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© 2011 Financial Operations Networks LLC
Vendor Master File Strategiesto Improve Performance
and Reduce Risk Greg CrowEquifax
Tuesday, April 12, 2011
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THE ACCOUNTS PAYABLE
Leadership ConferenceAgenda
• Identify keys to spotting potential fraud in your vendor master file
• Ensure you are in compliance with U.S. laws and regulations, including IRS and OFAC
• Deploy a process to verify supplier identities and potential for risk before you release funds
• Provide visibility into potential supplier deterioration and failure in your supply base
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Leadership Conference
How can I reduce fraud?
How can I show management
that we have effective compliance to policy?
How can I comply with IRS, OFAC and state-level laws
and regulations?
How can I streamline the supplier
boarding process?
How can I reduce duplicate suppliers and duplicate payments?
There are many questions ...
How does Sarbanes- Oxley impact AP?
How can I do all of this with such a small team?
AccountsPayable Executives
How can I help my firm better manage
cash flow?
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Leadership ConferenceDemand is Great
Other Requirements
Fraud Prevention and DetectionLegal and Regulatory
ComplianceProcess
Improvement
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Are we doing everything possible to reduce the opportunity for fraudsters?
Are we complying with:• IRS 1099 reporting• Sarbanes-Oxley• OFAC• FTO• State requirements• Industry-specific
requirements
How can we leverage techniques such as Six Sigma, benchmarking and technology to identify opportunities for improvement?
Are we meeting our goals for tracking spend management savings and supplier diversity?
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Leadership ConferenceYour SuppliersAre Changing
Source: http://www.freepress.net/files/att_history.swf
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Leadership ConferenceInternal Obstacles
• Policy does not equal practice
• Technology does not deliver business process improvement
• Outsourcing can reduce accountability
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Leadership ConferenceWhat is the Impact?
5% of Total Spend:• Tax reporting non-compliance
• Regulatory burdens and fines
• Duplicate payments
• Missed supplier discounts
• Delays in delivery of supplier services
• Escheatment issues― Uncashed checks― Unapplied credits
• Increased risk of supplier or employee fraud
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Leadership Conference
Assessing Risk in Your Vendor MasterMaking the Case for Change
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Leadership Conference
• Can be done using internal IT resources, consultants or service providers
• Assesses VMF data quality
• Makes specific recommendations on improving overall accuracy of information
• Key deliverables include:―Identifying file duplication―Assessing/improving address quality―Standardizing other elements (country, tax ID, telephone)
Vendor Master Profiling
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Leadership ConferenceSample ReportMetric
SupplierRecords
% of Total Records
ABC Company Spend
% of Total Spend
ABC Company supplier records 17,917 100.0% $1,288M 100.0%ABC Company supplier records matched to Equifax Database 14,832 82.8% $1,191M 92.5%ABC Company supplier records not matched to Equifax Database 3,085 17.2% $97M 7.5%
Non-matched records with primary exceptions 2,160 12.0% $68M 5.2%
Non-matched records without primary exceptions 926 5.2% $29M 2.2%
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.
Medium Risk1,882 Suppliers
Low/Medium Risk5,784 Suppliers
Low Risk15,816 Suppliers
Medium/High Risk887 Suppliers
Suppliers
Count Spend $
Lowest Risk 15,816 128.4M
Low/Medium Risk 5,784 47.0M
Medium Risk 1,882 13.5M
Medium/High Risk 887 6.2M
Highest Risk 254 6.5M
Bankruptcy 689 15.6M
Bankruptcy689 Suppliers
High Risk254 Suppliers
Sample SupplierFailure Profile
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Leadership Conference
Commercial services rely upon robust reference databases and automated and manual review to identify 75+% of all duplicates
12345AceLoading Dock 12Dallas, TX
75220(214) 555-1234
NCC1701A.C.E. Supply3050 Northwest HwyDallas, TX 75220(214) 555-1234
A-4895John SmithAce Mart3050 NW HwyIrving, TX214.555.123492345
EFX # 112233456Name 1 Ace Mart Supply Inc.Name 2 Ace SupplyStreet 3050 W Northwest HwyCity DallasState TXPostal Code 75220-5941Telephone (214) 555-1234Owner John SmithLegacy Vendor # 1 12345Legacy Vendor # 2 NCC1701Legacy Vendor # 3 A-4895
Vendor Master Records
All represent the same business:
Vendor De-duplication
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Leadership ConferenceManual VMF Cleanup• Take advantage of cleanup opportunities
― Systems upgrades/migrations― Merger/acquisition
• Cutoff by last transaction date, marking the balance of records for archive review
• You can identify 25-40% of supplier duplicates by doing the following:― Step 1: Extract supplier number, supplier name, supplier address,
phone and TIN into an Excel file or Access database. You may also choose a few other attributes such as 1099 status, etc.
