Foley & Lardner Attorneys Guide to Spotting Financial Distortions
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Transcript of Foley & Lardner Attorneys Guide to Spotting Financial Distortions
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Spotting Financial Distortions:A Primer for Attorneys
The Web Conference Series For Corporate Counsel
January 17, 2007
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Addressing TrendsSharing Solutions
2006 Year in Review book coming in January
Todays summary in March InsideCounsel
Advance copy for todays participants
Todays Moderator
Robert Vosper
Editor, InsideCounsel
InsideCounsel is the leading publicationexclusively for general counsel andother in-house counsel
Editorial mission be the business and
management tool for the corporatelegal department
Dedicated to the exploration of therelationship between in-house counseland the law firms that serve them
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Todays Presenters
Mark PlichtaSenior Counsel, Foley & Lardner LLP
Member of Transactional & SecuritiesPractice Area
Practice covers mergers &acquisitions, and general corporatebusiness law
Regularly counsels publicly heldcompanies regarding compliancematters
Todays Presenters
James PajakowskiManaging Director, Protiviti Inc.
Member of Protivitis Global Business RiskServices Group
Focuses on financial Investigations &Litigation Consulting practice, e-Discoveryand Data Forensics Consulting, Sarbanes-Oxley Compliance Consulting, Financial
Risk Consulting, and Operational RiskConsulting Experience includes audit services,
business process improvementconsulting, enterprise risk managementprojects
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Spotting Financial Distortions:A Primer for Attorneys
The Web Conference Series For Corporate Counsel
January 17, 2007
Discussion Topics
SOX: Results so far
Recent fraud statistics
Identification and detection techniques
Common fraud scenarios
Client considerations
Protivitis 2007 Fraud Risk Management Survey
Accounting issues to watch in 2007
Areas of focus / key take-aways
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Results So Far SOX 404 Compliance
Results for Year 1 filers (through May 30, 2006): Almost 3,600 filed internal control reports
Over 580 companies, or 16.2 percent, reported materialweaknesses
Results for Year 2 filers (through May 30, 2006): Over 2,900 companies filed internal control reports
215 ( 7.4%) reported material weaknesses
While over 16% of companies subject to Section 404 disclosed
internal control weaknesses in their first year of reporting,more than half of these companies reported in Year 2 that theyhad corrected them.
Year 1 and Year 2 Section 404Disclosure Stats
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How many financial restatements has your
organization experienced within the last three
years?
One
Two
Three
Four or more
Live Meeting Poll
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Results So Far Restatement Activity
0
200
400
600
800
1000
1200
1400
1600
1800
2000
2001 2002 2003 2004 2005 2006
(forecasted)
Source: Audit Analytics.com April 25 and June 9, 2006
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Results So Far Restatement Activity(contd)
The number of restatements is expected to increase in 2006compared to 2005, however this increase is being driven bysmaller companies.
Large audit firms clients were responsible for 65% of therestatements in 2005, however they were associated with lessthan half of public company restatements in the first half of2006.
Meanwhile smaller auditing firms clients share of
restatements has more than doubled, with 497 restatements inthe first half of 2006 compared to 185 restatements in the firsthalf of 2005.
History of Restatements
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History of Restatements (contd)
History of Restatements (contd)
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Wall Street Journal May 8, 2006
Tracking the Numb ers Outside Audit:
Checks on Internal Control Pay O ff
27.7%
Down5.7%
25.7%
Russell 3000
share index
17.7%
Companies that
reported no
internal-controlweaknesses in
2004 or 2005
Companies
reporting
internal-controlweaknesses in
2004, but no
weakness in 2005
Companies reporting
internal-controlweaknesses in both
2004 and 2005
Regulation
PaysShare price performance
of companies complying
with internal-control rules
called for under the
Sarbanes-Oxley Act *
* From March 31, 2004 to March 31, 2006
Does SOX Have A Positive Impact onCompanies?
