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ACCT461AuditingandAssuranceServices8thEdition-TimothyLouwers.pdf

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Auditing & Assurance Services

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Timothy J. Louwers, PhD, CPA, CISA, CFF Professor Emeritus James Madison University

Penelope L. Bagley, PhD, CPA Department Chair and Associate Professor of Accounting Appalachian State University

Allen D. Blay, PhD, CPA Denise Dickins Accounting Faculty Fellow and Associate Professor Florida State University

Jerry R. Strawser, PhD, CPA KPMG Chair of Accounting Texas A&M University

Jay C. Thibodeau, PhD, CPA Rae D. Anderson Professor of Accounting Bentley University

Auditing & Assurance Services

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AUDITING & ASSURANCE SERVICES, EIGHTH EDITION

Published by McGraw-Hill Education, 2 Penn Plaza, New York, NY 10121. Copyright © 2021 by McGraw-Hill Education. All rights reserved. Printed in the United States of America. Previous editions © 2018, 2015, and 2013. No part of this publication may be reproduced or distributed in any form or by any means, or stored in a database or retrieval system, without the prior written consent of McGraw-Hill Education, including, but not limited to, in any network or other electronic storage or transmission, or broadcast for distance learning.

Some ancillaries, including electronic and print components, may not be available to customers outside the United States.

This book is printed on acid-free paper.

1 2 3 4 5 6 7 8 9 LWI 24 23 22 21 20

ISBN 978-1-260-36920-5 (bound edition) MHID 1-260-36920-X (bound edition) ISBN 978-1-260-70373-3 (loose-leaf edition) MHID 1-260-707373-8 (loose-leaf edition)

Portfolio Manager: Elizabeth Eisenhart Product Developers: Erin Quinones Marketing Manager: Katherine Wheeler Content Project Managers: Mary E. Powers (core), Angela Norris (assessment) Buyer: Laura Fuller Design: Matt Diamond Content Licensing Specialists: Abbey Jones Cover Image: © Oskari Porkka/Shutterstock Compositor: SPi Global

All credits appearing on page or at the end of the book are considered to be an extension of the copyright page.

Library of Congress Cataloging-in-Publication Data

Names: Louwers, Timothy J., author. | Blay, Allen D., 1970- author. | Thibodeau, Jay C., author. | Strawser, Jerry R., author. | Bagley, Penelope, author. Title: Auditing & assurance services / Timothy J. Louwers, James Madison University, Allen Blay, Florida State University, Jay Thibodeau, Bentley University, Jerry Strawser, Texas A&M University, Penelope Bagley, Appalachian State University. Other titles: Auditing and assurance services Description: Eighth edition. | New York, NY : McGraw-Hill Education, 2021. | First edition entered under title. Identifiers: LCCN 2020010135 (print) | LCCN 2020010136 (ebook) | ISBN 9781260369205 (bound edition) | ISBN 9781260703733 (loose-leaf edition) | ISBN 9781260703672 (ebook) Subjects: LCSH: Auditing. Classification: LCC HF5667 .A815 2021 (print) | LCC HF5667 (ebook) | DDC 657/.45—dc23 LC record available at https://lccn.loc.gov/2020010135 LC ebook record available at https://lccn.loc.gov/2020010136

The Internet addresses listed in the text were accurate at the time of publication. The inclusion of a website does not indicate an endorsement by the authors or McGraw-Hill Education, and McGraw-Hill Education does not guarantee the accuracy of the information presented at these sites.

mheducation.com/highered

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Some people come into our lives and quickly go. Some stay awhile and leave footprints on our hearts and we are never quite the same.

Anonymous

We dedicate this book to the following educators whose footprints we try to follow:

Professor Homer Bates (University of North Florida)

Professor Stanley Biggs (University of Connecticut)

Professor Lewis C. Buller (Indiana State University)

Professor Patrick Delaney (Northern Illinois University)

Professor William Hillison (Florida State University)

Professor John Ivancevich (University of Houston)

Professor Richard Kochanek (University of Connecticut)

Professor John L. “Jack” Kramer (University of Florida)

Professor Jack Robertson (University of Texas at Austin)

Professor Robert Strawser (Texas A&M University)

Professor Sally Webber (Northern Illinois University)

Professor “IBM Jim” Whitney (The Citadel)

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Meet the Authors Timothy J. Louwers is Professor Emeritus at James Madison University. Professor Louwers received his undergraduate and master’s degrees from The Citadel and his PhD from Florida State University. Prior to beginning his academic career, he worked in public accounting with KPMG, specializing in financial, governmental, and informa- tion systems auditing. He is a certified public accountant (South Carolina and Virginia) and a certified information systems auditor. He is also certified in financial forensics.

Professor Louwers’s research interests include auditors’ reporting decisions and ethi- cal issues in the accounting profession. He has authored or coauthored more than 60 publications on a wide range of accounting, auditing, and technology-related topics, including articles in the Journal of Accounting Research, Accounting Horizons, the Jour- nal of Business Ethics, Behavioral Research in Accounting, Decision Sciences, the Jour- nal of Forensic Accounting, Issues in Accounting Education, the Journal of Accountancy, the CPA Journal, and Today’s CPA. Some of his published work has been reprinted in Russian and Chinese. He is a respected lecturer on auditing and technology-related issues and has received teaching excellence awards from the University of Houston and Louisiana State University. He has appeared on both local and national television news broadcasts, including MSNBC and CNN news programs.

