Lapping

Lapping does not actually involve the misappropriation of funds but is a fraud that may be committed by an employee to conceal a misappropriation of funds, usually funds paid by a customer of the employer. The employee conceals the misappropriation by applying funds subsequently paid by a second customer to conceal the deficiency in the first customer's account. However, this means that the accounting records would show an amount owing by the second customer that had in fact been paid. The employee then uses funds paid by a third customer to conceal the deficiency in the second customer's account. The employee continues this "lapping" of customer's funds until the fraud is ultimately discovered, which may be some months after the initial misappropriation and perhaps after the employee resigns his/her employment from the entity.

Lapping can occur in entities which do not record details of customer cheques when the mail is opened, and/or entities in which employees are not required to take regular annual leave, and/or entities in which the employee responsible for handling customer cheques is also responsible for preparing bank deposit advices.


Warning signals that lapping may have occurred include complaints by customers of the entity that the customer statements they have received show the credits to their account some days after the payment should have been received by the entity, or that their statement has missing credits, or shows unusual credits, or that they have not received customer statements (the statements may be withheld or destroyed by the dishonest employee) and a frazzled look on the face of the employee responsible, as it can be a very testing time keeping track of which customers' accounts have been misappropriated and by how much.

Audit procedures that may detect this fraud include (i) the confirmation of accounts receivable, with particular attention being given to replies to the auditors from customers disputing the timing of their payments and (ii) the comparison of the original bank deposit advices with cash receipt records. (Auditors prefer to use original bank deposit advices, as the copies retained by the client may have been altered by the employee).

Exercises

1-Which of the following would be the best protection for a company that wishes to prevent the "lapping" of trade accounts receivable?

a. Segregate duties so that the bookkeeper in charge of the general ledger has no access to incoming mail.
b. Segregate duties so that no employee has access to both checks from customers and currency from daily cash receipts.
c. Have customers send payments directly to the company's depository bank.
d. Request that customers' payment checks be made payable to the company and addressed to the treasurer.

2. The auditors who are engaged to examine the financial statements of a business enterprise will request a cutoff bank statement primarily in order to:

a. verify the cash balance reported on the standard financial institution confirmation form.
b. verify reconciling items on the client's bank reconciliation
c. detect lapping
d. detect kiting

3 - Which of the following situations has the best chance of being detected when a CPA compares current revenues and expenses with the prior year and investigates all changes exceeding a fixed percentage?

a. An increase in property tax rates has not been recognized in the company's 1999 accrual.
b. The cashier began lapping accounts receivable in 1999.
c. Because of worsening economic conditions, the 1999 provision for uncollectible accounts was inadequate.
d. The company changed its capitalization policy for small tools in 1999.


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The Lap Trap

Lapping is the fraudster’s version of “robbing Peter to pay Paul” skimming. It is the extraction of money from one account to cover shortages in another account. For example, a fraudster steals the payment intended for customer A’s account. When a payment is received from customer B, the thief credits it to A’s account. And when customer C pays, that money is credited to B. Repeated many times, lapping is difficult for the dishonest employee to keep track of. As a result, almost all lapping schemes quickly reveal themselves.

All material cash misappropriations send telltale signs: reduced cash combined with increased expenses and/or decreased revenue (see “Enemies Within,” JofA, Dec.01, page 31). Most lapping occurs because of inadequate control over incoming payments. Following are some classic “red flags” of lapping:
-Excessive billing errors.
-Slowing accounts receivable turnover.
-Excessive writeoffs of accounts receivable.
-Delays in posting customer payments.
-Accounts receivable detail doesn’t agree with general ledger.
-A trend of decreasing payments on accounts receivable.
-Customer complaints.

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A skimming method doomed to failure over time.

Lapping It Up

BY JOSEPH T. WELLS

Nelson, a computer programmer for a financial institution in New Orleans, sat across the desk from his boss. Nelson flinched when the boss told him the news that he, an 11-year company veteran, was in trouble with the home office in Dallas because of irresponsible behavior.

More than a year ago, Nelson had accepted a promotion requiring a transfer to New Orleans from Dallas. The company extended him a $15,000 bridge loan, temporary funds to cover moving and household expenses. Nelson never paid back the loan, however, even after repeated requests to do so.

Unbeknownst to the company, Nelson had been in serious hock for years. He and his wife just couldn’t seem to control their spending. With creditors hounding him, Nelson had taken the $15,000 and paid some of his most pressing debts. Now, with the boss facing him, he didn’t know what excuse to use this time for not paying back the company.

But the boss was beyond being mollified with any more excuses. “Nelson,” he said, “the company has made it pretty clear: If you don’t get this debt taken care of, it’s going to cost you your job. Do you understand?” Nelson understood.

Necessity being the mother of invention, Nelson concocted a plan made possible only by an internal control deficiency at the company big enough to drive a truck through: unrestricted access to “live” data (read: customer accounts). Even as the bank’s chief programmer, Nelson never should have had access to such data, but he did. That could have been because he was the principal architect of the entire computer system.

Skimming Schemes: Comparison of median losses

Source: Occupational Fraud and Abuse, by Joseph T. Wells, Obsidian Publishing Co., 1997.

The first step of Nelson’s plan involved opening a savings account at the bank under someone else’s name. In this case, he chose the ID of his own elderly, infirm uncle. Once the account was active, Nelson set about reprogramming the bank’s computers to accommodate a highly complex and seemingly foolproof lapping scheme.