Securities Fraud Class ActionsDecreased in 2006
In 2006, securities fraud class actions decreasedby 38%, whileallegations of specific accounting irregularities in filedcomplaints increased
Cases involving other accounting irregularities dramaticallyincreased almost 50% related to stock-option issuances
Total Disclosure Dollar Loss was $52B in 2006 - a 44%decrease from 2005 (i.e., market capitalization losses at end of
class period, typically time of disclosure of alleged fraud)
Maximum Dollar Loss fell from $362B in 2005 to $294B in2006 (i.e., shareholder losses measured by largestcapitalization decline experienced during class period
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Securities Fraud Class ActionsDecreased in 2006 (contd)
Three contributing factors cited:
Strengthened federal enforcement environment /pressure on companies to conduct internalinvestigations that implicate individual executivesresponsible for fraud
Strong stock market combined with lower stockprice volatility
Majority of securities fraud class actions filed inlate 1990s-early 2000s are behind us
Recent Fraud Statistics
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Three Perspectives on Fraud Blacks Law Dictionary defines fraud as:
All means by which one individual can get an advantage over another byfalse suggestions or suppression of the truth. It includes all surprise, trick,cunning or dissembling, and any unfair way by which another is cheated.
Institute of Internal Auditors defines fraud as: Any illegal acts characterized by deceit, concealment or violation of
trust. These acts are not dependent upon the application of threat ofviolence or of physical force. Frauds are perpetrated by parties andorganizations to obtain money, property or services; to avoid payment orloss of services; or to secure personal or business advantage.
Statement on Auditing Standards No. 99 (SAS 99) defines fraud as: An intentional act that results in a material misstatement in financial
statements that are the subject of an audit. Two types of misstatements arerelevant to the auditors consideration of fraud: (1) fraudulent financialreporting and (2) misappropriation of assets.
Common Types of Financial Fraud
Asset Misappropriation (91.5%) $150,000 median loss
Corruption (30.8%) $538,000 median loss
Fraudulent Financial Statements (10.6%)
Most costly, median losses of $2 million per scheme
Note: The sum of percentages in this chart exceeds 100% because a number of cases involvedmultiple schemes that fell into more than one category.
Source: Association of Fraud Examiners 2006 Report to the Nation
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Note: Total exceeds 100% because some survey participants cited more than one
method for initial discovery of the frauds
Source: Association of Fraud Examiners 2006 Report to the Nation
Who Discovers Fraud?
Tips (34.2%)
By accident (25.4%)
Internal Audit (20.2%)
Internal controls (19.2%)
External Audit (12%)
Notification by law enforcement (3.8%)
Occupational Frauds Based On Industry Sorted By Frequency
MiningAgriculture, Fishing and HuntingCommunications/PublishingArts, Entertain. and Recreation
Transportation and Warehousing
Wholesale TradeReal Estate
Oil and GasUtilitiesConstructionService (professional, scientific or technical)Service (general)
EducationRetailInsuranceHealth Care
Manufacturing
Government and Public Admin
Banking/Financial Services
Industry
$17,000,0001$71,0008
$225,00016$175,00022
$109,00027
$1,000,00030$200,00030
$154,00032$124,00034$500,00035$300,00058$163,00060
$100,00073$80,00075
$100,00078$160,00089
$413,000101
$82,000119
$258,000148
Median Loss# Cases
Source: Association of Fraud Examiners 2006 Report to the Nation
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Examples include:
Embezzlement
Theft of Company Property
T&E Fraud
Vendor Kickbacks
Diversion of CorporateOpportunities
Unauthorized Use of Property
Who Benefits from Fraud? Management Fraud Acts where the
principal benefits of the act are
derived by the company
Employee Fraud Acts where the
principal benefits of the act are
derived by the individual
Third Party Fraud Acts where the
principal benefits of the act are
derived by an entity outside the
organization
Examples include: Financial Statement Fraud Bribery Price Fixing Contract Bidding Fraud
Examples include:
Duplicate Invoices
Altered Payee on Checks
Commission Schemes
Related Party Transactions
Supplier Fraud
Contractor Fraud
Whos Involved in Fraudulent Acts?
