Risk Based Internal Auditing in Taiwanese Banking Industry Yung Ming

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    Risk Based Internal Auditing in Taiwanese Banking Industry

    Yung-Ming Shiu

    Assistant Professor

    Department of Business Administration,

    National Cheng Kung University, Taiwan

    Email: [email protected]

    Mei-Lan Yeh

    Department of Business Administration,

    National Cheng Kung University, Taiwan

    Email: [email protected]

    Date: 25 June 2008

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    i

    CONTENTS

    CHAPTER 1 INTRODUCTION 1

    1.1 RESEARCH BACKGROUND AND MOTIVATIONS 1

    1.2 PURPOSE OF RESEARCH AND FINDINGS 2

    1.3 STRUCTURE OF THIS STUDY 3

    CHAPTER 2 CURRENT USE OF RBIA IN TAIWANESE BANKING

    INDUSTRY.................................................. 4

    CHAPTER 3 LITERATURE REVIEW AND HYPOTHESIS

    DEVELOPMENT....................................................................... 10

    3.1 RISK MANAGEMENT 11

    3.2 INTERNAL CONTROL 12

    3.3 CORPORATE GOVERNANCE 13

    3.4 TECHNICAL COMPETENCE 15

    CHAPTER 4 METHOD..................................................................... 17

    4.1 DATA COLLECTION AND SAMPLE 17

    4.2 NON-RESPONSE BIAS 17

    4.3 MEASUREMENT OF VARIABLES 18

    4.4 MODEL 20

    CHAPTER 5 RESULTS.................................................................. 24

    5.1 DESCRIPTIVE STATISTICS 24

    5.2 UNIVARIATE RESULTS 24

    5.3 ASSUMPTION TEST RESULTS 25

    5.4 REGRESSION RESULTS 26

    CHAPTER 6 CONCLUSION AND LIMITATION.................................... 32

    6.1 CONCLUSION 32

    6.2 LIMITATION 33

    REFERENCE.................................................................. 34

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    ii

    TABLES

    TABLE 1 RESULTS OF LEVENES TEST AND INDEPENDENT SAMPLE T

    TEST 22

    TABLE 2 COMPOSITION AND RELIABILITY OF VARIABLES 22

    TABLE 3 DEFINITION OF VARIABLES USED IN THE MODEL 23

    TABLE 4 DESCRIPTIVE STATISTICS 27

    TABLE 5 FACTORS OF DOMESTIC BANKS SEGMENTED BY DEGREE OF

    RBIA 28

    TABLE 6 CORRELATION MATRIX 30

    TABLE 7 VIF VALUE 31

    TABLE 8 RESULTS OF TOBIT REGRESSION ANALYSIS 31

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    FIGURES

    FIGURE 1 USE OF RBIA BY BANKS 4

    FIGURE 2 COMPLETENESS AND CORRECTNESS OF THE CONTENT OF

    RISK REGISTER 5

    FIGURE 3 DEFINITION OF RBIA ACTIVITY IN AUDIT CHARTER 6

    FIGURE 4 PROPORTION OF AUDIT PLAN THAT IS RISK-BASED 7

    FIGURE 5 ALLOCATION OF INTERNAL AUDIT RESOURCES 7

    FIGURE 6 INTERNAL AUDITS EVALUATION BASED ON RISK

    ASSESSMENT 8

    FIGURE 7 FREQUENCY OF REPORTING TO THE BOARD OF

    DIRECTORS 8

    FIGURE 8 BANKS CONCERN ABOUT EXECUTING RBIA 9

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    Chapter 1 Introduction

    1.1Research Background and MotivationsRecent corporate collapses and financial scandals have provoked world-wide

    concern with corporate governance highlighted apparent failures of accountability

    (Spira and Page 2003), and subsequent new laws, regulations in response to them (the

    Sarbanes-Oxley Act, 2002 and SEC rules) provide compelling evidence that internal

    auditing, serves as part of sound corporate governance framework (Spira and Page

    2003), matters and is important. More recently, various releases by the Institute of

    Internal Auditors (IIA)-UK and Ireland Position Statement on Risk Based Internal

    Auditing(hereunder refers to RBIA) (IIA 2003) and the Standards for the

    Professional Practice of Internal Auditing (IIA, 2004) reveal the focal point of internal

    auditing and the role of this function in organizations has moved from traditional

    control and compliance orientation to a more risk-based focus (Kippenberger 1999;

    Walker et al. 2003;IIA, 2003).

    This is consistent with Turnbulls broader approach to internal control as

    Turnbull has stated that directors shall adopt a risk-based approach to establish a

    sound system of internal control and reviewing its effectiveness, and to incorporate

    risk management and internal control by the company within its normal management

    and governance processes (FRC 2005).

    In recent years, banking regulators have changed their examination techniques

    by placing emphasis on an institutions internal control system and on the way it

    manages and controls its risks (McCool 2000). In conjunction with the

    implementation of the New Basel Capital Accord (NBCA), known as Basel II, of

    which the main goal is to reinforce the risk management system within the banking

    industry, the Financial Supervisory Commission of the Executive Yuan (the FSC) in

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    Taiwan has pushed the regulatory authority to build up a risk-based supervisory

    system and amend related laws and regulations where banks are mandated to conduct

    more public disclosure of qualitative and quantitative information for finance,

    business, corporate governance and risk management operation (FSC 2004). The FSC

    further urges banks to set up a well-arranged risk management mechanism, such as

    internal control system, risk management mechanism and internal audit function that

    are mandated by the law Enforcement Regulations for Bank Internal Audit Control

    System. Furthermore, the risk management strategies and execution quality of the

    bank will be the focal point of supervision in the future, and face check and balance

    imposed by market functions.

    An effective risk management by banks and effective risk-based supervision by

    regulators are highly dependent both on the implementation of adequate internal

    control systems and on the competence of internal audit staffs (Katz 1998). In Taiwan,

    banks operate in an institutional environment where internal auditing is a statutory

    requirement1. Despite all of the recent attention focused on RBIA, research on the

    existence or extent of this sector in general in corporations has been scant. Therefore,

    the purpose of this study aims to investigate the current use of RBIA by Taiwanese

    banking industry and to identify factors associate with the demand of RBIA among

    banks.

