to show how the control is designed, implemented and operating. This is
particularly true in situations where a third party (such as an external auditor)
assesses the effectiveness of the entity’s controls. At the same time, gathering
and maintaining more evidence may present additional challenges for a control
involving judgment.

Practical tip
In the words of the COSO Framework, controls “cannot be performed entirely in
the minds of senior management without some documentation of management’s
thought process and analyses.” It may be most effective for control operators to
retain such documentation concurrently with the performance of a control
involving judgment. To do so, the control operator could document their thought
process, including how they identified and resolved outliers, or what led them to
not identify any outliers.

Question 5.9.20
How is it determined if a control activity involves
judgment?
Interpretive response: Determining whether a control activity involves
judgment is done at the attribute level. A control attribute involves judgment if
there is judgment or subjectivity in:

• applying the criteria for investigation (see Question 5.10.60);

• identifying outliers (see Question 5.11.30); or
• determining whether the item subject to the control is correct/reasonable for
any individual control attribute.

In addition, use of expectations in a control attribute indicates the involvement of

judgment.

In many cases, when judgment is involved in the underlying accounting for the
transaction (e.g. use of an estimate), there is likely to be judgment involved in
the related control activities.

Question 5.9.30
Do all control activities involve judgment?

Interpretive response: No. Many controls are binary and don’t involve
judgment – e.g. a three-way match process control activity compares objectively
determinable data elements among various source documents. But many other
control activities involve the control operator making decisions about what
constitutes an outlier or how to resolve an outlier.

Control activities may include a combination of control attributes, some involving

judgment and others not involving judgment.

In determining whether a control attribute involves judgment, it can be helpful to

consider whether:

• a simple automated control activity could perform the control attribute; or

• the control attribute requires a person to think and make decisions.
If a simple automated control activity could perform the control attribute, it is
unlikely that judgment is involved. But, if a control attribute requires a person to
think and make decisions, it likely involves judgment.

In addition, words like determines, evaluates and considers can indicate that the
control attribute involves judgment. Conversely, words like agrees, calculates or
validates may be indicators of control attributes that do not involve judgment.

Example 5.9.10
Identifying judgment in a control activity – margin
analysis
Scenario

Management has a manual process control activity over revenue and cost of
sales with the following control attributes.

Attribute 1: For each customer, the Assistant Controller agrees the total amount of
revenue and cost of sales for current year to date and prior year to date in the margin
analysis calculation spreadsheet to a report of revenue and cost of sales generated
from the ERP system.

Attribute 2: The Assistant Controller determines the criteria used in the control to
identify items for follow-up and investigation and concludes that an outlier will be
identified if there are changes in margin greater than 5% and $1 million per customer
or aggregate changes over $10 million.

Attribute 3: The Assistant Controller identifies all outliers meeting the criteria above.

Attribute 4: The Assistant Controller investigates all outliers and provides

explanations and supporting documentation for the variances.

Attribute 5: The Assistant Controller checks the mathematical accuracy of the margin
analysis spreadsheet.

Analysis

Attributes 2 and 4 involve judgment due to the subjectivity involved in executing

the attributes. Attributes 1, 3 and 5, all are simple tasks that could be performed
by a system. No judgment is required to complete them because they are not
subjective.

Example 5.9.20
Identifying judgment in a control activity – fixed asset
reconciliation
Scenario

Management has a manual process control activity over a fixed asset

reconciliation with the following control attributes.

Attribute 1: The Assistant Controller reconciles the fixed asset system subledger
report to the general ledger.

Attribute 2: The Assistant Controller agrees the CIP additions amount per the
reconciliation to the manual listing of CIP additions.

Attribute 3: The Assistant Controller evaluates the reconciling items for

reasonableness by assessing whether:

• each item on the manual listing of CIP additions was properly capitalized; and
• each item continues to represent CIP or was placed into service.

Analysis

Attributes 1 and 2 do not involve judgment as the criteria for investigation are
not subjective (i.e. the fixed asset subledger + CIP additions either agrees with
the general ledger balance or it does not). Attribute 3 involves judgment due to
the decisions made by the control operator in determining whether the identified
items were properly capitalized and represent CIP.

Question 5.9.40
Are there different considerations related to judgment
when the control activity is associated with an
estimate?
Interpretive response: No. However, estimates are often complex and involve
risks specific to each element of the estimate (i.e. the methods, assumptions
and data underlying the estimate). Therefore, multiple controls are often
necessary to address the risks associated with an estimate. Some of these
controls may involve judgment, and some may not.

5.10 Designing and documenting a control activity:

Precision

Question 5.10.10
What is precision in the context of a process control
activity?
Interpretive response: Precision is essentially the size of a potential
misstatement the control activity would prevent, or detect and correct on a
timely basis, when it operates effectively.

Considering a control activity's precision includes evaluating whether the control

activity is designed to operate at a 'would' level (see Question 5.3.20).

Question 5.10.20
Is precision considered for all process control activities?

Interpretive response: Yes. Precision is an important consideration for all

process control activities. The determination of precision involves evaluating the
factors in Question 5.10.30.

Question 5.10.30
What are the primary factors used in determining the
level of precision for a process control activity?
Interpretive response: The following are the primary factors used in
considering the level of precision for a process control activity.

• Level of aggregation. A process control activity performed at a more

granular level is generally more precise than one performed at a higher
level. For example, an analysis of revenue by location or product line is
more precise than an analysis of total entity revenue.

• Consistency of performance. A process control activity consistently and

routinely performed with predefined frequency is generally more precise
than one performed sporadically. In addition, a process control activity that
operates only over certain transactions or items (e.g. on a sample basis
(see section 5.16) or over transactions/items above a certain dollar value) is
less precise than a control that operates over the entire population due to
both the decreased frequency of the control’s operation as well as the risks
inherent in the population of transactions/items that are not subject to the
control. In this situation, management should assess the residual risk
inherent in the population not subject to the control and whether it may
represent a risk of material misstatement.

• Predictability of expectations. Some process control activities use Key

Performance Indicators (KPIs) or other information to develop expectations
about reported amounts. The precision of those process control activities
depends on the ability of the control operator to develop sufficiently precise
expectations to highlight potentially material misstatements.

• Criteria for investigation. The threshold for identifying and investigating

deviations or differences from expectations relative to materiality (or the
inherent imprecision of the estimate), indicates a process control activity’s
precision.

A control is deemed to be sufficiently precise when the operation of the control

would prevent, or detect and correct on a timely basis, a material misstatement.

Example 5.10.10
Determination of precision – review of purchases
Scenario

An entity’s materiality for the current year is $2 million. In response to a PRP,

the entity has a control in which the Purchasing Manager reviews and approves
all purchases over $1 million to ascertain that all purchases are for valid
business purposes and the amounts are accurate in that they are within $10,000
of the expected cost based on the Purchasing Manager’s knowledge and
previously approved purchase orders. As part of assessing the control’s design,
management notes a significant volume of purchases, the vast majority of which
are below $1 million.

Analysis

The following is an analysis of each of the factors used in determining the right
level of precision for a process control activity.

• Level of aggregation. The control is performed at the individual transaction

level, so there is no aggregation.

• Consistency of performance. The control is performed on each occurrence

over the threshold of $1 million. However, given that there are few
transactions above the threshold, there is a low frequency of occurrence for
the control. Overall consistency of performance is potentially lower due to
the decreased frequency and the high volume (and aggregate value) of
transactions not subject to the control in relation to the entity’s materiality.

• Predictability of expectations. The control does not involve developing

expectations.

• Criteria for investigation. Relative to materiality and the value of the

purchase transactions subject to the control activity, the control includes a
reasonably low threshold for identifying and investigating deviations.

Based on this analysis, the control may not be sufficiently precise to detect a
material misstatement because there is more than a remote chance that a
material misstatement exists, in the aggregate, in the population of purchases
not reviewed. This is due to the high threshold for the control’s operation in
relation to the assessed materiality, which results in a low frequency of
occurrence for the control and a large population of purchases not subject to the
control (both in terms of the volume of transactions and the aggregate dollar
amount).

Example 5.10.20
Determination of precision – purchase order price
comparison
Scenario

An entity’s materiality for the current year is $2 million. The entity begins using
an automated control activity to compare prices on all purchase orders to the
price master file. This check produces a report of every extended variance over
$10. A separate manual control activity requires the purchasing supervisor to
investigate all variances noted.

Analysis

The following is an analysis of each of the factors used in determining the right
level of precision for the manual process control activity related to the
purchasing supervisor’s investigation of the variances.

• Level of aggregation. The control is performed at the individual transaction

level, so there is no aggregation.

• Consistency of performance. There is a separate automated control that

compares all purchase orders with no threshold. This manual control is
performed on each variance over the threshold. There are multiple items a
day on the variance report, so there is a high frequency of occurrence
resulting in a higher consistency of performance.

• Predictability of expectations. The control does not involve developing

expectations.

• Criteria for investigation. There is a low threshold for identifying and

investigating deviations.

Based on this analysis, the control would likely be precise enough to address
the identified PRP due to the low threshold for investigation applied at the
individual transaction level. However, the volume of transactions and related
dollar amount of transactions not subject to the control (i.e. below the $10
variance threshold) should still be considered to determine if the criteria for
investigation is sufficiently precise.

Question 5.10.40
What if a process control activity is not sufficiently
precise?
Interpretive response: A process control activity does not sufficiently address
the risk(s), and therefore is deficient, when it:

• is not designed to operate with sufficient precision; or

• does not operate effectively with sufficient precision.

The precision of the process control activity should either be modified to a

sufficiently precise level, or a sufficiently precise compensating control should
be implemented.

Question 5.10.50
How is the development of expectations evidenced?

Interpretive response: The development of expectations is evidenced by

preparing sufficiently detailed documentation defining the related control
attribute, including what the expectations are and how they were developed. As
noted in Question 5.5.50, it is important that documentation of control attributes
be sufficiently detailed for the control operator to have a clear understanding of
what is expected of them in executing the control.

Example 5.10.30
Control attributes that involve expectations
Scenario

Management has documented the following process control activity:

Management reviews the revenue forecast used in the assessment of goodwill
impairment for a reporting unit, through performance of the following attributes:

Attribute 1: The control operator sets an expectation for Year 1 revenue growth
based on examining the following internal and external information:
• 3-year historical growth for the entity’s peer group;
• 12-month prospective growth forecast for the entity’s peer group (when available);
• industry analysts’ 12-month revenue forecast; and
• the internal sales group’s revenue goals by product line, and comparison of past
sales goals with actual sales results.

Attribute 2: The control operator sets an expectation for Years 2-5 revenue growth
based on the following internal and external information:
• 5-year historical entity-specific and industry-specific growth trends;
• the internal sales group’s revenue goals by product line; and
• comparison of past sales goals with actual sales results.

Attribute 3: The control operator compares the actual forecast for each of the periods
listed with the expectation and investigates outliers that differ by more than $10 million
or 1.5% of the expectation. Outliers are investigated and resolved with persuasive
supporting evidence or adjustment to the forecast.

Analysis

Attributes 1 and 2 are instances where a control attribute involves development

of expectations.

Attribute 3 covers both the identification of outliers based on the expectations

developed in Attributes 1 and 2, and the investigation and resolution of these
outliers. It is also common for these concepts to be split into two attributes, one
for the identification of outliers and another for the resolution of those outliers.

Question 5.10.60
What are criteria for investigation?

Interpretive response: Criteria for investigation are the thresholds or

characteristics used in the operation of the control activity to identify outliers, –
i.e. items that require further investigation and/or resolution (see Question
5.11.10).

For some control activities, there may be no threshold or characteristics applied

such that any difference identified is investigated and resolved. For other control
activities, there may be a pre-defined quantitative threshold, a variable
quantitative threshold, or qualitative characteristics that result in some, but not
all, differences being identified as outliers and then investigated and resolved.

The established criteria for investigation influence how precisely a control

activity is designed to operate.

Question 5.10.70
Why is it important to establish criteria for investigation
when designing a control activity?
Interpretive response: It is important to establish criteria for investigation
because, without established criteria, it is difficult to determine whether:

• the control is precise enough to prevent, or detect and correct on a timely

basis, a material misstatement;
• the control is performed consistently; and
• the control appropriately addresses the identified PRP(s).

Question 5.10.80
Are the criteria for investigation of a control activity
documented?
Interpretive response: Yes. The criteria for investigation should be clearly
documented for all control activities, regardless of whether judgment is involved.

The criteria for investigation are often not obvious in the control description.
When objective criteria for investigation have not been explicitly documented, it
is challenging for:

• a control operator to know how to execute the control activity; and

• those responsible for the entity’s monitoring activities (e.g. the internal audit
department) to understand whether the control activity is designed to
consistently operate at an appropriate level of precision to achieve the
control's objective – i.e. operate at the 'would' level.

Question 5.10.90
How are precision and criteria for investigation applied
in the operation of a control?
Interpretive response: All process control activities have precision. One of the
factors influencing precision is the criteria for investigation which can be pre-
defined or variable. The criteria for investigation should be applied consistently
each time the control is performed.

Control operators can choose to perform the process control activity at a higher
level of precision (i.e. lower threshold for investigation) than documented in the
design of the control. However, if they perform it at a higher threshold for
investigation (i.e. lower level of precision) than was determined by management
when designing the control activity, the control is no longer operating at the set
precision and there would be a control deficiency.

For example, a control over a bank reconciliation requires all differences greater
than $10,000 to be investigated (i.e. the set precision). However, the control
operator determines for one bank reconciliation that they want to investigate a
difference of $5,000. This would still be appropriate because it is less than the
predetermined threshold for investigation. However, if there is a difference of
$12,000 that is not investigated, the control activity would not be operating as
designed and there would be a control deficiency.

Question 5.10.100
What is a threshold?

Interpretive response: A threshold is the criteria that is used to identify items

that require further investigation. Thresholds can take a variety of forms but are
typically either quantitative or qualitative in nature (see Questions 5.10.110 and
5.10.130, respectively).

Question 5.10.110
What are quantitative thresholds?

Interpretive response: Quantitative thresholds are numerically defined, such

as by dollar amount (e.g. $10,000) or percentage (e.g. 5%). Quantitative
thresholds can be either ‘pre-defined’ or ‘variable’ in nature (see Question
5.10.120).

Question 5.10.120
What are ‘pre-defined’ and ‘variable’ quantitative
thresholds?
Interpretive response: A pre-defined quantitative threshold does not change
throughout the year and would be consistent during each instance of a control
activity’s performance. This threshold is typically based on a specific numerical
value or range, such as a percentage or dollar amount. For example, a pre-
defined quantitative threshold for accounts receivable may be set at 5% of total
revenue.

