On May 14, 2013, the Committee of Sponsoring Organizations of the Treadway Commission (COSO) issued the revised version of its Internal Control-Integrated Framework (the Framework). The revised Framework will help improve implementation of internal control but further adjustments are warranted to align internal control across the globe and to help organizations better manage their risks and improve their overall performance.

The Professional Accountants in Business (PAIB) Committee of the International Federation of Accountants (IFAC) has been closely involved in the revision, with two representatives on the COSO advisory council for the project. Additionally, the PAIB Committee submitted two formal comment letters to both COSO internal control exposure drafts.

Key Features of the Revised Framework

The revised Framework uses the same definition of internal control as the previous version and builds on the same five components of internal control: the control environment, risk assessment, control activities, information and communication, and monitoring activities. The Framework also continues to emphasize the importance of management judgment in designing, implementing, and conducting internal control, and in assessing its effectiveness.

So what has changed? The revised Framework now:

• articulates the fundamental concepts underlying the five components in the form of 17 guiding principles and more detailed points of focus;
• takes into account environmental changes, such as increased globalization, complexity, and regulation, the growing importance of technology, and increased expectations for better governance oversight and fraud prevention;
• expands the operations objective from “effective and efficient use of the entity’s resources” to “effectiveness and efficiency of the entity’s operations, including operational and financial performance goals, and safeguarding assets against loss;”
• broadens the reporting objective from “published financial statements” to “internal and external financial and non-financial reporting;” and
• provides additional approaches and examples relevant to operations, compliance, and non-financial reporting objectives.

COSO also issued two additional publications.

• Illustrative Tools for Assessing Effectiveness of a System of Internal Control assists users when assessing effectiveness of internal control based on the requirements of the Framework.
• Internal Control over External Financial Reporting: A Compendium of Approaches and Examples assists users when applying the Framework to external financial reporting objectives.

The revised Framework will supersede the original Framework at the end of 2014, giving organizations time to transition. COSO anticipates a relatively easy transition process for those organizations that have properly applied the original Framework (1992). In fact, the new principles and points of focus should make it easier for organizations to see what is covered and where gaps may exist.

IFAC PAIB Committee’s View

The IFAC PAIB Committee commends COSO for being one of the first and foremost thought leaders in internal control, starting with the publication of the original Framework and followed by a series of related high-quality publications. The committee agrees that while many of the underlying concepts of the original Framework have proven themselves over time, global developments, including the financial crises, in recent years required a revision.

However, while the revised Framework represents a step forward in articulating principles of effective internal control and incorporating a number of considerations relevant to today’s complex business environment, there remains work to be done to advance and harmonize risk management and internal control guidelines across the globe and to better support organizations dealing with the many economic, social, and environmental challenges they face.

The PAIB Committee believes that it is in COSO’s long-term interest to continue evolving its Framework in order to make it more relevant to the broader global community and the challenges faced, and stands ready to assist COSO make progress in this area. The PAIB Committee has formulated a number of recommendations for further development.

• For the Framework to remain relevant in an environment of greater global integration, COSO should further integrate its Internal Control Framework with its Enterprise Risk Management (ERM) Framework, released in 2004, as well as better align it with the concepts and terminology in other frameworks, standards, and guidelines on governance, risk management, and internal control from across the globe. This will enable organizations to make internal control a natural and integrated part of their overall risk management and governance arrangements.
• The Framework should embrace a wider perspective than its current limited application to internal control over reporting, operations, and compliance, for example, by broadening the definition of internal control so as to permit the inclusion of other areas, such as business strategy and finance, in which internal control also plays a crucial role. Before the string of financial crises, many organizations were overly focused on financial reporting controls. These crises highlighted the fact that many, if not most, of the risks that affected organizations derived from external circumstances. This includes the increasing social and environmental risks that organizations encounter, such as mitigating the threats and taking advantage of the opportunities related to global warming.
• As the achievement of objectives is at the heart of the COSO definition of internal control, objective setting should be included in the components of internal control. This would assure better alignment with the related COSO ERM Framework, which includes objective setting as a separate component, and emphasize that strengthening an entity’s systems of internal control can only be done from the perspective of the organization’s objectives.
• The Framework should further align the various concepts and terminology in relation to risk management and internal control with the other standards, guidance, and frameworks that have been issued since the conception of the original Framework. This includes the definitions of risk and internal control, balancing the positive and negative sides of risk, and rethinking of difficult to understand concepts such as risk appetite and inherent controls.

