One Accounting Firm's Response to Addressing Risk,
Post Sarbanes-Oxley
The evolution
of risk management through the lens of KPMG was the focus of Scott Showalter's
October 28th presentation to the Accountancy Lyceum. Showalter, a partner
at KPMG, LLP, explained that risk management, post Enron, is taken more
seriously and has become institutionalized. "We have a vice chairman
of risk and regulatory matters, [a position] that did not even exist before
Enron."
During
a brief overview of the company's risk management structure, Showalter
cited the importance of KPMG's security division, which is headed by a
former CIA operative. Not only do employees undergo background checks,
but such scrutiny is given to management of public company clients of
KPMG as well. "One of the things we did, before Enron, was require
background checks of major clients. You'd be surprised how some CFO's
have bounced from company to company and they've done it to every company
they've been with-where they falsify the forms. If a CFO of a company
has been involved in a major re-statement, we will not accept that client."
KPMG's
system of quality controls is all encompassing and has become an accepted
part of the company's structure. "If you walk up to a public accounting
firm and ask them about risk management, they will miss 90% of what I'm
going to tell you because it's so much built into what they do that they
don't recognize it as risk management."
Among
the cogs in KPMG's engine of quality control are:
-
the
compliance and ethics hotline, a reporting system for any illegal
or unethical activity within the company
-
KICS,
KPMG's independent compliance system, which reports all of the firm's
investments
-
a
policy of dispute resolution, which is a defined process on how to
deal with professional disagreements
-
an
online, international global conflict system called Sentinel that
monitors the independence of partners and their clients and tracks
the securities of the firm's partners
Showalter
elaborated on Sentinel's emergence as a tool for quality control. "We
must be able to monitor the services and the conflicts globally. While
all of us say we're global firms, we are not actually global organizations;
we're actually a holding company that, in KPMG's circumstance, has 135
member firms around the world that agree to work on their common structure.
But each one of us, legally and structurally, is independent in the countries
that we sit in. "
Thus,
explains Showalter, the Sentinel program became absolutely necessary in
tracking who the other 134 member firms are serving. "We record what
services we provide to clients because, under Sarbanes-Oxley, I have to
get approval to be able to perform certain services. When you extend a
non-audit service to a client who is not approved by the audit committee,
both the audit committee and the auditor is at risk."
Sentinel
offers features that facilitate prevention and management. An automatic
email, for example, is usually sent to the lead partner for a client when
an account is opened that outlines the client's overall risk to KPMG.
Partners can also use Sentinel to perform queries on everything from client
location to the services that KPMG is providing.
Sarbanes-Oxley
has also impacted personnel management at accountancy firms. "With
the Sarbanes-Oxley mandate that prevents the partner assigned to an account
and the internal reviewing partner from working an account for more than
five years in either role, we have had to put someone in charge of overseeing
partner rotation or the cycling of partners from one case to another when
their five years are up."
KPMG's
continual monitoring of its clients has sparked an increase in the number
of clients that the firm has dropped. "We've looked at our risk portfolio,
we don't like some of the risks we've had, and we're acting on that. Washington
isn't happy with the number of clients the Big Four firms have resigned
from."
The federal
government's campaign to uphold the ethics in business has Showalter's
support. "The world has really changed a lot, I think for the positive.
My oldest son is beginning in the profession so I hope I'm leaving him
a good impression with all of this."
D. Scott
Showalter is presently a partner in the Department of Professional Practice
at KPMG LLP. He has served on numerous leadership councils within the
firm and since joining KPMG in 1975, he has worked as a technical advisor
and lead partner to many of the company's largest and most complex public
sector clients. He co-teaches several accountancy classes at the U of
I. Showalter currently resides in New York.
--Michael
Romain
November 2004
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