A variable quantitative threshold changes based on the circumstances of the

control’s performance. The control operator may need to set dynamic criteria for
a control to operate at the ‘would’ level of assurance. Adjustments to the
threshold may be in response to changes in external and internal factors – e.g.
the nature or subject matter of the control activity. For example, a variable
quantitative threshold for inventory may be set based on the demand for a
particular product or the time of year.

Whether predefined or variable, quantitative thresholds should be clearly

defined and documented in the control attributes.

Question 5.10.130
What are qualitative thresholds?

Interpretive response: A qualitative threshold is used to identify items for

investigation and does not involve a quantitative amount or percentage.

When a qualitative threshold is used, there is an expectation that it would outline

a range of acceptable differences to produce a ‘trigger point’ at which the control
operator would be required to investigate outliers. Qualitative thresholds need to
be ‘measurable’ – they need to be finite and reperformed by others. Example
5.10.40 provides examples of measurable qualitative thresholds.

Practical tip
When asked, control operators sometimes struggle to identify a specific
precision for the control activity that they execute, and state that precision is
based on differences that appear abnormal to them when exercising their
professional judgment and experience. While there can be variable precision,
the nature of that precision still needs to be specified.

When articulating the precision of a process control activity for purposes of

defining a control attribute, a control operator might consider asking themselves
questions such as the following.

• What is the smallest amount of a difference that I would investigate when

executing the control activity?
• What would trigger follow-up on an item included in my review?
Questions like these can help identify and articulate a quantitative or qualitative
precision for a control activity. For a qualitative precision, understanding what
specific attributes would be investigated and why, assists in defining the
precision. If there is no set precision, the process control activity likely does not
operate consistently and, therefore, is not appropriately designed.

Example 5.10.40
Qualitative thresholds
Process control activity description: The General Counsel (GC) evaluates
the following, all of which are included within a quarterly package prepared by
the legal finance team:

• a Claims Status Report (CSR) printed from the eCounsel database;

• the summary of the accrual for legal contingencies; and
• the disclosures associated with legal contingencies.

The following table lists the control attributes for this process control activity, all
of which involve a qualitative threshold. The qualitative thresholds are further
analyzed to explain the documentation that should be prepared by the GC to
capture how they applied the qualitative thresholds.

Control attribute Analysis

Attribute 1: The GC inspects detailed See analysis for Attributes 2 and 3 below.
support for each claim identified in the
CSR, including:
• information received from external
counsel;
• relevant case law or judgments; and
• legal opinions/letters used to support
ongoing judgments and estimates
regarding the claim (if applicable).

Control attribute Analysis

Attribute 2: The GC assesses the Evaluating the timeliness of the
relevance of the information inspected information likely involves a qualitative
(detailed support in Attribute 1) by: threshold that could depend on the type
• evaluating the timeliness of the of case. In their documentation, the GC
information; and specifies why a certain timeframe was
used to determine whether the CSR
• determining whether the information information was either ‘timely’ or
is relevant to the current claims in ‘untimely’.
the database (such as how closely
Evaluating the relevance of case law to
aligned case law is to the entity’s
current claims also involves a qualitative
cases).
threshold. In their documentation, the GC
specifies how they determined whether
particular case law is aligned with the
entity’s cases.
Attribute 3: The GC assesses the The evaluations performed all use a
reliability of the information inspected qualitative threshold. In their
(detailed support in Attribute 1) by documentation, the GC specifies or
evaluating: explains:
• the source of the information (e.g. a • how they determined that a law firm
reputable law firm); was considered reputable and
• the nature of the information (e.g. a reliable;
formal legal opinion is more reliable); • what type of information was
and received, and how it was assessed
• the complexity of the information. for reliability; and
• the complexity of the information and
its effect on the information’s
reliability.
Attribute 4: The GC evaluates the The GC’s evaluation of the estimated
estimated probability of an unfavorable probability of an unfavorable outcome
outcome and whether the range of uses a qualitative threshold. This
potential losses is estimable and evaluation requires careful analysis of the
appropriate, which includes assessing information supporting the claims. In their
any changes to the probability documentation, the GC supports their
determination or the estimated range of conclusion on the estimated probability
potential losses based on the latest by evaluating that probability against the
information available. supporting information.
The GC’s estimate of the range of
potential losses is often a qualitative
metric. In their documentation, the GC
supports their conclusion on the estimate
of the range of potential losses by
evaluating that range against the
qualitative information used in their
determination (from Attribute 1).

Question 5.10.140
What are management review controls and how is their
precision considered?
Interpretive response: Management review controls (MRCs) involve a member
of management or another employee reviewing information contained in
underlying documents, reports or other information produced by the entity to
reach or evaluate a conclusion affecting an entity’s financial reporting.

Information that management or another employee may review includes

variance reports, exception reports, detailed calculations supporting financial
statement balances or disclosures, and reports containing management
estimates or judgments. MRCs are generally control activities.

Overall, the design, documentation and operation of MRCs is no different than

that of other manual controls. However, when MRCs are being evaluated by
management or external auditors, it is often more difficult to obtain sufficient
evidence about their design and operating effectiveness compared to other
controls. This increased difficulty is attributable to the level of inherent judgment
and subjectivity exercised in performing MRCs. Additionally, because MRCs
often are used in more judgmental and complex areas that have the potential for
a higher RMM, more persuasive evidence is required to demonstrate the design
and operating effectiveness of the control.

The concept of precision is important for MRCs when considering the objective
of the control and the nature and types of potential misstatements the MRC is
intended to address. Without understanding the precision at which an MRC
functions, it is not possible to understand whether the control sufficiently
addresses the relevant financial reporting risks.

The adequacy of design, documentation and evaluation of MRCs has been

under significant regulatory scrutiny in recent years. The SEC staff has stated
that some MRCs might not be designed to operate at an appropriate level of
precision 4. The PCAOB has also highlighted significant auditing practice issues
in this area identified in its inspections of external audit firms, specifically as it
relates to assessing precision of MRCs 5. The SEC staff has stated that the
practice issues identified by the PCAOB may extend beyond audit execution in
that they may be indicative of underlying deficiencies in management’s controls
and assessments 6.

4
Brian Croteau, SEC Deputy Chief Accountant, Panel Discussion on Current Topics in ICFR
Before the 2015 AICPA National Conference on Current SEC and PCAOB Developments,
December 2015.
5
PCAOB Staff Audit Practice Alert No. 11, Considerations for Audits of Internal Control Over
Financial Reporting, October 2013.
6
James Schnurr, SEC Chief Accountant, Remarks Before the UCI Audit Committee Summit,
October 2015.

5.11 Designing and documenting a manual control

activity: Investigation and resolution

Question 5.11.10
What is an outlier?

Interpretive response: An outlier is an item that meets the criteria for

investigation established in the control activity’s design. Entities often define the
criteria for investigation based on items that fall outside a range of acceptable
differences from the expectations inherent in the control activity’s design.

Question 5.11.20
Is an outlier a misstatement?

Interpretive response: Not necessarily. Outliers do not necessarily lead to

misstatements. Rather, they trigger the control operator to perform further
investigation to:

• determine whether the outlier:

— is appropriate;
— is an error that needs correction; or
— otherwise indicates that the related account balance contains an error
that needs correction; and

• determine whether further information or activities are needed to resolve the

matter.

Question 5.11.30
How are outliers identified?

Interpretive response: Outliers are identified by appropriately applying the

established criteria for investigation (see Question 5.10.60 and Example
5.11.10).

Example 5.11.10
Fixed asset reconciliation – identification of outliers
Scenario

An entity has a control activity with the following as one of its control attributes:
The control operator investigates any differences between the fixed asset
subledger and the general ledger greater than $10,000.

During the operation of the control attribute, the control operator identified the
following.

$ Balance
Fixed asset subledger 1,140,000
General ledger 1,163,000
Difference (23,000)

Analysis

The control operator identifies the difference of ($23,000) as an outlier because

it exceeds the $10,000 threshold set in the design of the control attribute.

Question 5.11.40
Are all outliers investigated?

Interpretive response: Yes. All outliers are required to be investigated to

confirm whether they are appropriate, represent an error or otherwise indicate
that the related account balance contains an error. If the control operator does
not investigate all outliers, the control would not operate effectively.

Example 5.11.20
Fixed asset reconciliation – investigation of outliers
Scenario

This scenario is a continuation of Example 5.11.10.

Analysis

The control operator used the fixed asset subledger and the general ledger
detail to further understand and resolve the identified outlier. The control
operator noted the following.

Fixed asset
$ subledger General ledger
Balance, March 31, 20X1 1,000,000 1,000,000
Additions: IT equipment - 23,000
Additions: Machinery 140,000 140,000
1,140,000 1,163,000

During the control operator’s investigation, they identified that the IT equipment
had not been added to the fixed asset subledger. The control operator
evaluated whether the IT equipment had been appropriately recorded to the
general ledger by obtaining the associated purchase invoices.

Question 5.11.50
Are all outliers resolved?

Interpretive response: Yes. All outliers must be resolved by concluding

whether each outlier is either appropriate or an error.

Example 5.11.30
Fixed asset reconciliation – resolution of outliers
Scenario

This scenario is a continuation of Example 5.11.20.

Analysis

Based on their investigation, the control operator determined that the IT

equipment was appropriately recorded to the general ledger in the correct
period. As a result, the control operator updated the fixed asset subledger to
include the additions of IT equipment during the period.

After updating the fixed asset subledger, the control operator re-ran both the
fixed asset subledger and the general ledger. A comparison of the two produced
an exact match of $1,163,000. As a result, the control operator determined that
further investigation was not required.

Question 5.11.60
What should be documented related to the identification
and resolution of outliers?
Interpretive response: Sufficient documentation should be maintained by the
control operator to evidence:

• the criteria for investigation in the performance of the control;

• the outliers that were identified in applying the criteria for investigation to the
population of items subject to the control; and
• how the outliers were resolved.

Documentation of how outliers were resolved should include evidence of follow-

up actions taken by the control operator and the conclusions reached related to
each outlier, including whether potential misstatements were appropriately
investigated and whether corrective actions were taken as needed.

Practical tip
Sometimes management’s familiarity with the control and the related business
process may unintentionally result in their preparation of limited documentation
related to the identification and resolution of outliers. Management should guard
against this result by carefully considering and being mindful of the external
auditors’ requirement under relevant professional standards to gather sufficient,
appropriate evidence of the design and operating effectiveness of control
activities. While management’s documentation might be viewed as sufficient for
their own assessment of ICFR, consideration should be given to whether
sufficiently detailed documentation exists for an external auditor to conclude on
the design and operating effectiveness of management’s control activities.

Question 5.11.70
What if no outliers are identified in the performance of a
control activity?
Interpretive response: Depending on the level of aggregation of a control
activity, there may be differing amounts of outliers identified. Some control
activities, such as those performed at a transaction level, may identify many
outliers on a regular basis. Other controls, such as those performed at the
financial statement caption level, may rarely identify outliers.

When a control operator performs a control activity that rarely (or never)
identifies any outliers, they, along with management, should first evaluate:

• whether the control operator appropriately performed the control; and

• whether any outliers should have been identified (e.g. the control operator is
aware of a change in the business that should have been identified as part
of the performance of the control but was not).

Next, the control operator, along with management, should consider if the
control activity is designed effectively with a sufficient precision to prevent, or
detect and correct, a material misstatement in a timely manner related to the
PRP it is intended to address.

Careful consideration should be given when no outliers are identified because

this may indicate that the control activity is not designed at the appropriate level
of precision and, therefore, is deficient.

Practical tip
In instances where a control activity operates, but does not identify any outliers,
contemporaneous documentation of the control’s operation should be prepared,
including what criteria for investigation have been applied and how they have
been applied. This documentation supports the control operating as designed,
which is needed when a third party (such as internal or external auditors) is
assessing the effectiveness of the entity’s ICFR. Absent this documentation,
when no outliers are identified, no evidence exists to support the control
operating at a ‘would’ level of precision.

Like with other factors, appropriate documentation also assists future control
operators in determining how to identify and handle outliers by understanding
the full design and operation of the control.

5.12 Designing and documenting a manual process

control activity: Information
Chapter 6 covers the identification and evaluation of information used in the
performance of a control activity.

5.13 Controls responding to a fraud risk

Question 5.13.10
Is it necessary to design control activities to address
fraud risks?
Interpretive response: Yes. When a fraud risk has been identified by the entity
that creates a reasonable possibility of a material misstatement of the financial
statements, the entity should design a control activity to address that risk.

Principle 8 of the COSO Framework requires organizations to consider the

potential for fraud in assessing risks to the achievement of objectives (see
Question 2.5.120). Principle 8 identifies four types of fraud that require
consideration:

• misappropriation of assets;
• fraudulent financial reporting;
• corruption and other illegal acts; and
• management override of controls (see Question 5.14.40).

The SEC has stated the following in SEC Release No. 33-8810: “Management
should recognize that the risk of material misstatement due to fraud ordinarily
exists in any organization, regardless of size or type, and it may vary by specific
location or segment and by an individual reporting element.”

While the design and implementation of controls over fraud risks should
consider all the previous guidance provided in this chapter, there are additional
considerations when management is designing a controls response to fraud
risks and operating the related controls. These considerations are discussed in
the following questions. See Appendix B for example fraud risk factors.

Question 5.13.20
What is an anti-fraud control?

Interpretive response: An anti-fraud control is:

• a process control activity that directly addresses an identified risk of fraud at

the assertion level or financial statement level; or

• an entity-level control (see section 2.3) that supports the effective

functioning of process control activities that directly address an identified
risk of fraud.

Anti-fraud controls should be designed to:

• mitigate incentives for, and pressures on, management to falsify or

inappropriately manage financial results;

• prevent, deter and detect fraud (e.g. controls to promote a culture of

honesty and ethical behavior); and

• mitigate specific risks of fraud (e.g. process control activities to address

risks of intentional misstatement of specific accounts or misappropriation of
assets such as cash or inventories).

Question 5.13.30
What activities generally require anti-fraud controls?

Interpretive response: Anti-fraud controls are often necessary in the following

scenarios:

• significant unusual transactions, particularly those that result in late or

unusual journal entries;

• the period-end financial reporting process, including posting of non-standard

journal entries and adjustments;

• transactions with related parties, including significant related party

transactions outside the entity's normal course of business; and

• accounting estimates that give rise to increased risks of material

misstatement due to their complexity, subjectivity and estimation
uncertainty.

