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The US Securities and Exchange Commission (SEC) is planning what could be among the largest
changes in the history of American
companies are more likely to be supported with adequate resources and staff devoted to the
[knesota
accounting-a
rmdo.
College of Business
conversion from Generally Accepted Accounting Principles (GAAP) to Intemational Financial Reporting Standards (IFRS). This article integrates
lessons leamed from previous implementations
mfr:mation systems.
investor relations.
For companies in the UK, Ireland and Italy that have already converted to IFRS, the biggest problem was the unexpected time commitment in understanding IFRS, in training, in assimilating requirements, and, for some, in major changes
lrihs
responsibility in
;ilcuities rS
and Exchange
that audit committees (ACs), chief financial officers (CFOs) and IT auditors can use to identify
career, BrOwn
eE ssreral project
Mltlrs
irnplement
lmilwr StStemS.
hJL
mr
Approximately 29 miliion private businesses and 44,000 certified public accountant (CPA) firms in the US will be required to switch to
IFRS-based standards.l The most likely effective date for an IFRS implementation will not come until 2016. A recent 2010 survey by Financial Executives International (FEI) and I(PMG found that responders could attain an implementation deadline of 2016, if the IFRS decision is made
standards. While most companies relied heavily on their auditors to advise them, complications arose when the Big Four audit firms did not agree on the treatment of certain items. The feedback from these countries suggests that the IFRS conversion should be viewed as a significant project.
Pike, CPA, is
professor at
mewrt
lfwnm. idlege
1tr.
of Business.
While the timeline for the US adoption/ convergence to IFRS is still unclear, there are several critical questions that corporate officers
should be addressing now to achieve a successful IFRS implementation. These questions include:
iM argirt
auditing and
Itmi]umm
acounting at the
in 201
1.2
. What
are the requirements for IFRS? r What has been leamed from ERP and Sarbanes-Oxley implementation projects?
compliant starting in 2011. Of 146 senior executives responding to a 2010 Financial Executives Research Foundation (FERF) survey, most respondents lrom Canadian companies indicated that they were converting because their companies were publicly accountable-meaning, therefore, that conversion was mandatory. The survey also reported that the maiority of
companies were planning on running IFRS and Canadian GAAP in parallel.s Canadian IFRS
. What
are the roles of COBIT and the Committee of Sponsoring Organizations of the Treadway Commission (COSO) ?
project management (PM) skills? Planning and appropriate resource allocations are necessary IFRS implementation requirements. Moreover, the implementation should be
integrated with IT and internal controls in order to meet or exceed regulatory requirements.
IFRS REQUIREMENTS
implementation in small enterprises, which is similar to what is expected in the US, is often the responsibility of CFOs, who are also charged with most other financial management
issues
The impact of IFRS on IT and financial systems can vary depending on the firm's IT and financial
tsAcA JIURNAL VoLUfvE 3, 201
17
product costs and gross margins, is also affected. While figure 1 identifies the data and applications affected by an IFRS implementation, the consequences must be understood in a business context, which involves a broad training effort inside the organization and corresponding lead times.
systems' capability/integration, industry complexity, size. relevance of business process/transaction, intemal control structure, mergers and acquisitions process, and othet attributes.5 Integrating both accounting and IT requirements
New data requirements may result in: . More detailed presentation of informatlon . New data elements or fields to be recorded lnformation to be calculated on a different basis There will almost always be a change to the chad of accounts due to reclassifications and additional reporting criteria. Reconfiguration of existing- ,"-,-. Existing systems may already have capablities built in to deal with the specific IFRS requirements.
multinational company exposes an array of variables that, in combination, can escalate the overall risk of an IFRS for
a
sYstems
t'i':":"
New reporls and calculations may be required to accommodate IFRS. Spreadsheets and models integral to the financial reporting process should be included when considering the required systems modifications. Where previous financial repoding standards did not require the use of a system, or if the existing system is inadequate for IFRS repofting, it may be necessary t0 implement new software. With the introduction 0f new source systems and the decommissioning of old systems, interJaces may need to be changed or developed, and changes to existing mapping tables to the financial system may be required. Under IFRS, there will potentially be changes to the number and type of entities that need t0 be included in the group consolidated financial statements. Reporling tools may need t0 be modified to: . Gather additional disclosure information from branches or subsidiaries operating on a standard general ledger package
as
edenced by the rgsults of a sulvey of Canadian public companies in which 61 percent said that the IFRS conversion
would have a medium or high impact on IT systems, whereas only 27 percent of private companies expected a medium
.IFRS impact are
or high iiirpact.l Some of the differences in perceiyed attributable to the data collection aid
mainlenance lequirements.
authors describe the implementation ol IFRS as a major syslem eonversion.o Moreover. conversion to IFRS can be more pervasive to the enterprise than man perceive.
