Internal Controls, Policies and Procedures


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Table of Contents

How to Use this Manual xi

Preface xiii

Governance Journey 1

A01 Big G to little g governance journey 3

Appendix: Background for COSO, SOX, PCAOB 7

A02 Risk Assessment 10

A03 Oversight 16

A04 Documentation 20

Internal Control Program 25

B01 Internal Control Program 27

B02 Internal Control Process 37

B02a Internal Control Policy and Procedure 52

B02b Internal Control Program Charter 55

B02c Internal Control Plan 57

B03 Authorization and Approval Program 69

B03a Delegation of Authority 73

B03b Authorization - Delegation, SubDelegation of Authority 79

B03c Responsibility, Authority, Support, Counsel, and Inform (RASCI) 83

B04 Information Technology Program 87

B04a End-User Computing-Control of Spreadsheets Policy and Procedure 95

B05 Account Reconciliation Program 97

B05a Account Reconciliation 101

B06 Quarterly Subcertification Program 105

B06a Quarterly Subcertification 120

B06b Quarterly Subcertification - Matrix 122

B06c Quarterly Financial Subcertification Training For First-Time Subcertifiers 124

Control Activity Program Testing Guides 133

C01 Control Activity Program 135

C01a Control Activities Template 147

C01b Result of Control Activity Testing 148

C01c Internal Control - Planning, Testing, and Remediation Worksheet 149

C01d Reporting Scorecard 151

C02 AP - Disbursements 153

C02a AR - Allowance for Doubtful Accounts 158

C02b AR - Cash Applications 162

C02c AR - Collections 166

C02d AR - Credit Administration 169

C02e Cash and Marketable Securities 172

C02f Financial Planning and Analysis 176

C02g Fixed Assets, Long Lived Assets 179

C02h Intercompany Transactions - Cross Charges 183

C02i Raw Materials and Inventory 187

C02j Journal Entries 194

C02k Payroll 197

C02l Procurement 201

C02m Revenue Recognition 205

C02n Retail Sales Orders to Business Partners 209

C02o Income Tax 213


Internal Control Planning, Testing and Remediation Worksheets 217

Acronyms 263

References 265

Index 267

About the Author

ROSE HIGHTOWER, ACCOUNTANT, MSC, has been the owner of IDEAL Consulting Solutions International, LLC, for ten years, consulting in implementing internal controls and policy and procedure programs for large companies. Bringing over twenty years of experience from IBM and serving as finance manager, her program contains practical lessons and simple solutions for any size company. She is known as "The Policy Guru" and offers advice and counsel to clients from her Web site,

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