CH18-Treasury Policies & Procedures Flashcards
5 primary reasons treasury policies and procedures are necessary
- Organizational needs
- Risk management
- Define Roles and Responsibilities
- Compliance
- Governance
Correctly designed controls must consider
- internal and external controls
- reporting and audit trails
- controls on Third Party Service providers
- compliance with SOX 404, stock exchange regulatory requirements
What is achieved by a Board resolution outlining position responsibilities?
Delegation of authority
What is a key control that can reduce fraud and error risks?
Segregation of Duties
What comes first - policy or procedure?
Policy first, Procedure second
Policies drive procedure development.
The policy development process
- Pre-development = get highest level support, assign leader with accountability
- Identify issues and conduct analyses = include all areas, create flowchart
- Draft the Policy = what, not how; make readily available; identify SME
10 Basic Elements of a Policy
- Objectives
- Scope
- Basic guidelines - expectations
- Roles and responsibilities
- Performance measurement and reporting
- Controls and compliance
- Name who can approve Exceptions
- Review cycle
- Definitions
- Policy attachments
The general risk of intentional employee fraud is known as
defalcation risk
the specific case of theft of money, securities or property by an employee is known as
fidelity risk
Proper segregation of duties significantly reduces which category of risk?
fidelity risk
The structure of the specific treasury policy and procedures documents will need to reflect ________________.
department practice
What is the key objective of the consultation phase of policy development?
Develop a workflow of existing practices and identify where risk points occur
T/F: Exceptions should be allowed but there should be some documented segregation of duties involved
True
Who should conduct Investment policy reviews ?
Internal and/or External Auditors
Key issues to be addressed in an outsourcing policy include:
- Delegation of authority
- Vendor and operational risk management
- Information security and confidentiality requirements
- Performance measurement, including compliance with relevant existing company policies
- Termination of outsourcing contract