    1.2 Purpose of Research and Findings

    This study explores factors associate with Taiwanese banks demand of RBIA

    from perspectives of risk management, internal control, corporate governance and

    internal auditors technical competence. Using data from a survey of domestic banks

    1

    Implementation Rules for Bank Internal Audit and Internal Control System, 2007 modified;Regulations Governing the Implementation of internal control and Audit Systems by Holding

    Companies, 2005 modified.

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    together with information from corporate annual reports, we find support that the

    degree of RBIA used by banks is associated with information disclosures about

    financial, compliance, health and safety, technology, internal process and change

    management risk management; the existence of a risk management committee; ratio

    of Non-Performing Loan; the banks size and complexity; board size; proportion of

    independent board members; the level of shareholdings held by institutional

    shareholders; and internal auditors technical competence.

    1.3 Structure of This Study

    The paper is structured as follows. The next section discusses current use of

    RBIA in Taiwanese Banking Industry. The third section describes a literature review

    and the hypothesis development. Subsequent sections present the method and results.

    The final section provides discussion, conclusions and limitations of the study, and

    also suggestions for future research.

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    Chapter 2 Current Use of RBIA in Taiwanese Banking Industry

    A survey is designed to gather information on the current use of RBIA in banking

    industry. The questionnaire is developed based on the Standards for the Professional

    Practice of Internal Auditing (IIA 2004a) and the Implementation Rules for Bank

    Internal Audit and Internal Control System (FSC 2007), and includes four parts: part

    one asked about current status of the banks risk management; part two requests for

    the definition of RBIA activity in audit charter and technical competence of internal

    auditors; part three investigates the performance of RBIA in related to audit planning,

    nature of work and communication; and part four inquire about basic information of

    the banks. Our sample consists of all of the 39 domestic banks, and of the 39 surveys

    mailed, 24 completed responses were returned for a response rate of 61.54%.

    Of the 24 survey responses, 13 (54.1%) of the banks report that more than 60%

    of their internal audit activities are risk oriented. As Figure 1 illustrates, we find that 8

    of 24 (33.3%) respondents indicating that they use a relatively high level of RBIA,

    about 61%-80%, while 6 (25%) of the banks report that about 21%-40% of their

    internal audit work are risk-based.

    FIGURE 1

    0% 5% 10% 15% 20% 25% 30% 35%

    Percentage of Responding Banks

    0-20%

    21%-40%

    41%-60%

    61%-80%81%-100%

    PercentageofRBIA

    Used

    Use of RBIA by Banks

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    The effectiveness of RBIA derives from a reliable risk register, also a complete

    risk register will be available for audit planning (Griffiths 2006). Question 1 and 2

    asked each bank to identify the completeness and the correctness of the content of its

    risk register. Of all the 24 responses, there is one missing data on these two questions.

    As illustrated by Figure 2, a significant percentage reported a complete and correct of

    the risk register, notably 3 (13%) of the banks reported no risk register.

    FIGURE 2

    0% 10% 20% 30% 40% 50%

    Percentage of Responding Banks

    No Risk Register

    General

    Complete/Correct

    Most Complete/Correct

    Completeness and Correctness of the Content of Risk register

    Completeness Correctness

    As regulated by the Standards for the Professional Practice of Internal Auditing,

    the purpose, authority, and responsibility of the internal audit activity should be

    formally defined in a charter (IIA 2004a). To get an indication of how clearly RBIA

    activities are defined, banks were asked whether it is been clearly defined in the audit

    charter or work manual that internal auditor should audit and assure the adequacy and

    effectiveness of risk management and control system in Question 5. As shown in

    Figure 3, a large majority of banks (70%) reported RBIA activities are been clearly

    defined in the audit charter, while only 1 bank reported no definition of any RBIA

    activities in audit charter or work manual.

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    FIGURE 3

    0% 10% 20% 30% 40% 50% 60% 70% 80%

    Percentage of Responding Bank

    Not Defined

    General

    Clear

    Very Clear

    Definition of RBIA Activity in Audit Charter

    To see the extent of audit activities that are risk-based, we asked banks a series of

    questions concerning audit planning. Question 8.2 asked respondents the proportion

    of Engagement plan that are based on annual risk assessment. Except 3 missing data,

    approximately 12 of 21 (57.1%) respondents expressing that less than 40% of

    Engagement plan are based on annual risk assessment. We also inquired about the

    proportion of annual audit plan that is based on each business units risk character and

    that the priority of audit activities is determined on risk assessment in Question 8.3

    and 8.4. As Figure 4 demonstrates, the percentage drops to about 50% for

    approximately 61%-100% of annual audit plan to each business unit that is risk-based,

    while 42% of banks indicated less than 40% of annual audit plan that is risk-based.

    The annual audit plan on the priority of audit activities shows the same outcome, with

    50% and 38% respectively for about 61%-100% and less than 40%.

    Question 9.5 asked banks to rank the allocation of internal audit resources on

    each of audit activities. Figure 5 presents the percentage of responding banks that

    expressed none, a few, few, regular, many, great many about each audit activities. A

    great many of internal audit resources were allocated to internal control audit, with

    92% of responding banks expressing many to great many of audit resources.

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    FIGURE 4

    0%

    5%

    10%

    15%

    20%

    25%

    30%35%

    40%

    Percentageof

    RespondingBank

    s

    0-20% 21%-40% 41%-60% 61%-80% 81%-100%

    Proportion of Audit Plan

    Proportion of Audit Plan that is Risk-based

    Engagement

    Business Unit

    Audit Priority

    Financial, operational and information system audits are also audit activities that

    have been allocated of most audit resources for the respondents, with 54%, 55% and

    51%, respectively, indicating many to great many audit resources. Risk management

    and special projects and others audits are the next two audit activities, with 46% and

    41%, respectively, expressing many to great many of resources for each activity. The

    activity of least allocation is corporate governance audit, where only 34% of

    responding banks that allocate many to great many of audit resources.

    FIGURE 5

    4%8%

    33%

    46%

    8%

    0%0%8%

    63 %

    29 %

    4%8%

    38 %

    25 %

    21 %

    4%8%

    33%

    38%

    17%

    0%0%

    50%

    38%

    13%

    4%

    17%

    42%

    21%

    13%

    8%

    8%

    42%

    33%

    8%

    0%

    20%

    40%

    60%

    80%

    100%

    Pcao

    Rep

    n

    Ba

    Financial Internal

    Controls

    Risk Mgt. Operational Info rmation

    system

    Corporate

    Governance

    Special

    Projects and

    Others

    Allocation of Internal Audit Resources

    None A Few Few Regular Many Great Many

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    RBIA is all about providing an opinion on whether risks are being properly

    managed (IIA 2003; Griffiths 2006). Question 9.4 asked banks to indicate how

    frequency internal auditors would evaluate the adequacy and effectiveness of control

    of following issues based on results of risk assessment. As Figure 6 presented, most of

    banks evaluation on the issues always based on risk assessment results.

