Pub. 5 2014 Issue 1
spring 2014 17 West Virginia Banker your existing documentation. Also, consider mapping the 17 principles to existing controls and identify what is currently covered and missing. 3. Take advantage of changes to re-engineer processes and systems – Management, internal audit and risk management departments should consider this transition as a time to implement process changes to improve control efficiency and effectiveness, including integration with the Enterprise Risk Management function. 4. Start early – Internal auditors and risk management groups should consider the updated Framework within the context of the current year internal audit planning and execution pro- cess, as these groups are executing walkthroughs and testing. COSO has publicly stated its belief that “users should transition their applications and related documentation to the updated Framework as soon as is feasible under their particular circum- stances.” Paul Beswick, chief accountant of the SEC, noted in a speech on May 30, 2013, that the “SEC staff plans to monitor the transition for issuers using the 1992 Framework to evaluate whether and if any staff or commission actions become necessary or appropriate at some point in the future. However, at this time, I will simply refer users of the COSO framework to the statements COSO has made about their new framework and their thoughts about transition.” 1 We encourage companies using the 1992 Framework to begin assessing how the updated Framework will impact their organiza- tion and transitioning to the updated Framework. Because different organizations have different circumstances, the extent of time necessary to assess existing systems of internal control and implement the transition to the updated Framework will vary from organization to organization. The updated Framework provides organizations with tools and guidance to update their internal control systems to better match today’s ever-changing business environments. Companies that start early and embrace the opportunity to make positive changes will find ways to improve efficiency and effectiveness of their control systems. n 1- Source: Remarks at the 32nd Annual SEC and Financial Reporting Institute Conference by Paul Beswick About the author: Wesley Allen is a senior manager in the Financial Institution Services Group at Dixon Hughes Good- man LLP. He has more than 10 years of public accounting experience, working with financial institutions in the areas of process and control evaluation, external financial reporting to regulatory agencies and investors and compliance with laws and regulations. He works primarily in the area of financial statement audits, SOX compliance, control evaluation, mergers and acquisitions and SEC reporting. To learn how our advisors can assist your organization with planning or implementing the updated Framework, contact Wesley Allen at Wesley.Allen@ dhgllp.com. www. gsblsu .org You’re never too old to set another goal or to dream a new dream. We’re 65 and not ready to retire. The Graduate School of Banking at LSU has educated thousands of young bankers and we’re just getting started. Our up-to-date curriculum addresses the future leadership needs of your bank. Contact us today because those who keep learning stay young and continue to venture forward. 225-766-8595 • 4273 Highland Road, Baton Rouge, LA 70808 65 YEARS STRONG Growing up without growing old. For information on our 2014 Session: May 25 – June 6 Photo taken in 1958 as bankers arrived at the Baton Rouge airport.
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