2.6%2.2%1.6%N/A1%Board of Directors
31.8%14.9%57.4%43%31%Accounting
34.4%27.9%26.4%17.8%25.7%Executive / UpperManagement
1.9%
13.8%
1.1%
5.6%
6.3%
6.3%
1.9%
3.3%
N/A
2.6%
4.5%
7.8%
Corruption
0.6%N/A0.9%3.3%Information Technology
1.9%4.7%5.6%3.8%Finance
3.9%4.7%11.2%4.8%Customer Service
N/A
18.7%
N/A
N/A
0.9%
1.9%
N/A
N/A
N/A
Cash Larceny
2.4%
7.6%
1.9%
7.1%
3.3%
5.2%
1.4%
1.4%
N/A
BillingSchemes
ExpenseReimbursement
CheckTamperingDepartment
0.6%N/AInternal Audit
N/AN/AWarehousing / Inventory
14.3%3.1%Sales
2.6%N/AResearch & Development
0.6%0.8%Purchasing
1.9%N/A
Marketing / Public
Relations
1.3%0.8%Manufacturing &Production
1.9%N/ALegal
1.3%0.8%Human Resources
Source: Association of Fraud Examiners 2006 Report to the Nation
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Whos Involved in Fraudulent Acts? (contd)
N/A1.4%1%1.1%3.1%Board of Directors
25%42.4%47.6%11.1%17.3%Accounting
48.2%23%19.4%23.7%50%Executive / UpperManagement
N/A
19.4%N/A
2.2%
N/A
1.4%
N/A
0.7%
N/A
0.7%
0.7%
7.9%
Skimming
N/AN/A4.2%N/AInformation Technology
12.5%1%3.2%8.2%Finance
5.4%9.7%12.1%1%Customer Service
7.9%
17.4%2.6%
4.2%
1.6%
8.9%
0.5%
1.6%
N/A
Non-CashMisappropriations
1%
11.2%N/A
3.1%
1%
1%
2%
1%
N/A
FinancialStatement
Fraud
Wire TransferSchemes
PayrollSchemesDepartment
N/AN/AInternal Audit
N/A1%Warehousing / Inventory
7.1%5.8%SalesN/A3.9%
Research &
Development
N/AN/APurchasing
1.8%1%Marketing / PublicRelations
N/A3.9%Manufacturing &Production
N/A2.9%Legal
N/A2.9%Human Resources
Source: Association of Fraud Examiners 2006 Report to the Nation
Identification and Detection
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Typical Factors - Intentional FinancialDistortions
Incentive / Pressure
Rationaliz
ation O
pportu
nity
Preve
nt
Deter
Detect
Eva
luate
Mitigate
Monitor
Typical Factors - Unintentional FinancialDistortions
Pressure
Complexity C
apacity
Preve
nt
Deter
Detect
Eva
luate
Mitigate
Monitor
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Common Fraud Scenarios:Excerpt of Potentially Material Frauds
Percentage-of-completionOn false estimations
CollusionTo non-existent customersRecord fictitious revenue
Recording revenue instead ofliability when cash received
Side agreements
Record revenue when:
Obligation exists to provide
future services
Buyer right-of-return
No buyer obligation-to-pay
Inability of buyer to pay
Goods dont meet buyerspecifications
Record revenue when:
Customer has options toterminate, void or delay sale
Channel stuffing
Bill and hold
Holding books open untilafter period end
Side agreements
Back-Dating salesagreements and documents
Ship goods before sale is completeRecognize unearnedrevenue
Materially overstate revenues
ExamplesFraud RiskSub-CategoryCommonFraud Scenario
Common Fraud Scenarios:Excerpts of Potentially Material Frauds (contd)
Inappropriate methods
Excessive lives
Depreciating or amortizingcosts too slowly
Bad debts
Bad loans
Excess and obsoleteinventory
Bad investments
Continuing to carry worthlessassets
Start-up costs
R&D costs
Normal period expenses
Overstating goodwill in anacquisition
Improper capitalizationShifting current periodexpenses to future periods
Materially understateexpenses
Supplier credits and rebates
Kickbacks
On receipt of vendor credits
Like-kind exchanges withintent to record a gain
Barter transactions
On exchange of similar assetsRecord fictitious revenue(contd)
Materially overstate revenues(contd)
ExamplesFraud RiskSub-CategoryCommonFraud Scenario
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Common Fraud Scenarios:Excerpt of Potentially Material Frauds (contd)
Hiding losses underdiscontinued operations
Misuse of discontinued operations
Mixing gains from recurringand non-recurring activities
Mingling operating and non-operating income
Restructuring charges vs.
operating expenses
Not segregating unusual and non-recurring gains/losses fromnormal operating results
Bad investments stock
Bad investments -acquisitions
Fixed assets under-performing plants, etc.
Failing to record assetimpairments to reduce to net-realizable value
Bad debts
Bad loans
Excessive and obsoleteinventory
Failing to record losscontingencies to reduce to net-realizable value
Overstating assetsMaterially misleadingpresentation of financialposition and/or results ofoperations
ExamplesFraud RiskSub-CategoryCommonFraud Scenario
Ask these Questions
Where are the weakest links in the systemscontrols?
What deviations from conventional good accountingpractices are possible?
How are off-line transactions handled and who hasthe ability to authorize these transactions?