N4any
will impact
policies.'The scope ol the lT changesincluds tha qllire fod chain from data generation
processes and new accounling
Collect information from subsidiaries that use different financial accounting packages
andbusinessproceSseStofinalreporting(seefigure:1-). While figure ! seems straightforward. United Technologies Corporation G"fC), anarly adoptei of IFRS, noted t.hat
Thre international experts from corripnies in the midsl of adoptirrg IFRS warn against underestimating the IT challenges ahail, including the potential for mjllions of lines of new data for a large muftinational organization.rr One expert
to IFRS affects every aspgqt.of-buSings6r:1ry1t6'. ramifications for everything from compenq4lion to bonuses
a move
:,,
18
TSACA
J\URNAL V0'
ulV
1, 20'
;- -.-
maintained during the dual reporting period, which, :r ::,are1y, requires a complete reconciliation of GAAp . : TRS for each reporting period. For SEC registrants, - -i -:mpanies must report US GAAP and IFRS in parallel
.,' ::,ree years from the initiation of IFRS. In creating a
'
rhe expanded IFRS data requirements. Assuming RS requirements are met, traditional GAAp reporting .be
,-
Barrier
Lack of discipline Lack of change managemenl lnadequate training
Poor reporting procedures: technical
Category
People People People People People People People People
:,.--:r.l accounting environment, the company's internal . -r::!r1 and operational audit staff should evaluate prolonged
-r::rol and operational audit staff can provide in_depth *1edge for conversion planning and ensure that overall '.- -
Technical
People Process People
sP
::,:lspm.r
r.ons
Po!ryn
Ii
cation'.F.?lggement
Technical
ERP
-.
-]tloirre Consulring , conductecl in-deprh interviews with .:-1 individuals ar 62 Forlune 500 companies that used ERp
projects following Y2K, Weidong Xia and Gwanhoo LeerT demonstrated the influence ol organization and personnel in
large lT projects across several industries: Organizational aspects. incluclirrg the use ol qualilied personnel. were the leading lactors rhat conlribuled to projecr success. Sarbanes-Oxley
Ite
:*rrpose of the study was to evaluate ERp development issues. study summarized performance problems and the leading
:uses
. People-62
(see
figure 2):
The Public Company Accounring Oversighr Board (PCAOB) assumed Sarbanes-Oxley regulatory oversight
oi approximatel I 5.000 comparries and I .423 accounting lirms in the US.rs. " Three retgarch reporrs on enlerprises
that reported at least on. -u,)ql *.uk r.r, ttltWl from 2002 to 2005 lound rhar rhese e\erprises were more Iikely
Formal decision-making processes o ln{egrared rest plans and managed resr processes
to be smaller. younger. riskier. mpre complex and linancially weaker, with poorer acciual eaylings qualtry.!o.zt,zt Bonnie Klamm and t\4arcilWeidenmier Warson2;
examined 490 iirms rhat reported lVWs in rhe lirsr year oi Sarbanes-O..ley en lorcemen t to eva I uate rhe in terrela teclness
Failure to inregr.ale lessons Iearned jnto currenr pracrices In a survey of critical success lactors ( CSFs) throughout
all stages of ERP implementations in g6 companies, factors -imlar ro those reported by Benesh and Deloitre Consulring ri'ere ranlced high in importance.r' In-depth interviews with more thair 50 chief information,officers (CIes) prd.duced a similar rheme: P\4 and process .ngin..ring rLlls were frequently inentioned as shortcomings in the course of
enrerprise developmenr.,o ln their study
and
:
.
ol
54
large lT
a positive association with the remaining four weak COSO componenrs. i.e.. COSO components are likel5 ro allect each other.
