Careful what you complain about...

by Admin 22. July 2013 15:28

There were highs and lows being a senior manager in a bank. The lows tended to have something in common. That thing was invariably Audit.

Hearing that you were about to be audited tended to spoil a very promising month. Don’t get me wrong, this wasn’t because I feared the outcome of the audit. Oh, no; it was the process I hated. There was a time, long ago now, when audit engaged less frequently and on an altogether more scientific basis. Audit engagement would consist of very defined stages as the auditors endeavored to identify if the controls they expected were in place and effectively designed and if those controls were operating effectively. Good sound statistical methods were used to select sample sizes and then to test those samples. I complained of course, it was always frustrating to have your carefully laid plans disrupted by an unexpected audit but I was generally confident that the basis upon which we designed, built and operated controls was very sound. It was more frustration than anything… Of course I always understood that Audit was a good thing; a necessary thing. Providing oversight of the control environment was a very important and essential task and Audit did it very well for the most part.

But that was then. And then was pre the current financial crisis. Audit very much changed its approach after that and I’m still struggling to understand why. For one thing, Audit became a lot more aggressive in their approach. The scientific analysis had been replaced with threats and hostility. No longer were we looking at samples but Audit were asking my team to provide “all the data for the past year”. I was always tempted to give it to them but always gave in in the end and instead tried to explain that the data for the past year amounted to hundreds of terabytes and in what form would they like it, printed or on thousands of memory sticks? And any error in all of that data seemed to result in an audit failure. Any single mistake meant that our controls were worthless and we needed to run some huge process to replace or upgrade them. The idea of an acceptable error rate was not a subject to bring up with them!

And the other thing which changed was the politics. I can see that Audit felt that bringing in security people was a good idea when it came to auditing security systems, but I think they might have been better to have brought those people in from outside the organisation. Hiring security people who were already disillusioned with their lot in life and looking to leave the bank generated a very toxic environment, particularly after a slimming down exercise when middle managers found their departments subsumed under other teams. Dealing with an auditor who has no experience of audit, but fancies himself an expert in security is bad enough but when he has a personal ambition to pin something on you can be pretty tiresome. And trying to explain to someone who built a totally useless security control which was not well operated and which you then replaced with a much better control and good, sound operational processes that you don’t feel his audit findings are sound can be a very unsatisfactory conversation. The real shame however is that the security people lacked the sound audit skills and experience. Who would have thought that I'd miss profesional auditors but it turns out that they are much better than amateur ones!

So the question which ultimately arises is “Is this new audit methodology effective”? Well, I’m not qualified to answer that. I guess you need to look at the failings of banks over the last few years since this new regime took hold and ask whether their controls have been effective? Are Audit improving the control environment?  Have the number of scandals involving misspelling or market manipulation dropped off to nothing or do they still seem to appear in the financial and general press with alarming regularity? And are these failures identified by Audit or do we hear about them from whistle blowers, other financials, regulators and exchanges? Now let me think…

Please bring back the professional auditor who knows how to audit and has no axe to grind. I’ll never complain again, I promise!

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