External Audits Of Microfinance Institutions

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THE CONSULTATIVE GROUP TO ASSIST THE POOREST[A MICROFINANCE PROGRAM]External Audits ofMicrofinance InstitutionsA HandbookVolume 2For External AuditorsTechnical Tool Series No. 3December 1998

ContentsForewordixAcknowledgmentsxAcronyms and AbbreviationsxiChapter 1 Introduction11.1 Audiences and uses for this handbook1.2 Limitations of this handbook41.3 Organization of this volume43Chapter 2 Auditing Microfinance Institutions: An Overview2.1 Scope of services52.1.1 Annual financial statement audits52.1.2 Agreed-upon procedures62.1.3 Special purpose audits62.2 The contracting process72.3 Auditing standards and accounting standards72.4 Stages of the audit process85Chapter 3 Understanding the Microfinance Industry93.1 Background and history of microfinance93.2 Microfinance lending methodologies103.2.1 Differences between microfinance and conventional lending3.2.2 Types of microfinance lending methodologies113.3 Types of institutions providing microfinance133.4 Decentralized operations and internal controls153.5 Fraud issues15Chapter 4 Planning the Audit194.1 Gaining knowledge of the business194.1.1 Meetings194.1.2 Visits214.1.3 Review of reports and documents214.2 Understanding accounting standards and methods4.2.1 Accounting standards214.2.2 Accounting methods214.2.3 Financial institution or nonprofit?22iii2110

ivEXTERNAL AUDITS OF MICROFINANCE INSTITUTIONS: A HANDBOOK, VOLUME 24.3 Understanding accounting systems and internal control systems4.3.1 Accounting systems224.3.2 Internal control systems244.4 Assessing audit risk244.4.1 Inherent risk244.4.2 Control risk254.4.3 Detection risk254.5 Defining materiality254.6 Assessing and establishing relationships with internal auditorsChapter 5 Obtaining Audit Evidence: An Overview295.1 Key account balances295.2 Identifying potential errors for each account balance305.3 Identifying business risks for each account balance305.4 Identifying audit risks for each account balance315.5 Performing tests of control325.6 Performing substantive procedures325.7 Determining samples335.7.1 Sampling for tests of control335.7.2 Sampling for substantive procedures335.8 Obtaining management representations35Chapter 6 Obtaining Audit Evidence: The Loan Portfolio6.1 What makes MFI portfolios unique?376.2 Business risks396.2.1 Credit risk396.2.2 Fraud risk406.2.3 Interest and exchange rate risk416.3 Audit risk416.4 Tests of control416.4.1 Tests of control at the head office426.4.2 Tests of control at retail outlets456.4.3 Tests of control through client visits476.5 Substantive procedures476.5.1 Tests of detail486.5.2 Analytical procedures506.6 Tests for interest receivable and interest income516.6.1 Interest accrual516.6.2 Interest income testing516.7 Agreed-upon procedures for the loan portfolio53Chapter 7 Obtaining Audit Evidence: Loan Loss Provisionsand Write-offs557.1 The importance of loan loss provisions55372227

CONTENTS7.2 The need for loan write-offs577.3 Tests of control587.3.1 Report accuracy597.3.2 Noncash paydown issues597.3.3 Loan loss provisioning607.4 Substantive procedures617.4.1 Tests of detail617.4.2 Analytical procedures617.5 Compliance with laws and regulationsv62Chapter 8 Obtaining Audit Evidence: Cash and Equivalents8.1 Potential business risks638.1.1 Liquidity risk638.1.2 Fraud risk648.2 Potential audit risks648.3 Tests of control658.3.1 Test for segregation of duties658.3.2 Test the movement of cash within the organization8.3.3 Test bank reconciliation procedures658.4 Substantive procedures66Chapter 9 Obtaining Audit Evidence: Capital Accounts9.1 Potential business risks689.1.1 Fiduciary risk689.1.2 Regulatory risk689.2 Tests of control689.3 Substantive procedures69636567Chapter 10 Obtaining Audit Evidence: Payables and AccruedExpenses7110.1 Tests of control7210.1.1 For payables7210.1.2 For accrued expenses7210.2 Substantive procedures7210.2.1 Tests of detail7210.2.2 Analytical procedures73Chapter 11 Obtaining Audit Evidence: Savings and Deposits11.1 Potential business risks7611.2 Tests of control7611.3 Substantive procedures7611.3.1 Tests of detail7611.3.2 Analytical procedures7675

