On Wed, 7 Jan 2009 06:59:45 -0600, Chase, John <jch...@ussco.com> wrote:
>Indeed.  If management merely "rubber-stamps" whatever recommendations
>or suggestions auditors make, it certainly can create the appearance
>that the auditors are "running the show".  That doesn't change the facts
>that management makes policy and auditors report on compliance with
>policy, and that if the policy is "wrong" it's not the auditors' heads
>that will roll.

While I generally support the position that auditors should not "make
policy", having worked at a national bank previously I think there is an
aspect of this discussion that no one has mentioned yet.

There can be different levels of "policy".  For example, when the national
bank examiners (aka, "auditors") visited us they conducted audits according
to the policies established by the national body that chartered/insured our
bank.  (That was a long time ago, so I'm not sure what body they were
representing, but the idea is right, I think.)

When they made findings based on thse national policies, we could (and did)
argue some of them, but primarily we had to comply or demonstrate how we had
some compensating factor that addressed their concerns.

Thus, it was not -our- management making that policy, but an outside body
making the policy, and we had to adhere to it or show why it should not
apply to us.

Our internal auditors, on the other hand, did audit us according to our
management-specified policies.

Of course, I suppose one could argue that one of our management's policies
was "comply to the national examiners' policies", and in that sense it was
still our management setting the policy.   But they had little choice in
that, nor in what that externally applied policy required.

The same applies today with policies set by Visa, Mastercard, etc.

-- 
  Walt Farrell (speaking as a former banker, not in my usual role as an IBMer)

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