HAWKE: We don’t have, obviously, an independence concern in that regard
We haven’t surveyed our other regions, but if that ratio is typical of what’s going on throughout the country, I think it’s an issue that should present serious concerns.
We have had situations where banks have out-sourced internal loan review to their external auditors, for example, and we have prohibited that because we think that’s a violation of the independence rule
MR. We would want to make sure that management is still paying attention to the quality of internal audit. This is a key concern for management, and we would want to make sure that boards of directors and management didn’t view their responsibilities at an end just because they had out-sourced an audit to an external firm.
COMMISSIONER CAREY: Do you feel that audit committees at the banks under your regulation are playing a sufficient role in monitoring these practices on the boards of the banks that you regulate?
MR. HAWKE: I would be reluctant to make an across-the-board judgment on the quality of audit committee performance. This is a subject, though, that we put a tremendous amount of importance on.
We think that both in dealing with the external auditors and particularly in assuring the independence ofinternal audit, the function of audit committees https://rksloans.com/title-loans-ct/ is criticalMISSIONER HUNT: Doesn’t it bring to the argument, sir, that when an auditing firm performs outside functions, other functions for a client, it gets to know the client better and therefore can do a better audit?
MR. HAWKE: I think there is certainly something to the notion that the external auditors know the institution well and can perform an internal audit perhaps without some of the start-up learning and costs that might be involved if audit were out-sourced to a different external firm.
But I think that the price in the long run that one pays for that is not worth that efficiency.
HAWKE: Well, I can’t say that we have found problems
COMMISSIONER UNGER: You had said earlier that the firms or, rather, the banks that out-sourced their internal audit function are, perhaps, examined more closely. Are they considered more risky?
MR. HAWKE: They’re not considered more risky, but when we’re ination resources, if we — for example, in the compliance area, if we find that a bank’s internal audit function is weak, we will not be able to rely on them to the same extent that we would if the function were strong in areas like compliance or any other area of internal audit, which means that we have to devote more examination resources to that area. Where a bank has astrong internal audit function, it gives a great deal of comfort.
COMMISSIONER UNGER: So in the examination function of the banks that out-source their internal audit function, have you found problems with the institutions that have the same auditing firm perform the internal and external audit?
MR. But as I said in my testimony, these questions of independence are extremely subtle, and one doesn’t easily come across concrete evidence that there has been an impairment of independence.
What we’re concerned about is the lack of checks and balances between internal and external audit when both functions are performed by the same firm, and we’re concerned about the subtle influences that work on the external auditor when they have an opportunity to capture that additional engagement.
COMMISSIONER UNGER: Right. Well, we have found actual instances where there are problems, and what I’m trying to quantify is whether you’ve found instances wherethere are problems when that relationship exists.
MR. HAWKE: Let me step out of the area of out-sourcing of internal audit and look at other areas. Loan review is a management function that should not be out-sourced to external auditors.