Question 5.13.40
What are control activities that address the risk of
misappropriation of assets?
Interpretive response: Control activities that address the risk of
misappropriation of assets are also referred to as control activities over the
safeguarding of assets. Management puts these control activities in place to
prevent or detect the unauthorized acquisition, use or disposition of assets that
could result in a material misstatement to the financial statements. When PRPs
are identified related to such unauthorized activity, management should identify
the process control activities that mitigate those PRPs (see Example 3.2.10 for
example risks related to safeguarding of assets).

Common examples of control activities over the safeguarding of assets include:

• segregating duties;
• comparing the results of physical cash, security and inventory counts with
accounting records on a periodic basis;
• enforcing appropriate management approval before an employee executes
a contract that binds the entity to certain obligations; and
• enforcing appropriate authorization for access to computer programs and
data files.

Safeguarding control activities do not physically protect assets or prevent bad

business decisions. Their objective is to mitigate RMMs due to the
misappropriation of assets.

5.14 Controls responding to a risk related to journal

entries and other adjustments

Question 5.14.10
How are risks related to journal entries and other
adjustments considered when designing control
activities?
Interpretive response: Due to the different types of journal entries and other
adjustments (e.g. on-top (i.e. topside) and post-close adjustments), there are
various types of related risks (as discussed in Question 4.7.30) that
management should address through appropriately designed control activities.

Often a combination or suite of process control activities working together is

necessary to address the PRPs related to journal entries and other adjustments.
For example, there may be a process control activity involving the independent
review and approval of manual journal entries and supporting documentation
before the entry is recorded in the system. This process control activity is
generally designed to address the existence and accuracy of the transaction

recorded through the journal entry. However, because of the risk of

management override of this control, it is generally necessary to have a
separate process control activity that verifies that all entries that were posted
were in fact subject to the upfront review and approval control.

The general risks related to journal entries and other adjustments are the
following.

• All journal entries and other adjustments that should have been recorded
were not recorded (completeness).

• Journal entries and other adjustments recorded do not represent a true

transaction of the entity or have not been recorded accurately to appropriate
accounts (existence and accuracy).

• Management may override controls through posting of journal entries and

other adjustments (fraud risk).

While the design and implementation of controls related to journal entries and
other adjustments should consider all the previous guidance provided in this
chapter, there are additional considerations when management is designing a
control to respond to risks involving journal entries and other adjustments and
operating the related control activities. These considerations are discussed in
the following questions.

Question 5.14.20
What types of control activities can address the risk of
completeness associated with journal entries and other
adjustments?
Interpretive response: Completeness of journal entries and other adjustments
is generally addressed through various control activities involved in the period-
end financial close and reporting process. These control activities are often
designed to mitigate the risk that journal entries and other adjustments that
should have been recorded were not recorded. Examples of such control
activities include:

• completion of a closing procedural checklist designed to determine that all

appropriate journal entries and other adjustments have been recorded;

• comparison of reports summarizing all manual journal entries posted during

the period to a list of standard manual journal entries required for each
reporting period; and

• verification that there are no ‘pending’ or unposted entries in the system

when review and approval controls over journal entries are automated.

Account reconciliation process control activities demonstrate that the detailed

subledger account (or other data source) reconciles with the general ledger
control account. However, the effectiveness of these process control activities to
address the completeness of journal entries and other adjustments is dependent

on the precision of the control activity and the nature and magnitude of accounts
subject to the control.

Question 5.14.30
What types of control activities can address the risk of
existence and accuracy associated with journal entries
and other adjustments?
Interpretive response: In most instances, a mix of both manual and automated
controls should be used to address the PRPs related to the existence and
accuracy of journal entries and other adjustments. The factors discussed in
Question 5.6.50 should be considered when determining the appropriate nature
of the controls to design and implement.

The following table includes examples of automated and manual controls that
can address the risk of existence and accuracy associated with journal entries
and other adjustments. Automated control activities would also require relevant
GITCs to support their effective operation.

Automated control activities Manual control activities

• Control activities over the interface • Reconciliation between subledger
between subledger systems and the systems and the general ledger.
general ledger. • Review and approval of the manual
• Configuration control activities journal entry and supporting
preventing modifications to journal documentation by an appropriately
entries after posting or requiring re- knowledgeable supervisor
approval if modified. independent of the preparer to
• Configuration control activities validate the existence of the
preventing journal entries from transaction and the accuracy of
posting without approval from a dollar amounts, general ledger
separate party. accounts and accounting period.

• Configuration control activities to • Review and approval of other

provide completeness and accuracy adjustments included on an
checks over the number of journal adjustment schedule and the related
entries, the dollar amounts and supporting documentation by an
relevant general ledger accounts. appropriately knowledgeable
supervisor independent of the
• Configuration control activities preparer to validate the existence of
preventing a manual journal entry the underlying transaction or activity
from being posted if it is out of and the accuracy of dollar amounts,
balance (i.e. debits do not equal general ledger accounts and
credits), includes invalid account accounting period.
numbers or is coded to a closed or
future accounting period.

Practical tip
When the review of a manual journal entry is intended to address the existence
and accuracy of the amounts being recorded to the general ledger, then the

review needs to also evaluate the completeness and accuracy of the underlying
information supporting the journal entry.

Question 5.14.40
What is the risk of management override of controls?

Interpretive response: The risk of management override of controls relates to

the risk that internal controls that otherwise appear to be well-designed and
effective may be overridden by management. Because management is in a
unique position to perpetrate fraud due to their ability to manipulate accounting
records directly or indirectly, the risk of management override of controls is
considered in any control environment.

Examples of how management may override controls include:

• creating, or instructing an employee to record, fictitious manual journal

entries to circumvent the regular process for approving and recording
journal entries or other adjustments;

• applying bias when making estimates and judgments; and

• accounting for significant unusual transactions in a manner inconsistent with

their substance and/or the requirements of the applicable financial reporting
framework.

Question 5.14.50
How is the risk of management override addressed?

Interpretive response: As part of the design of an effective system of internal

control, management should consider the risk of management override and
design and implement controls that:

• are performed by control operators who are not subject to management

influence;

• include appropriate segregation of duties to reduce opportunities for an

individual within the organization to both perpetrate and conceal fraud;
and/or

• prevent or detect the recording of inappropriate journal entries and other

adjustments.

Question 5.14.60
What types of control activities can address the risk of
management override associated with journal entries
and other adjustments?
Interpretive response: The risk of management override of controls generally
is associated with manual journal entries and other adjustments. This risk is
usually not sufficiently covered through the controls over the existence and
accuracy of journal entries and other adjustments and needs to be addressed
separately.

Examples of anti-fraud process control activities that may be designed and

implemented by an entity, as part of a suite of controls, to address the risk of
management override of controls through the recording of inappropriate journal
entries and other adjustments include:

• a separate manual journal entry control where the control operator, who is
independent from the journal entry process, validates the following for the
population of all recorded manual journal entries:
— each journal entry was reviewed and approved by an appropriate
approver;
— the amounts recorded in the general ledger and the accounts in which
they were recorded, among other key data elements of the journal entry,
agree to what was initially approved; and
— there is a valid business purpose for the journal entry;

• a separate control over other adjustments where the control operator, who
is independent from the other adjustments process, validates the following
for the population of all other adjustments:
— each other adjustment was reviewed and approved by an appropriate
approver;
— the amounts and impacted accounts, among other key data elements of
the other adjustment, agree to what was initially approved; and
— there is a valid business purpose for the other adjustment;

• an automated control that prevents executive management from

independently initiating, authorizing or recording journal entries or other
adjustments within the IT system;

• an automated control that prevents users from independently initiating,

authorizing and recording journal entries or other adjustments within the IT
system without approval from a separate party;

• automated control activities that prevent changes, or require re-approval

when changes are made, to relevant information before or after a journal
entry or other adjustment has been posted, such as changes in the identity
of the user that created or posted a journal entry or other adjustment, or
account; and

• other indirect control activities, such as account reconciliation controls or

analytical reviews of posted journal entries for trends or unusual or high-risk
entries, or monitoring controls.

Practical tip
Recall the importance of implementing and operating controls to address the
relevance and reliability (completeness and accuracy) of information used in
controls. The same considerations apply to information used in controls over
journal entries and other adjustments (e.g. reports or listings of all recorded
manual journal entries and other adjustments). Also recall that for automated
controls to be relied on throughout the period, related general IT controls that
support their continued and consistent operation are required.

Question 5.14.70
Can other indirect control activities address journal
entry risks?
Interpretive response: It depends. Other indirect types of journal entry
controls, such as account reconciliations or analytical reviews of posted journal
entries for trends or unusual or high-risk entries, are commonly insufficient on
their own to address risks related to journal entries but may be effective when
operated together with other controls.

These controls may function together with other controls as part of a suite of
controls in place to address the risk of management override of controls in
certain circumstances. If management is planning to rely on other indirect
control activities, careful consideration is needed as it may be difficult to
conclude such controls operate at a ‘would’ level of precision (see Question
5.3.20) to address the related risks, given they are not performed over each
instance of a relevant activity within the process.

Management may consider the following questions to evaluate whether these

other indirect control activities respond to the risk of management override of
controls.

• Do account reconciliation controls cover the relevant balance sheet and

income statement accounts and validate those reconciliations were
performed completely and accurately for the period?

• When and by whom are account reconciliation controls performed? For

example, are they performed by individuals whose duties are appropriately
segregated from the journal entry process, and are they performed after the
control activities at the process level have been completed, but before the
financial information is reported?

• Is the objective of the account reconciliation control to validate that the

balance includes only activity that derives from appropriately controlled
business processes? For example, is the balance reconciled to the output of
the related process-level controls pertaining to the account?

• Is the precision of the reconciliation control sufficient to prevent, or detect

and correct on a timely basis, a material misstatement? For example, is the
dollar threshold below which reconciling items require no further evaluation
sufficiently precise when considering aggregation over time and across
accounts?

• If any adjustments are made resulting from the account reconciliation

controls, are these subject to appropriate review and approval?

• When executing an analytical review of posted journal entries, are the

criteria for what constitutes a journal entry requiring further review clearly
defined? Has management performed sufficient analysis to conclude that
the other posted journal entries are not ‘high-risk,’ individually or in the
aggregate?

• Is information used in the analytical review or other monitoring controls

complete and are specific data elements used in the control deemed to be
accurate through the effective operation of other controls?

• Where certain accounts or portions of the journal entry population are not
subject to review, has management evaluated and concluded on the level of
risk present in this remaining population? For example, when the controls
involve sampling or a dollar threshold over which journal entries are
reviewed, management should consider the remaining population and
evaluate whether the risk in this population has been sufficiently reduced via
monitoring and/or other controls.

5.15 Controls responding to going concern, significant

unusual transactions, and related parties

Question 5.15.10
Are there special considerations for control activities
over the risk related to an entity’s ability to continue as
a going concern?
Interpretive response: Yes. As part of the risk assessment process,
management’s assessment of going concern may lead to the determination that
there is an RMM related to either:

• an inappropriate conclusion on the entity’s ability to continue as a going

concern; or
• inadequate financial statement disclosures related to the entity’s ability to
continue as a going concern.

If either of those RMMs is present, appropriate process control activities must

be designed and implemented to address the related PRPs. Question 3.2.40
discusses risk assessment related to an entity’s ability to continue as a going
concern.

While the design and implementation of controls over going concern should
consider all the previous guidance provided in this chapter, there may be
additional considerations when management is designing a controls response to
going concern risks and operating the related control activities.

Specifically, proper control activities should be designed and implemented

related to the entity’s going concern assessment, including:

• the completeness of events and conditions identified that may raise

substantial doubt;

• the preparation of forecasts of the entity’s financial condition and liquidity (or
the effect on those forecasts of plans to mitigate the conditions and events
that give rise to a going concern uncertainty);

• the reasonableness of assumptions used in the forecasts;

• the completeness and accuracy of information used; and

• the appropriateness of relevant disclosures.

Because of the considerations likely involved in the going concern assessment,

the related control activities may include control attributes that require judgment
(see section 5.9). In addition, because some of the control activities related to
the entity’s going concern assessment may operate with a low frequency
(annually or less frequently if risks of material misstatement related to the
entity’s going concern assessment are not identified in a given period),
management should confirm the design of the controls is appropriate in the
specific circumstances of the entity and its going concern assessment. In
addition, operators of these control activities may lack experience with their
execution or subject matter. Therefore, additional and timely monitoring
procedures over the design and operation of these controls may be necessary.

Related to process control activities over preparation and use of forecasts of the
entity’s financial condition and liquidity, management may be able to leverage
existing processes and control activities over projected financial information
used in other areas of its financial reporting.

Practical tip
Management should have control activities in place each period in which a risk
related to the going concern assessment is identified through management’s
risk assessment. However, the nature, extent, and precision of the control
activities should reflect the significance of the risk identified. As with any other
control activities, management should consider the objective (i.e. PRPs being
addressed) and the required precision when designing the control(s).

Question 5.15.20
What are significant unusual transactions?

Interpretive response: A significant unusual transaction (SUT) is a significant

transaction that is outside the normal course of business for the entity or that
otherwise appears to be unusual due to its timing, size, or nature.

Examples of significant unusual transactions include:

• business combinations executed by an entity that is not regularly

acquisitive;
• issuance of debt, or refinancing of existing debt, under a new vehicle or
agreement with terms not typical to the entity;
• a long-lived asset impairment trigger within an entity that does not regularly
have such triggers;
• restructuring charges; and
• unusual sales transactions (e.g. large one-off sales contracts with terms that
differ from normal sales).

Question 5.15.30
What kind of controls over SUTs does management
need to have in place?
Interpretive response: While SUTs may not occur in every reporting period,
management should have controls in place to timely identify SUTs when they
occur. Monitoring for and identification of SUTs are usually elements of the
entity’s risk assessment process (see chapter 3).

However, certain process control activities may also identify the existence of
SUTs. Examples include controls where management reviews and approves:

• arrangements/transactions with third parties above a certain amount defined

in the entity’s policies;

• arrangements/transactions with related parties above a certain amount

defined in the entity’s policies;

• arrangements/transactions for which key terms and conditions are

inconsistent with entity policies (e.g. modified credit terms, atypical liability
terms);

• arrangements/transactions with regulators or counterparties to settle

claims/litigation;

• arrangements/transactions that include options, embedded derivatives, or

other similar features; and

• cross-border intercompany arrangements/transactions subject to transfer

pricing rules.

Once a SUT has been identified, management should identify and assess the
RMMs and PRPs related to the SUT and design specific process control
activities to respond to those risks, considering all the previous guidance
provided in this chapter.