Constructive Dialogue

IFAC is well-positioned to facilitate a constructive dialogue with the issuers of standards, guidance, and frameworks in the area of governance, risk management, and internal control across the world on how the terminology, various concepts, and guidelines could be better aligned in the future.[1]

Further international alignment is an ambitious and challenging goal, but the potential benefits are significant. It is up to all those responsible for developing, implementing, using, and enforcing requirements and guidelines on governance, risk management, and internal control to work together to produce globally-aligned terminology, concepts, and guidelines that are relevant to all. IFAC and the PAIB Committee look forward to contributing to this collaborative effort.

Additional IFAC Guidance

Despite the existence of sound internal control guidelines, such as the revised COSO Framework, it is often theapplication of such guidelines that fails or could be further improved in many organizations. With the International Good Practice Guidance, Evaluating and Improving Internal Control in Organizations (IFAC, 2012), the PAIB Committee provides a practical guide focused on how professional accountants in business can support their organization in evaluating and improving internal control as an integral part of its governance system and risk management. The guidance is complementary to existing internal control guidelines and is based on those internal control matters that often cause difficulties in practice. Both the full guidance as well as an executive summary are available free of charge on the IFAC website. 

The latest IFAC SMP Quick Poll showed that the vast majority (73%) of the nearly 4,000 small- and medium-sized accounting practices (SMPs) surveyed are either currently providing or have plans to provide sustainability services to their clients, suggesting that there’s a sizeable market for these services among the small businesses that SMPs typically serve.

Of those who offer sustainability services, many offer more than one service; the most common service provided, indicated by over 75% of respondents, is advisory services. Reporting and assurance are the next most commonly provided services with about 50% and 40%, respectively.

“The widespread provision of sustainability services suggests that small businesses are increasingly recognizing the tangible benefits of operating more sustainably. This, in turn, seems to be fueling a desire to seek advice from their professional accountants,” commented SMP Committee Chair Giancarlo Attolini. “SMPs can help their SME clients in many ways, for example, advising on the costs and benefits of behavioral changes aimed at reducing waste, appraising potential investments in alternate sources of energy, and assisting with the implementation of an environmental management system (EMS). This is a large and growing area of demand that SMPs need to be prepared to meet.”

Results varied somewhat by size of practice and region. The larger the size of the SMP, the more likely it was to be offering sustainability services. More than half of the practices with 21 or more professional accountants currently offer these types of services, compared to 37% of sole practitioners. By region, Asia and Africa/Middle East were most likely to offer sustainability services, while Central/South America and Australasia/Oceania were the least likely.

The report also includes results on the biggest challenges facing SMPs and their clients, among other topics. As in previous polls, burden of regulation and economic pressures ranked highest. However, tensions around rising costs, competitive stresses, and keeping up with technology gained in importance. This changing mix suggests that SMPs are enjoying a more favorable economic climate and planning for growth.

See the full report in the SMP Committee area of the IFAC site: www.ifac.org/SMP. Due to different response rates in different geographic areas, results may not be statistically representative of global or regional populations of SMPs.

The mid-year 2013 poll received 3,678 responses and was conducted in 16 languages from May 29 to July 8. The poll, conducted twice annually, is intended to take a snapshot of key challenges and trends influencing SMPs globally. IFAC wishes to thank the many member and regional organizations that helped with translation and distribution of the poll.

About the SMP Committee
The SMP Committee of the International Federation of Accountants (IFAC) represents the interests of professional accountants operating in small- and medium-sized practices (SMPs). The committee develops guidance and tools and works to ensure the needs of the SMPs are considered by standard setters, regulators, and policy makers. The committee also speaks out on behalf of SMPs to raise awareness of their role and value, especially in supporting SMEs, and the importance of the small business sector overall.

About IFAC
IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 173 members and associates in 129 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

This report summarizes the results of the IFAC SMP Quick Poll, conducted May 29-July 8, 2013. This edition of the poll received 3,686 responses and was conducted in 16 languages.