What would be the simplest way to compromise the
system? What control features in the system can be
bypassed by higher authorities? What is the nature of the work environment?
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Entity Level Red Flags
Internal control gaps, deficiencies,weaknesses
Business results that continuallyoutperform expectations
Management override of controls Rapid or significant turnover of
resources Senior management Key financial positions Key employees
Inadequate segregation of duties Turnover Cut-backs / lay-offs
Unusual end-of-month or end-of-quarter variations
High-level of related-partytransactions
Systems are manual and/ordecentralized
Employee, customer or vendorcomplaints
Repeated changes of independentpublic accountants
Continuous problems with variousregulatory agencies
Significant and continuing issueswith reconciling financial
statements to underlying support
Process-Level Considerations - BeSkeptical! Always request original documents
Ask yourself whether transactions make sense (e.g. too high, low, round, often, rare)
Have documents been altered?
Look to see where the documents are maintained (e.g. are certain invoices maintainedseparately from all other invoices)
Is there a right to audit relationship with customers and vendors? (if so, have they oryou exercised that right)?
Are reconciliations of underlying data to summaries (bank recs, A/R, A/P) alwaysdelayed or do they always involve significant and conflicting reconciling items?
Do employees have close personal relationships with vendors?
Is there a lack of supporting documentation?
Do background checks on employees and vendors identify related parties and DBAs?
Does an answer not make sense?
Are you avoided more than usual?
When asking a relatively simple question, are you unexpectedly referred to someonehigh up in the organization?
Go with your gut
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Monitor Fraud Risk with Computer-Assisted Audit Techniques
Search for duplicate payments
Analyze voids and refunds by employee, usingpasswords or employee ID numbers
Search for duplicate addresses within files: Payroll,Vendor, Accounts Receivable Write-offs
Analyze use of override transactions
Analyze file maintenance on employee accounts
Look for patterns
List large payments to individuals
Client Considerations:
Managing Intentional and
Unintentional Financial
Distortions
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SEC and PCAOB Guidance on FraudRisk Management
Proposed changes to SEC and PCAOB Internal ControlAuditing and Reporting focus on:
Risk management and assessment in general
Fraud risk management in particular:
Audit Committees role in the oversight of fraud riskmonitoring activities
Risk (and mitigation/testing) of management being able toover-ride controls to perpetrate financial or financial reportingfraud
Monitoring activities at all levels of the organization asemployees, supervisors and senior management perform theirdaily activities and how those are assessed.
What is the main role of General Counsel within
your organizations fraud risk management
program? Responsible for management of one or more fraud prevention
or detection activities
Consulted by others on an as-needed basis regarding
development of programs, policies, practices or procedures
Reactive only, i.e., involvement limited to investigation,remediation and/or prosecution / recovery
Other
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What is Fraud Risk Management?
Anti-fraud policy
Anti-fraud programs
Background checksand screeningprocedures
BoD / AC oversight
Code of conduct /ethics
Corporate fraud risk
strategy Corporate compliance
and ethics programs
Forensic data analysis
Fraud risk assessment
Fraud risk brainstormingsessions
Fraud testing plans
Investigative unitresourcing
Investigative protocolsand procedures
Incident response andcase management
Disciplinary,prosecution andrecovery guidelines
Preventive / detectivecontrols andmonitoring
Self-reporting /disclosure guidelines
Security functions
Training andawareness workshops
Whistleblowerprograms
Fraud risk management involves the strategies, techniques, programs and
controls utilized by an organization to evaluate, mitigate and monitor its risk to
fraud and misconduct. This includes, but is not limited to:
Entity-Level Considerations:Control Environment
Control Environment Sets tone of organization, which
influences controlconsciousness of its people
Foundation for all othercomponents of internal control
Factors include: Integrity and ethical values Commitment to competence Board of Directors and Audit
Committee Managements philosophy and
operating style Assignment of authority and
responsibility Human resource policies and
practices
COSO: Internal Control Integrated Framework
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Entity-Level Considerations:Anti-Fraud Program and ControlsPrevention
Tone at the top Value system (Code of Ethics
/ Conduct) Positive workplace
environment Hiring, promoting and
retaining appropriateemployees
Training and awarenessprograms
Confirmation / affirmation ofCode of Conduct or Ethics
Ombudsman programs Whistleblower programs Incident response / case