Question 5.15.40
Why are there special considerations for controls
related to SUTs?
Interpretive response: Given the unique nature, size, and complexity of SUTs,
they often present a higher RMM to the entity’s financial statements. This is
because there may be:

• incentives for management to conclude on a specific accounting treatment;

• greater manual intervention for data collection and processing;
• complex calculations or accounting principles;
• difficulty in implementing effective processes to account for the transactions
(due to their nonroutine nature); and/or
• related party involvement.

In addition, the processes and process control activities for an individual SUT
are often not part of the entity’s historical or ongoing operations. If the entity
does not have an instance of a SUT during a year, the related process control
activities will remain dormant and there will be no instance for which to evaluate
the operating effectiveness of the controls. This may increase the risk that the
process control activities will not operate as designed, or that the design of the
controls will no longer be adequate, when a SUT does take place and needs to
be accounted for and reported by the entity. Furthermore, because of the unique
nature of many SUTs, entities often design and implement new process control
activities to respond to the risks related to these transactions. These new
process control activities often have higher risks associated with their operating
effectiveness because they do not have a consistent history of performance or
because they will be performed by control operators who are not as experienced
with the risks related to the SUT. Therefore, additional and timely monitoring
over the process control activities related to SUTs may be necessary.

Question 5.15.50
Are there special considerations for controls over
related party relationships and transactions?
Interpretive response: Yes. Management is required to have controls in place
over the identification of relationships that result in related parties as well as
transactions with the identified related parties. If there are risks identified related
to transactions with related parties, management should design and implement
process control activities to address those risks.

Furthermore, if management has made an assertion in the financial statements

that a transaction with a related party was conducted at ‘arm’s length’ (see
Questions 5.15.70 and 5.15.80), a process control activity should be designed
and implemented to address the risk that an assertion of arm’s length is not
appropriate.

Question 5.15.60
What are examples of controls that may be in place to
address the completeness of related parties?
Interpretive response: The following are examples of controls that may be in
place to address the completeness of related parties.

• Quarterly review for completeness of the listing of related parties that is

maintained by the entity’s legal department by tying back to source
documentation, which includes director and officer questionnaires and new
transactions executed during the period with entities or persons that were
identified as related parties.

• A comparison of the related party transactions is performed year-over-year

and fluctuations over a set amount are investigated.

• Annually, management performs a data search for the names of related

parties within the sales and expense populations to identify related party
transactions.

Question 5.15.70
When management asserts a transaction occurred at
arm’s length, what terms of the transaction is that
assertion referring to?
Interpretive response: Without disclosure to the contrary, there is a general
presumption that related party transactions are not consummated at arm’s
length because the requisite conditions of competitive, free-market dealings
may not exist. However, when management makes an assertion that a
transaction was conducted at terms equivalent to those prevailing in an arm's-
length transaction, they are asserting that all the terms of the transaction are at
arm's length, not just the price. This includes credit terms, contingencies,
warranties, etc.

Question 5.15.80
What controls can management design and operate to
address the risk of an inappropriate assertion that a
related party transaction is at arm’s length?
Interpretive response: Management may design and operate controls that
provide the following evidence:

• other similar or identical transactions conducted by management between

the entity and unrelated parties with identical terms;

• a report from management’s specialist that has evaluated or determined a

market value for the transaction and shows the transaction’s terms are
consistent with that market value; and

• other similar transactions conducted outside the entity by other parties in an

open market with identical terms.

It may be difficult for management to substantiate their arm's length assertion of

the transaction's terms unless the entity routinely engages in similar
transactions with unrelated entities. This difficulty does not negate the need for
substantiation.

5.16 Controls executed on a sample basis

Question 5.16.10
Can controls be designed to be executed on a sample
basis?
Interpretive response: Using a sampling technique in the design and execution
of controls may be acceptable. Although the use of sampling is not specifically
discussed in the COSO Framework, the approach is not explicitly prohibited.

The COSO Framework requires management to use judgment in designing,

implementing, and executing internal controls, based on the results of their
thorough risk assessment process to respond to identified and assessed RMMs.
Such risk assessment may lead management to conclude that certain controls
designed and implemented to be operated on a sample basis can respond
effectively to an identified risk. However, these instances are expected to be
rare and require careful consideration by management.

Practical tip
If management is planning to rely on a control activity that operates on a sample
basis to address a PRP, it is recommended to discuss the use of sampling with
the external auditors before implementation to ensure agreement that sampling
is appropriate. It may be difficult to conclude that a sampling process control
activity operates at a ‘would’ level of precision (see Question 5.3.20) to address

the PRP(s), given it is not performed over each instance of a relevant activity
within the process.

Question 5.16.20
When might it be appropriate to design controls to
operate on a sample basis?
Interpretive response: Generally, sampling in controls should be limited to
lower risk areas due to sampling risk. Sampling risk is the risk of reaching an
incorrect conclusion because the conclusion reached based on a sample may
be different than if the same procedures were applied to 100% of the population.
Management should support their risk assessment and the sampling approach
used in controls with robust documentation that considers the following:

• Whether the control that operates on a sample basis is monitoring the

effectiveness of other controls or is the primary response to an
identified PRP. Sampling is often more supportable when it is used in
controls that monitor the effectiveness of other control activities. For
example, management may design a control to count inventory on a sample
basis because that control is monitoring the design and operating
effectiveness of controls over inventory movements recorded in the
perpetual inventory listing.

• Nature of the process. When the processes are complex, not routine,
contain historical errors or control deficiencies, it may not be appropriate to
consider sampling in the design of controls. For example, management may
determine that sampling is inappropriate in processes that contain critical
accounting policies or processes where one or more deficiencies were
identified in the current and/or prior years. Overall, sampling is most
effective when errors are not expected to exist in the population. When a
sampling approach is used and exceptions are identified, management
generally either reconsiders whether a sampling approach is appropriate or
extrapolates the errors identified.

• Residual population. By nature, sampling is defined by drawing

conclusions about an entire population by testing only selected items from
that population. Sampling is most appropriate when the sample selection
subject to the control is:
— highly representative of a homogenous set of transactions; or
— designed such that enough of the population is covered and a
reasonable conclusion can be drawn that there is a remote risk of
material misstatement in the residual population.

• Risk of error associated with the account or disclosure addressed by

the control. As mentioned earlier, sampling in controls should be limited to
lower risk areas.

• Competence of the control operator. In general, sampling in controls

should be limited to areas where the control operator has demonstrated
competence.

• Nature of the control. When the control is complex or involves significant

judgments, it may be inappropriate to consider sampling in the design of the
control.

• Nature of the transactions. Transactions that are subject to the control

that operates on a sample basis should be more routine in nature. For
example, transactions that result from complex calculations often have
multiple inputs, each of which may present a possibility for error. Verification
checks, binary confirmations or simple calculations with fewer inputs may
have a lower chance of error and therefore may lend themselves to a
sampling approach. Additionally, the population of transactions subject to
the control would ordinarily be expected to have a consistent risk profile
such that they are initiated, authorized, processed and recorded in the same
manner.

Example 5.16.10
Evaluating whether a control that operates on a sample
basis is appropriate for an inventory count
Scenario

An entity has determined existence of inventory represents a low inherent risk of

error and the nature of the population of inventory is homogenous. In addition,
there are process control activities over the receipt and sale of inventory.

Analysis

Management has concluded a manual process control activity that operates

over a sample of inventory items – a cycle count instead of a full year-end
inventory count – sufficiently addresses the identified PRPs because:

• the cycle count process control activity is monitoring the effectiveness of the
other process control activities; and
• the sample selection and results are representative of a full inventory count.

Question 5.16.30
What method is used to select the sample size to be
used in a control?
Interpretive response: It depends on the facts and circumstances. However, in
all cases, sampling should provide a basis for extrapolating results to the entire
population from which the sample was selected.

Management should have a well-documented basis for their sampling

methodology and strategy, including determination of the size of the sample to

be used in a control’s operation. Setting a sample size of a certain number of

items with little to no documented basis is inappropriate.

Practical tip
When using a sampling method, management is responsible for understanding
and establishing the parameters, assumptions and sampling method used to
determine and select the sample.

Question 5.16.40
What other factors should management consider when
designing a control that operates on a sample basis?
Interpretive response: Management should consider the following additional
factors when designing controls that operate on a sample basis.

• Whether the population to be sampled is complete. For example, tying

the population total back to the general ledger.

• The characteristics of the population to be sampled. The population’s

characteristics are important in determining whether it is suitable for
sampling, and the characteristics may affect how the sample is designed.
Management may consider the following questions to understand the
population’s characteristics:
— Are there positive and negative or zero-value items present?
— Is the population spread across multiple locations?
— Are there groups or sub-populations within the population that have
different risk characteristics?

Consistency of risk profile is important in evaluating the population, which

may be divided into multiple sub-populations or strata based on similar
characteristics. It is critical that management assess the homogeneity within
the separate sub-populations to conclude that one transaction is
representative of the population subject to sampling.

• Definition of an error. A clear understanding of what constitutes an

exception helps to focus on the relevant conditions. For example,
management designs a control for warehouse personnel to compare a bill of
lading to a pick list generated by the entity’s sales system to verify customer
name, SKU number and order quantity. The objective of the control is the
existence and accuracy of the sale and shipping information. Discrepancies
in payment terms or collectability would not be considered exceptions for
this specific control and would be addressed by other controls in the sales
and receivables process, as applicable.

• Relationship between the objective of the control and the sample

selected. Using the bill of lading and pick list comparison example above,
because the objective of the control is the existence and accuracy of the
sale and shipping information, management would likely select samples
from the population of sales invoices, because they presumably would have

an associated pick list and bill of lading. Conversely, management would not
select samples from a population of customer payments because they may
not be directly associated with individual sales and shipments.

Question 5.16.50
Can a sampling control be used to address
completeness?
Interpretive response: No. A control that operates on a sample basis is
inappropriate to address a PRP regarding completeness. If a PRP regarding
completeness is identified, additional process control activities would need to be
designed and implemented to address this PRP.

5.17 Considerations when there are changes to

controls

Question 5.17.10
What is considered a change in a control?

Interpretive response: A change in a control includes changes to:

• how the control attributes address the objective of the control;

• the nature or type of the control;
• the frequency of the control’s performance;
• the precision with which the control operates;
• the investigation and resolution process for outliers identified in operating
the control; and
• the information used in the performance of the control.

Question 5.17.20
What is the impact of a change in a control?

Interpretive response: When there have been changes to a control, including

those listed in Question 5.17.10, they can affect the control’s ability to address
the objective(s) of the control (i.e. prevent or detect a material misstatement).
This could result in a control deficiency and/or the need to identify other
compensating controls.

Practical tip
When any of the changes listed in Question 5.17.10 occur, the control is
considered a ‘different control’. Therefore, as part of an ICFR assessment,
management should consider testing both the old and new versions of the
control separately in performing their assessment of the effectiveness of ICFR.

Question 5.17.30
What are the impacts of a change in the control
operator?
Interpretive response: A change in the control operator may not directly affect
the design of the control, but if the new control operator does not have the
authority and competence to perform the control, the change could result in the
control not being appropriately performed.

The following table provides common pitfalls and related best practices when
there is a change in the control operator.

Common pitfalls Best practices

• The new control operator changes • There is a process in place to
the attributes or precision of the transition the control to the new
control such that they no longer control operator before the former
address the risk. control operator stops performing the
control.
• Management maintains and makes
available to the control operator
documentation of how controls
operate, including their precision,
frequency, attributes, timing, and
documentation.

• The new control operator forgets to • There is a process in place where

perform the control (or is unaware of Internal Audit reviews the control’s
the control). first performance after a change in
• The new control operator uses a the control operator to identify and
different report to perform the control remediate any issues identified on a
without considering the relevance timely basis.
and reliability of the information (see
chapter 6).
• The new control operator does not
maintain sufficient evidence of
performance of the control.
• The new control operator does not
have the authority or competency to
operate the control.

• The new control operator has • Management evaluates the nature of

sufficient competence in the the information necessary for the
underlying subject matter of the control operator to perform the
control but lacks sufficient knowledge control and has procedures in place

Common pitfalls Best practices

of the entity to be able to properly to share that information with the
identify all expected outliers. new control operator.

Question 5.17.40
Does a change in the PRP addressed by a process
control activity require a change in the control?
Interpretive response: It depends. Controls are generally designed to address
certain objectives. If the risk has changed to where the process control activity,
as currently designed, no longer addresses the PRP, the control needs to be
modified.

A change in the process or a change in the PRP could necessitate a change in

the process control activity.

Risk assessment (materiality and scoping of

accounts) Change in scope
Chapter 3

Process understanding (identification of systems

and risk points) Change in process
Chapter 4

Controls implemented to address risk points

Change in control (automated, manual, service organization)
Chapter 5

Controls implemented over information utilized in

Change in controls
information used Chapter 6

GITCs over systems utilized in controls

Chapter 7

See section 3.7 for guidance on changes in risk assessment.

Practical tip
Failing to adequately respond to changes in the entity’s ICFR is often a root
cause of identified deficiencies. Open communication between upper
management and control operators is important to identify and manage changes
to the ICFR process to ensure risks (and changes to those risks) are properly
identified and addressed by controls that would prevent or detect material
misstatements.

5.18 Monitoring procedures over process control

activities

Question 5.18.10
Is testing of process control activities performed as part
of monitoring procedures?
Interpretive response: It depends. Management has several different ways
they can obtain the evidence necessary to support their assessment of
effectiveness of ICFR (see section 2.7).

However, if management has determined, as part of their monitoring strategy, to

direct test controls, their testing may include entity-level controls (see chapter
2), process control activities (this chapter) and GITCs (see chapter 7). If the
entity has an internal audit function, it typically assists in management’s direct
testing of internal controls.

Practical tip
Management is required to support its assessment of ICFR with direct evidence
of the effectiveness of controls. A control’s effectiveness cannot be inferred from
the absence of misstatements detected by management or any related internal
or external audit procedures. Accordingly, developing an appropriate testing
plan to accumulate the evidence necessary to support management’s
assessment of ICFR is important.

Question 5.18.20
What is included in the direct testing of process control
activities?
Interpretive response: Direct testing of process control activities includes
testing their operating effectiveness. In performing this testing, management
should evaluate all the factors discussed in Question 5.4.30, including whether
the control is properly designed to address the PRP and operating at a level of
precision to prevent or detect a material misstatement.