    FIGURE 6

    0%

    20%

    40%

    60%

    80%

    Percentageof

    RespondingBanks

    Rarely Regular Sometimes Always

    Internal Audit's Evaluation based on Risk Assessment Reliability andIntegrity of Financial

    and Operational

    Information

    Effectiveness andEfficiency of

    Operations

    Safeguarding of

    Assets

    Compliances with

    Laws, Regulations

    and Contracts

    The frequency that chief internal auditor is reported to the board of directors has

    important impacts on RBIA. Question 10.2 asked banks the frequency chief internal

    auditor is reported to the board of directors regarding banks significant risk exposures

    and controls. Figure 7 presented that a large majority of banks (88%) responded

    regular to frequently report to the board of directors.

    FIGURE 7

    0%

    10%

    20%

    30%

    40%

    50%

    Percentageof

    RespondingBanks

    None Seldom Regular Frequently

    Frequency of Reporting to the Board of Directors

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    Question 13 asked responding banks to specify their concerns regarding RBIA

    usage. As shown in Figure 8, the greatest concern is lack of proper tool to identify

    risks, with 14 of 24 responding banks. Lack of experience is the next greatest concern

    to the banks, with 12 of banks. Lack of relevant principles or guidelines is also issue

    of some concern for the respondents, with 7 responding banks. The item of least

    concern is lack of relevant knowledge. Other concern specify by the responding banks

    is the difficulty of present risk-based concept to internal auditors.

    FIGURE 8

    0

    2

    4

    6

    8

    10

    12

    14

    Numberof

    RespondingBanks

    Lack ofrelevant

    Knowledge

    Lack ofExperience

    Lack ofProper Tool

    to Identify

    Risks

    Lack ofRelevant

    Principles or

    Guidelines

    Others

    Banks' Concern About Executing RBIA

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    Chapter 3 Literature Review and Hypothesis Development

    In 1999, the Institute of Internal Auditors (IIA) promulgated a new

    definition of internal auditing which identifying an assurance and consulting role for

    internal audit, highlighting the changing focus and the expansion scope of internal

    auditing into risk management, corporate governance, and adding value2

    (The IIA,

    2004;Walker et al. 2003; Jenny 2004). The new definition emphasize that internal

    audit function can add value to the organization in terms of risk management and

    corporate governance, and RBIA is an approach that can help to meet these

    requirements (IIA 2003). This approach is consistent with Turnbulls broader

    approach to internal control as Turnbull implies that high level, risk-based internal

    audit functions are a sine qua non (Fraser and Henry 2007).

    Empirical research has investigated the existence or extent of internal auditing

    from risk or governance perspectives. Goodwin-Stewart and Kent (2006) use an

    agency framework to explore firm characteristics associated with the existence of

    internal audit function from risk management, control and governance perspectives.

    He argues that internal auditing is either to be a complementary or substitution

    mechanism aligns with other risk management and governance mechanisms, and that

    survey evidence indicates a significant association between the use of internal

    auditing and a commitment to strong risk management and firm size, however, the

    results reveal a mixed support for the corporate governance factors.

    Using an agency cost framework, Carey, et al.(2000) examined demand for both

    internal and external auditing by family business with two agency proxies which are:

    2 In 1999, the Institute of Internal Auditors (IIA) approved the new definition of internal auditing as:

    an independent, objective assurance and consulting activity designed to add value and improve an

    organizations operations. It helps an organization accomplish its objectives by bringing a systematic,disciplined approach to evaluate and improve the effectiveness of risk management, control, and

    governance process.

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    (1) the proportion of nonfamily management, and (2) the proportion of nonfamily

    representation on the board of directors. They found that the two agency cost proxies

    are associated with demand for external audit, but do not explain the demand for

    internal audit. Carcello, et al. (2005) examines factors associated with U.S. public

    companies investment in internal auditing, and the result indicates that total internal

    audit budgets (in-house plus outsourced portions) are related to factors associated

    with company risk, e.g. company size, complexity and leverage.

    3.1 Risk Management

    The separation of ownership and management functions and the presence of

    information asymmetry introduce the possibility of principal-agent conflicts (Haniffa

    and Hudaib 2006), it also incurs risks to stakeholders in the organization

    (management, shareholders, creditors, etc.) (Spira and Page 2003). Those agency

    conflicts, agency costs and risks are now managed within the corporate governance

    framework through accountability mechanisms, such as internal control and audit.

    (Haniffa and Hudaib 2006; Spira and Page 2003). Stakeholders now compete to

    participate in corporate governance to seek power in organizations by asserting their

    own conceptions of risk and how it should be managed, and a focus on risk

    management has become central to this competition since it defines the accountability

    of the management of the organization (Spira and Page 2003). This is consistent with

    Hay and Knechels (2004) argument that the demand for auditing is a function of the

    set of risks faced by individual stakeholders in an organization and the set of control

    mechanisms available for mitigating those risks. Therefore, internal auditing's risk

    management orientation has given the audit function increased credibility across the

    enterprise and greater acceptance by management (Beumer 2006). Drawing from the

    preceding discussion, the following hypothesis is therefore proposed:

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    H1: The use of RBIA is positively associated with the level of risk confronting

    with the stakeholders.

    The objective of RBIA is to provide independent assurance to the board that

    there is a sound of risk management framework within the organization, and risks that

    may affect the organisations business objectives and strategies are been identified,

    managed and reduced to a level that is acceptable to the board (IIA 2003) . One

    indication of risk management framework is the existence of a separate committee or

    group, comprised of directors and managers (Goodwin-Stewart and Kent 2006) to

    develop risk management development policy. The preceding discussion is reflected

    in following hypothesis:

    H2: The use of RBIA is positively associated with the existence of a risk

    management committee.