Because Nelson needed $15,000 all at once, he easily located a customer checking account with a large balance. But since he knew a funds transfer would create a record on the customer’s statement, he removed the funds from the “ending balance” field on the statement itself. He transferred the money to the uncle’s account, over which he had signature authority. Nelson debited the uncle’s account and credited his own, using the proceeds to pay his bills.

The bank’s computers were programmed to print account statements throughout the month (for example, customer A’s statement mailed on the first day of the month, customer B’s on the second and the last one on the 30th). That being the case, Nelson figured he would have use of the funds for 29 days—no more. So he programmed the computer to simply “roll” the $15,000 through the ending balance field on other checking accounts according to a predetermined schedule. Nelson’s plan, in effect, was to let the money bounce throughout the computer program until he could legitimately repay his “loan.”

Alas, this method was too easy for Nelson, and therefore too tempting. He rationalized that the bank wouldn’t find out or even miss the cash. So he continued to “loan” himself more money to pay off other pressing obligations.

When the amount ballooned to $150,000 and involved thousands of customer checking accounts, Nelson’s ingenious 29-day computer program failed to reverse some transactions in time to avoid detection. In his haste, he forgot there were only 28 days in February. Customers started pouring into the bank with statements in hand showing a major discrepancy: Their ending balances last month were different from the beginning balances this month—a mathematical impossibility.

Although Nelson initially blamed the problem on a programming error, he finally confessed to his boss what happened. He had always planned to pay the money back, Nelson promised solemnly, but he was at a loss to explain exactly how he could do that.

Ever the nice guy, Nelson helped the authorities gather the evidence to convict him of embezzlement. It’s a good thing he did, too. Chasing down every single transaction would have been extremely time-consuming. Nelson’s cooperation got him only 15 months as a guest of the Louisiana penal system.

ROBBING PETER BUT FORGETTING TO PAY PAUL

If Nelson had been anything other than a rank amateur, he never would have picked lapping as the scheme of choice for covering cash thefts. Although he managed to lap customer checking accounts for about nine months—no small chore—Nelson’s plan was probably doomed from the outset.

That’s because lapping almost always goes beyond robbing Peter to pay Paul. Once the first attempt is successful, lapping tends to increase at exponential rates. Now, the fraudster has to steal from other customers. Then, there are many accounts to keep track of. Therein lies the fraudster’s pact with the devil: The more lapping occurs, the greater the chance of making a mistake.

That’s exactly what happened to Nelson. In his case, even his “move-the-money-around” program couldn’t keep track of the thousands of transactions. So when an accounting student once asked me the best way to detect lapping schemes, I couldn’t help myself: “Time,” I replied, only partially in jest. “In time, lapping schemes will invariably reveal themselves.”

A LIST OF SINS

Because of Nelson’s sins, a lot of people in his company suffered. The boss lost a valuable computer programmer and long-term employee. Since the prosecution of Nelson drew headlines, the bank lost credibility with some of its customers, likely costing it many multiples of the $150,000 he stole. Nelson’s coworkers at the bank suffered a loss of morale. Management was embarrassed. Nelson’s family had to ask for public assistance while he was imprisoned.

But Nelson wasn’t the only one at fault in this case. Take, for example, the bank’s upper management. It is ultimately responsible for the flawed system of internal control that permitted Nelson to commit his crime in the first place. Not only were there computer system problems, but the bank never should have allowed Nelson to open an account using the identification of a relative 40 years his senior.

And management did not recognize the signs of a financially strapped employee. Had someone done so, the company might have sought an alternative to forcing Nelson into a tight corner; desperate people do desperate things. Many large companies, for example, provide financial counseling to troubled debtors.

The bank’s external auditors should have detected the fact that Nelson could both program and modify customer accounts—a serious deficiency. The internal auditors should have spotted the glaring control weakness long before that.

TURNING WATER INTO WINE

To the bank’s credit, it decided to do something positive after Nelson’s fall from grace. First, it closed the internal-control hole. Second, the company appointed an ombudsman to counsel employees in times of stress—financial and otherwise. Most important, it implemented companywide antifraud training to sensitize its managers and employees to not only how workers commit fraud, but why they do it in the first place.

When putting together its employee video-training program, the bank went looking for an expert to talk about the fraud problem. It found one: From behind prison walls, Nelson—now full of remorse—volunteered. He looked directly at the camera and, through the tears, told his own story.

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Answers to the exercise

1 - Which of the following would be the best protection for a company that wishes to prevent the "lapping" of trade accounts receivable?

c. Have customers send payments directly to the company's depository bank.

2. The auditors who are engaged to examine the financial statements of a business enterprise will request a cutoff bank statement primarily in order to:

b. verify reconciling items on the client's bank reconciliation

3 - Which of the following situations has the best chance of being detected when a CPA compares current revenues and expenses with the prior year and investigates all changes exceeding a fixed percentage?

d. The company changed its capitalization policy for small tools in 1999.
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Reference:
1-Abrema (http://www.abrema.net/abrema/lapping_g.html)
2-Journal of Accounting (http://www.journalofaccountancy.com/Issues/2002/Feb/LappingItUp.htm)

Terjemahan perkataan
conceal=sembunyi
embezelled=menggelapkan
misappropriation=salahguna