Question 5.18.30
What is the timing of direct testing of process control
activities?
Interpretive response: SEC Regulation S-K Item 308(a) requires management
of public companies to provide its report on ICFR containing its assessment of
the effectiveness of ICFR as of the end of the most recent fiscal year in its
annual report. Therefore, when direct testing process control activities for

purposes of completing the annual assessment of ICFR, management’s overall

evaluation of the effectiveness of controls is as of year-end. Nevertheless, the
testing of controls usually needs to begin before year-end for it to be completed
in time to support the assessment included in the annual report.

In addition, given the cumulative nature of many balance sheet and income
statement accounts, management may consider direct testing process control
activities throughout the year to gain assurance that the controls are effective at
preventing, or detecting and correcting, errors on a timely basis, including in
connection with any interim financial reporting. Testing of process control
activities before year-end also allows time for management to respond to any
identified control deficiencies. For example, if management identifies a
deficiency in the process control activity related to a cash reconciliation midway
through the year, they have time to remediate the deficiency, operate the control
activity appropriately for the remainder of the year, and not have a control
deficiency as of their year-end assessment.

Practical tip
Communication with those charged with governance and external auditors is
key when testing process control activities. When management requests that
external auditors use a portion of testing performed by, for example, internal
audit or others under the direction of management, alignment on timing of
testing procedures, sample sizes and evidence required can reduce the burden
on control operators and others by not requiring them to duplicate their efforts.

In addition, external auditors generally use the effective performance of controls

to reduce the substantive procedures they perform as part of their audit. A
control deficiency can result in increased substantive test work to be performed,
including larger sample sizes and additional procedures. Therefore, the
identification of deficient controls as of an interim date can provide sufficient
time for the incremental testing to be completed.

Question 5.18.40
What is the extent of direct testing performed over a
control activity?
Interpretive response: The extent of direct testing performed over a control
activity depends on the frequency of the control’s performance.

A process control activity over a balance sheet account or financial reporting

performed at year-end may prevent, or detect and correct on a timely basis, a
material misstatement as of year-end. In this instance, direct testing of the
annual performance of the control at year-end may be sufficient. However, due
to the cumulative nature of income statement accounts, process control
activities affecting those accounts likely need to operate over the entire period to
prevent or detect a material misstatement. The more frequently a process
control activity is performed, the greater the extent of the direct testing
performed (i.e. the number of instances of the control’s operation to be tested).

Question 5.18.50
What evaluation strategies can be used in direct testing
process control activities?
Interpretive response: To determine whether a process control activity is
operating effectively through direct testing of control activities, one of the
following evaluation strategies (or a combination of the strategies) may be
applied.

Procedure Manual Automated

Inquiry – May include asking the May include asking the
Whenever inquiry is control operator to determine system owner to determine
used, it should not be what they look for when how the system is
used as the sole performing the control and configured to operate the
procedure. what actions they take to control.
address exceptions. It may
also include asking about the
number and magnitude of
outliers detected in the past
and then obtaining evidence
that those outliers were
properly resolved in a timely
manner.
Inspection May include examining May include examining the
documents used by the system configuration and/or
operator in performing the code to obtain evidence to
control to obtain evidence to corroborate information
corroborate information obtained through inquiry (if
obtained through inquiry (if performed) and evaluate the
performed) and evaluate the effectiveness of the control
effectiveness of the control as as implemented within the
implemented by the control system.
operator.
Observation Watching a control activity Watching the system
being performed by the execute the control, such as
control operator and others, observation of the system
such as observing key blocking a payment when a
meetings or execution of three-way-match fails.
inventory cycle counts.
Reperformance This may include This may include
independently using the independently reperforming
control operator’s metrics, a calculation to verify the
thresholds, or criteria to mathematical accuracy by
identify outliers or exceptions using the information used
and then evaluating the by the control after
control operator’s follow-up understanding the business
on these items. When a rules driving the calculation.
control is reperformed, there
should still be sufficient
evidence showing that the
control was, in fact,
performed. In particular, this
relates to the evidence of

Procedure Manual Automated

follow-up actions taken by the
control operator, and their
resolution of all identified
outliers.

Question 5.18.60
What evidence is maintained for the operation of
process control activities to enable the performance of
monitoring activities?
Interpretive response: Proper evidence is required to be available to enable
the individual(s) performing the testing over controls to evaluate whether the
process controls activities were operating effectively. This evidence should
cover the operation of all the attributes of the control, including the identification,
investigation, and resolution of outliers. Examples of this evidence may include
notes written by control operators for each outlier, original and final copies of
documents used in performance of the control, and communications or support
used during the investigation process.

Practical tip
The ‘example of one’ is evidence of a completed instance of a control activity’s
operation during the current period. It includes supporting documentation
showing how the control was performed, including any information used in the
execution of the control such as queries, reports, or reconciliations. It may also
include documentation of the related risk assessment and process, including a
risk-and-control matrix. An annotated ‘example of one’ includes markups and
references to the factors discussed in Question 5.4.30 that demonstrate how
attributes, information, and precision of the control are evidenced in the
performance of the control.

An ‘example of one’ is very beneficial to document and maintain annually to

evidence the design and operation of a control for the use of management and
external auditors as part of their testing procedures. Annotated ‘examples of
one’ may also be beneficial to facilitate turnover in control operators, including
the best practices described in Question 5.17.30. Other benefits of documenting
and maintaining annotated ‘examples of one’ for control activities include:

• availability of documentation to evidence the consideration of the relevance

and reliability of information used in the operation of control activities;

• availability of documentation to evidence how the control is performed and

aligns with the control attributes;

• availability of documentation to evidence how process control activities

operate at a level of precision to prevent, or detect and correct on a timely
basis, a material misstatement;

• early issue identification and resolution of gaps in the design and

implementation of control activities and related documentation; and

• ability to improve alignment of external auditors’ control understanding and

documentation with how management has designed and performs the
control activity when provided to the external auditors.

Question 5.18.70
Is management required to test all control activities
each year if using the direct testing approach?
Interpretive response: Not necessarily. For automated control activities,
management could apply a benchmarking approach. Benchmarking automated
controls uses a combination of:

• evidence obtained in prior monitoring periods (i.e. prior years), which

establishes the baseline; and
• evidence obtained in the current year that the operation of the automated
control has not changed.

Benchmarking may enable management to determine whether the automated

control is implemented and operating effectively in the current period.

Practical tip
If management expects their external auditors to rely on management’s direct
testing of control activities, they should discuss with the auditors the possibility
of using or changing to a benchmarking approach because there are limitations
on an auditor’s ability to rely on this approach.

Key takeaways

• A properly designed process control activity addresses the PRPs it is

intended to address and operates at a level of precision that ‘would’ prevent,
or detect and correct on a timely basis, a material misstatement.

• Control attributes need to be specific and sufficiently detailed for the control
operator to understand what is expected of them in executing the control
attributes and for the control to be performed consistently each time it is
executed.

• Management should consider whether manual or automated controls are

the most suitable in achieving a control objective, and use a mix of
preventive and detective controls in their ICFR.

• The precision of a control increases when the frequency and consistency of

its performance increases. Management considers if the control would
prevent, or detect and correct, a material misstatement on a timely basis
when determining the frequency.

• Control operators should have the authority within the organization to

enforce the control’s operation or correct its results, and the knowledge
(including knowledge of the entity) and skills to effectively perform the
control the way it was designed. As the level of judgment required by, and
complexity of, a manual control increases, so does the necessary level of
authority and competency of the control operator.

• Control activities involving judgment require more evidence and

documentation to show how the control is designed and operated.

• The precision of a process control activity is the size of a potential

misstatement the control activity would prevent, or detect and correct on a
timely basis, when it operates effectively.

• Control operators should evidence the criteria for investigation used in the
performance of the control, the outliers that were identified in performing the
control, and how the outliers were resolved.

• If the performance of a control activity does not regularly identify outliers,

careful consideration should be made of whether the control is designed to
operate at a sufficiently precise level to address the control objective.

• Management should design control activities that address the risks

associated with journal entries and other adjustments, including the
completeness, existence and accuracy of recorded journal entries, and risks
of management override of controls through manual journal entries and
other adjustments.

• Management should design controls that would identify significant unusual

transactions (SUTs) as well as related party transactions, even if no
transactions occur in the period.

• Designing controls that operate on a sample basis requires careful

consideration of whether the control achieves the control objective and

addresses the identified risk. Instances of controls that operate on a sample

basis are expected to be rare.

• Changes to controls, or changes to the operator of a control, need to be

identified timely and management should evaluate whether the change
impacts the control’s ability to address the objective of the control.

6. Information used in controls

Detailed contents
6.1 Management’s ICFR journey
6.2 Identification of information in controls
Questions
6.2.10 What information is identified related to a control?
6.2.20 What is information that is the subject of the control?
6.2.30 What is information used by the control operator to perform
the control?
6.2.40 What are the specific data elements within information that
are used in the control?
6.2.50 Why does management need to identify the specific data
elements within information that is used in the control?
6.2.60 What does reliability of information mean?
6.2.70 What does relevance of information mean?
6.2.80 What are the different forms of information?
6.3 Relevance and reliability of external information
Questions
6.3.10 What is external information?
6.3.20 What does management consider when assessing the
relevance of external information used in a control activity?
6.3.30 What does management consider when assessing the
reliability of external information used in a control activity?
6.3.40 What if external information is stored in the entity’s IT
systems?
6.4 Relevance and reliability of internal information
Questions
6.4.10 What is internal information?
6.4.20 What does management consider when assessing the
relevance of internal information used in a control activity?
6.4.30 What does management consider when designing control
activities to address the reliability of internal information?
6.4.40 Why does management understand the flow of information?
6.4.50 What are the data risks?
6.4.60 What forms of control activities address data risks?

6.4.70 When does a control attribute within the control activity

address its completeness and accuracy?
6.4.80 When does a control attribute in another control activity
address the completeness and accuracy of internal
information?
6.4.90 When is internal information subject to separate control
activities that are specifically designed to address the
completeness and accuracy of that information?
6.4.100 What is data input risk and how is it addressed through
separate control activities?
6.4.110 What is data integrity risk and how is it addressed through
separate control activities?
6.4.120 How are data input and integrity risks considered if
information originates in multiple systems?
6.4.130 What are data extraction and manipulation risks?
6.4.140 How is internal information extracted from its source?
6.4.150 How is data extraction risk addressed through separate
control activities?
6.4.160 How is data manipulation risk addressed through separate
control activities?
6.4.170 Can management assume information received directly from
a service organization is reliable?
6.4.180 What are the repercussions of control activities that address
risks over information being deficient?
6.4.190 Who should be involved in the identification of risks and
control activities over information used in control activities
and how should they be documented?
Examples
6.4.10 Relying on another control activity to address the
completeness and accuracy of internal information
6.4.20 Internal information subject to separate control activities that
are specifically designed to address the completeness and
accuracy of that information
Key takeaways

6.1 Management’s ICFR journey

As stated in the COSO Framework, “Information is necessary for the entity to
carry out internal control responsibilities to support the achievement of
objectives. Management obtains or generates and uses relevant and quality
information from both internal and external sources to support the functioning of
internal control.” Simply put, appropriately identifying and assessing the
relevance and reliability of information used in controls is critically important to
ICFR.

2. Entity-level controls

3. Risk assessment

4. Process understanding

5. Process control activities

6. Information used in controls 7. General IT controls 8. Service organizations

Identify information and RDEs Identify systems utilized – Service organization

utilized in the control consider all IT layers provides a SOC report

9. Identify and evaluate deficiencies

Yes No

Identify risks in IT layers related Manual

Evaluate
relevance

Control activities or GITCs to

This chapter starts by discussing information associated with a control and how
it is identified (see section 6.2) and then delves further into assessing the
relevance and reliability of external and internal information used in controls
(see sections 6.3 and 6.4, respectively).

The process of understanding and identifying controls and assessing the

relevance and reliability of the related information involves management and
others with ICFR responsibilities, such as control operators and IT personnel.
As part of this process, management identifies the data elements in the
information, which are the units or types of data included in the information. One
piece of information may have one or more data elements. Management’s

process also involves identifying information as external or internal. Doing so

requires consideration of the information’s source, as well as other factors that
could result in information from an external source being treated as internal
information.

Once information used in controls is identified and the source is determined,

management assesses the information’s relevance and reliability. To assess the
relevance and reliability of a piece of information, management assesses the
relevance and reliability of each relevant data element in the information.

Management’s evaluation of the reliability of external information considers the

information’s nature and source. Management’s evaluation of the reliability of
internal information involves understanding the flow of information and whether
the data risks associated with that information are addressed by:

• a control attribute of the control activity;

• a control attribute of another control activity that uses the same information;
and/or
• a control activity specifically designed to address the completeness and
accuracy of the information.

For the control attributes of a control activity to support the completeness and
accuracy of internal information, those attributes must address the data risks
present in that information. These risks relate to data input, data integrity, and
data extraction and manipulation.

Throughout the process of identifying information used in controls and

Abbreviations

We use the following abbreviations in this chapter.

COSO Committee of Sponsoring Organizations of the Treadway

Commission
GITC General IT control
ICFR Internal control over financial reporting
RAFIT Risk arising from IT
RDE Relevant data element
SOC System and Organization Controls

6.2 Identification of information in controls

Question 6.2.10
What information is identified related to a control?

Interpretive response: Management identifies all information associated with

the control. There are two types of information:

Information that is the

Information used in the control
subject of the control

Most manual controls involve information – determining the type will guide
management’s response to the information. While it is important to identify all
information associated with a control, it is critical for management to separately
identify information used by the control operator, and specifically what individual
data elements (see Question 6.2.40) are relied on, to determine what requires
further attention from management. If information used by the control operator is
not identified and/or controls over the relevance and reliability of information
used do not exist or are not designed and/or operating effectively, the control
will be deficient.

All information

Information used by
the control operator

Specific data
elements used by
the control operator

Assess relevance
and reliability

Question 6.2.20
What is information that is the subject of the control?

Interpretive response: Information is the subject of the control when the

relevance and reliability of the information itself is directly addressed by the
control objective and therefore no further assessment over the information is
necessary by management.

For example, consider a process control activity where management reviews

the bank reconciliation to determine if the reconciliation has been properly
performed. The bank reconciliation directly addresses the accuracy of the cash
recorded in the financial statements establishing its relevance, and
management’s review addresses the reliability of the bank reconciliation.
Therefore, in this example, the information (the bank reconciliation and the
related documents supporting the various reconciling items) is the subject of the
control and therefore the reliability of the information is addressed through the
performance of the control.

Question 6.2.30
What is information used by the control operator to
perform the control?
Interpretive response: Information used by the control operator to perform the
control includes any information that is relied on by the control operator to
effectively execute the control.