I.SACAJAURNAL VOLUI\4E
201]
19
spiil over to create more MWs and misstatements not related to IT.
required to become compliant with Sarbanes-Oxiey, and therefore, they lack the experience necessary for complex implementation/conversion.
reporting reliability and add to the number of non-IT MWs reported. Moreover, the conclusion from Klamm and Watson's research is that the IT domain appears to affect overall cont rol effecti veness. Cumrilative edence from Y2K ERP and subsequent IT project and Sarbanes-Oxley implementations suggest several risk drivers for IFRS: . The scpe of IT changes required to support IFRS . The complexity of the enterprise, including the number of subsidiaries and the nature of assets and liabilities . Smaller, younger, riskier, more complex and financially weaker organizations that lack either adequate resouices or
the leadership ro execute change managemenr
An assessment of the accounting organization is particularly meaningful because mosl accountants and
CPAs are not trained lor PM or sysrems implementations. If accountants have experience in any of these disciplines,it
,
was more rhan likel obrained outside rhe roles of financial statement. auditor or tax preparer; .two major qareer paths that accountants oiren follow.
Young Hoon l(wak and C. William lbbs2o presented a PM model that progresses from an unsophisticaied level to
a sophisticared maturity level. Each marurity level consists of enhancements to major PM characteristiQq, factors and processes (see figure 3). Kwak'u demonstrared thar the average organizalion across several industries spends 6 percent ol project value on toral PM costs. which suggests an overall low cosr given the polential range of adverse ';. r, consequ.hcgs lor inef lective PM. In a study oi 38 large
C0S0/00B|TI, or-
''
The authors believe thar the CSF lies in the organizatiorr's capbility tq gxeeure an IFRS implementation whil sustaining improving internal'liontrols as the accounting enuironment grows in:compl-eity. A. robust implementation of the COSO
I
internationai companies in four industries. overall P1\.i . i . maturity. ranged from a low of 3. 1 for information systems conrpanlqs to a high of.3.4 for engineering construqtion '.
iompaniesl with an average for all companies
'
of 3: j.11
...
n tern
al
Con
rol-l
n t e gra
In a scale with level 1 at the low end of maturity and level 5 at the high end of maturity, how should chief executive
of the COBIT25 framework and a critical examination of the accounting organization lor PM skilis are effective responses 1o the risk drivers relerenced earlier. The COSO lramewoik supporrs the establishment ol an internal control lramework lor iinancial reporting, and COBIT supports the establishment of.an lT,frame,fvork for
. . .
No PM processes 0r practices are consistenily available. No PM data are consistently collected or analyzed.
lnformal PM processes are defined. o lnformal PM problems are identified. o lnformal PM data are collected. Level 3, Managed
.,. . -, . .r ':: .:
,
.
. .
-,
,,
)'
:
II : :: ,. vulnrabteirilipnS i^pl;"fii"i sasci onihe pqeviously ', .' mgftlaned:i9$eaich ot-r Sarbanes-Oxley Act implmentiiticin
experiences.2o
27 28
Accounling organizations thar lack either adequare resources : or th.,1e{rdership to execute PM are among th;;ost . :
Formal project planning and control systems are managed. Formal PM data are managed. Multiple PM program management exsts. PM data and processes are integrated. PM processes data are quantitatively analyzed, measured and stored.
PM processes are continuously improved PM processes are fully understood. PM data are optimized and sustained.
.
. .
. .
(SMEs):rryient,the,higheii'liqkgrijpfor,potentil|FRS
implementtidirissues. Moreover, many SMEs wre n.ur
srcnostt!-,vtrg,
.
,
"
,'
.:
..:
,.',.,?9:
zoll
'
(CEOs) or CFOs evaluate their organizationai .. --,,::,itr to initiate, plan, control and close out one-of-a-kind ' :..', ots? At a minimum, any IFRS PM effort should not . :t.ou. the average benchmarks of 3.3 identified by l(wak rr * -:bs.;; At level 3, defined control systems are in place -r: =:equately documented. The Capability Maturity Model ,'r,L\I) levels of 1 or 2 for a planned IFRS implementation ,,"id not be acceptable by an AC, the CEO or the CFO'
'',.:s
The authors believe that ACs and corporate officers should evaluate their intemal organization skills as the project is fully defined and proposed. The evaluation should be based on the premise that:
1. Accountants and CPAs do not acquire PM skills in most
'
2. Successful IT implementations are inextricably linked to qualified staff and effective PM. 5. SMEs are more at risk due to a lack o{ resurces or efiective leadershiP. 4. A minimum of CMM level i lor intemal controls should be attained ior an IFRS implemenlation. A priority for the AC, corpo{ate officers and the IT auditor is to understand the IFRS impact on lT requiremnts because IT domain weaknesses spill over to other IT and non-IT intemal control effectiveness aleas in other-COSO domains' On a larger scale; for an IFRS conversion, the ieadership of the SEC, the Financial Accouniing Standards Board (FASB), the I n ternatiorrl'{ccounting Standards Boa rd t I AS B ) and the American Institirte of Certified Public Accountants
-,:,. and workshops, full support from business process levei 3 for an IFRS ':::rs, and accountability, a CMM acceptable' COBIT integrates a CMM :r:.ementation may be . : rtemal controls, which is particularly important for a , - SO/Sarbanes-Oxley-compliant organization (see figure 4)'
Haturity
Level
:,::
0.