― Step 2: Identify exact duplicates on name and address― Step 3: Try the sorts on the following slide, looking for near duplicates
populating one field and leaving the rest as “same”― Step 4: Identify candidates for joint AP and procurement review
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Leadership ConferenceManual Duplicate Review
Supplier #
Supplier Name Address Phone TIN# Category
Different Same Same Same Same Simple Duplicate
Different Similar/DBA vs. Legal Same Same Same
Supplier Name Duplicate*
Different SameSimilar/Physical vs. Mailing
Same SameSupplier Address Duplicate*
Different Same Same Similar/ One Null Same Phone Duplicate
Different Same Same Same Similar/One Null TIN Duplicate*
* Potential indicator of fraud: review is suggested
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Leadership Conference
Legal/Regulatory Compliance What You Need to Know
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Leadership Conference
Sarbanes-Oxley Compliance• Law: The Sarbanes-Oxley Act of 2002 (SOX)
• Purpose: established corporate governance requirements
• Applies to: all U.S.-based public firms and certain foreign-owned firms that are cross-listed in the U.S. (often required of private firms with significant bank loans)
• There are two specific sections which are most relevant to accounts payable:― Section 302: Corporate Responsibility for Financial Reports ― Section 404: Management Assessment of Internal Controls
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Leadership ConferenceSOX ComplianceBest Practices
• Enforce appropriate segregation of duties
• Monitor payments to auditors – 5% rule on non-audit services
• Monitor payments to directors (and related entities)
• Follow best practices for vendor master file management
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Leadership ConferencePolling Question
How frequently does your firm check suppliers against debarment/denied parties lists?
a) Neverb) Supplier setup onlyc) Regular (monthly or quarterly) vendor
master screens for changesd) Supplier setup and regular vendor
master screens
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Debarred PartiesBest Practices
• Challenges― The Office of Foreign Assets Control (OFAC) offers Web-based
searches and a downloadable database—but this is just one of many lists
― The many government agencies do not coordinate or integrate their lists
― Each agency has their own update schedule and some are ad-hoc
• Best Practices― Work with procurement and legal to establish a risk-based
approach to compliance― Existing suppliers: quarterly batch match and append using a
consolidated database service― Prospective suppliers: transactional online search against all
required lists or a consolidated database as part of onboarding
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Leadership ConferencePrimaryDebarment Sources
List Purpose Applies To
U.S. Department of Treasury’s Office of Foreign Asset Control
Enforces economic and trade sanctions against certain countries, individuals and terrorism sponsoring organizations
All U.S.-based businesses
U.S. Department of Commerce’s Bureau of Industry and Security Denied Parties List
Trade sanctions against certain individuals and businesses
All U.S.-based businesses exporting goods
GSA Excluded Parties
Identifies parties excluded from receiving federal contracts, certain subcontracts, and certain types of federal financial and non-financial assistance and benefits.
All federal contractors
Health & Human Services Excluded Parties
Identifies parties excluded from receiving federal payments for healthcare services
Federal contractors to the HHS
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Leadership ConferenceThe Costof Non-Compliance
• Portions of Boeing Co. space systems operations remain ineligible to receive government contracts
• Eden Prairie company was fined $400,000 for export violations
• Lloyds TSB expects £180M bill for U.S. blacklist breach• OFAC fines National Australia Bank a $3M for ‘trading
with enemies’• OFAC (Office of Foreign Assets Control) fines more than
100 travelers $1,000 each • OFAC fines 74-year grandmother $8,500 for bicycling
in Cuba
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Leadership Conference
Supplier Data Management Know Your Suppliers, Mitigate Your Risk
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Leadership ConferenceSDM Best Practices
• Educate all constituents on the importance of supplier data management
• Publish a supplier information packet explaining policies
• Define supplier master ownership and access controls and enforce them
• Closely secure and regularly monitor supplier master changes
• Perform annual supplier archiving
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Leadership ConferenceSupplier Setup Steps
• Compare supplier information to publicly available or licensed business information (see Resources)
• Require W-9 for U.S.-based suppliers during setup, W-8 for non-U.S.-based suppliers
• Perform online TIN matching to confirm supplier information before releasing funds
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THE ACCOUNTS PAYABLE
Leadership ConferenceSupplier Setup Checklist• Develop a scorecard, allocating limited AP review
resources based on level of risk
• A few suggestions for a supplier red-flag checklist― Mail receiving agency addresses/vacant
addresses/prison addresses― Residential addresses with large invoices― No telephone number― Supplier with same address/phone number/SSN/bank
account as employee
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Leadership ConferenceVendor Master:Supplier Name
• W-9 or W-8 should be the source for business name, unless it appears to be inaccurate, in which case, follow policy regarding correcting with supplier
• Such a policy will yield better compliance for 1099 reporting
• In general, W-9s do not need to be updated annually unless there is a change in the supplier’s legal structure or legal name
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Leadership ConferencePolling Question
On what percentage of active U.S. suppliers do you have a W-9 document on file?