For example, a credit limit exception report is used by the control operator to
evaluate customers with outstanding balances greater than their approved credit
limit. The process control activity will only be effective at identifying and
following up on specific outliers if the credit limit exception report is complete
and accurate. As such, the credit limit exception report is relied on by the control
operator in performing the control.

Question 6.2.40
What are the specific data elements within information
that are used in the control?
Interpretive response: A data element is a unit or type of data included within
a piece of information. Data elements include both financial and nonfinancial
data used in a calculation, selection or other manipulation of the information
(e.g. to sort, filter or group data).

If the information used in the control has more than one data element,
management identifies each of the specific data elements that are used in the
control (RDEs) and evaluates whether those RDEs are sufficiently relevant and

reliable. Data elements that are not used in the control do not need to be
assessed for relevance and reliability.

For example, the control operator uses a report of all journal entries as part of
the process control activity related to the review of all manual journal entries that
ensures the entries were posted in the correct period, by an appropriate user,
for the correct amount, and for a valid business purpose. The aging report has
six data elements for each journal entry, and management identifies the four
specific data elements used in the process control activity, i.e. the RDEs.

Used in the
Data element control
Journal entry number No
Journal entry type code (e.g. manual or automated entry) Yes
Journal entry date Yes
Debit/credit amount Yes
Username (i.e. user who posted the entry) Yes
Description of the entry No

Journal entry type code, date, debit/credit amount, and username are all used
by the control operator as these data elements are relevant to the review of
manual entries for the period.

Practical tip
In some cases, it is easier to identify RDEs by working backward from the final
control product to the information source. This can assist in narrowing down the
data elements used in the control.

Question 6.2.50
Why does management need to identify the specific
data elements within information that is used in the
control?
Interpretive response: Management identifies the specific data elements used
in the control so that the consideration of the relevance and reliability of the
information is targeted. The data elements targeted are those that affect the
control operator’s decision or support a key input or assumption; these are
relevant data elements.

If information used by the control operator to perform the control is not relevant
and reliable (i.e. accurate and complete), there is a deficiency in the design of
the control (see Question 6.4.180).

Question 6.2.60
What does reliability of information mean?

Interpretive response: Reliability as it relates to internal information in a control

equates to:

Reliability Complete Accurate

This means that such information contains:

• all the data that is necessary;

• only the data that is necessary; and
• data that is correct.

'Accuracy' in this context also relates to the way the data is manipulated and
presented in a report, such as groupings, calculations based on the data, and
totals in the report.

Reliability as it relates to external information in a control is a more qualitative

analysis that considers factors related to the nature and source of the
information. See Question 6.3.30 for more detailed information about these
factors.

Question 6.2.70
What does relevance of information mean?

Interpretive response: Relevance is the relationship between the information

and the objective of the control where the information is used. Information is
sufficiently relevant when it has a logical connection or relationship with the
objective of the planned control and is precise and detailed enough to meet the
objective of the planned control.

Question 6.2.80
What are the different forms of information?

Interpretive response: Information used in the control may take various forms.
Whether the information is from internal sources or external sources, it is
important to identify the information (see Questions 6.3.10 and 6.4.10 for
additional discussion of external and internal information, respectively).

Depending on the nature and source of the information, the relevance and
reliability may be addressed differently. Each of these forms of information is
discussed in upcoming sections of this chapter.

Does any of the

Does any of the information come from internal sources
information come from
(including service organizations or specialists)?
external sources?

Internal information
Information addressed by subject to other controls
a control attribute (this that are specifically
External information control or another control designed to address the
that uses the same completeness and
information) accuracy of that
information

Section 6.3 Questions 6.4.70 and 6.4.80 Question 6.4.90

6.3 Relevance and reliability of external information

Question 6.3.10
What is external information?

Interpretive response: External information is information that is used by the

entity that originates from a source (individual or organization) outside of the
entity (i.e. an external source).

Examples of external information are listed below. Note that the list does not
include information from service organizations or management’s specialists, as
these are typically considered internal information. Section 8.10 discusses
information from service organizations. Question 4.5.230 discusses information
from management’s specialists.

• Contracts/Purchase orders • Shipping documents

• Vendor invoices • Company share prices

• Insurance policies • Loan agreements

• Mortgages • Royalty or usage reports

• Foreign exchange rates • Interest rates

• Periodic statements, such as bank • Market, industry or competitor

statements information, including forecasts

• Rental agreements for both • Information received from licensees

operating and finance leases or collaborators

• Prices from a pricing service and pricing-related data, suitable for a broad range
of users for a fee

Question 6.3.20
What does management consider when assessing the
relevance of external information used in a control
activity?
Interpretive response: Relevance of external information used in a control
activity is often very simple to assess because it is often obvious. For example,
relevance of bank statement information is clear from the objective of the control
and the control attributes performed and documented in a bank reconciliation
control. However, assessing the relevance of information is not always that
obvious.

For example, consider a process control activity to evaluate whether the entity's
discount rate is reasonable. The control operator obtains the discount rate from
10 publicly traded companies and assesses which of the 10 are relevant to the
objective of the control. When evaluating the relevance of the discount rates, the
control operator might consider the size, capital structure, industry, etc. of each
of the 10 companies compared to the entity.

Specific to controls, the relevance of the information used depends on:

• the account balances, disclosures or assertions to which the information

relates and the design of the control;
• whether there have been changes in the information or the account to which
the information relates;
• the aggregation of the information;
• the period of time to which the information relates, and its age; and
• the timing of the control.

For example, when performing a process control activity over bank

reconciliations monthly, the information used should be at a sufficiently detailed
level and for the appropriate period (e.g. the bank statement for the month the
control is performed over).

Practical tip
Control operators should maintain documentation of their assessment of
relevance to evidence management’s ICFR environment. The control operator
should consider if they need to reassess relevance with each control operation
due to changes in circumstances. For example, if the entity begins operations in
a new market or line of business, a control that uses information from
comparable entities will need to be revisited to assess whether those entities

are still comparable – i.e. relevant – given the change to the entity’s own
business.

Question 6.3.30
What does management consider when assessing the
reliability of external information used in a control
activity?
Interpretive response: In assessing the reliability of external information,
management considers the nature and source of that information. Management
may consider the following factors when evaluating the reliability of information
obtained from an external source.

Reliability factors
Source Nature
• The competence and reputation of • Whether the external source
the external source with respect to accumulates overall market
the information information or engages directly in
• Past experience with the reliability of ‘setting’ market transactions
the information provided by the • Whether the information is suitable
external source for use in the way it is being used
• Extent of regulatory oversight of the and, if applicable, was developed
external source using the applicable financial
reporting framework
• The ability of management to
influence the information obtained • Whether the information has been
through relationships with the subject to review or verification by
external source the external source or another
external party
• Whether the information has been
originated, aggregated, or adjusted
by the external source

Sometimes it is helpful to think about the nature of the information in terms of

where it falls on a spectrum of reliability. The following diagram includes factors
that may indicate information is more or less reliable.

Less reliable More reliable

• No evidence of general market • Evidence of general market

acceptance of its reliability when acceptance of its reliability when
used for a similar purpose used for a similar purpose
• Lack of corroboration through • Corroboration through other
other sources sources
• Existence of contradictory • Lack of contradictory alternative
alternative information information
• Substantive disclaimers or • Limited or no disclaimers or
restrictive language restrictive language
• Obtained through a complex • Obtained through a straightforward
process process

Practical tip
Control operators should maintain documentation of their assessment of
reliability to evidence management’s ICFR environment. The control operator
should consider if they need to reassess reliability with each control operation
due to changes in circumstance. For example, if a control relies on information
from an external party that has been historically reliable, but concerns have
recently been raised as to their reputability, the assessment of reliability will
need to be revisited to determine whether the external source is still reliable
given the change in circumstances.

Question 6.3.40
What if external information is stored in the entity’s IT
systems?
Interpretive response: If management stores external information in the
entity’s IT systems, the relevance and reliability of the external information up to
the point at which it is transferred onto the entity’s IT systems should be
addressed is in accordance with Questions 6.3.20 and 6.3.30 above. From the
point of transfer, the relevance and reliability should be addressed in
accordance with the guidance in section 6.4.

6.4 Relevance and reliability of internal information

Question 6.4.10
What is internal information?

Interpretive response: Generally, internal information originates from the

entity, whereas external information originates from a source outside of the
entity (i.e. an external information source) (see Question 6.3.10). Additionally, if
information from third parties is developed specifically for use by the entity, it is
considered internal information. External information that originates from a
source outside of the entity that has been manipulated once received by the
entity is considered internal information.

Examples of internal information

• Trial balances/subledgers • Listings of transactions

• Spreadsheets, cost allocations,

• Analyses of subledgers or balances
computations, and reconciliations

• Rollforward schedules • Queries

Examples of internal information

• Budgets/forecasts • Minutes of meetings

• Information provided by a service

• Internal audit reports
organization (see section 8.10)

• Internal marketing information (e.g. information developed by the entity's sales

function is an assumption in making an accounting estimate for a warranty
provision)

• Prices from a pricing service for specific financial instruments not routinely priced
for its subscribers

Question 6.4.20
What does management consider when assessing the
relevance of internal information used in a control
activity?
Interpretive response: Relevance of internal information used in a control
activity is often very simple to assess because it is often obvious. For example,
relevance of a listing of PP&E additions is clear from the objective of the control
and the control attributes performed and documented in a roll forward of PP&E
control. However, assessing the relevance of information is not always that
straightforward. The assessment of relevance is the same for external and
internal information. Accordingly, it is important to consider the factors listed in
Question 6.3.20 and whether the information is precise and detailed enough to
meet the objective of the planned control.

For example, when performing a process control activity over the recoverability
of accounts receivable monthly, the information used should be at a sufficiently
detailed level (e.g. the customer or transaction level) and for the appropriate
period.

Question 6.4.30
What does management consider when designing
control activities to address the reliability of internal
information?
Interpretive response: To design control activities, management:

• understands the flow of information;

• identifies the risks related to the information (the data risks); and
• designs control activities to address the data risks.

Given the nature of entity level controls, the extent of procedures to evaluate the
reliability of information used in entity level controls is different. See Question
2.3.70 for consideration of reliability of information used in entity-level controls.

Question 6.4.40
Why does management understand the flow of
information?
Interpretive response: To identify the risks to internal information and data
elements, it is important for management to understand the flow of information
and data elements through the information system(s) back to the point of
origin/data input. When determining the source of the information, management
needs to consider all systems that the data passes through, from the originating
control activity that verifies the data was correctly input into the system to the
point of extraction.

For example, if information is entered into a sales or billing system that is then
transferred to the general ledger system where the information is extracted, both
systems need to be considered. However, if the data is entered directly into and
extracted directly from the sales system, only one system needs to be
considered.

Identification of the systems will assist management in identifying the related

data risks and the necessary control activities that address the risks over the
specific data elements.

Practical tip
When understanding the flow of information from the source, it can be beneficial
to involve others in the discussion, including IT personnel (see Question
6.4.190). Flowcharts or other documentation created as part of process
understanding (see chapter 4) may help in tracing information from the source
to the extraction point.

Question 6.4.50
What are the data risks?

Interpretive response: There are three types of data risk – data input, data
integrity, and data extraction and manipulation. Each data risk needs to be
addressed by control activities to address the completeness and accuracy of
internal information. The following table includes example risks for each type of
data risk.

Data risk Example risks

Input risks • Data is incompletely or inaccurately entered into the
IT system or not properly converted from its original
source to electronic form.
• Data arising from hard-copy source documents or
electronic data interface (EDI) may be compromised
before input.
Integrity risks • Data is inappropriately altered during processing.
• Data is inappropriately altered while in storage.
• Data does not accurately transfer from one system
to another.
• Data is not valid.
Extraction and • The information does not contain all data when
manipulation risks extracted.
• The information contains additional data when
extracted.
• The manipulation of data used to produce the
information is incorrect or inaccurate.

Question 6.4.60
What forms of control activities address data risks?

Interpretive response: The reliability (or completeness and accuracy) of

internal information and specific data risks could be addressed by:

• a control attribute of the control activity (see Question 6.4.70);

• a control attribute of another control activity that uses the same information
(see Question 6.4.80); or
• separate control activities that are specifically designed to address the
completeness and accuracy of the information (see Question 6.4.90).

Each data risk may be addressed through one or multiple forms of controls. See
Example 6.4.10.

Question 6.4.70
When does a control attribute within the control activity
address its completeness and accuracy?
Interpretive response: The completeness and accuracy of information is
addressed by a control attribute within the control activity when the control
operator performs a step that results in the verification of the completeness
and/or accuracy of the information. This includes addressing the three types of
data risk discussed in Question 6.4.50.

Often, for non-system generated information that is manually maintained (e.g.

Excel spreadsheets), control operators address the completeness and accuracy
of the information through control attributes within the control activity. For
example, for the net income data element in an Excel spreadsheet used to track
debt covenant compliance, the control operator agrees net income to the
consolidating income statement to assess completeness. For another example,
the data elements and related data risks in an Excel spreadsheet used to
calculate interest expense are verified by the control operator performing the
following control attributes.

Data risk and how addressed

Data element Control attribute through attribute
• Input risk – addressed as agreed
back to a signed third-party
Interest rate document
• Integrity and extraction risk – N/A
Agrees to signed
as agreeing to original so no risk of
third-party loan
data being inappropriately modified
agreement
after input and data is not extracted
Loan amount • Manipulation risk – addressed
through the steps over interest
expense

• Input, integrity and extraction risk –

Recalculates based addressed through the steps over
Interest expense on verified interest interest rate and loan amount
rate and loan amount • Manipulation risk – addressed
through the recalculation of RDE

Question 6.4.80
When does a control attribute in another control activity
address the completeness and accuracy of internal
information?
Interpretive response: The completeness and accuracy of internal information
can be addressed when a control attribute of a different control activity
addresses the completeness and accuracy of the same information. This
includes addressing the three types of data risk discussed in Question 6.4.50.

This approach can only work effectively if the two control activities use the same
information for the same timeframe. Determining whether the information is the
same can be tricky. For example, consider a scenario in which the information
represents reports that are extracted, and the completeness and accuracy of
those reports as extracted are addressed in another control activity. The reports
are then manually manipulated as part of the current control activity (e.g.
formulas are added to an extracted report to produce a total column). Therefore,
in this scenario, the additional risks associated with the manual manipulation of
the reports are not covered in the other control activity.

