The study “Completing the Internal Control system in
Vietnamese Commercial Banks” has a general objective to assess the
current state of the Internal Control system of Commercial Banks
and proposes recommendations to complete the Internal Control
system in Vietnamese Commercial Banks.
Detail goal of research
From the overall research objective to improve the Internal
Control system in Vietnamese Commercial Banks, the specific
research objectives and tasks include:
(1) Assessing the status of the Internal Control system in
Commercial Banks in Vietnam.
(2) Analyzing the components of the Internal Control system in
Vietnamese Commercial Banks.
(3) Proposing recommendations to improve the Internal Control
system in Vietnamese Commercial Bank
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stem and the
financial performance at the Graduate Training Institute in Uganda;
Muraleetharan, P. (2011) studied that Risk Assessment, Control
Activities and Monitoring have a positive effect on corporate
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financial performance in Sri Lanka; Olumbe, C.O.O. (2012)
demonstrated that good corporate governance of Kenyan
Commercial Banks relates to strong Internal Control system; Leng, J.
& Zhao, P., (2013) studied the quality of the Internal Control system
positively related to the efficiency of business activities of
enterprises in China; Magara, C.N. (2013) explored the impact of the
Internal Control system on financial performance in credit companies
(SACCOs) in Kenya; Musya, F.A. (2014) studied the relationship
between components of the Internal Control system with the revenue
of County Commission in Kenya.
3. Research objectives
General goal of research
The study “Completing the Internal Control system in
Vietnamese Commercial Banks” has a general objective to assess the
current state of the Internal Control system of Commercial Banks
and proposes recommendations to complete the Internal Control
system in Vietnamese Commercial Banks.
Detail goal of research
From the overall research objective to improve the Internal
Control system in Vietnamese Commercial Banks, the specific
research objectives and tasks include:
(1) Assessing the status of the Internal Control system in
Commercial Banks in Vietnam.
(2) Analyzing the components of the Internal Control system in
Vietnamese Commercial Banks.
(3) Proposing recommendations to improve the Internal Control
system in Vietnamese Commercial Banks.
5
4. Research questions
The study raised four main research questions as follows:
Question (1): What is the actual situation of the Internal Control
system in Commercial Banks in Vietnam?
Question (2): What does the role of the components of the
Internal Control system effect on the Control objectives in
Vietnamese Commercial Banks?
Question (3): Which components of the Internal Control system
in Vietnamese Commercial Banks need to be completed?
Question (4): What recommendations is proposed to improve the
Internal Control system in Vietnamese Commercial Banks?
5. Research subjects and scope of research
The research object of the thesis is the theory and practice of the
Internal Control system of Commercial Banks in Vietnam.
The research scope of the thesis focus on the Internal Control
system in order to propose recommendations for improving the
Internal Control systems of Vietnamese Commercial Banks.
The scope of space, focusing on domestic group of Commercial
Banks, including State-owned Commercial Banks and Joint Stock
Commercial Banks.
The scope of time, survey questionnaires are made in State-
owned and Joint Stock Commercial Banks in 2016.
6. Research methodology
Theoretical basis
Research is based on agency theory and contingency theory
approach, based on the concept of the Internal Control, components
of the Internal Control, Control Objectives under the framework of
COSO and Basel.
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Research methods
Qualitative research methods including: literature review method,
expert methodology, questionnaire survey methodology, descriptive
statistical methodology, analytic and evaluation methodology,
comparison methodology.
Quantitative research methods including: Cronbach Alpha analysis,
Exploratory Factor Analysis (EFA), T-test and ANOVA analysis,
Confirmatory Factor Analysis (CFA), Structural Equation Model (SEM).
Data research
Research used primary data which has collected through the
sampling survey. Using the interview method through the questionnaire.
Duration of the survey is from June 2016 to September 2016. As a
result, 293 valid questionnaires for the study.
Data processing methods
The thesis used SPSS software for Cronbach Alpha analysis,
Exploratory Factor Analysis, descriptive statistics the Internal Control
systems of Commercial Banks in Vietnam, T-test and ANOVA
analysis to test the differences in the Internal Control systems among
Commercial Banks Groups.
The thesis used AMOS software for Confirmatory Factor Analysis,
Structural Equation Model to test the theoretical model analysing the 5
components of the Internal Control and the influencing of the Control
Environment on the other components of the Internal Control system.
7. The contribution of the thesis
Theoretically, the thesis has the following contributions:
Firstly, the research has contributed to the systematization of
theoretical basis and the development of theories on the Internal
Control system of corporation in generally and the Internal Control
system of bank in particularly.