Co-hosted with the Institute of Certified Public Accountants of Uganda
and the Pan African Federation of Accountants 

IFAC President Warren Allen and IIA President/CEO Richard Chambers discuss the recently signed Memorandum of Understanding with Compliance Week.

The International Federation of Accountants (IFAC) and The Institute of Internal Auditors (The IIA) have signed a Memorandum of Understanding (MoU) to create a formal basis for the advancement of risk management and internal controls toward a common goal of enhanced governance.

Signed today at The IIA’s International Conference, the IFAC-IIA MoU outlines a new plan for enhanced coordination, collaboration, and resource sharing that will draw on the strengths and expertise of the two organizations. Both are engaged in the restoration of public confidence in business reporting and enhancing governance processes in the private and public sectors.

“This Memorandum of Understanding further strengthens the important relationship between The IIA and IFAC. It represents our united commitment to serve the public interest and restore the confidence of the general public in business reporting,” said Richard Chambers, president and chief executive officer of The IIA.

As outlined in the MoU, IFAC and IIA recognize that the following are fundamental to an organization fulfilling its objectives, implementing reliable financial management and reporting, and serving its stakeholders and the public interest:

• The implementation of international auditing and accounting standards;
• Strong risk management practices, including the design and implementation of effective and efficient internal controls; and
• An effective governance process.

“IFAC welcomes this opportunity to continue our collaboration with The IIA,” said IFAC President Warren Allen. “Our professions are closely related, we share common goals, and address the same issues. Joining our efforts and voices therefore makes sense.”

Through the development of an Annual Work Plan, the organizations will create structures and processes appropriate to share information and best practices in government, risk management, and internal control as well as in audit methods and the application of international standards.

About IFAC
IFAC is the global organization for the accountancy profession, dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. It is comprised of 173 members and associates in 129 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

About The IIA
Established in 1941, The IIA serves more than 180,000 members in 190 countries and is the internal audit profession's global voice, chief advocate, and principal educator. The Institute develops and maintains the International Professional Practices Framework for internal auditing, comprising the International Standards for the Professional Practice of Internal Auditing, and certifies professionals through the globally recognized Certified Internal Auditor. Visit www.theiia.org for more information.

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The IFAC Nominating Committee plays a vital role in establishing the expertise of the independent standard-setting boards, the IFAC Board, Compliance Advisory Panel, and IFAC committees by seeking out and identifying the best candidates for vacancies. Whether it is one of the independent standard-setting boards or an IFAC committee, the Nominating Committee examines nominations from around the world, analyzes experience and expertise, and considers diversity when recommending new members and leadership for the boards and committees, all while maintaining transparency and strict adherence to due process. The Nominating Committee, under the oversight of the Public Interest Oversight Board (PIOB), also strives to ensure sufficient nominations are received each year and helps professional accountancy organizations and other stakeholders establish an effective nominations strategy.

The Nominating Committee is comprised of two ex-officio members—the IFAC president and deputy president—and at least four non-ex-officio members, of whom no more than two can be IFAC Board members. There are currently two Board members on the committee—Ana Maria Elorietta and Japheth Katto—although during some years there have been none. For 2013, the non-Board members, or ordinary members, are Margaret Parker, Professor Judy Tsui, and Sir David Tweedie.

I asked committee members to share their experiences and thoughts on the work of the committee in order to increase the knowledge among our stakeholders of the work and diligence involved.

—Warren Allen, IFAC President

1. What made you interested in serving on the Nominating Committee?
   
   Ana Maria Elorrieta: Due to my accumulated knowledge of IFAC, I felt that I had a reasonable understanding of most of the needs at the board and committee level so I realized that I could contribute to the nominations process. Additionally, in so doing, I would be representing Latin America.
   
   Japheth Katto: I wanted to make a contribution to the leadership and governance of IFAC, its committees, and the independent standard-setting boards by being part of the selection of professionals serving on the boards and committees. In my view this is an important exercise as serving the public interest is the foundation of IFAC's mission.
   
   Margaret Parker: My member body contacted me to put my name forward. I was on a nominating committee in my state in Australia so was familiar with the overall requirements of a nominating committee at the local level.
   
   Sir David Tweedie: I believe passionately in global standards, whether they are in accounting, auditing, ethics, or education. If we are to gain acceptance for these standards, we need the very best people the profession can offer to draft them. I wanted to do my best to ensure that the [boards and] committees were filled by those who were respected thinkers in their particular specialisms and had an international outlook rather than being merely placemen.
    