    3.2 Internal Control

    As organizations grow in size and complexity, effective risk management

    becomes increasingly problematic (Fraser and Henry 2007). Previous study for

    demand of internal auditing linked to the cost vs. benefit from undertaking monitoring

    (Carcello et al. 2005; Goodwin-Stewart and Kent 2006). Carcello, et al. (2005) asserts

    that increased organizational complexity would result in greater risk and companies

    facing higher risk will increase their organizational monitoring. In addition, from

    transaction cost perspective, larger firms have opportunities to gain economies of

    scale from investment in the fixed costs of internal auditing (Carey et al. 2000; Carey

    et al. 2006). From preceding discussion, the following hypotheses are therefore

    proposed:

    H3a: The use of RBIA is positively associated with a banks size.

    H3b: The use of RBIA is positively associated with the complexity of a bank.

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    Recently, Taiwanese authorities have urged for financial reforms, many domestic

    banks are merged into one large financial holding company. Based on preceding

    discussion, we would expect that as the financial holding company is larger in size

    and more complicated, it would be more likely to use RBIA and request its subsidiary

    to use RBIA for monitoring of risk management. Therefore, this study tests whether

    domestic banks that are a subsidiary of financial holding companies are more likely to

    use RBIA. The preceding discussion is reflected in following hypothesis:

    H3c: The use of RBIA is positively associated with a bank that is a subsidiary of

    a financial holding company.

    3.3 Corporate Governance

    IIA (2005) in their submission to the Turnbull Review Group, requested that

    boards should be responsible for determining acceptable risks and for managing them.

    While board members have ultimate responsibility for risk management and internal

    control, they require assurance that risks throughout the organization have been

    identified, assessed and managed (Fraser and Henry 2007). Hence, internal auditings

    risk-based orientation would be a key component for such assurance. Haniffa and

    Hudaib (2006) indicates that board size affects the extent of monitoring and

    controlling. As a small board may be seen to be more effective, we would expect a

    higher percentage of RBIA may be used. However, as bigger boards seems to be more

    symbolic rather than being a part of the management process (Hermalin and Weisbach,

    2000; Haniffa and Hudaib 2006; Chen 2003), they would require internal audit

    activities to be more risk orientation, as a substitute mechanism. From preceding

    discussion, we test whether the use of RBIA is associated with board size, but do not

    predict a direction:

    H4: The use of RBIA is significantly associated with the board size.

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    In banking industry, information asymmetry problem is relatively higher among

    external bank stockholders, including institutional investors as they have little control

    over bank managers (Zeckhauser and Pound 1990; Ross 1989). Meanwhile, Pound

    (1988) and Cebenoyan et al. (1999) suggest that because of contractual clauses

    specifying what types of investments institutional investors must hold, they have less

    ability to diversify risks and stronger incentives to monitor individual investments.

    Therefore, we would expect that when institutional investors shareholdings are

    proportionately higher, they will be more likely to ensure that internal auditing

    focuses its resources on the banks business and strategic risks. The preceding

    discussion is reflected in following hypothesis:

    H5: The use of RBIA is positively associated with the level of shareholdings held

    by institutional shareholders.

    Internal auditing plays an important role in organizational governance by

    monitoring organizational risks and assessing controls (IIARF 2003). Previous study

    argues that internal audit is a substitute mechanism for monitoring by directors

    (Anderson et al.1993), however, Goodwin-Stewart and Kent (2006) argues that

    information asymmetry problems exist between executive and independent directors,

    internal auditing is more likely to be a complementary mechanism among other

    corporate governance mechanism. Since independent directors lack of day-to-day

    business involvement, they may not have enough information, moreover, they also

    may concern about his or her personal exposure if management commits fraud or

    some other scandal erupts related to the organization (i.e., reputation risk) (Knechel

    and Willekens 2006). Internal auditings risk-based orientation would be a key

    component for such information risk assurance. The preceding discussion is reflected

    in following hypothesis:

    H6: The use of RBIA is positively associated with the proportion of independent

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    board members on the board of directors3.

    3.4 Technical Competence

    The IIAs standard 1210 on proficiency of the auditor requires that the internal

    auditors possess the knowledge, skills and other competencies needed to perform their

    responsibilities (IIA 2004a; Dessalegn Getie and Aderajew Wondim 2007).

    Internal auditors are potentially important providers of independent evaluations

    of the organizations risk management and internal control system (assurance),

    eventually combined with more practice-oriented management assistance (consulting)

    in this area (Sarens and De Beelde 2006). Following Turnbull and Position Statement

    (IIA 2004b), internal auditors are being expected to be increasingly prominent in

    ERM but concerns have been expressed about expertise (Fraser and Henry 2007).

    This new role has led internal auditors to internal expertise that requires different

    technical competence and in-depth understanding of risk that some internal audit may

    not possess, for example, the appropriate qualifications and experience; including the

    necessary specialized skills (e.g. risk management and system design), industry

    specializations as industry-specific factors influenced the risk appetite of the business

    and technological expertise (Spira and Page 2003; Spekle et al. 2007; Carey et al.

    2006; Fraser and Henry 2007). This situation could have potentially serious

    consequences as an internal audit function which has been allocated a prominent role

    in the assessment of the appropriateness of risk management but which lacks the

    necessary expertise could be a weak link in the risk management chain (Fraser and

    Henry 2007).

    Over the last decade, the cost of finding, recruiting and keeping appropriately

    qualified staff has become increasingly more difficult and expensive (Martin et al.

    3 In Taiwan, members of the board of directors contain directors and supervisors.

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    2000). In terms of cost-benefit perspective, the organizations economic

    principle/agent seeks to adopt governance structures that match their control needs in

    a cost-effective way, thus may consider the benefits and drawbacks of adopting RBIA

    while lacking of technical competence internal auditors. Consequently, the propensity

    for banks to use RBIA is more likely to be high when internal auditors are

    technologically competent in this area. Based on the preceding discussion, the

    following hypothesis is therefore proposed:

    H7: The use of RBIA is positively associated with the internal auditors technical

    competence.

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    Chapter 4 Method

    4.1 Data Collection and Sample

    The present study combined data collected from the corporate annual report and

    a survey of domestic banks. Data that are extracted from the banks annual report

    contains information regarding the disclosures of the banks risk management,

    corporate governance structure and ownership of shareholdings, based on fiscal year

    ends from 1 January 2006 to 31 December 2006. A survey was developed to gather

    information on the degree of RBIA employed by the bank, the existence of risk

    management committee and internal auditors technical competence.