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Secondly, the study identified the Internal Control system
components and Control objectives in Commercial Banks based on
components and principles of the Internal Control under the COSO
and Basel framework.
Thirdly, the study used descriptive statistics method, T-test and
ANOVA analysis, Structural Equation Model (SEM) to evaluate and
analysis the actual situation of the Internal Control system; using
expert methods to identify the components of the Internal Control
system that need to improve in Vietnamese Commercial Banks.
In practice, the thesis has the following contributions:
Firstly, the study evaluated the components and control objectives
of the Internal Control system in Vietnamese Commercial Banks,
analyzing the difference of the Internal Control system in
Commercial Banks groups by ownership and by region.
Secondly, the research has analyzed 5 components of the Internal
Control system to be completed; moreover, the study verified the
role of the Control Environment that influence on the Risk
Assessment, the Control Activities, the Information and
Communication; as a basis for proposing recommendations to
complete the Internal Control system.
Thirdly, the practical meaning of the study has been shown in the
recommendations of improving the Internal Control system in
Vietnamese Commercial Banks. This is a valuable reference to adjust
and supplement the design of the Internal Control system of
Commercial Banks, to meet the requirements of the Internal Control
system in Vietnamese Commercial Banks.
Fourthly, the study has built a survey questionnaire on the
Internal Control system in Commercial Banks, as a basis for
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designing the evaluation questionnaire of the checking the Internal
Control system in Commercial Banks, as well as recording on the
Internal Control system and reporting to the State Bank of Vietnam.
8. New points of the thesis
Firstly, the research has approached the contingency theory
explaining the Internal Control systems under the framework of
COSO and Basel.
Secondly, the research has made the reliable survey questionnaire
about the Internal Control system of Commercial Banks. It can be
used evaluating the Internal Control system which bases on COSO
and Basel framework.
Thirdly, the research has collected the database of 293
questionnaires from bank staff with a high level of knowledge about
the Internal Control system, covering all 3 regions of Vietnam.
Fourthly, the study assessed the status of the Internal Control
system, explored the differences in the Internal Control system in
Vietnamese Commercial Banks groups by ownership and by region.
Fifthly, the study has used the SEM to analyze the components of
the Internal Control system, as a basis for recommendations to
complete the Internal Control system in Vietnamese Commercial
Banks. The method allows the study to analyze the effect of
exogenous variables on endogenous variables, at the same time
analyze the effects of exogenous and endogenous variables.
Sixthly, the research has found the influence of the Control
Environment on the Risk Assessment, the Control Activities, the
Information and Communication. This is a new point of the thesis in
studying the recommendations to complete the Internal Control
system in Vietnamese Commercial Banks.
9
Seventhly, the research combined quantitative and qualitative
methods proposing recommendations to complete the Internal
Control system in Vietnamese Commercial Banks under the
framework of COSO 2013 and Basel 1998 framework.
9. The thesis structure
In addition to the introduction and conclusion, the thesis is
organized into 4 chapters:
Chapter 1: Theoretical approach and Literature review of the
Internal Control system
Chapter 2: Commercial Banks and Research Design
Chapter 3: Assessing the Internal Control system in Vietnamese
Commercial Banks
Chapter 4: Recommending to complete the Internal Control system
in Vietnamese Commercial Banks
CHAPTER 1: THEORETICAL BASIS AND LITERATURE
REVIEW OF THE INTERNAL CONTROL SYSTEM
1.1. Theoretical approach
1.1.1. The Agency theory approach
Agency theory approach assumes that there is the agency problem in
the coperation “separating between ownership and control leads to
conflict of interest and risk sharing”. Corporate governance helps satisfy
ownership and controls the coperation to make the company's operations
more efficient. The Internal Control system is one of the internal
governance mechanisms of the company. Research on the Internal
Control system approaching agency theory explains the necessity of the
Internal Control system of coperation.
10
1.1.2. The Contingency theory approach
Contingency theory approach assumes the Internal Control
system can be changed. Contingency theory approach provides
research on the Internal Control system that is a process of
implementing control procedures in accordance with characteristics,
size, structure and change of the coperation. This is the theory to
study the Internal Control in context of diverse types of companies,
diverse industries and much change of the coperation.
1.2. Overview of the Internal Control system
1.2.2. Internal Control concept
The internal control system is the process of implementing
control procedures and mechanisms to achieve business goals,
including: effectiveness and efficiency operation; reliability of
financial statements; complying with laws and regulations.