2. Since you became a member, has your view of the Nominating Committee and its work changed? Has serving on the Nominating Committee been what you expected?
   
   Japheth Katto: I always knew that the committee played a very big role and that its job was not an easy one. However, I did not fully appreciate how intricate and complicated the process was, especially when you have many candidates who fit the criteria of "best person for the job."
   
   Margaret Parker: Serving on the committee has been much more than I expected. The rigor and concern for the public interest are foremost in the committee’s mind. I have also come to understand that the work of the committee is vital to the quality of volunteers on the boards and committees.
   
   The committee is very cohesive and cooperative, which adds to the overall enjoyment of the work. On a personal level, it has been a wonderful experience to be on an international committee where the members are from all over the world.
   
   Judy Tsui: I was pleasantly surprised to find out that the Nominating Committee has established such comprehensive and consistent procedures and processes for all the nominations. The PIOB observer, in particular, serves as a monitor of public interest.
   
   Sir David Tweedie: I have been astounded at the thoroughness of the work of the committee. It seeks to be scrupulously fair—it examines the CVs very carefully, then ensures that not one committee member has an undue influence in the result. I have found the work of the committee and its staff extremely professional—far exceeding anything else I have experienced with nominating committees.
    
3. The competition for membership on boards and committees is very high; how does the committee select the “best” candidates for positions?
   
   Ana Maria Elorrieta: This is really a very important activity. We first analyze the profile of the best candidate in accordance with the boards’ and committees’ needs. Then we analyze the CVs received and try to match one to the other. The analysis of the CVs is very detailed work performed individually by each Nominating Committee member, so when we discuss as a group, each member has a point of view on the best candidates. Then we complete our knowledge of the candidates through the interviews to provide the basis for the final decision. It is a very comprehensive process.
   
   Japheth Katto: In arriving at the best candidate for the position, the committee's guiding criteria is the candidate's knowledge, experience, and ability to add value to the board or committee. Before the final decision, other factors, such as geographical and sector (Big 4, small- and medium-sized practices, professional accountants in business, etc.) representation are taken into account. Clearly, it wouldn't be in the public interest if all or most members of a board or committee were from the Big 4 or one region. Diversity is important.
   
   Margaret Parker: The committee members read all the CVs submitted via the Call for Nominations. We also consider the requirements of the boards and committees for which we are recommending candidates. It is, therefore, important for nominees to include their experience relevant to the particular board in their CV. The committee members individually rank the nominees prior to our meeting. At our next face-to-face meeting, a technical voting system is used to rank the nominees who are then chosen for either telephone or face-to-face interviews.
   
   Committee members, together with board/committee chairs, conduct telephone interviews, gleaning the candidates’ experience of the work of the board/committee, their relevant work experience, and what they may bring on a personal level. Written reports of the interviews are provided to the Nominating Committee for further consideration in choosing the recommended nominee.
   
   In making the final choice, all aspects of the “best” person for the job are considered—relevant experience required by the board/committee, regional representation, gender representation, and English language skills.
   
   Sir David Tweedie: Once the CVs have been read by the individual members, we all vote electronically at the same time and then select for interview those nominees that receive the highest number of votes. We usually interview twice as many candidates as there are vacancies. The interviews are carried out by a Nominating Committee member and the chair of the committee [in question]. The notes on these interviews are then passed to the whole committee at the next meeting where the interview results are debated. If there are doubts about the caliber of those interviewed other candidates may be sought from member bodies.
    
4. How is your role as an ordinary (non-Board) member different from a Board member? How is your role as a Board member different from an ordinary (non-Board) member?
   
   Ana Maria Elorrieta: The difference between a Board member and non-Board member is that we have the input from the Board, including suggestions and concerns related to the other boards and committees. This includes discussions around strategy and risks. We can add this perspective to the Nominating Committee discussion.
   
   Japheth Katto: I think as a Board member, I bring the perspective of the Board as a whole. I will know the Board's thinking based on previous experience and on ongoing consultations between the Nominating Committee and the Board.
   