    As the questionnaires were to be sent out via mail, initial versions were drafted

    and tested by three non-specialists to eliminate misunderstanding due to wording and

    technical terms. After the initial alteration, a further test was conducted by two

    specialists. With minor modifications, the final questionnaire was mailed to chief

    internal auditors in January, 2008, with a letter explaining the purpose of the survey

    and assuring that the response would be treated in a strictly confidential manner. A

    reminder phone call was made two weeks later.

    The population from which our sample is drawn consists of all of the 39

    domestic banks that are under operation and regulated by the Financial Supervisory

    Commission of the Executive Yuan. Of the 39 surveys mailed, 24 responses were

    received, generating a response rate of 61.54 per cent. Of all the 24 responses, there

    were no unusable responses; hence, the final usable response rate was also 61.54 per

    cent.

    4.2 Non-response Bias

    To assess whether non-respondents (n=15) differed significantly from usable

    responding banks (n=24), the present paper compared the scores of responding banks

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    on total assets and net income before tax to those of the non-respondents. We use

    Levenes test and Independent Sample T test to examine the Homogeneity of

    variances and Equality of Means, respectively. The results indicate that there were no

    significant differences between the two groups on these variables. Thus, there have no

    indications of non-response bias (see table 1 for further details).

    4.3 Measurement of Variables

    The dependent variable is the percentage of RBIA employed by the bank (RBIA).

    This variable is derived from a single question: percentage of internal audit activities

    that are considered to be risk-based.

    The independent variables used in the analyses are summarized in Table 3 and

    explained below:

    Risk ManagementPrevious research has used a set of risk and risk management measures that

    reflect the organizations own assessment of risk and risk management efforts. This

    study adopts the same risk measures to Knechel and Willekens (2006) where six areas

    of risk and related risk management practice are measured. We use annual report to

    evaluate risk management information disclosed by the bank to compute the six

    separate risk management measures. Each risk management measure is computed on a

    five-item scale where one point is added for disclose each of the five information

    regarding a specific area of risk and risk management. As no companies scored the

    maximum score (5) on each risk variable, each risk measure is scaled by its own

    maximum score actually observed, e.g. a company with a score of three for a measure

    where the maximum observed value across all companies was four was scaled to 0.75.

    The six separate risk management measures are as following:

    RISK 1 A score from 1 to 5, scaled by the maximum value in the sample, reflecting

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    the extent of disclosures aboutfinancial risk and risk management.

    RISK 2 A score from 1 to 5, scaled by the maximum value in the sample, reflecting

    the extent of disclosures about compliance risk and risk management.

    RISK 3 A score from 1 to 5, scaled by the maximum value in the sample, reflecting

    the extent of disclosures about environmental and safety risk and risk

    management.

    RISK 4 A score from 1 to 5, scaled by the maximum value in the sample, reflecting

    the extent of disclosures about technology risk and risk management.

    RISK 5 A score from 1 to 5, scaled by the maximum value in the sample, reflecting

    the extent of disclosures about internal process risk and risk management.

    RISK 6 A score from 1 to 5, scaled by the maximum value in the sample, reflecting

    the extent of disclosures about change management risk and risk

    management.

    In addition, since financial characteristics reflect company risk and ability to pay

    for monitoring, company in weak financial condition would try to mitigate their

    heightened risk through enhanced monitoring by internal audit (Carcello et al. 2005).

    Consequently, we include the following financial proxy in the analysis that is most

    concerned in banking industry:

    NPL Ratio of Non-Performing Loan.

    One additional variable is included in the model based on the hypothesis:

    RMC Dummy variable = 1 if the bank has a risk management committee, zero

    otherwise.

    Internal ControlLNINTEST Natural log of net interest revenue.

    FORBNH Foreign branches divided by total branches (if there are no foreign

    branches, this variable equals 0).

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    FHC Dummy variable =1 if the bank is a subsidiary of financial holding

    company; zero otherwise.

    Corporate GovernmentBODNR Total number of members on the Board of Directors

    4.

    INSOWN Percentage of shareholdings held by institutional shareholders.

    NONEXD Percentage of non-executive directors and supervisors on the board of

    directors

    Technical CompetenceThe questionnaire contains 7 items that were measured on a five-point scale, and

    designed to acquire different aspects of technical competence of the internal auditors

    (Q7.1~Q7.7). Confirmatory factor analysis conveys that five of these items load on a

    single factor. Therefore, we combine these items by calculating the mean of the five

    items to obtain a single score for technical competence (see table 2 for further details).

    The correlations of the other two items with the factor were too low and we dropped

    these items from the analysis. The Cronbachs alpha coefficient for TECHCOM is

    0.836.

    TECHCOM A score measured by computing the mean of five questionnaires,

    representing the extent of technical competence of internal auditors in

    the internal audit department.

    4.4 Model

    We use a Tobit model in our analyses, which is a regression technique suited to

    analyse limited (censored) dependent variables (Tufano 1996; Spekle et al. 2007):

    RBIA= bo + b1RISK1 + b2RISK2 + b3RISK3 + b4RISK4 + b5RISK5 +

    b6RISK6 + b7NPL+ b8RMC + b9LNINTEST + b10FORBNH +

    4 In Taiwan, members of the board of directors contain directors and supervisors ; therefore, this paper

    investigates the proportion of non-executive directors and supervisors

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    b11FHC + b12BODNR + b13INSOWN + b14NONEXD +

    b15TECHCOM + e

    Where:

    RBIA Percentage of RBIA employed by the bank

    RISK 1 The extent of disclosures about financial risk and risk

    management

    RISK 2 The extent of disclosures about compliance risk and risk

    management

    RISK 3 The extent of disclosures about environmental and safety

    risk and risk management

    RISK 4 The extent of disclosures about technology risk and riskmanagement

    RISK 5 The extent of disclosures about internal process risk and

    risk management

    RISK 6 The extent of disclosures about change management risk

    and risk management

    NPL Ratio of Non-Performing Loan

    RMC Dummy variable = 1 if the bank has a risk management

    committee, zero otherwise

    LNINTEST Natural log of net interest revenue

    FORBNH Percentage of foreign branches on total branches

    FHC Dummy variable =1 if the bank is a subsidiary of a financial

    holding company; zero otherwise

    BODNR Total number of members on the Board of Directors

    INSOWN Percentage of shareholdings held by institutional

    shareholders

    NONEXD Percentage of non-executive directors and supervisors on

    the board of directors

    TECHCOM A score measured by computing the mean of five

    questionnaires, representing the extent of technical

    competence of internal auditors in the internal audit

    department

    Since tobit regression is used to test the hypotheses, assumptions of

    multicollinearity, independence of error terms and heteroskedasicity are also tested.