management processes Investigative procedures Discipline, prosecution and
recovery guidelines
Prevention
Tone at the top Value system (Code of Ethics
/ Conduct) Positive workplace
environment Hiring, promoting and
retaining appropriateemployees
Training and awarenessprograms
Confirmation / affirmation ofCode of Conduct or Ethics
Ombudsman programs Whistleblower programs Incident response / case
management processes Investigative procedures Discipline, prosecution and
recovery guidelines
Detection
Identification andmeasurement of fraud risk(fraud risk assessment)
Processes and proceduresto mitigate identified fraudrisk
Effective internal controlsat entity and process level
On-going monitoringactivities
Computer-assisted audittechniques
Investigation of: Internal control
weaknesses / breaches Non-response to Code
confirmation /affirmation
Reported issues
Detection
Identification andmeasurement of fraud risk(fraud risk assessment)
Processes and proceduresto mitigate identified fraudrisk
Effective internal controlsat entity and process level
On-going monitoringactivities
Computer-assisted audittechniques
Investigation of: Internal control
weaknesses / breaches Non-response to Code
confirmation /affirmation
Reported issues
Deterrence
Active oversight by Boardand/or Audit Committee
Fraud risk assessmentand related measures
Code confirmation /affirmation process
Managementsinvolvement in financialreporting process andoverride of control
Process to receive,retain and treatcomplaints of fraud /unethical conduct
Internal and externalaudit effectiveness
Internal audit Evaluation of adequacy
/ effectiveness ofinternal controls
Disciplinary examples
Deterrence
Active oversight by Boardand/or Audit Committee
Fraud risk assessmentand related measures
Code confirmation /affirmation process
Managementsinvolvement in financialreporting process andoverride of control
Process to receive,retain and treatcomplaints of fraud /unethical conduct
Internal and externalaudit effectiveness
Internal audit Evaluation of adequacy
/ effectiveness ofinternal controls
Disciplinary examples
Which one of the following statements best describes yourorganizations fraud risk strategy?
Very well defined - strategy exists to proactively identify fraud risks andcorresponding anti-fraud programs and controls are agreed upon,monitored and measured by Board and senior management on an on-goingbasis
Defined - no formal strategy, but anti-fraud programs and controls and areagreed upon, monitored and measured by Board and senior managementon an on-going basis
Less defined - no formal fraud risk strategy, but some anti-fraud programsand controls exist
Reactive only Fraud risk management is limited to reacting to allegationsof fraud or misconduct.
Undefined - no formal fraud risk strategy or anti-fraud programs andcontrols
Dont know
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Highlights and Preview Results:Protivitis Fraud Risk Management Survey (2007)
Only one-half of F1000 indicated their fraud risk strategy is very welldefined, suggesting room for improvement in many organizations
More than half of organizations do NOT include anti-fraud overview ordefinition of fraud in policy
High percentage of organizations have no plan in place when fraudreported
One-third of F1000 have no documented protocols and procedures for
investigations
One-half of F1000 have no incident response plan.
Key challenges for managing fraud risk, two-thirds indicated: Fraud not considered high risk No fraud here mentality Or, dont know
Accounting Issues to Watch in 2007
New proxy rules will have companies summarizing, under counsels scrutiny, moreinformation about executive compensation and inclusion within the proxy.Companies may discover things that heretofore had either been un-reported or mis-categorized.
Mop-up on stock compensation as it relates to back-dating.
Ongoing issues on either options or their replacements/successors: deferredcompensation plans, restricted stock, etc.
ExecutiveExecutive
CompensationCompensation
Again, caused by a new accounting pronouncement.
As companies approach placement of pension numbers (more of them) on balancesheet, there may be some who discover that what they previously reflected may notconform to the old rules (especially amounts that should be in comprehensiveincome, tax-effected, time-sensitive valuations, etc.).
Pension AccountingPension Accounting
Advent of FIN 48 will have companies focus on accounting, including pastaccounting) for uncertain tax positions, such as:
aggressive positions
audit roulette
transfer pricing
the s word [shelters]
Income TaxesIncome Taxes
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Areas of Focus / Key Take-Aways
1. Fraud risk assessment
2. Financial reporting risk profile
3. Entity-level review
4. Hotline and other reporting mechanisms
Thank you for your participation
Look for your advanced copy of todays programsummary in the next few weeks.
For more information on the Web Conference series visitwww.foley.com/webconference
To receive a free subscription to InsideCounsel, please visitwww.insidecounsel.com/freeoffer.
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Thank you for your participation
Jim Pajakowski
Mark Plichta