Internal Control Frameworks (COSO)
The COSO Internal Control Integrated Framework is the standard used on the CPA exam for evaluating internal controls. Auditors must understand its components, principles, and how deficiencies are classified and communicated.
COSO Five Components of Internal Control
| Component | Description | Key Elements |
|---|---|---|
| Control Environment | The foundation; sets the tone of the organization | Integrity and ethical values; board oversight; organizational structure; commitment to competence; accountability |
| Risk Assessment | Identifying and analyzing risks to achieving objectives | Specifying objectives; identifying risks; assessing fraud risk; identifying significant changes |
| Control Activities | Actions established through policies and procedures | Segregation of duties; authorization; physical controls; IT general controls; reconciliations |
| Information & Communication | Relevant information is identified, captured, and communicated | Quality information; internal communication; external communication |
| Monitoring Activities | Ongoing evaluations to assess whether controls are operating | Ongoing monitoring; separate evaluations; communicating deficiencies |
Memory aid (CR-CIMM): Control environment, Risk assessment, Control activities, Information & communication, Monitoring.
The 17 COSO Principles
| # | Principle | Component |
|---|---|---|
| 1 | Demonstrates commitment to integrity and ethical values | Control Environment |
| 2 | Exercises oversight responsibility | Control Environment |
| 3 | Establishes structure, authority, and responsibility | Control Environment |
| 4 | Demonstrates commitment to competence | Control Environment |
| 5 | Enforces accountability | Control Environment |
| 6 | Specifies suitable objectives | Risk Assessment |
| 7 | Identifies and analyzes risk | Risk Assessment |
| 8 | Assesses fraud risk | Risk Assessment |
| 9 | Identifies and analyzes significant change | Risk Assessment |
| 10 | Selects and develops control activities | Control Activities |
| 11 | Selects and develops general controls over technology | Control Activities |
| 12 | Deploys through policies and procedures | Control Activities |
| 13 | Uses relevant information | Information & Communication |
| 14 | Communicates internally | Information & Communication |
| 15 | Communicates externally | Information & Communication |
| 16 | Conducts ongoing and/or separate evaluations | Monitoring |
| 17 | Evaluates and communicates deficiencies | Monitoring |
Internal Control Deficiency Classification
| Deficiency Level | Definition | Communication Requirement |
|---|---|---|
| Deficiency | A control does not allow management or employees to prevent or detect misstatements on a timely basis | May communicate to management (not required) |
| Significant Deficiency | A deficiency or combination that is less severe than a material weakness yet important enough to merit attention by those charged with governance | Must communicate in writing to those charged with governance |
| Material Weakness | A deficiency or combination where there is a reasonable possibility that a material misstatement will not be prevented or detected on a timely basis | Must communicate in writing to management AND those charged with governance |
Segregation of Duties (Key Internal Control)
The four functions that must be separated:
- Authorization: Approving transactions (management function)
- Recording: Maintaining accounting records (accounting/bookkeeping)
- Custody: Physical access to assets (warehouse, cashier)
- Reconciliation: Comparing records to actual assets (independent verification)
Key rule: No single employee should perform more than one of these functions for the same class of transactions.
IT General Controls (ITGCs)
- Access controls: Logical and physical access restrictions to programs and data
- Change management: Controls over program changes and system updates
- Computer operations: Job scheduling, backup procedures, incident management
- Program development: System development lifecycle (SDLC) controls
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