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    The Pearson Correlation Matrix and Variance Inflation Factor (VIF) are used to test

    the multicollinearity assumption, while an analysis of residuals and the plots of the

    studentised residuals against predicted values are conducted to test for independence

    of error terms and heteroskedasicity.

    TABLE 1

    Results of Levenes Test and Independent Sample T Test

    Levenes Test Independent Sample T Test

    Variables F-statistics p-value t-value p-value

    Assets 6.562 0.015* -1.164 0.258

    Net Income before Tax 0.180 0.673 -1.480 0.147

    Note: Significant at the 0.05 level.

    TABLE 2

    Composition and Reliability of Variables

    ItemsComponent

    Loading

    Understanding of COSOs ERM (Q7.1) Understanding of risk management framework that are

    established for Basel II (Q7.2)

    knowledge of information technology risk and controls (Q7.3) proportion auditing related certificates holders (Q7.6)

    proportion of risk management related certificates holders (Q7.7)Cronbachs alpha: 0.836.

    0.900

    0.859

    0.779

    0.925

    0.921

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    TABLE 3

    Definition of Variables Used in the Model

    Variables Definition Expected sign

    Dependent Variable

    RBIA Percentage of internal audit activities that are

    considered to be risk-based.

    Independent Variables

    Risk Management Variables

    Risk 1 A score from 1 to 5, scaled by the maximum value in

    the sample, reflecting the extent of disclosures about

    financial risk and risk management.

    +

    Risk 2 A score from 1 to 5, scaled by the maximum value in

    the sample, reflecting the extent of disclosures about

    compliance risk and risk management.

    +

    Risk 3 A score from 1 to 5, scaled by the maximum value in

    the sample, reflecting the extent of disclosures about

    environmental and safety risk and risk management.

    +

    Risk 4 A score from 1 to 5, scaled by the maximum value in

    the sample, reflecting the extent of disclosures about

    technology risk and risk management.

    +

    Risk 5 A score from 1 to 5, scaled by the maximum value in

    the sample, reflecting the extent of disclosures about

    internal process risk and risk management.

    +

    Risk 6 A score from 1 to 5, scaled by the maximum value in

    the sample, reflecting the extent of disclosures about

    change managementrisk and risk management.

    +

    NPL Ratio of Non-Performing Loan. +

    RMC Dummy variable = 1 if the bank has a risk

    management committee, zero otherwise.

    +

    Internal Control Variables

    LNINTEST Natural log of net interest revenue +

    FORBNH Percentage of foreign branches on total branches +

    FHC Dummy variable =1 if the bank is a subsidiary of a

    financial holding company; zero otherwise.

    +

    Corporate Governance Variables

    BODNR Total number of members on the Board of Directors. ?

    INSOWN Percentage of shareholdings held by institutional

    shareholders.

    +

    NONEXD Percentage of non-executive directors and

    supervisors on the board of directors.

    +

    Technical Competence Variable

    TECHCOM A score measured by computing the mean of five

    questionnaires, representing the extent of technical

    competence of internal auditors in the internal auditdepartment.

    +

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    Chapter 5 Results

    5.1 Descriptive Statistics

    Table 4 presents descriptive statistics for the dependent and independent

    variables in the model. Start from independent variable in Panel A, the 24 responding

    samples have conducted moderate RBIA, with a mean RBIA about 0.5833 reflecting

    58.33% of internal auditing activities are risk-oriented. The risk management

    disclosure scores could be divided into two groups. Standardized risk management

    scores 0.7708 and 0.7292 for financial risk management and compliance risk

    management respectively, comparatively higher than that for the rest of four risk

    management, ranging from 0.375 for change management risk management to 0.4563

    for internal process risk management. The percentage of foreign branches on total

    branches ranges from 0 to 0.2727, with a mean of 0.0377. For corporate government

    variables, Panel A indicates that, on average, 12.5313 per cent of shareholdings held

    by institutional shareholders. Technical competence of internal auditors in the internal

    auditing department ranges from 2 to 4.2, with a mean score of 2.7667.

    Panel B shows that of the 24 respondent banks, 79.2 per cent have a risk

    management committee. Panel B also shows that 45.8 per cent of banks in the sample

    are under controlled by a financial holding company.

    5.2 Univariate Results

    We report further descriptive statistics for the banks in the sample, breaking the

    sample on the 25th percentile and the 75th percentile of the degree of RBIA where

    banks engage in infrequent RBIA (RBIA30 percent), some RBIA (RBIA between

    30 and 70 percent), and extensive RBIA (RBIA exceeding 70 percent). Table 5 reports

    a t-test of the differences in the means of these groups and a nonparametric Wilcoxon

    signed-rank test of the differences between the distributions.

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    The univariate analysis of means represents that banks employing infrequent

    RBIA are hardly distinguishable from those employing moderate levels of RBIA,

    apart from the percentage of non-executive directors and supervisors on the board of

    directors (as predicted). The Wilcoxon signed-rank test reports the same result.

    Banks employing extensive RBIA differ from those employing moderate level of

    RBIA along a variety of factors. They disclose less about internal processrisk and risk

    management (contrary to the predictions) and have fewer board members. The

    percentage of non-executive directors and supervisors on the board of directors is

    higher. Finally, technical competence of internal auditors in the internal audit

    department is higher as anticipated.

    Finally, we examine whether banks employing intensive RBIA distinguishable

    from those employing infrequent of RBIA. Three factors are significant differs:

    disclosure about internal process risk and risk management, percentage of

    non-executive directors and supervisors on the board of directors and technical

    competence of internal auditors in the internal audit department.

    5.3 Assumption Test Results

    Table 6 presents the correlation matrix for the dependent and continuous

    independent variables. TECHCOM is significantly associated with the degree of

    RBIA ( r.546, p0.01). The highest correlation for the independent variables is

    -0.404 between RISK1 and NONEXD. In addition, table 7 reports VIF values for the

    continuous independent variables. FORBNH has the highest VIF value of 4.521. The

    correlation matrix and VIF values present that multicollinearity is not a problem5. The

    Durbin-Watson value (2.250) and the plots of the residuals indicate no problems of

    independence of error terms and heteroskedasicity.

