The Rotational CAE Model: Is it Good for Internal Auditing?

There was a time when a career goal for many internal audit professionals was to rise through the corporate internal audit ranks to become their company’s General Auditor – what is known as today’s Chief Audit Executive (CAE).  My first CAE had been an internal audit professional almost 20 years when I joined the organization.  He was still the CAE 13 years later when I took his place (having left and returned to the department twice).

Today’s CAE, however, is quite a different executive than in the past.  In the modern corporate model, the CAE position is frequently a rotational assignment that is filled for 3-5 year tenures by upwardly mobile executives out of the CFO organization.  In fact, recent studies have indicated that as many of 40 percent of Fortune 500 CAE positions are now considered rotational.  The question is no longer whether this model is widely practiced.  The question is now: Is this good for internal audit?

Why the rotational model is good for internal audit:  I have had the opportunity to work closely in recent years with scores of CAEs in Fortune 500 companies.  Many of them were career financial executives who were in a rotational assignment as a CAE.  In most cases, they brought a tremendous level of energy and enthusiasm to the role.  Having not spent their careers in internal auditing, they also brought a fresh and innovative perspective to such fundamental tasks as risk assessment and audit planning.  Some of them became leaders in the internal audit profession and even took and passed the Certified Internal Auditor (CIA) exam.  Because they transitioned into internal audit from “the business,” they had a strong appreciation for key risks and opportunities facing the enterprise, as well as strong relationships with other key executives in the company.  These relationships often help create an environment where management is open and receptive to internal audit findings and recommendations.  In short, there are many benefits that have accrued to the profession in general – and corporate audit functions in particular – by virtue of the proliferating rotational CAE model.

Why the rotational model is bad for internal audit:  Despite the many positive aspects of the rotational model, there are also clear drawbacks.  The most obvious drawback relates to the actual or perceived objectivity of CAEs who are slated to only spend a short tenure in an internal audit leadership role.  As mentioned above, these executives are often from the CFO area of the organization – with a clear expectation of returning there after serving as the CAE.  Without exception, each of the CAEs with whom I have had the opportunity to work has had an independent mindset.  In addition, their CFOs have made it clear that they respected the independence of internal auditing.  Regardless of the realities, however, the perception can still present a problem.  I have had many conversations with executives in companies where the CAE is actually a career CFO organization professional, and their colleagues believe their objectivity is impaired when auditing CFO functions or programs.  If this belief is widely held, it can erode the stature of the CAE and the entire internal audit function. 

Another potential drawback to the rotational model occurs when it’s intentionally designed to be brief (I.e. less than three years).  In such instances, it is sometimes difficult for the CAE to achieve the level of effectiveness that often comes with tenure in a senior executive position.  In addition, if the entire internal audit department is rotational (including the CAE), there is a significant challenge in accumulating the institutional knowledge of the company’s risk and controls that an effective internal audit function needs.

Safeguards for rotational CAE models:  Whether the rotational model is good or bad for internal auditing is not black and white.  Regardless of one’s views on the subject, it is a practice that appears to be here to stay.  In order to minimize the risks associated with such a model, I would offer five safeguards:

1. The Audit Committee should understand the advantages, disadvantages and risks of such a model, and be engaged in the selection and evaluation of the CAE.
2. The Audit Committee should pay particular attention to the risk assessment results and audit coverage of the area from which the individual is drawn (and would be expected to return). 
3. If possible, the CAE should have an administrative reporting relationship outside of the area from which he or she is drawn (and expects to return).  For example, a CAE from the CFO organization could report administratively to the CEO or General Council.
4. The terms of the rotation should preclude the individual from returning to the same functional area from which they were drawn.
5. The rotation should be at least a five-year assignment.  The longer the individual is expected to serve as the CAE, the lower the perceived risk of objectivity impairment.