a) <10%b) 10%-25%c) 25%-50%d) >50%
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Leadership ConferenceIRS TIN Matching
• TIN Matching is available to any qualified payor to help reduce the number of “B” Notices
• Options include online matching (up to 25 records) and bulk matching (up to 100K records)
• Important: TIN Matching now only compares the EIN/SSN/ITIN and the first 4 characters of the supplier legal name (name control)—poor data quality practices are more likely to cause a mismatch than in the past
• IRS name control may only contain the following characters:― Numeric (0- 9), Alpha (A-Z), Hyphen (-), Ampersand (&)
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Leadership ConferenceVendor Master:Supplier Name
The most important rule is to simply be consistent but there are a few best
practices that practitioners agree on …
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Leadership ConferenceStandards:Business Names• Always include name suffixes (Corp, Inc, LLC)
• Name formatting― Avoid apostrophes and periods in business names― Always use CAPS
• Abbreviation― If you must abbreviate to fit a system limitation, abbreviate
from right to left as little as required― Follow a standard list of abbreviations
• Bad examples: ― “Mary’s One Time Supplier”― “.”― “ ”
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Leadership ConferenceStandards:Individual Names
• Exclude honorifics such as Mr., Mrs., etc.
• Exclude spaces in surnames ― (McDonald, not Mc Donald)
• Apply consistency in last name, first name vs. first name last name standards
• Bad example: employee vendors
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Leadership ConferenceStandards:Government Names
Taxing Authorities• In general, use the same rules as for business name
• Recommended naming convention for government entities:― TEXAS, STATE OF― DALLAS, CITY OF― DALLAS, COUNTY OF
• Put departments in a secondary field if possible
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Leadership ConferenceStandards:Addresses
Online services verify addresses as deliverable and for other suspect conditions (see Resources)• Do not run business name into address line 1
• USPS Publication 28
• Universal Postal Union
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Leadership ConferenceSupplier Portal• These services implement best practice supplier setup and ongoing
maintenance with a self-service model, reducing risk
• Some include supplier data validation and research, leveraging third party reference data for verification
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Leadership ConferenceSupplier Monitoring
• Manage monitored suppliers based on risk profile
• Set risk thresholds to drive daily updates to procurement and AP
• Receive notification of key supplier changes which increase risk― Bankruptcy― Business deterioration― Suspected out of business― Debarred files (OFAC, EPLS, etc.)
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Leadership ConferenceCase Study• Background
― Global manufacturer with 200K suppliers with a decentralized AP model― Developing a shared service model for consistent best practices
supplier data management approach across multiple divisions and systems and needed technology and verification services
• Solution― Eliminated nearly 25% of vendor master records (duplicates, inactive)― Implemented a streamlined supplier boarding service to support
supplier data verification prior to releasing funds― Developed integration with SAP supplier master using robust business
rules for change management― Improved response SLA to the business by over 50%― Maintains visibility to 99% of total spend, reducing ongoing vendor
master based risk
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Resources Where to Go for More
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Leadership ConferenceDebarred andDenied Parties
Sarbanes-Oxley frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=107_cong_bills&docid=f:h3763enr.tst.pdf
U.S. Treasury OFAC www.treas.gov/ofac
GSA Excluded Parties www.epls.gov
Bureau of Industryand Security www.bis.doc.gov/dpl/default.shtm
Health & Human Services exclusions.oig.hhs.gov
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Leadership ConferenceSupplier Verification
State Secretary of States www.secstates.com/
Non-profits www.irs.gov/app/pub-78/
USPS Address Search www.usps/zip4
USPS Publication 28 pe.usps.gov/cpim/ftp/pubs/Pub28/pub28.pdf
Universal Postal Union www.upu.int
IRS TIN Matching www.irs.gov/taxpros/article/0,,id=107478,00.htmlwww.irs.gov/businesses/corporations/article/0,,id=155677,00.html