    5 Multicollinearity problem exists when the correlation exceeded 0.80 and VIF values exceeds 10.

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    5.4 Regression Results

    The results of the tobit regression are shown in Table 6. This model identifies

    factors that are associated with a banks use of risk-basked internal auditing. The

    model is significant atp0.000 with an Adjusted R2of 0.944.

    As expected, all of our risk and risk management variables are significant. Risk 1,

    Risk 2 and Risk 4 are positive and significant, consistent with hypothesis 1. Risk 3,

    Risk 5 and Risk 6 are significant but negative. The three variables that are significant

    and positive support our hypothesis that banks that are more sensitive to risks, are

    more likely to employ higher percentage of RBIA. Moreover, NPL is positively and

    significantly associated with RBIA, also supporting Hypothesis 1, this reflects that

    banks with higher NPL levels appear to be more risk-based in internal auditing

    activities so as to mitigate their higher agency costs. The use of RBIA is significantly

    positively associated with the existence of a risk management committee. The finding

    support Hypothesis 2 and suggests that banks with an integrated risk management

    framework are more likely to have a higher percentage of RBIA.

    Results for use of RBIA from internal control perspective are mixed. Hypotheses

    3a is supported, with the results presenting a positive and significant association

    between banks size and the use of RBIA (p0.05). Moreover, as expected, the

    complexity of a bank is found to have a positive and significant (p0.01) relationship

    with the level of RBIA employed (Hypothesis 3b). However, contrary to our

    expectations, the hypothesized impact of whether the bank is a subsidiary of a

    financial holding company (FHC) is not associated with the use of RBIA, and hence

    Hypothesis 3c is not supported.

    Results for the use of RBIA from corporate governance factors are substantially

    supported. Board size (BODNR) is found to have a significant and negative

    relationship with the level of RBIA employed, thus allowing us to accept Hypothesis

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    4. We observe that INSOWN is significant and positive, consistent with Hypothesis 5.

    The result indicates a significant and negative association between NONEXD and the

    degree of RBIA. This suggests that banks that have a lower proportion of

    non-executive Directors have, on average, use higher percentage of RBIA. Finally,

    TECHCOM is also found to have significant and positive coefficient with the degree

    of RBIA used, supporting Hypothesis 7.

    TABLE 4

    Descriptive Statistics

    Variable (N=24) Mean S.D. Minimum Maximum

    Panel A: Continuous variables

    RBIA 0.5833 0.2761 0.1000 0.9000

    RISK 1 0.7708 0.0706 0.7500 1.0000

    RISK 2 0.7292 0.1021 0.5000 1.0000

    RISK 3 0.3958 0.2545 0.0000 1.0000

    RISK 4 0.4558 0.2580 0.3300 1.0000

    RISK 5 0.4563 0.2387 0.3300 1.0000

    RISK 6 0.3750 0.3970 0.0000 1.0000

    NPL 2.4938 2.2399 0.2400 10.8300

    LNINTEST 15.4814 1.2443 13.0451 17.3089

    FORBNH 0.0377 0.0712 0.0000 0.2727

    BODNR 16.1667 3.7027 10.0000 23.0000

    INSOWN 12.5313 27.2462 0.0000 100.0000

    NONEXD 0.6591 0.1691 0.3800 0.9300

    TECHCOM 2.7667 0.6767 2.0000 4.2000

    Panel B: Dichotomous variables

    Yes % No %

    RMC 19 79.2 5 20.8

    FHC 11 45.8 13 54.2

    Notes: See Table 3 for variable definitions.

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    TABLE 5

    Factors of Domestic Banks Segmented by Degree of RBIA

    All variables are defined in Table 3. Banks are partitioned on the 25th percentile and the 75th percentile of pro

    30 percent), some RBIA (30 percentRBIA70 percent), and extensive RBIA (RBIA70 percent)). Thon the level of RBIA. Mean and medians are reported. The pairs ofp-values represent the t-tests of the differ

    level of the Wilcoxon sign-rank test. P-values less than 0.10 are shown in boldface type.

    Factors of Domestic Banks by Level of RBIA Values of D

    Infrequent

    (30%,N=8)

    Some (between

    30-70%,N=9)

    Extensive

    (70%,N=7)Infrequent vs.

    SomeSome vs.

    Mean Med. Mean Med. Mean Med.t-value

    (p-value)

    -statistic

    (p-value)

    t-value

    (p-value)

    Z

    RBIA 0.25 0.30 0.63 0.70 0.90 0.90

    RISK 1 0.78 0.75 0.78 0.75 0.75 0.750.083

    (0.93)

    -0.086

    (0.93)

    0.875

    (0.40)

    RISK 2 0.72 0.75 0.72 0.75 0.75 0.75-0.057

    (0.96)

    -0.130

    (0.90)

    -0.875

    (0.40)

    RISK 3 0.44 0.50 0.44 0.50 0.29 0.50-0.057

    (0.96)

    0.000

    (1.00)

    1.099

    (0.29)

    RISK 4 0.50 0.33 0.48 0.33 0.38 0.330.127

    (0.90)

    -0.131

    (0.90)

    0.914

    (0.38)

    RISK 5 0.54 0.33 0.48 0.33 0.33 0.33 0.448(0.66)

    -0.340(0.73)

    1.842(0.10)

    RISK 6 0.44 0.50 0.22 0.00 0.50 0.501.138

    (0.27)

    -1.166

    (0.24)

    -1.438

    (0.17)

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    TABLE 5

    Factors of Domestic Banks Segmented by Degree of RBIA

    Factors of Domestic Banks by Level of RBIA Values of D

    Infrequent

    (30%,N=8)

    Some (between

    30-70%,N=9)

    Extensive

    (70%,N=7)Infrequent vs.

    SomeSome vs.