1.2.1. Nature of Internal Control
The Internal Control system is one of the internal corporate governance
mechanism, contributing to the achievement of objectives in operation.
1.3. Literature review
1.3.1. Internal Control framework
1.3.1.1. Internal Control under the COSO framework
Under COSO's Internal Control framework, the Internal Control
system consists of 5 components, developed into 17 principles.
1.3.1.2. Internal Control in banks under Basel framework
The Basel framework sets out 13 principles for designing and
evaluating the Internal Control system of banks; basically, these
principles are similar to the 5 components of the Internal Control
system in the framework of COSO.
11
1.3.2. Empirical literature review
This section reviews the international and domestic study on the
Internal Control systems. Including: research on the COSO and Basel
framework of the Internal Control; research on the Internal Control
components, the effectiveness and efficiency of the Internal Control
system; researching and assessing the status of the Internal Control
systems of companies and commercial banks; studying the impact of
the Internal Control system on control objectives. From there, study
gived policy implications based on research results.
1.4. Research gap
Through the literature review of the research situation, the thesis
identified 5 gaps in theorical gap as well as practicing gap for the
research on the Internal Control system in Vietnam: (1) The study
mainly bases on the COSO framework, (2) The study has not
combined the COSO and Basel framework, (3) Little study
approachs agency theory and contingency theory for analysing the
Internal Control system in Vietnam, (4) Research is mainly based on
qualitative, (5) Mainly case study for only one bank.
CHAPTER 2: COMMERCIAL BANKS
AND RESEARCH DESIGN
2.1. Overview of commercial banks
2.1.1. Concept of Commercial Bank
A Commercial Bank is a financial institution that accepts deposits
from the public and creates credit by monetary and banking services.
2.1.2. Classify Commercial Banks by ownership
State-owned Commercial Banks: The State owns more than 50% of capital.
Non-state Commercial Banks include: joint-stock Commercial
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Banks, joint-venture Banks, foreign Bank branches, 100% foreign-
owned Commercial Banks.
2.1.3. Operation of Commercial Banks
Deposits, Credit, Financial investment, Foreign exchange,
Payment services, Valuable property preservation, Government
activities funding, Stakeholder, some other services ...
2.2. Developing research hypothesis
Hypothesis H1: There is a positive impact of the Control
Environment (CE) to Internal Control Objectives (ICO) of
Commercial Banks in Vietnam
Hypothesis H2: There is a positive impact of Risk Assessment (RA)
to Internal Control Objectives (ICO) of Commercial Banks in Vietnam
Hypothesis H3: There is a positive impact of Control Activities (CA)
to Internal Control Objectives (ICO) of Commercial Banks in Vietnam
Hypothesis H4: There is a positive impact of Information and
Communication and (IC) to Internal Control Objectives (ICO) of
Commercial Banks in Vietnam
Hypothesis H5: There is a positive impact of Monitoring Activities (MA)
to Internal Control Objectives (ICO) of Commercial Banks in Vietnam
Hypothesis H6: There is a positive impact of Control Environment
(CE) on Risk Assessment (RA) of Commercial Banks in Vietnam
Hypothesis H7: There is a positive impact of Control Environment
(CE) on Control Activities (CA) of Commercial Banks in Vietnam
Hypothesis H8: There is a positive impact of Control Environment (CE)
on Information and Communication (IC) of Commercial Banks in Vietnam
Hypothesis H9: There is a positive impact of Control Environment
(CE) on Monitoring Activities (MA) of Commercial Banks in Vietnam
13
2.3. Modeling the components of the Internal Control system in
Vietnamese Commercial Banks
2.3. Scale measurement components of the Internal Control
system and the Control Objectives
2.4. Scale measurement components of the Internal Control
system and the Control Objectives
2.4.1. Scale measurement of the Control Environment (CE):
measured by 7 observed variables from CE1 to CE7.
2.4.2. Scale measurement of Risk Assessment (RA): measured by 5
observed variables from RA1 to RA5.
2.4.3. Scale measurement of Control Activities (CA): Measured by 5
observed variables from CA1 to CA5.
2.4.4. Scale measurement of Information and Communication (IC):
H1
H2
H3
H9
H8
H7
H6
CE
H4
H5
RA
CA
IC
MA
Internal Control
Objectives
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measured by 5 observed variables from IC1 to IC5.
2.4.5. Scale measurement of Monitoring Activities (MA): measured
by 5 observed variables from MA1 to MA5.
2.4.6. Scale measurement of Control Objectives (ICO): measured by
6 observed variables from ICO1 to ICO6.
