How Internal Auditors can win The War against Spreadsheet Fraud

To prevent another round of million dollar scandals due to fraudulent manipulations on spreadsheets, regulatory bodies have launched major offensives against these well-loved User Developed Applications (UDAs). Naturally, internal auditors are front and center in carrying out these offensives.

While regulations like the Sarbanes-Oxley Act, Dodd-Frank Act, and Solvency II can only be effective if end users are able to carry out the activities and practices required of them, auditors need to ascertain that they have. Sad to say, when it comes to spreadsheets, that is easier said than done.

Because spreadsheets are loosely distributed by nature, internal auditors always find it hard to: locate them, identify ownership, and trace their relationships with other spreadsheets. Now, we’re still talking about naturally occurring spreadsheets. How much more with files that have been deliberately tampered?

Spreadsheets can be altered in a variety of ways, especially if the purpose is to conceal fraudulent activities. Fraudsters can, for instance:

  • hide columns or rows,
  • perform conditional formatting, which changes the appearance of cells depending on certain values
  • replace cell entries with false values either through direct input or by linking to other spreadsheet sources
  • apply small, incremental changes in multiple cells or even spreadsheets to avoid detection
  • design macros and user defined functions to carry out fraudulent manipulations automatically

Recognising the seemingly insurmountable task ahead, the Institute of Internal Auditors released a guide designed specifically for the task of auditing user-developed applications, which of course includes spreadsheets.

But is this really the weapon internal auditors should be wielding in their quest to bring down spreadsheet fraud? Our answer is no. In fact, we believe no such weapon has to be wielded at all?because the only way to get rid of spreadsheet fraud is to eliminate spreadsheets once and for all.

Imagine how easy it would be for internal auditors to conduct their audits if data were kept in a centralised server instead of being scattered throughout the organisation in end-user hard drives.

And that’s not all. Because a server-based solution can be configured to have its own built-in controls, all your data will be under lock and key; unlike spreadsheet-based systems wherein storing a spreadsheet file inside a password-protected workstation does not guarantee equal security for all the other spreadsheets scattered throughout your company.

Learn more about Denizon’s server application solutions and discover a more efficient way for your internal auditors to carry out their jobs.

More Spreadsheet Blogs

 

Spreadsheet Risks in Banks

 

Top 10 Disadvantages of Spreadsheets

 

Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry

 

How Internal Auditors can win the War against Spreadsheet Fraud

 

Spreadsheet Reporting – No Room in your company in an age of Business Intelligence

 

Still looking for a Way to Consolidate Excel Spreadsheets?

 

Disadvantages of Spreadsheets

 

Spreadsheet woes – ill equipped for an Agile Business Environment

 

Spreadsheet Fraud

 

Spreadsheet Woes – Limited features for easy adoption of a control framework

 

Spreadsheet woes – Burden in SOX Compliance and other Regulations

 

Spreadsheet Risk Issues

 

Server Application Solutions – Don’t let Spreadsheets hold your Business back

 

Why Spreadsheets can send the pillars of Solvency II crashing down

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How the Dodd-Frank Act affects Investment Banking

The regulatory reform known as the Dodd-Frank Act has been hailed as the most revolutionary, comprehensive financial policy implemented in the United States since the years of the Great Depression. Created to protect consumers and investors, the Dodd-Frank Act is made up of a set of regulations and restrictions overseen by a number of specific government departments. As a result of this continuous scrutiny, banks and financial institutions are now subject to more-stringent accountability and full-disclosure transparency in all transactions.

The Dodd-Frank Act was also created to keep checks and balances on mega-giant financial firms that were considered too big to crash or default. This was especially deemed crucial after the collapse of the powerhouse financial institution Lehman Brothers in 2008. The intended result is to bring an end to the recent rash of bailouts that have plagued the U.S. financial system.

Additionally, the Dodd-Frank Act was created to protect consumers from unethical, abusive practices in the financial services industry. In recent years, reports of many of these abuses have centered around unethical lending practices and astronomically-high interest rates from mortgage lenders and banks.

Originally created by Representative Barney Frank, Senator Chris Dodd and Senator Dick Durbin, the Dodd-Frank Wall Street Reform and Consumer Protection Act, as it is officially called, originated as a response to the problems and financial abuses that had been exposed during the nation’s economic recession, which began to worsen in 2008. The bill was signed into law and enacted by President Obama on July 21, 2010.

Although it may seem complicated, the Dodd-Frank Act can be more easily comprehended if broken down to its most essential points, especially the points that most affect investment banking. Here are some of the component acts within the Dodd-Frank Act that directly involve regulation for investment banks and lending institutions:

* Financial Stability Oversight Council (FSOC): The FSOC is a committee of nine member departments, including the Securities and Exchange Commission, the Federal Reserve and the Consumer Financial Protection Bureau. With the Treasury Secretary as chairman, the FSOC determines whether or not a bank is getting too big. If it is, the Federal Reserve can request that a bank increase its reserve requirement, which is made up of funds in reserve that aren’t being used for business or lending costs. The FSOC also has contingencies for banks in case they become insolvent in any way.

? The Volcker Rule: The Volcker Rule bans banks from investing, owning or trading any funds for their own profit. This includes sponsoring hedge funds, maintaining private equity funds, and any other sort of similar trading or investing. As an exception, banks will still be allowed to do trading under certain conditions, such as currency trading to circulate and offset their own foreign currency holdings. The primary purpose of the Volcker Rule is to prohibit banks from trading for their own financial gain, rather than trading for the benefit of their clients. The Volcker Rule also serves to prohibit banks from putting their own capital in high-risk investments, particularly since the government is guaranteeing all of their deposits. For the next two years, the government has given banks a grace period to restructure their own funding system so as to comply with this rule.