   Margaret Parker: I don’t believe my role as an ordinary member is different from a Board member. We all have a say in the decision making, all have a vote in choosing the candidates for interview, all have an opportunity to provide input after an interview. The Board members will have wider experience with IFAC, which occasionally will impact our decisions; however, generally, there is no difference.
   
   Sir David Tweedie: In most cases, there is no difference between the two roles. The Board members, however, are more experienced with the workings of IFAC—they can explain IFAC policies and answer questions about individuals who have served on IFAC boards/committees in the past or explain the history of certain applications.
    
5. What does serving the public interest, which is embedded in IFAC’s mission, mean to you as a member of the Nominating Committee?
   
   Ana Maria Elorrieta: To serve the public interest is to act with an objective and balanced view and avoid influence of any type. It means to think strategically and with a long-term view, looking to protect the society and not any individual part.
   
   Japheth Katto: Simply put, serving in the public interest means selecting those candidates that are going to work not in the interest of their nominating organization or their employers or regions, who are not going to allow [themselves] to be unduly influenced, and who are going to act with integrity in the interest of the global profession and the public that it serves.
   
   Margaret Parker: To me, serving the public interest means making decisions that are best for the whole rather than a part of the whole. This can be applied from a wide perspective, such as making decisions that are best for the world rather than a particular country or region, or doing what is best for a group rather than the individual. When applying this philosophy to the nominating [process], it means making decisions that are in the best interest of the public at large, rather than the accountancy profession in particular, or a particular region, country, or individual.
   
   Sir David Tweedie: The public interest should be in the DNA of every accountant. In looking at candidates, I look for those that have clearly been involved in public policy issues, have written articles advocating professionalism, or have given time to move the profession forward. Public interest to me is acting in a neutral, unbiased way to present transparent information to society at large and to act with integrity and objectivity without regard to particular interests. I look for this in those who are nominated for the [boards or] committees.
    
6. How does the committee ensure due process in its actions?
   
   Ana Maria Elorrieta: There is a clear and objective process that is carefully followed. There are discussions at each phase, to reaffirm the adequacy of the decisions taken at each stage of the process. Every member is free to contribute and discuss.
   
   Japheth Katto: The committee has procedures and processes that are agreed [to], including Terms of Reference [which are approved by the IFAC Council and the PIOB]. It makes consensus decisions and documents its processes. In addition, its work is observed by the PIOB.
   
   Judy Tsui: Due process is ensured through:
   
   • Open, detailed, and rigorous discussions;
   • Adhering to anonymous electronic voting [to derive a shortlist of candidates];
   • Adhering to the principle of candidate selection based on the “best person for the job” and meeting geographical and gender diversity when possible once the candidates meet performance criteria; and
   • Maintaining the practice of having the board/committee chair and Nominating Committee members conduct telephone interviews for selecting board/committee members, and conducting in-person interviews for selecting IFAC Board and Nominating Committee members, and board/committee chairs.
   Margaret Parker: The committee members are very conscious of working in the public interest and according to the Terms of Reference of the committee. Members of the staff of IFAC who are familiar with the Constitution and regulations surrounding the work of the committee are also in attendance at the meetings to provide input where necessary. However, the meetings of the Nominating Committee are overseen by a member of the PIOB who ensures due process is followed and that the public interest is protected.
   
   Sir David Tweedie: See the answer to question three. Sometimes, however, excellent candidates simply are unable to obtain a place on a committee by virtue of the fact that their country or region is over represented and views from other parts of the world are necessary to give balance to that committee. In such cases, the unsuccessful candidates are frequently advised to reapply for a position. Due process isn’t simply looking for the best candidates but seeking to achieve a balanced composition on any board or IFAC committee.

IFAC President Warren Allen presented “Driving Sustainable Organizational Success” at the Institute of Chartered Accountants of the Caribbean’s (ICAC) 31st Annual Caribbean Conference held June 28 in Barbados.

IFAC believes that high-quality reporting lies at the heart of strong and sustainable organizations, financial markets, and economies, as the disclosure of useful information is crucial for the various internal and external stakeholders who need to make informed decisions regarding an organization’s capacity to create and preserve value. As organizations depend on their stakeholders for their sustainable success, it is in their interest to provide high-quality reports.

The SMP Committee submitted this comment letter to the International Auditing and Assurance Standards Board (IAASB)'s Consultation Paper, A Framework for Audit Quality.