Practical tip
When designing new control activities or modifying control activities,
management should consider the source of information used by the control
operator and whether there is information that is already addressed by a
separate control activity that can be relied on. This may be more efficient and
effective than running a new report or using a separate source for the same
information. Agreeing the information directly to the report used in the other
control activity helps ensure the information is the same in both control
activities.

Example 6.4.10
Relying on another control activity to address the
completeness and accuracy of internal information
A control operator reviews the equity rollforward on a quarterly basis. The
control operator agrees the share repurchases on the equity rollforward to the
repurchase schedule using the data elements of the repurchase date and
repurchase value. The repurchase schedule is information that is used in the
process control activity.

There is a separate quarterly process control activity where a control operator

reconciles the same repurchase schedule, including the same data elements
mentioned above, by:

• agreeing them to information from the registrar;

• agreeing them to the bank statement; and
• evaluating whether all transactions included in the information from the
registrar are reflected in the repurchase schedule.

Therefore, the internal information (repurchase schedule) used in the process

control activity over the equity rollforward, and the related specific data
elements, are addressed by a control attribute in another process control activity
that covers the completeness and accuracy of the same information.

The following table outlines the data elements, the control attributes that
address them and how the data risks are addressed through those attributes.

Data risk and how addressed

Data element Control attribute through attribute
• Input risk – addressed through
agreeing back to the trial balance
Beginning balance
• Integrity and extraction risk – N/A
as agreeing to trial balance so no
Agree to the trial risk of data being inappropriately
balance modified after input and data is not
extracted.
Net income loss • Manipulation risk – addressed
through the recalculation of the
period-end balance

Data risk and how addressed

Data element Control attribute through attribute
Agree to the stock
Stock compensation
compensation schedule (not
• Addressed in the control over the
stock compensation schedule
expense included in the
example)

Share repurchase Agree to the share • Addressed in the control over the
amount repurchase schedule repurchase schedule

• Input, integrity and extraction risk –

addressed through the steps over
beginning balance, income, stock
Period-end Recalculates based compensation expense and share
balance on other inputs repurchase amount
• Manipulation risk – addressed
through the recalculation of RDE

Share repurchase schedule control

Data risk and how addressed
Data element Control attribute through attribute
• Input risk – addressed through
Amount of stock agreeing back to the third-party
buyback bank statement and information
from the registrar
• Integrity and extraction risk – N/A
Agree to the bank as agreeing to third-party bank
statement and third- statement and the registrar so no
party repurchase risk of data being inappropriately
notice modified after input and data is not
Date extracted
• Manipulation risk – addressed
through the recalculation of the
total repurchase amount for the
period

• Input, integrity and extraction risk –

Total stock addressed through the steps over
Recalculates based amount of stock buyback
repurchase
on other inputs
amount for period • Manipulation risk – addressed
through the recalculation of RDE

Consideration should be given to whether all data elements being relied on in

the current control activity are addressed for completeness and accuracy
through the other control activity. If the repurchase date’s completeness and
accuracy was not addressed in the process control activity to reconcile the
repurchases, it could not be relied on in the equity rollforward process control
activity.

Question 6.4.90
When is internal information subject to separate control
activities that are specifically designed to address the
completeness and accuracy of that information?
Interpretive response: If the completeness and accuracy of the information
used by the control operator to perform the control is not addressed by an
attribute of the control itself, or through an attribute of another existing control,
separate control activities must be designed and implemented. When separate
control activities are specifically designed to address the completeness and
accuracy of information, especially around extraction risk, they are typically
information controls. Information controls are generally used as the method to
address the completeness and accuracy of internal information in:

• reports generated directly from IT systems (i.e. system-generated reports);

• reports generated using report writers that interface with IT systems (i.e.
custom reports); and
• schedules created using end-user computing applications (i.e. end-user
computing schedules).

Question 6.4.100
What is data input risk and how is it addressed through
separate control activities?
Interpretive response: Data input risks are risks that the information being
relied on is incomplete or inaccurate due to how the information was initially
obtained and input into the system.

Example risks Control consideration

• Data is incompletely or inaccurately The specific risk and related control
entered into the IT system or not activities differ depending on the source
properly converted from its original of the data and how the data gets into the
source to electronic form. IT system – EDI versus manual input of
data from source documents.
• Data arising from hard-copy source
documents or EDI may be
compromised before input.

Input risks may be addressed by process control activities over risk points when
the information is first entered into an IT system, including consideration of
proper authorization of transactions as specified by an entity's established
policies and procedures (e.g. approval of a transaction by a person having the
authority to do so).

Some entities design process control activities to address input risk in a system
that is not the originating system. For example, procurement-related
transactions may originate in a procurement system; however, process control
activities over the input of the data (e.g. three-way match and expenditure
review/approval controls) may occur in a downstream system.

Question 6.4.110
What is data integrity risk and how is it addressed
through separate control activities?
Interpretive response: Data integrity risks are risks that the information being
relied on is incomplete or inaccurate due to how the information is maintained
within the system(s).

Example risks Control consideration

• Data is inappropriately altered during If data is changed/processed by an IT
processing. system(s) or is transferred electronically
• Data is inappropriately altered while from one system to another, then control
in storage. activities are identified related to:
• Data does not accurately transfer • the processing and/or transfer of the
from one system to another. data; and
• Data is not valid. • the GITCs that address risks that
could affect the control activities’
consistent operation.
When data is stored in an IT system,
evaluating and testing GITCs that
address the applicable risks for the
relevant IT system layer (e.g. database)
may be sufficient to address the data
integrity risk (see chapter 7 for discussion
of GITCs). In more complex scenarios
(e.g. when data is processed or
transferred to another system),
management may also identify risk points
in the process and evaluate and test
controls outside of GITCs including
automated process control activities to
address the data integrity risk.

Integrity risk is generally addressed through GITCs over the systems identified
by management used to generate the information used in the control. Situations
in which data transfers between multiple systems tend to involve more control
activities and risk points. At each point where information transfers to a new IT
system, management considers whether there is data transfer risk that needs a
process control activity to address the completeness and accuracy of the data
transfer. This process control activity can be automated, manual or a
combination of both.

The entity evaluates whether GITCs are designed and operating effectively in
systems in which management is relying on automated process control activities
(e.g. configuration controls related to extracted reports) to address processing
and data transfer risks related to data integrity.

Question 6.4.120
How are data input and integrity risks considered if
information originates in multiple systems?
Interpretive response: Data elements can originate in different systems, which
can result in different risk points and control activities for different data elements
from the same information/report. For example, consider an invoice payment
report. The data elements identified are the invoice number, invoice amount,
date, payment date and payment amount. While the invoice information
originates in the procurement system (which resides at a service organization),
the payment information is directly entered into the ERP system where the
information is extracted. This results in different process control activities
addressing data input risk for the data elements. In addition, more control
activities are necessary to address data integrity risk for the procurement
system and movement of data between systems. Using a diagram, the flow of
information and the control activities that address the risks of input and integrity
can be more easily visualized (CO – control objective in the SOC-1 report from
the service organization; PCA – process control activity).

Input risk Integrity risk

Invoice COs 2-4

CO-1 scanned into Procurement
system system
GITCs

PCA-4

Payment
PCA-5 recorded in ERP system GITCs
system

In this diagram, the risks are addressed by the following.

System Input risk Integrity risk

Procurement system Control Objective 1 from the Control Objectives 2, 3 and 4
service organization report from the service organization
report
GITCs that respond to Risks
arising from IT (RAFIT) over
integrity risk
Transfer between Process control activity 4
systems
ERP system Process control activity 5 GITCs that respond to
RAFITs over integrity risk

Question 6.4.130
What are data extraction and manipulation risks?

Interpretive response: Data extraction and manipulation risks are risks that the
information being relied on is incomplete or inaccurate due to how the
information is pulled from the system and/or subsequently altered.

Example risks Control consideration

• The information does not contain all Data extraction and manipulation risks
data when extracted. are present for all types of information
obtained from IT systems – including
• The information contains additional
system-generated reports, custom
data when extracted.
reports and end-user computing-
• The manipulation of data used to schedules (including Excel, Alteryx,
produce the information is incorrect Power BI and other tools).
or inaccurate.
An entity’s use of custom reports and
end-user computing schedules increases
data extraction and manipulation risks.

The risk over data manipulation will vary based on where the data is extracted
to and if there is intentional manipulation after extraction. Most information has
some risk of manipulation after extraction. In many cases, information is
extracted into Microsoft Excel, Microsoft Access, etc. and many entities are
using additional tools such as Alteryx and Power BI where the data is
intentionally manipulated or has a risk of being unintentionally manipulated.

Question 6.4.140
How is internal information extracted from its source?

Interpretive response: Generally, internal information is extracted from its

source using the following methods.

• Configuration reports or system-generated reports are reports configured

directly within an entity's IT systems. These reports may be built into off-the-
shelf IT systems from software vendors (sometimes referred to as canned
reports) or custom-created by either the software vendor or management to
meet the specific needs of the entity. Canned reports in many cases require
the end user to select parameters before running the report, but
management does not have access to the report code or ability to modify
the report beyond the parameter selection.

• Query reports are custom reports that are written by management using
query language (e.g. SQL queries).

• Report writer reports are custom reports that use a separate tool or report
writer application to pull the report from the system (e.g. Crystal Reports,
Essbase). The end user usually is required to select inputs to run the report.

• Service organization reports are those provided to the entity that involve no
intervention by management as part of the extraction (e.g. the service
organization emails management the report). If management extracts
information from a service organization system, it would fall in one of the
other sources.

Question 6.4.150
How is data extraction risk addressed through separate
control activities?
Interpretive response: Management considers the nature of the report,
including the method used to extract the data in the report from its source, to
determine how the data extraction risk is addressed.

How to address data Additional

Nature of report extraction risk considerations
Configuration An automated process
control activity over the
configuration of the report
or a manual process
control activity(s) over the
completeness and
accuracy of the
information.
Query and report writer A process control activity When a report writer is
over the configuration of used, the integrity of the
the custom report or the data flowing to the tool and
control operator reviews the integrity of the
the query or extraction information while in the
script. tool also needs to be
considered and
addressed.
Service organization A process control activity See chapter 8 for
or control objective within guidance on use of SOC
the SOC report that reports.
explicitly identifies the
information and addresses
the completeness and
accuracy of the report.

For all reports, if parameters are entered by the control operator to extract the
report, there is an extraction risk that should be addressed through a manual
process control activity (generally an attribute within the control using the
information).

Tools and programs that use routines (e.g. macros in Excel, Alteryx) to process
data or those that filter data (e.g. Power BI) are also subject to data
manipulation and extraction risk. The entity should design and implement
controls over the completeness and accuracy of the information in and out of the

tools as well as over the configuration of the routine or filters used. This is
similar to controls over information in a query or report writer.

Practical tip
Reports may be generated from off-the-shelf applications where management
does not have access to make changes to the code. These reports are often
called canned, standard or system reports, as they are developed by the vendor
that provides the IT system and management cannot make changes to the
reports that come from these applications. In contrast, custom reports (such as
SQL reports) have parameters that are established by an IT developer. Custom
reports are more prone to have information (e.g. data elements, records)
inappropriately excluded or included. When designing new control activities that
require information from a custom report developed specifically for that control
activity, proper review of the development of the report should occur by the
control operator upfront and whenever the report is modified.

Question 6.4.160
How is data manipulation risk addressed through
separate control activities?
Interpretive response: Management considers where the data is extracted to
and whether it is intentionally manipulated or has a risk of being unintentionally
manipulated.

Control activities over manipulation risk can be a combination of:

• process control activities to check that the logic is functioning as intended

(e.g. controls that reconcile the report to the data from which it was derived
and compare the individual data from the report to the source and vice
versa);

• use of validation software tools that systematically check formulas or

macros (e.g. spreadsheet integrity tools); and

• use of access restrictions (e.g. password-protected server locations with

restricted access and version controls).

Data manipulation risk generally occurs for each instance of the control activity’s
operation. For example, data manipulation risk occurs each time a report is
moved into Excel and the data within it is sorted and filtered and/or calculations
are added.

Practical tip
Embedding the control attribute to address data manipulation risk into the
attributes for the control activity that is using the information will assist in
ensuring the consistent operation and documentation of how the risk is
addressed.

Example 6.4.20
Internal information subject to separate control activities
that are specifically designed to address the
completeness and accuracy of that information
Payroll information is uploaded from the HR system to the financial reporting
system. On a monthly basis, a control operator reconciles the payroll register to
the general ledger (GL) and investigates any variances. The control operator
relies on the payroll register from the HR system to agree to the Interface
summary and the GL. As the GL and the payroll summary reports are the
subject of the control, the completeness and accuracy are addressed through
the control. Therefore, the payroll register is identified as information. It is
extracted from the HR system through a configuration report. Gross earnings,
taxes, deductions and net earnings are identified as RDEs.

For purposes of this example we will assume all RDEs are addressed through
the same controls.

Data risk How data risk is addressed

• Controls over input of payroll into the HR system (timesheet,
salary rates, hiring controls, etc.)
Input • Controls over calculation of taxes, deductions and net
earnings
• Monthly payroll variance control
Integrity • GITCs over HR system database layer

• Control over the extraction of the report including a test of

Extraction one agreeing each RDE from the system to the report and
agreeing the total

• As the report is exported into Excel, control operator agrees

the total of each RDE back to the system to ensure no
Manipulation
manipulation. No further manipulation is performed over the
Excel file for purposes of the control.

Question 6.4.170
Can management assume information received directly
from a service organization is reliable?
Interpretive response: No. Even if information is received directly from a
service organization with no intervention by management (e.g. the service
organization emails management the report), management cannot assume the
information is complete and accurate or that there are control activities
addressing its completeness and accuracy. Generation of information by a
service organization does not make the information complete and accurate
unless the information is explicitly identified and subject to control activities
captured in the SOC 1 report or if other procedures are performed to confirm

with the service organization and the service auditor that controls have been
performed over the completeness and accuracy of the information.

Many SOC 1 reports do not explicitly identify the information or reports provided
to user entities. Therefore, management may need to perform additional
procedures to determine whether a SOC 1 report addresses the risks over
information produced by the service organization. These procedures may
include:

• inquiring of the service organization and/or service auditor to understand

how the control objectives and related controls included in the Type 2 SOC
1 report address the accuracy and completeness of the information,
including the relevant data elements;

• reviewing the control objectives and tests of controls performed by the

service auditor to determine if the accuracy and completeness of relevant
data elements in the information used by management are addressed by
the control objective and tests of controls;

• reviewing the control objectives to determine if the Type 2 SOC 1 report

includes a control objective, control activities and tests of controls related to
the accuracy and completeness of the output produced by the service
organization;

• reviewing 'Management's Description' in the Type 2 SOC 1 report to

determine if the information is specified as being produced for user entities;
and

• inspecting the service level agreement between the service organization

and the user entity to determine if the information is listed as part of the
service organization's output delivered to the user entity.