,:existent
There is no recognition of the need for internal control. Control is not part of the organization's culture or mission.
(AICPA) should:
-:,:
-?)"ad h1c
There is some recognition of the need for iniernal control. The approach to risk and control equipment is adfoc There is n0 communication or monitoring of risks
0r controls.
Emphasize the organizational capability to impiement and sustain an lFRS-compliant environment based on COSO/COBIT vs. a message that suggests a few courses
:
in IFRS
. .
::eatable
:
. Controls are in place, but are not documented. . Operation is dependent on the knowledge and
motivation of individuals.
-: intuitive
. .
. i,'el
4, ',ranaged and
Develop well-defined requirements- to drive a successful implementation and ongoing application of IFRS Cieate a conversion schedule that accommodates 29 million companies and the audit/consulting resources to support
those conversions
Controls are in place and adequately documented. Operating effectiveness is evaluated on a periodic
basis.
CONCLUSION
-:asurable
. A formal, documented evaluation of controls occurs frequently. . Many controls are automated and regularly revieved' o Management is likely to detect most. bui not all
control issues.
An enterprisewide risk and cOntrol proEram provides continuous and effective resOlLr'Ljci o control and risk issues. o lnternal control and risk management a'e ':::
For lT auditors ancl lT professionals. IFRS should be a priority because the demand will be high for those wittl' . technical knowledge to interpret and translate IFRS into lT requirements, COSO/COBIT-supporting references and audit programs. The capability to eiecute an IFRSimplerirentation s'hile sustaining or improving intemal controls is a CSF. Lessons ftom Sarbanes-Oxley:irplsmentations indicate' that IT and intemal controls can be materially affectecl. The :nr ersion to IFRS in the US will be a difficult and t:nou: ii*,-ess for many companies. However, fo-r, those who iearned
with enterprise Practlces. lnternal control and risk management are supported with automated real{ime m0ni:lr': -s* with full accountability for control monitonri
management and compliance enforcemen:
::;: iaileJ implementations in the pasr. IFRS will present .:: -::.rnit\ io mo\e the organization to a higher CMM
,:,.. :: ra:uritr.$hile
simultaneously adding capacity and
ri,-'ce:
-.:..-:.-::. -. l luiul'.'''ndcavorS'
ISACA JOURNAL Vl]LUI\4
3, 20]
21
ENDNOTES
AICPA, "Looking to the Future: An Interview With AICPA President & CEO Barry Melancon, CpA," CpA Letter Daily , 1 5 December 201.0, www.smartbrief. com/ serylet/wireles s? i s sueid=F D 7 7 83 FB-FD 5 4- 4206A7 C6- C9 E7 E3 2 E9 B EE &sid=9 a3 7 5fB 1 - 7 0 8 d- 4te ca5c1 147Bab7
5 -a
1r Deloitte Consulting, ERp's Second Wuve: Maximizing the Value of ERP Enabtes processes, 1999. www.ctiforum.
la
com/t e chnolo gy /CR M /wp7 1 / dow nlo ad/ erp2w, p df Benesh, i\4ariel "Managing your ERp project." Sofrwure
5fl -
p.38-43
f9g; i
'? Goldschmid, Harvey; "IFRS at a Critical Crossroad,,, speech at the Financial ExecutiveS International (FEI) . Current Financial Reporting Issues Conference 2010, held in New York, USA, I 5-l 7 November 20 10, ww w. ifi s. o r g/ N ew s / Announc en ent s + an d+ S p e ec h e s /
2001
Planning Implementations, " proceedings of the .3,1 Hawaii lnternational Conference on System S.ien.es. IEEE. USA.
