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Internal Controls & Assurance - March 2010
Ash Shaw plans to help Independent Trustees prepare their Internal Control Reports using The Internal Controls Reporting System™.
This is a process of 7 simple steps. These steps will cover The Internal Controls Self Assessment Analysis™ through to maximising your investment in your Internal Controls Report.
This month, The Internal Controls Self Assessment Analysis™ is to help you assess your current position and identify strengths and weaknesses with your current internal controls. Next month we will look at step 2, The Internal Controls Reporting Roadmap™.
In December 2009 the Pensions Regulator launched a ‘Consultation on the Pensions Regulator’s Trustee Register’. More specifically, the review focuses on how they operate the judgement-based conditions of the Trustee Register and states that a number of revisions and refinements to make this judgement are necessary.
The key changes relate to:
- The interpretation of ‘overall management responsibility’ and ‘significant influence’ when considering who is a Key person and Officer;
- The applicant’s ‘sufficient relevant experience’;
- Whether the applicant has ‘sound administrative and accounting procedures’; and
- Whether the applicant has ‘adequate indemnity insurance cover’
Independent Trustees who want to remain on the register will almost certainly have to obtain an Internal Controls Report over their controls. We believe that the key considerations include:
- Are your processes, procedures and controls documented? If not, who will document them?
- What period will your first internal controls report cover?
- Who will write the report?
There are a number of documents available to support this new requirement:
Improvement begins with rigorous, honest and robust self evaluation against a set of control objectives.
We have created a self analysis worksheet which may be completed by individuals or in groups. You can then make a judgement against each of the control objectives and use the evidence section to make notes on links between your judgements.
We are currently developing an Internal Controls tool kit to support the production of Internal Controls Reports, and to share effective strategies that reduce the need for exceptions. Our first tool is a Discussion Forum for Independent Trustees. which we believe will be of great interest for those who want to join or remain on the Pension Regulator’s register.
We have created a group on Linked In for independent pension scheme trustees to consider the implications of the Pensions Regulator's '‘Consultation on the Pensions Regulator’s Trustee Register". We will soon send you an invitation to join this group and we look forward to hearing your thoughts on this topic.
We have started our discussion by asking the following question:
Is there an easier way to provide the assurance the Regulator requires rather than produce an Internal Controls Report?
Comment
Would you like to comment? To share your thoughts on this topic please contact Sally Tasker on 0207 7917 2987 or email Sally Tasker. |