2.5. Scale of research components: using the 5-point Likert scale.
2.6. Developing the survey questionnaire: the questions in the
questionnaire are accordant to the scale of the Internal Control
components and Control Objectives.
2.7. Research methods: qualitative research methods and
quantitative research methods.
2.8. The research framework of the Internal Control system in
Vietnamese Commercial Banks
2.9. The research process of the Internal Control system in
Vietnamese Commercial Banks
CHAPTER 3: ASSESSING THE INTERNAL CONTROL
SYSTEM IN VIETNAMESE COMMERCIAL BANKS
3.1. Describe the research sample
Commercial Banks by ownership Commercial Banks region
Classify Amount % Classify Amount %
State-owned
Commercial Banks 110 37,54%
North 18 6,15%
Central 181 61,77%
Joint stock
Commercial Banks
183 62,45% South 94 32,08%
Total: 293 100% Total: 293 100%
15
3.2. Evaluating the reliability of the scale - Cronbach Alpha method
Variables after performing Cronbach alpha analysis: CE (CE2,
CE3, CE4, CE5, CE6, CE7), RA (RA1, RA2, RA3, RA5), CA (CA1,
CA2, CA3, CA4, CA5), IC (IC1, IC2, IC3, IC4, IC5), MA (MA1,
MA3, MA4, MA5), ICO (ICO1, ICO2, ICO3, ICO4, ICO5, ICO6)
are included in the Exploratory Factor Analysis ( EFA).
3.3. Evaluation of scale value of Internal Control components
and Control Objective - Exploratory Factor Analysis (EFA)
After extracting variables, the result of EFA is: CE (CE2, CE3,
CE6, CE7), RA (RA2, RA3, RA5), CA (CA1, CA2, CA5), IC (IC1,
IC3, IC4) MA (MA1, MA4), ICO (ICO1, ICO2, ICO3, ICO5, ICO6).
3.4. Statistics Internal Control components, the Internal Control
system and Control Objectives in Vietnamese Commercial Banks
Analysis data shows that the scale of measuring 5 components of
the Internal Control, general assessment of the Internal Control system
and the Control Objectives of Vietnamese Commercial Banks are
rated above average and at a quite good level.
3.5. Analyzing the difference in the Internal Control system in
Vietnamese Commercial Banks
There is no difference in evaluating 5 components of the Internal
Control, general assessment of the Internal Control system and
assessing Control Objectives between Vietnamese Commercial Banks
groups by ownership and by region. The Risk Assessment (RA) has
the difference between Commercial Banks by ownership and by
region, but this gap is not large.
16
3.6. Analysing the 5 components of the Internal control system
and Control Objectives - Confirmatory Factor Analysis (CFA) -
Critical measurement model
17
3.7. Analysing the 5 components of the Internal control system in
Vietnamese Commercial Banks - Structural Equation Model (SEM)
SEM (standardized) results of theory model
SEM (standardized) results of adjustment model
18
The SEM (standardized) results of the adjustment model based on
the MI coefficient
19
The regression coefficient of the adjustment model;
R2: Internal Control Objectives = 72,8%;
R2: Risk Assessment = 10,5%; R2: Control Actitivites = 48,7%;
R2: Information&Communication = 48,6%
Correlate
Non-
standardized
Estimate
Standardized
Estimate
S.E. C.R. P
CE → RA 0,242 0,324 0,067 3,591 0,0000
CE → CA 0,684 0,698 0,106 6,470 0,0000
CE → IC 0,777 0,697 0,111 6,973 0,0000
CE → ICO 0,257 0,286 0,145 1,767 0,077
RA → ICO 0,192 0,160 0,088 2,184 0,029
CA → ICO 0,186 0,203 0,112 1,655 0,098
IC → ICO 0,308 0,383 0,096 3,229 0,001
MA → ICO 0,284 0,228 0,100 2,829 0,005
CHAPTER 4: RECOMMENDING TO COMPLETE
THE INTERNAL CONTROL SYSTEM IN VIETNAMESE
COMMERCIAL BANKS
4.1. Recommended to complete the internal control components
of Vietnamese Commercial Banks
4.1.1. Control Environment (CE): the best assessment (3,819),
affecting the other Internal Control components, affecting the
Control Objective at a high level (0.286). Focus on developing CE to
create the core values of the Internal Control system of Commercial
Banks, to support the other Internal Control components, to
achieving the Control Objectives of Vietnamese Commercial Banks.