? Commodity Futures Trading Commission (CFTC): The CFTC regulates derivative trades and requires them to be made in public. Derivative trades, such as credit default swaps, are regularly transacted among financial institutions, but the new regulation insures that all such trades must now be done under full disclosure.

? Consumer Financial Protection Bureau (CFPB): The CFPB was created to protect customers and consumers from unscrupulous, unethical business practices by banks and other financial institutions. One way the CFPB works is by providing a toll-free hotline for consumers with questions about mortgage loans and other credit and lending issues. The 24- hour hotline also allows consumers to report any problems they have with specific financial services and institutions.

? Whistle-Blowing Provision: As part of its plan to eradicate corrupt insider trading practices, the Dodd-Frank Act has a proviso allowing anyone with information about these types of violations to come forward. Consumers can report these irregularities directly to the government, and may be eligible to receive a financial reward for doing so.

Critics of the Dodd-Frank Act feel that these regulations are too harsh, and speculate that the enactment of these restrictions will only serve to send more business to European investment banks. Nevertheless, there is general agreement that the Dodd-Frank Act became necessary because of the unscrupulous behaviour of the financial institutions themselves. Although these irregular and ultimately unethical practices resulted in the downfall of some institutions, others survived or were bailed out at the government’s expense.

Because of these factors, there was more than the usual bi-partisan support for the Dodd-Frank Act. As a means of checks and balances, the hope is that the new regulations will make the world of investment banking a safer place for the consumer.

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ESOS Guide for UK Manufacturers Available

The Engineering Employers’ Federation (EEF) is the UK’s largest sectoral structure. Its goal is to promote the interests of manufacturing, engineering and technology-based businesses in order to enhance their competitiveness.

EEF has positioned itself in London and Brussels in order to be in a position to lobby at EU and Westminster level. Part of its role is helping its members adapt to change and capitalise on it. When it discovered that a third of UK manufacturers must comply with ESOS (and 49% had not even heard of it) EEF decided it was time to publish a handbook for its members.

According to EEF’s head of climate and environment policy Gareth Stace, For the many manufacturers that have already taken significant steps to improve energy efficiency, ESOS can be viewed as a ?stock taking exercise?, ensuring that momentum is maintained and new measures are highlighted and taken when possible?.

He goes on to add that others that have not begun the process should view it as an ‘impetus’ to go head down and find the most cost-effective ways to slash energy costs. Ecovaro adds that they would also have the opportunity to reduce carbon emissions almost as a by-product.

Firms with more than 250 employees, over 250 million revenue or both must comply with ESOS across all UK sectors. In simplest terms, they must have conducted an energy audit by 5th December 2015, and logged their energy saving plan with the Environmental Agency that is Britain?s sustainability watchdog.

The Department of Energy & Climate Change (DEEC) that oversees it believes that large UK businesses are wasting ?2.8 billion a year on electricity they do not need. Clearly it makes sense to focus on larger targets; however EcoVaro believes those halfway to the threshold should voluntarily comply if cutting their energy bills by 25% sounds appealing.

We are able to assist with interpreting their energy audits. These are often a matter of installing sub-meters at distribution points, and reading these for a few representative months to establish a trend. Meters are inexpensive compared to electricity costs, and maintenance teams can install them during maintenance shutdowns.

Ecovaro helps these firms process the data into manageable summaries using cloud-based technology. This is on a pay-when-used basis, and hence considerably cheaper than acquiring the software, or appointing a consultant.

The Connection Between Six Sigma and CRM

Six Sigma is an industrial business strategy directed at improving the quality of process outputs by eliminating errors and system variables. The end objective is to achieve a state where 99.99966% of events are likely to be defect free. This would yield a statistical rating of Sigma 6 hence the name.

The process itself is thankfully more user-friendly. It presents a model for evaluating and improving customer relationships based on data provided by an automated customer relations management (CRM) system. However in the nature of human interaction we doubt the 99.99966% is practically achievable.

Six Sigma Fundamentals

The basic tenets of the business doctrine and the features that set off are generally accepted to be the following:

  1. Continuous improvement is essential for success
  1. Business processes can be measured and improved
  1. Top down commitment is fundamental to sustained improvement
  1. Claims of progress must be quantifiable and yield financial benefits
  1. Management must lead with enthusiasm and passion
  1. Verifiable data is a non-negotiable (no guessing)

Steps Towards the Goal

The five basic steps in Six Sigma are define the system, measure key aspects, analyse the relevant data, improve the method, and control the process to sustain improvements. There are a number of variations to this DMAIC model, however it serves the purpose of this article. To create a bridge across to customer relationships management let us assume our CRM data has thrown out a report that average service times in our fast food chicken outlets are as follows.

<2 Minutes 3 to 8 Minutes 9 to 10 Minutes >10 Minutes
45% 30% 20% 5%
Table: Servicing Tickets in Chippy?s Chicken Caf?s

Using DMAIC to unravel the reasons behind this might proceed as follows

  • Define the system in order to understand the process. How are customers prioritised up front, and does the back of store follow suit?
  • Break the system up into manageable process chunks. How long should each take on average? Where are bottlenecks most likely to occur?
  • Analyse the ticket servicing data by store, by time of day, by time of week and by season. Does the type of food ordered have a bearing?
  • Examine all these variables carefully. Should there for example be separate queues for fast and slower orders, are there some recipes needing rejigging
  • Set a goal of 90% of tickets serviced within 8 minutes. Monitor progress carefully. Relate this to individual store profitability. Provide recognition.

Conclusion

A symbiotic relation between CRM and a process improvement system can provide a powerful vehicle for evidencing customer care and providing feedback through measurable results. Denizon has contributed to many strategically important systems.?

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