    Mean Med. Mean Med. Mean Med.t-value

    (p-value)

    -statistic

    (p-value)

    t-value

    (p-value)

    Z

    NPL 2.32 1.71 3.33 1.99 1.63 1.61-0.810

    (0.43)

    -0.770

    (0.44)

    1.369

    (0.19)

    LNINTEST 15.44 15.60 15.46 15.50 15.55 15.53-0.039

    (0.97)

    -0.096

    (0.92)

    -0.125

    (0.90)

    FORBNH 0.03 0.00 0.02 0.00 0.07 0.020.355

    (0.73)

    -0.450

    (0.65)

    -1.214

    (0.24)

    BODNR 16.50 16.00 17.56 18.00 14.00 13.00-0.604

    (0.56)

    -0.681

    (0.50)

    2.035

    (0.06)

    INSOWN 9.76 0.00 13.19 0.57 14.85 0.00-0.297

    (0.77)-0.625

    (0.53)

    -0.107

    (0.92)

    NONEXD 0.67 0.74 0.52 0.50 0.82 0.822.193

    (0.05)

    -1.879

    (0.06)

    -6.859

    (0.00)

    TECHCOM 2.38 2.20 2.60 2.40 3.43 3.60-1.065

    (0.30)

    -0.851

    (0.39)

    -2.610

    (0.02)

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    TABLE 6

    Correlation Matrix

    RBIA RISK1 RISK2 RISK3 RISK4 RISK5 RISK6 NPL LN-INTEST

    FORBNH

    Q11PRO

    RISK1 -0.093 1.000

    RISK2 0.141 0.063 1.000

    RISK3 -0.304 -0.176 -0.087 1.000

    RISK4 -0.071 0.250 0.104 0.096 1.000

    RISK5 -0.343 0.276 0.113 0.226 0.209 1.000

    RISK6 0.020 0.097 -0.335 0.081 0.160 -0.056 1.000

    NPL -0.037 -0.146 -0.044 0.179 -0.221 -0.118 -0.116 1.000

    LNINTEST 0.005 0.344 0.242 0.134 0.257 0.111 0.356 0.034 1.000

    FORBNH 0.161 0.371 0.113 0.124 0.279 0.010 0.167 -0.338 0.209 1.000

    BODNR -0.295 0.152 -0.048 -0.096 -0.207 -0.008 -0.177 0.082 -0.351 -0.313

    INSOWN 0.092 -0.142 0.063 0.182 0.062 0.362 -0.265 -0.111 -0.300 0.375

    NONEXD 0.235 -0.404 0.000 -0.171 -0.319 -0.259 0.051 0.014 -0.033 -0.085

    TECHCOMP 0.546*** -0.212 -0.105 -0.349 -0.225 -0.299 0.356 -0.339 -0.191 -0.228

    Notes:

    *** Correlation is significant at the 0.01 level (two-tailed).

    See Table 3 for variable definitions.

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    TABLE 7

    VIF Value

    RISK1 RISK2 RISK3 RISK4 RISK5 RISK6 NPL

    2.993 2.159 1.636 1.629 2.679 2.601 2.178

    LNINTEST FORBNH BODNR INSOWN NONEXD TECHCOMP

    4.335 4.521 2.094 4.120 1.993 3.215

    TABLE 8

    Results of Tobit Regression Analysis

    Variable (N=24) Expectedsign

    Coefficient S.E. z-Statistic Prob.*

    C -1.188 0.210 -5.654 0.000

    RISK1 + 0.535 0.181 2.959 0.003

    RISK2 + 0.489 0.106 4.604 0.000

    RISK3 + -0.147 0.037 -3.965 0.000

    RISK4 + 0.116 0.037 3.185 0.001

    RISK5 + -0.229 0.051 -4.517 0.000

    RISK6 + -0.269 0.030 -8.968 0.000

    NPL + 0.046 0.005 9.460 0.000

    RMC + 0.330 0.025 13.172 0.000

    LNINTEST + 0.026 0.012 2.073 0.038

    FORBNH + 1.642 0.221 7.442 0.000

    FHC + 0.005 0.031 0.154 0.878

    BODNR ? -0.033 0.003 -11.318 0.000

    INSOWN + 0.003 0.001 6.135 0.000

    NONEXD + -0.308 0.062 -4.991 0.000

    TECHCOM + 0.384 0.020 19.659 0.000

    R2 0.983 Adjusted R

    20.944

    Log likelihood 46.129

    Notes: *One-tail test where direction predicted, otherwise two-tail.See Table 3 for variable definitions

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    Chapter 6 Conclusion and Limitation

    6.1 Conclusion

    This study aims to investigate current use of RBIA by Taiwanese banks and to

    explore factors associated with the adoption of RBIA by Taiwanese banking industry.

    To understand banks demand of RBIA, this study examines whether the use of RBIA

    varies with factors reflecting banks risk management, internal control, corporate

    governance and internal auditors technical competence.

    The models tested in this study find empirical support that banks use a relatively

    high level of RBIA when disclose more information about financial risk management,

    compliance risk management, technology risk management and have a higher ratio of

    Non-Performing Loan. The results support H1 that the level of RBIA employed is

    positively associated with the banks risk management. However, the results present

    that the use of RBIA is negatively correlated with information disclosure about

    environmental and safety risk management, internal process risk management, and

    change management risk management.

    Results support H2 that use of RBIA is positively correlated with the existence of

    a risk management committee. This finding is consistent with findings from prior

    empirical research investigation voluntary demand for internal auditing

    (Goodwin-Stewart and Kent 2006). Results from the present study suggest that a

    firms risk management framework is highly associated with the role of internal

    auditing in the firm. Results for H3 are mixed. Our results indicate a significant

    positive relationship between the level of RBIA used and Banks size, as well as the

    complexity of the banks. However, no support was found for H3c that the use of

    RBIA is positively correlated with a bank that is a subsidiary of a financial holding

    company.

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    The findings of this study indicate a significant negative correlation exists

    between the level of RBIA employed by a bank and the board size. Our finding

    suggests that a small board size seems to be more effective, and is more likely to use

    RBIA, as a complementary mechanism. Contrary to our expectations, the percentage

    of non-executive directors and supervisors on the board of directors is significant

    negative associated with the use of RBIA, the finding indicates that the higher

    percentage of independent directors and supervisors on the board presents better

    corporate governance, hence may not employ higher percentage of RBIA for

    monitoring of risk management, this result presents that the use of RBIA as substitute

    mechanism. Finally, the result support the hypotheses that banks use a relatively high

    level of RBIA when have a higher percentage of shareholdings held by institutional

    shareholders and internal auditors technical competence are higher.

    6.2 Limitation

    The result of this study should be considered in light of two limitations. First, our

    measure of dependent variable- the percentage of RBIA employed by the bank is

    derived from questionnaire and subject to subjective judgments of each banks

    executive internal auditor, and we rely on the accuracy of these responses. Second,

    our sample is relatively small. However, this study surveys all of the 39 domestic

    banks in Taiwan; the response rate is relatively high: 61.54% and non-response bias

    tests indicate that there is no significant difference between the responding banks and

    non-respondents. Future research might expand the sample and to test our hypothesis

    in the entire finance industry.

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