CE2 (COSO 02): the best assessment (3.87), strongly affects CE
(0.62). Need to determine the control objectives, determine supervision
responsibilities of the Board of Directors; the Board of Directors must
20
be independent; need to consider the duties of the Board of Directors
and the objectives of Commercial Banks; expect Management Board to
be honest, respect moral values, be capable of leadership; Board of
Inspectors perform the supervising role of the Board of Directors.
CE6 (COSO 04): the lowest assessment (3.76). Human resource
policy needs to retain qualified staff; Managers determine the
requirements for staff capacity, specifically by requirements of
knowledge and skills; Managers identify and evaluate important
positions and functions that help achieve operational goals.
CE7 (COSO 05): fairly high average (3.83), strongly affecting CE
(0.62). The Board of Directors is responsible for managing
Commercial Banks activities; Managers is supervised by the Board
of Directors on this responsibility; establish and implement
responsibility of Managers; measuring performance include
quantitative and qualitative standards; encourage managers and
employees to complete their tasks.
4.1.2. Risk Assessment (RA): under the average of the Internal
Control system (3,746), the lowest impact on the Control Objectives
(0.160). Focusing on RA could improve the Internal Control system
in Vietnamese Commercial Banks.
RA2 (COSO 07, Basel 04): fairly average assessment (3.74), the
strongest influence on RA (0.76), it is necessary to carry out Risk
Assessment, assessing risks at all level of Commercial Banks
activities, analysing risk assessment; dealing with risk.
4.1.3. Control activity (CA): under the average level of the Internal
Control system (3,747); low affect to Control Objective (0.203).
Completing CA to improve the Internal Control system in
Vietnamese Commercial Banks.
21
CA1 (COSO 10, Basel 05): lowest assessment (3.70). Control
Activities should be consistent with Risk Assessment, need to be
professional control for Commercial Banks activities, need to be
effective to coordinate Control Activities, Control Activities to
achieve the full, accurate, real and compliance objectives in
practicially, control is required at all level of Commercial Banks.
CA5 (COSO 12): assessed fairly (3.73), the strongest influence on
CA (0.62). Evaluating policies and procedures periodically, applying
necessary solution to correct control policies and control procedures,
policies and procedures in control activities are implemented
carefully and promptly.
4.1.4. Information and Communication (IC): lowest assessment
(3,696); strongest influence on Control Objectives (0.382). Focus on
IC to improve the Internal Control system and contribute to
achieving Control Objectives in Vietnamese Commercial Banks.
IC1 (COSO 13): lowest assessment (3,68). Identifying
information requirements for each level of management, selecting
sources that provide relevant and useful information, issuing
information management policies, stating responsibilities for
information quality.
IC4 (Basel 08): the best assessment (3.72), the strongest influence
on IC (0.69). Establishing and maintaining information systems to
fully manage the activities of Commercial Banks, focusing on
electronic information technology system.
4.1.5. Monitoring Activities (MA): under the average level of the
Internal Control system (3,744), affecting the Control Objectivies at
a high level (0.228). Completing MA to improve the Internal Control
system and helping to achieve Control Objectives in Vietnamese
Commercial Banks.
22
MA1 (Basel 10): the best assessment (3.77), the strongest
influence on MA (0.77). Continuously monitoring and evaluating the
Internal Control systems in the context of changes internal and
exterior Commercial Banks, Monitoring Activities are carried out by
the Supervisory Board and Internal Audit department; need regular
and periodic Monitoring Activities.
MA4 (Basel 11): the lowest assessment (3.71). The functions of
the Supervisory Board and internal audit should be independent of
the daily operational functions of commercial banks, Board of
Inspectors and Internal Auditors provide information about the
Internal Control systems and activities of Commercial Banks, Board
of Inspectors and Internal Auditor report on the Internal Control
system and the operation of Commercial Banks directly to the Board
of Directors and Managers.
4.2. Recommendations for law on the Internal Control in
Vietnamese Commercial Banks
State Bank of Vietnam need to promulgate more specific
guidelines for components of the Internal Control system. It is
possible to use and refer to the 2013 COSO framework and the 1998
Basel framework.
Specific guidelines on components of the Internal Control system
will help Vietnamese Commercial Banks to report more fully on the
Internal Control system to the State Bank of Vietnam.
10. Conclusions
The doctoral dissertation “Completing the Internal Control in
Vietnamese Commercial Banks” was done based on agency theory
and contingency theory for research on the Internal Control. Based
on the COSO 1992 framework, update 2013 and the Basel 1998
23
framework; established the principles and components of the Internal
Control system
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