viEXTERNAL AUDITS OF MICROFINANCE INSTITUTIONS: A HANDBOOK, VOLUME 2Chapter 12 Obtaining Audit Evidence: Revenue and Expenses12.1 Potential risks7712.2 Tests of control7812.3 Substantive procedures78Chapter 13 Reporting7913.1 The audit report7913.1.1 Unqualified opinion8013.1.2 Unqualified opinion with an emphasis of matter13.1.3 Qualified opinion8113.1.4 Disclaimer of opinion8213.1.5 Adverse opinion8313.2 The management letter847781Boxes4.1 Summary of ISA 400 on accounting systems and internalcontrol systems234.2 Summary of ISA 400 on inherent risk and control risk244.3 Example of control risk in an MFI254.4 Summary of ISA 320 on materiality264.5 Example of a calculation of materiality for an MFI274.6 Example of using internal auditing work285.1 Summary of ISA 400 on detection risk315.2 Summary of ISA 400 on tests of control325.3 Summary of ISA 520 on analytical procedures335.4 Summary of ISA 530 on audit sampling346.1 Examples of MFI experiences with fraud406.2 Possible elements of an MFI’s credit policy436.3 Illustrative loan file elements to be tested466.4 Illustrative issues for client interviews486.5 Example of sample size determination for client visits4913.1 Example of an auditor’s report expressing an unqualified opinion8013.2 Example of an emphasis of matter paragraph8113.3 Example of an emphasis of matter paragraph relatingto a going concern8113.4 Example of a qualified opinion due to a limitation on scope8213.5 Example of a qualified opinion due to a disagreement on accountingpolicies (inappropriate accounting method)8213.6 Example of a disclaimer of opinion due to a limitation on scope8313.7 Example of an adverse opinion due to a disagreement on accountingpolicies (inadequate disclosure)83Figure4.1 Ideal reporting lines for internal auditing28

CONTENTSTables4.1 Initial considerations in planning an MFI audit204.2 Examples of materiality levels264.3 Working with internal auditors in an MFI275.1 Examples of potential errors in account balances307.1 An illustrative loan aging schedule and correspondingloss provisions56vii

ForewordMicrofinance is the provision of banking services for the poor. Over the past 20 yearsthe field has been revolutionized as dozens of microfinance institutions (MFIs) havedemonstrated the feasibility of delivering such services on a financially sustainable basis.Having developed services that can be run profitably with commercial sources of funds,these institutions are positioned to expand their outreach to the poor far beyond thelimits of scarce donor and government funding. In this context, many MFIs are devoting increased attention to financial management and financial reporting.The Consultative Group to Assist the Poorest (CGAP) is a multidonor consortiumdedicated to the advance of sustainable microfinance worldwide. We believe that external audits can be an important tool for improving the quality and credibility of MFIs’financial reporting and management. At the same time, we have observed that MFIs,donors, and auditors often invest major effort and expense in audits without getting anappropriate return in terms of the transparency and reliability of the audited information. Audits often do a reasonable job of tracking the uses of donor funds, but far lessoften produce a meaningful picture of the health of an MFI’s financial service business.CGAP has produced this handbook to help audit customers—meaning theboards of directors and managers of MFIs, donors, creditors, and investors—contract for audits that are more responsive to their needs, and to help auditfirms deal with some of the unique issues presented by microfinance operations.Microfinance differs in crucial respects from commercial banking and otherbusinesses with which auditors are more familiar.Because this handbook is breaking new ground, we are sure that experiencewith its use will suggest many areas for improvement. Thus we are anxious to hearfrom the staff of audit firms, MFIs, and donors who have put it to the test of practical use. These busy people may not find it easy to free up time to offer commentsabout their experience with this handbook. Still, we know that many of them shareour belief in the immense human worth of microfinance efforts, and hope that theywill be motivated to help improve this tool in subsequent editions.Please communicate any comments and suggestions to Richard Rosenberg (rrosenberg@worldbank.org) or Jennifer Isern (jisern@worldbank.org). CGAP’s telephonenumber is 1 202-473-9594, its fax number is 1 202-522-3744, and its mailing addressis World Bank, Room Q 4-023, 1818 H Street NW, Washington, D.C. 20433, USA.Mohini MalhotraGeneral ManagerConsultative Group to Assist the PoorestDecember 1998ix

