| Booklet:
Audit
Section: Risk
Assessment and Risk-Based Auditing
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Action Summary

An
effective risk-based auditing program will cover all of an institution’s
major activities. The frequency and depth of each area’s audit will
vary according to the risk assessment of that area. Examiners should determine
whether the audit function is appropriate for the size and complexity
of the institution.
PROGRAM ELEMENTS
Properly designed risk-based audit programs increase audit efficiency
and effectiveness. The sophistication and formality of risk-based audits
may vary depending on the institution’s size and complexity. To
determine the appropriate level of audit coverage for the organization’s
IT environment, management should define an effective risk assessment
methodology. This assessment methodology should provide the auditor and
the board with objective information to prioritize the allocation of audit
resources properly. Risk-based IT audit programs should:
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Identify
the institution’s data, application and operating systems, technology,
facilities, and personnel; |
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Identify
the business activities and processes within each of those categories; |
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Include
profiles of significant business units, departments, and product lines,
or systems, and their associated business risks and control features,
resulting in a document describing the structure of risk and controls
throughout the institution; |
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Use
a measurement or scoring system that ranks and evaluates business
and control risks for significant business units, departments, and
products; |
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Include
board or audit committee approval of risk assessments and annual risk-based
audit plans that establish audit schedules, audit cycles, work program
scope, and resource allocation for each area audited; |
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Implement
the audit plan through planning, execution, reporting, and follow-up;
and |
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Include
a process that regularly monitors the risk assessment and updates
it at least annually for all significant business units, departments,
and products or systems. |
RISK
SCORING SYSTEM
A successful risk-based IT audit program can be based on an effective
scoring system.
In
establishing a scoring system, the board of directors and management should
ensure the system is understandable, considers all relevant risk factors,
and, to the extent possible, avoids subjectivity. Major risk factors commonly
used in scoring systems include the following:
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The
adequacy of internal controls; |
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The
nature of transactions (for example, the number and dollar volumes
and the complexity); |
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The
age of the system or application; |
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The
nature of the operating environment (for example, changes in volume,
degree of system and reporting centralization, sensitivity of resident
or processed data, the impact on critical business processes, potential
financial impact, planned conversions, and economic and regulatory
environment); |
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The
physical and logical security of information, equipment, and premises; |
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The
adequacy of operating management oversight and monitoring; |
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Previous
regulatory and audit results and management’s responsiveness
in addressing issues; |
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Human
resources, including the experience of management and staff, turnover,
technical competence, management’s succession plan, and the
degree of delegation; and |
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Senior
management oversight. |
Auditors
should develop written guidelines on the use of risk assessment tools
and risk factors and review these guidelines with the audit committee
or the board of directors. The sophistication and formality of guidelines
will vary for individual institutions depending on their size, complexity,
scope of activities, geographic diversity, and various technologies used.
The institution can rely on standard industry practice or on its own experiences
to define risk scoring. Auditors should use the guidelines to grade or
assess major risk areas and to define the range of scores or assessments
(e.g., groupings such as low, medium, and high risk or a numerical sequence
such as 1 through 5).
The
written risk assessment guidelines should specify the following elements:
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A
maximum length for audit cycles based on the risk scores. (For example,
some institutions set audit cycles at 12 months or less for high-risk
areas, 24 months or less for medium-risk areas, and up to 36 months
for low-risk areas. Audit cycles should not be open-ended.); |
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The
timing of risk assessments for each department or activity. (Normally
risks are assessed annually, but more frequent assessments may be
needed if the institution experiences rapid growth or significant
change in operation or activities.); |
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Documentation
requirements to support scoring decisions; and |
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Guidelines
for overriding risk assessments in special cases and the circumstances
under which they can be overridden. (For example, the guidelines should
define who can override assessments, and how the override is approved,
reported and documented.) |
Numerous industry groups offer resources where institutions can obtain
matrices, models, or additional information on risk assessments. Among
these groups are: ISACA, American Bankers Association (ABA), American
Institute of Certified Public Accountants (AICPA), and IIA. Day-to-day
management of the risk-based audit program rests with the internal audit
manager, who monitors the audit scope and risk assessments to ensure that
audit coverage remains adequate. The internal audit manager also prepares
reports showing the risk rating, planned scope, and audit cycle for each
area. The audit manager should confirm the risk assessment system’s
reliability at least annually or whenever significant changes occur within
a department or function. Operating department managers and auditors should
work together in evaluating the risk in all departments and functions
by reviewing risk assessments to determine their reasonableness.
Auditors
should periodically review the results of internal control processes and
analyze financial or operational data for any impact on a risk assessment
or scoring. Accordingly, operating management should be required to keep
auditors up to date on all major changes in departments or functions,
such as the introduction of a new product, implementation of a new system,
application conversions, or significant changes in organization or staff.
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