-..
t, ::
...i.t',
I F RS+C ri
ti
ca
l+C rossr(a
cl.
Canadian Financial Executives Research Foundation (CFER), "IFRS Readiness in-Canada ZO]O," Cu*au,
Kay JV. Nelson: ..ln Their Own :CIO Visions About the Ftre of:In_house Words: tT Organizations," Database for Advances in Info;;tion', Systems. I Oc(ober 2003. www.allbusiness.com/
a lnsri(ure ol Charrered
20 t 0, wtiw. fcanad.a. org/ trt dfs/CIA nioto z 0 IF RS % 2 0 Readinesso o20ino o2\Canadao.o2020 t 0.pdf
technology/35z274t-i.hmt,
Accouurants ol Scorland. "The ,GAAP Gap,,, Cl, Magzine,20 March 200 g, ww , camegonlne.9o.ik/Magaziue/2008-3/64.aspx ..
.
...,
: USA. 20 I O. www.ifrs.com/
nt -p roj ects/
'
6' "
https://www.in,kpmg'com/securedata/i'frs-In5titute/Files/.ucoonauehiointFinan]iQtMo,,n.*,,,.o,|* 7
Op cit.
2008,
,i,i. ;;,;;;;;;;";,
CFERF
\ickr
of
IFRS
on
lS'pdf ^ lanuary20l0.
tOV
Difazio.
l0 December 2004. hrtp://prooAr,r.",g/;;:/il,rrirr, *ges/tzlozy,+-i*:,{ritLitil;;;,:r:o:-20 Doyle. leflrey;Weili Ce; SarahMcVay:..Dererminantsol weaknesses in lntemal conrrol over Financial R";;;s.-
www'dcloitte'coin/view/en-l'ts/us/lnsights/Browse-byContenr-Tttpe/deloitte-review/article/319 te65Seea2Z
lourna! o lrruurting
laE.pctf
and
Conrrols Financial
2r Dole.
eurij+
www.journalofaciountancy.com/lssues/2009/
l.
20bZ
' .
r0 AICPA' "Getting to tFfiS: Those who Have-Been There Weaknesses in lniemal Control Airer the Sarbanesorrr Have Plenry o[ Advice," USA, 2009. www.ifrs.com/ Act... Accounting Horizons.september 2005. urrrr. ,.' $cl,ll'AcCgulifig Htitiin, Septrber 2005, i,lll. i :... advic:htnl.:.' :,:' :: advice'ht ml Iv;i.:hint,':,t ::. :.:. , ':-::i:, uic.edu/cla seshii:tg/{tctS95 I Ra iLigs/St ock_Opnori . . . .uii. e du/ daS sses/acre/tt 11..Ibid: "':":':i": 11'Il1id; i:::::.:;;...;' .,:....,...... _..,.:_...,-,,'',: ::.: .: :...',.:r.. sarbtn4;:oxteyirfup-,1rnsure-ofMqterial-weak.::vt12 r-t) ^:'. .:^^t s'
Op'cit;Aino!d:,.
,',,
22
BACA
-rr-
;*.:-'
.'.--:;!
2e Kwak, Young Hoon; C. William lbbs; ',project Management Process Maturity (pM), Model,,,
M a n a ge me nt En gin
e e ri n
lournal of
e du/ - kw ak/ P M P M _M o d el. p df r0 l(wak, Young Hoon; "A Systematic Approach to Evaluate Quantitative Impacts of Project Management (pM)," doctoral dissertation, Department of Civil Engiueering, University of California, Berkeley, USA, 1997 11 Kwak, Young Hoon; C. William lbbs; ,'Calculating
-Jtenninants
-':
l\4
Project Managemenl's Retum on lnvestment.'. proTect anugement lottrnal. lune 2000. www.lmarheller.com/
J:ancial Reporring"
J;ality
,'lt: c. Doyle, ]effrey; Weili Ge; Sarah McVay; ,,Accruals and Inten-lal Control Over Financial Reporting" c, Ge, Weili; Sarah McVay; ,.The Disclosure of
'3
Op cit,I(wak, Young Hoon; C. William Ibbs; ..Calculating Project Management's Return on Investment,'
3, 20]
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