AcknowledgmentsThe handbook was prepared with the assistance of Deloitte Touche TohmatsuInternational. Robert Peck Christen and Richard Rosenberg of CGAP wrote partsof the handbook and revised all of it. Jennifer Isern and Ira Lieberman of CGAPreviewed the handbook and provided useful comments. The handbook was editedby Paul Holtz, laid out by Garrett Cruce, and proofread by Daphne Levitas, allof Communications Development Incorporated. Special thanks are due to themanagement and staff of the MFIs that were visited during the preparation ofthis handbook—PRODEM and FIE in Bolivia, FINCA and CERUDEB in Uganda,and BRAC and Buro Tangail in Bangladesh—as well as the audit firms consultedduring this process.x

Acronyms and AbbreviationsCGAPGAAPIASISAMISMFINGOConsultative Group to Assist the Poorestgenerally accepted accounting principlesInternational Accounting StandardsInternational Standards on Auditingmanagement information systemmicrofinance institutionnongovernmental organizationxi

CHAPTER 1IntroductionThis brief chapter discusses the need for this handbook, offers suggestions for its use, and underscores its limitations.Microfinance—the provision of banking services for the poor—has been agrowth industry for the past 20 years. In 1997 an estimated 7,000 microfinance institutions (MFIs) around the world were offering tiny loans to microenterprises, deposit services tailored to the needs of poor households, and otherfinancial services such as transfers. To date most of these institutions havebeen nonprofit, nongovernmental organizations (NGOs). But many creditunions, especially in Africa, are offering microfinance services, and a fewlicensed finance companies and commercial banks are beginning to enter themarket.At present most microfinance is funded by donors and governments. Butstronger MFIs are realizing that the demand for their services far outstrips thelimited supply of donor and government funds. At the same time, they have shownthat they can provide microfinance on a financially sustainable basis: customersfind MFIs so valuable that they are willing to pay the full cost of their services.When an MFI becomes financially sustainable, it can begin funding its loans withdeposits and other commercial sources of capital. In doing so it escapes the limitations inherent in donor funding, while providing a safe and convenient savingsservice to its customers.In this context, boards of directors and managers of MFIs, as well as the donorsthat fund them, are focusing more closely on MFIs’ financial reports. Externalaudits have traditionally been the principal means of assuring the accuracy andmeaningfulness of those reports. But experience has shown that external auditsoften fail to produce an adequate review of an MFI’s financial position and internal controls—especially when it comes to information on its loan portfolio. Thereare three main reasons external audits often fall short: Customers requesting external audits—boards, managers, and donors—oftendo not understand what audits can and cannot be expected to do. Nor do theyunderstand what special procedures, beyond the scope of a normal statutory1External audits oftenfail to produce anadequate reviewof an MFI’s financialposition—especially itsloan portfolio

2Typical financialstatement auditprocedures are notwell-suited todetecting somecommon deficienciesof microfinanceportfoliosEXTERNAL AUDITS OF MICROFINANCE INSTITUTIONS: A HANDBOOK, VOLUME 2audit, may be needed to address certain issues, or how to craft terms of reference that communicate their needs to the auditor. Donors often provide terms of reference for external audits, but these usuallyfocus on compliance with the donors’ loan or grant agreements and on tracking the specific uses of the donors’ funds, rather than on the financial healthof the audited institution’s microfinance business. Few external auditors have much experience with microfinance. Thus theyseldom understand the unique features of the microfinance business, whichcall for different audit procedures than those used in conventional financialbusinesses.A further problem with audits of MFIs is that they often absorb too much timeof auditors and MFI staff with issues that are not especially material to the mainrisks inherent in the microfinance business. Audit firms tend to assign junior staffto MFI audits, and these staff often focus on checking compliance with detailedlists of accounting and operational prescriptions—not all of which are highly relevant to the basic soundness of the MFI’s financial reporting or the security andefficiency of its operations. For this reason, this handbook emphasizes a “riskbased” audit approach: the external auditor must evaluate the relative importanceof various areas of risk and focus most of the audit work on those areas that aremost material to the business being audited. For example, voluminous loan documentation and multilevel approval procedures are standard in normal commercial banking but may be utterly impractical in a microcredit setting. Discriminatingbetween important and less important issues requires an exercise of judgment thatis possible only if the auditor understands the MFI’s business. Most auditors willhave to devote considerable time to learning this business, but this effort shouldbe amply rewarded by saving time that would otherwise be devoted to elaboratetesting of items that are in fact less material.Reference was made above to “unique features” of the microfinance business. Most of these features have to do with an MFI’s loan portfolio. And it isprecisely the loan portfolio that is the most common source of serious problems that escape disclosure, or even management’s attention—sometimes untilit is too late to deal with them. Typical financial statement audit procedures arenot well-suited to detecting some common deficiencies of microfinance portfolios. Thus the chapters in each volume dealing with procedures for reviewing loan portfolio systems are among the most important parts of this handbook.Those chapters, more than the rest of the handbook, contain material that isunlikely to be found elsewhere. Auditors and audit customers should reviewthem especially closely.Readers will note that the handbook devotes much more attention to MFIs’loan operations than to their savings operations. This certainly does not reflect aview that credit is more important than deposit services for poor clients. If anything, the opposite is often true. Many MFIs want to become licensed financialinstitutions, not only to gain access to commercial funding but also to provide