If the information is not addressed in the SOC 1 report or though these

additional procedures, management may need to implement additional control
activities over the completeness and accuracy of the information.

If management is extracting information from a service organization’s system,

they consider data extraction and manipulation risks similar to how they do so
for information in configuration, query and report writer reports (see section 8.10
for further guidance).

Question 6.4.180
What are the repercussions of control activities that
address risks over information being deficient?
Interpretive response: When there are separate control activities that address
the completeness and accuracy (including data input risk, data integrity risk, and
data extraction and manipulation risk) of the information, a deficiency in any of
those control activities renders:

• the information unreliable; and

• the control activities where the information is used deficient.

Chapter 9 provides additional information about the evaluation of deficiencies.

Practical tip
It is important to understand and document which control activities rely on the
effective operation of other control activities. This is critical to appropriately
evaluating the effect of a control deficiency, especially when related to control
activities that address information risks for multiple manual control activities.

Question 6.4.190
Who should be involved in the identification of risks and
control activities over information used in control
activities and how should they be documented?
Interpretive response: When management is designing a control, it is
important to involve the appropriate parties to identify the related risks and
control activities over the information that will be used in the control.

Involving other control operators who are involved in the broader business
process or individuals who perform monitoring activities (e.g. Internal Audit) can
be helpful in identifying:

• another control activity that addresses the completeness and accuracy of

the information;
• manual process control activities to address the input risks, including the
risk of appropriate approval to initiate the transaction; and
• manual process control activities to address integrity risks in the movement
and/or transformation of information between systems.

Involving IT personnel with knowledge of the entity’s systems and how data
moves between each system can be helpful in identifying:

• automated process-level controls to address the input risks associated with

EDIs;
• GITCs to address the integrity risks associated with information maintained
in IT systems;
• automated process control activities to address integrity risks in the
movement and/or transformation of information between systems; and
• automated process control activities to address the extraction risks related
to the completeness and accuracy of system-generated reports.

Consistent with the documentation requirements of the COSO Framework,

management is required to document their identification of risks and how those
risks are addressed.

Practical tip
Due to the complexity of internal information that is subject to sperate control
activities, management may consider using a consistent template to document:

• the data elements;

• the flow of information; and

• how data input, data integrity, and data extraction and manipulation risks
are addressed.

This template can include the testing of data extraction risk. If management
uses a benchmarking approach (see Question 5.18.70), this template can also
be used to document and track the last change date for reports.

It’s beneficial to review any template with external auditors because use of an
appropriately designed template can improve not only an entity’s ICFR
documentation, but also streamline the related external audit procedures.

Key takeaways

• Assume information is involved in every manual control, including manual

GITCs.

• The relevance and reliability (i.e. completeness and accuracy) of all

information used by the control operator should be addressed and
documented.

• The risks related to internal information used in a control activity can be

addressed in three ways:
— a control attribute of the control activity;
— a control attribute of another control activity that uses the same
information; and/or
— a control activity specifically designed to address the completeness and
accuracy of the information.

• When using a control attribute of another control activity to address

information, be careful of modifications made to information between control
activities or the use of similar but not the same report(s).

• The control attributes need to address data input, data integrity, and data
extraction and manipulation risks (data risks) present in information used in
a control activity.

• A control activity is deficient if any of the control attributes that address data
risks for information used in the control are deficient.

7. General IT controls
Detailed contents
7.1 Management’s ICFR journey
7.2 Relevant layers of IT and RAFITs
Questions
7.2.10 What are the layers of technology that comprise an IT
system?
7.2.20 What are report writers and how are they relevant to ICFR?
7.2.30 What is a data warehouse and how is it relevant to ICFR?
7.2.40 What are the risks arising from IT and how are they
identified?
7.2.50 Is each IT process always relevant to ICFR?
7.2.60 What is a process risk point and how does it differ from a
RAFIT?
7.2.70 What is a relevant RAFIT?
7.2.80 When is a layer of technology relevant to ICFR?
7.2.90 Can multiple layers of technology be relevant to a single
automated control activity?
7.2.100 How does an entity document relevant IT systems and
layers?
7.2.110 Why is it important to identify IT layers and RAFITs?
Examples
7.2.10 Common RAFITs by IT process
7.2.20 IT system overview diagram
7.3 GITCs
Questions
7.3.10 What are GITCs?
7.3.20 Where are GITCs in the COSO Framework?
7.3.30 What is considered when designing and documenting
GITCs?
7.3.40 What are manual GITCs?
7.3.50 What are automated GITCs?
7.3.60 What are automated GITCs implemented in tools?
7.3.70 What additional considerations are relevant for information
used in GITCs?

7.3.80 What additional considerations related to GITCs are relevant

for third-party service organizations used by the entity?
7.3.90 How does an entity evidence that GITCs are designed and
operating?
Examples
7.3.10 RAFITs, GITCs and control attributes for manual GITCs
7.3.20 Automated GITCs
7.4 Monitoring procedures over GITCs
Questions
7.4.10 Is testing of GITCs performed as part of monitoring
procedures?
7.4.20 What is included in the direct testing of GITCs?
7.4.30 What is the timing of direct testing of GITCs?
7.4.40 What evaluation strategies can be used in direct testing
GITCs?
7.4.50 Can there be one GITC across multiple IT layers?
7.4.60 What are the additional considerations when a GITC exists
across multiple IT layers or IT systems?
7.4.70 What does management consider when testing the operating
effectiveness of a manual GITC across multiple IT systems?
7.4.80 What evidence is maintained for the operation of GITCs to
enable the performance of monitoring activities?
Example
7.4.10 One GITC applicable to multiple IT systems/layers
7.5 GITC deficiencies
Questions
7.5.10 How do ineffective GITCs affect management’s ICFR?
7.5.20 How does management respond to ineffective GITCs?
Example
7.5.10 Deficient GITC and ad hoc compensating GITCs
7.6 Cybersecurity
Questions
7.6.10 What are cybersecurity risks and incidents?
7.6.20 Are cybersecurity risks also relevant for third-party service
organizations used by the entity?
7.6.30 What are management’s responsibilities related to
cybersecurity risks?

7.6.40 What are management’s responsibilities when a

cybersecurity incident has been identified?
7.6.50 What are the auditors’ responsibilities related to
cybersecurity risks?
Example
7.6.10 Processes related to cybersecurity risk assessment
Key takeaways

7.1 Management’s ICFR journey

GITCs are control activities over the entity’s IT processes that support the
continued effective operation of the IT environment and the integrity of data and
information within the entity’s IT system. Understanding GITCs is an important
part of management’s ICFR journey because GITCs are critical to the effective
operation of automated process control activities (see chapter 5) that have been
identified to address risks of material misstatements (RMMs) (see chapter 3).

2. Entity-level controls

3. Risk assessment

4. Process understanding

5. Process control activities

6. Information used in controls 7. General IT controls 8. Service organizations

Identify information and RDEs Identify systems utilized – Service organization

utilized in the control consider all IT layers provides a SOC report

9. Identify and evaluate deficiencies

Yes No

Identify risks in IT layers related Manual

Evaluate
relevance

Control activities or GITCs to

Before GITCs are identified, management must first understand the IT layers
within the entity’s IT system and then identify the relevant risks arising from IT
(RAFITs) within each IT layer. Summary information about each is provided
next, along with where additional information can be found in this chapter.

Relevant layers of IT and RAFITs GITCs

(see section 7.2) (see section 7.3)

• RAFITs represent the susceptibility • GITCs are not expected to directly

of automated control activities to prevent, or detect and correct,
ineffective design or operation, or material misstatements. However,
risks to the integrity of information ineffective GITCs may lead to
in the entity’s IT systems, due to automated control activities that

Relevant layers of IT and RAFITs GITCs

(see section 7.2) (see section 7.3)
ineffective design or operation of don’t operate consistently and
GITCs. RAFITs may exist within the effectively, which may lead to the
entity’s processes to manage: automated control activities not
— access to programs and data; preventing, or detecting and
— program changes; correcting, a material misstatement
— program acquisition and on a timely basis.
development; and • GITCs can be either manual or
— computer operations. automated. A common example of
• A relevant RAFIT is an IT risk a manual GITC is a periodic user
where there is a ‘reasonable access review. An example of an
possibility’ that the risk could automated GITC is restricting
prevent the effective operation of access to make system changes to
the related automated control only authorized personnel in IT
activity and/or affect the integrity of operations.
data within the IT system. • Management considers a number
• The following four layers of of factors when designing and
technology comprise an IT system: documenting a GITC, including its
objective, nature, type and
— application;
frequency of operation, as well as
— database;
the judgment and information
— operating system; and
needed for its operation.
— network.
• Additional considerations exist
• A layer of technology is relevant to
when GITCs operate over multiple
ICFR when there is one or more
IT layers and when a service
RAFITs within that layer of
organization is responsible for
technology that are relevant to the
performing control activities.
effective operation of automated
control activities and/or the integrity • Management is required to prepare
of data and information within the IT and retain sufficient documentation
system. to evidence the design,
implementation and operation of
the entity’s GITCs.

Next, if management has determined to direct test controls as part of their

monitoring strategy, management tests the effectiveness of the GITCs designed
to address relevant RAFITs, which may result in the identification of GITC
deficiencies. Additional information about both is provided next, along with
where additional information about each can be found in this chapter.

Monitoring procedures over GITCs GITC deficiencies

(see section 7.4) (see section 7.5)

• GITCs are included in • If GITCs are ineffective,

management’s monitoring. If direct management may not be able to
testing is performed as part of rely on the automated control
monitoring, the testing of operating activities or the integrity of the
effectiveness of GITCs should be information they support, which
performed throughout the period. may impact management’s
• As part of testing, management conclusions on ICFR effectiveness.
should evaluate all the factors • When a GITC deficiency is
considered when designing and identified, management evaluates
documenting a GITC, including its severity and considers its effects

Monitoring procedures over GITCs GITC deficiencies

(see section 7.4) (see section 7.5)
whether the control is properly on the automated control activities
designed to address the RAFIT. that rely on the GITCs.

No discussion about IT-related risks is complete without discussion of

cybersecurity. So, this chapter ends with discussion on the topic that
emphasizes management’s responsibility to:

• evaluate the risk of cybersecurity incidents and cyber-related frauds across

all aspects of the entity’s business operations;
• establish processes, structures and safeguards to mitigate those risks; and
• assess the effects of a cybersecurity incident on the amounts and
disclosures in the financial statements and the entity’s ICFR.

Section 7.6 provides additional information about cybersecurity.

Abbreviations

We use the following abbreviations in this chapter.

COSO Committee of Sponsoring Organizations of the Treadway

Commission
GITC General IT control
ICFR Internal control over financial reporting
PCAOB Public Company Accounting Oversight Board
PRP Process risk point
RAFIT Risk arising from IT
RDE Relevant data element
RMM Risk of material misstatement
SEC Securities and Exchange Commission

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Internal Control

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Internal Control

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Internal control

About this publication .......................................................................................... 2

1. Executive summary ...................................................................................... 4

2. Entity-level controls .................................................................................... 13

3. Risk assessment ........................................................................................ 77

4. Process understanding ............................................................................. 116

5. Process control activities .......................................................................... 168

6. Information used in controls ..................................................................... 253

7. General IT controls ................................................................................... 282

8. Service organizations ............................................................................... 325

9. Identifying and evaluating deficiencies ..................................................... 367

Appendix A ............................................................................................... 426

Appendix B ............................................................................................... 433

Appendix C ............................................................................................... 446

Appendix D ............................................................................................... 468

KPMG Financial Reporting View ..................................................................... 469

US GAAP Handbooks ..................................................................................... 470

Acknowledgments ........................................................................................... 471

ICFR: always in the spotlight, always

Change creates risks and an effective system of ICFR is needed to manage

In this Handbook, we discuss and illustrate the key elements of a risk-based

About this publication

Organization of the text

See Appendix D for a discussion of ‘What’s new’ in the Handbook as compared

• entity-level controls are policies, procedures and structures that operate at

• control activities include process control activities and GITCs;

• process control activities mitigate a specific risk point within a business

• GITCs support the continued effective operation of automated process

AICPA American Institute of Certified Public Accountants

Risk points in processes that could result in a material misstatement

Throughout the process, identify and evaluate deficiencies

6. Information used in controls 7. General IT controls 8. Service organizations

Identify information and RDEs Identify systems utilized – Service organization

Identify risks in IT layers related Manual

Control activities or GITCs to

While a risk-based approach to designing, implementing, maintaining and

block on a journey to effective ICFR and, in the case of an assessment of ICFR,

There are five interrelated components of internal control established in the

Each of the five components and 17 principles is covered in more detail

Read more: Section 2.2 and Appendix A.

Entity-level controls are prevalent in the following components of ICFR.

Control environment Risk assessment

Control environment Risk assessment

Information and communication Monitoring activities

Read more: Chapter 2 and Appendix A

Identifying the relevant risks to financial reporting is an essential component of

The following are specific activities involved in executing an effective risk

• Consideration of materiality. Materiality involves both quantitative and

• Scoping of accounts and disclosures. Management identifies significant

• Scoping of components. Management determines which of the entity’s

• Identifying and assessing fraud risks. Management must assess the

• Consideration of changes that could impact ICFR. Management’s risk

Documentation of risk assessment often involves the creation and maintenance

Read more: Chapter 3

Identifying and documenting RMMs and PRPs

PRPs that could result in RMMs should be documented in sufficient detail to

Obtaining and documenting process understanding

The documentation of process understanding should be of sufficient detail to

Management also considers each of the following in its process understanding.

• Financial reporting and disclosures. Understand the period-end financial

• Estimates. Management should identify where there are estimates or

• Journal entries. Management obtains an understanding of business

Read more: Chapter 4

Process control activities

and procedures established to mitigate (either directly or indirectly) RMMs in the

An entity’s ICFR is effective when it provides reasonable assurance that its

The following are considerations in designing a process control activity.

Control objective Nature and type of control

Frequency Judgment involved

Level of precision Investigation and resolution process

Authority and competence of the Information used in the performance

Read more: Chapter 5

Information used in controls

Once information used in controls is identified and the source is determined,

Management’s evaluation of the reliability of external information considers the

Throughout the process of identifying information used in controls and