INTRODUCTIONsavings services to their target clients. Savings services receive only brief treatment here, however, because few MFIs are licensed to take savings and becauseaudits of MFIs’ savings operations, unlike audits of their credit operations, canbe quite similar to audits of commercial banks.Another key element of this handbook is annex A, which offers guidelines forthe content and presentation of MFIs’ financial statements. If these guidelinesare followed, readers of audited financial statements will be much better able tojudge whether an MFI has a business that can grow beyond the limited availability of subsidized donor funding.3The handbook isdivided into two1.1 Audiences and uses for this handbookThe handbook is divided into two volumes, for two distinct audiences. Volume 1is primarily for clients of external audits—including boards, managers, and staffof MFIs, as well as outside investors, especially donors. Topics covered in volume1 include: What to expect—and what not to expect—from external audits The relationship between internal and external audit functions The different products that external auditors can be asked for, including special purpose audits and agreed-upon procedures How to commission an audit, including writing terms of reference and selecting the auditor Special issues associated with MFIs’ loan portfolios How audits are conducted How audit reports should be interpreted.Volume 2 is for external auditors. It provides an overview of the microfinanceindustry—general concepts that must be supplemented by a thorough educationin the business and methodology of the MFI being audited. Volume 2 also provides guidance on a range of audit issues that are specific to MFIs. External auditors should review volume 1 as well, especially chapter 4 (which guides clients indefining the scope of work they require) and chapter 5 (which describes the challenges posed by microfinance portfolios).Both volumes may be of interest to government regulators and supervisors. Asthe microfinance industry grows, banking authorities in many countries are beingforced to confront the issue of supervising MFIs. Experience has made it clear thatefficient supervision of MFIs requires some adjustment in the regulations and examination procedures applied to more conventional financial intermediaries. Thishandbook is not an examination manual, but its contents might be useful in thepreparation of such a manual. In any event, supervisors responsible for overseeingMFIs may wish to refer them and their auditors to this handbook.A set of annexes illustrates material in both volumes.volumes, for twodistinct audiences

4EXTERNAL AUDITS OF MICROFINANCE INSTITUTIONS: A HANDBOOK, VOLUME 21.2 Limitations of this handbookThis handbook is not an accounting manual. It provides little guidance on accounting systems or internal controls. MFIs should have their own accounting procedures,manuals, and internal controls in place before commissioning an external audit.Nor is this handbook an audit manual. It should be used only to supplement authoritative audit standards and the audit firm’s internal policies, in thecontext of the laws and regulations applicable to the entity being reviewed.Even though the handbook is not an authoritative audit manual, volume 1 suggests that an MFI commissioning an audit might use the handbook in its contracting process. Before contracting an audit, the client might well ask the auditorto review the handbook, and to note in writing and discuss with the client, anymajor elements of the handbook’s guidance that the auditor does not believe shouldbe implemented due to issues of practicality, cost, or conflicting authoritativeguidance.Volume 2 is addressed to auditors of a wide range of MFIs in a wide variety of countries. Because these auditors vary immensely in experience and sophistication, it hasbeen difficult to provide a level of discussion that is appropriate for all readers. Inparticular, experienced auditors may have little use for material on general auditprinciples. It is hoped that such readers will understand the reason for including thismaterial, and focus on matters that are more specific to the challenges of MFI audits.1.3 Organization of this volumeChapters 2–5 of this volume provide an overview of MFI audits and backgroundon the microfinance industry—including discussion of how MFIs differ from conventional financial institutions. These chapters also review the audit standardsand procedures most relevant to an MF

3.2.1Differences between microfinance and conventional lending 10 3.2.2Types of microfinance lending methodologies 11 3.3Types of institutions providing microfinance 13 3.4Decentralized operations and internal controls 15 3.5Fraud issues 15 Chapter 4 Planning the Audit 19 4.1Gaining knowledge of the business 19 4.1.1Meetings 19 4.1.2Visits 21

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