Allen D. Blay is an Associate Professor of Accounting and the Denise Dickins Accounting Faculty Fellow at Florida State University.

Professor Blay completed his PhD at the University of Florida in 2000. He teaches auditing at all levels and teaches a seminar in auditing research in the doctoral program. His research interests relate to auditor judgment and decision making. Professor Blay has authored or coauthored publications on a wide range of accounting and auditing topics in journals such as Contemporary Accounting Research, Auditing: A Journal of Practice and Theory, Organizational Behavior and Human Decision Processes, the Journal of Business Eth- ics, Behavioral Research in Accounting, Issues in Accounting Education, the International Journal of Auditing, and the Journal of Accounting, Auditing, and Finance. He is currently an editor for Issues in Accounting Education and serves on several editorial boards.

Professor Blay has been active in the American Accounting Association, co-chairing the 2020 Auditing Section Midyear Meeting and serving on the steering committee for the Intensive Data and Analytics Summer Workshop the past three years, as well as in many other roles over the years. He is also active in the American Institute of CPAs, serving in various volunteer roles relating to the Uniform CPA Exam. Prior to entering academics, Professor Blay worked in public accounting auditing financial institutions. He currently directs the accounting doctoral program at Florida State University.

Jerry R. Strawser is Executive Vice President and Chief Financial Officer at Texas A&M University and holds the KPMG Chair in Accounting.

Prior to his current appointment, Professor Strawser served as dean of Mays Business School at Texas A&M University, interim executive vice president and provost at Texas A&M University, interim dean of the C. T. Bauer College of Business at the University of Houston, and Arthur Andersen & Co. Alumni Professor of Accounting.

Professor Strawser has coauthored three textbooks and more than 60 journal articles. In addition to his academic experience, he had prior public accounting experience at two Big Four accounting firms. He has also developed and delivered numerous executive development programs to organizations such as AT&T, Centerpoint Energy, Continental

Courtesy of James Madison University

Courtesy of Kallen M. Lunt

Courtesy Jerry R. Strawser

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Airlines, ConocoPhillips, Halliburton, KBR, KPMG, Minute Maid, PricewaterhouseC- oopers, McDermott International, Shell, Southwest Bank of Texas, and the Texas Society of Certified Public Accountants. Professor Strawser is a certified public accountant in the state of Texas and earned his BBA and PhD in Accounting from Texas A&M University.

Jay C. Thibodeau is the Rae D. Anderson Professor of Accounting and Director of PhD Programs at Bentley University.

Professor Thibodeau is a certified public accountant and a former auditor. He received his bachelor’s degree from the University of Connecticut in 1987 and his PhD from the University of Connecticut in 1996. He joined the faculty at Bentley in 1996 and has remained there ever since. Professor Thibodeau has conducted executive education pro- grams for numerous leading firms including Fidelity Investments, KPMG, Pricewater- houseCoopers, Stryker, and Blue Coat Technologies.

Professor Thibodeau’s scholarship focuses on audit judgment and decision making and audit education. He is a coauthor of two textbooks and has written more than 50 book chapters and articles for academics and practitioners in journals such as Auditing: A Journal of Practice & Theory, Journal of Information Systems, Accounting Horizons and Issues in Accounting Education.

Professor Thibodeau served as the president of the Auditing Section of the American Accounting Association for the 2014/2015 academic year. He has received national rec- ognition for his work six times: First, for his thesis, winning the 1996 Outstanding Doc- toral Dissertation Award presented by the ABO section of the AAA. Four other times, for curriculum innovation, winning the 2001 Joint AICPA/AAA Collaboration Award, the 2003 Innovation in Assurance Education Award, the 2016 Forensic Accounting Teaching Innovation Award, and the 2019 Innovation in Assurance Education Award. And finally, for outstanding service, receiving a Special Service Award from the Auditing Section for his work in helping to create the Center for Audit Quality’s Access to Auditors program.

Penelope L. Bagley is the Department Chairperson and Professor of Accounting at Appalachian State University.

Professor Bagley received her undergraduate and master’s degrees from North Caro- lina State University and her PhD at the University of Georgia. Prior to obtaining her PhD, Professor Bagley worked for a short time in the audit field. She is a certified public accountant in North Carolina. Professor Bagley teaches both undergraduate and grad- uate auditing courses. Professor Bagley has authored and co-authored publications on accounting and auditing topics in journals such as Auditing: A Journal of Practice & Theory, Accounting Horizons, and Behavioral Research in Accounting. She has also co- authored auditing cases, published in Issues in Accounting Education. Professor Bagley is active in the American Accounting Association and has served on various committees for the Auditing Section. In her spare time, Professor Bagley likes to spend time with her husband Matt and children, Garrett and Julianne. She is an avid runner, most recently qualifying and running the 2019 Boston Marathon.

Bentley University

Penelope L. Bagley

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As auditors, we are trained to investigate beyond appearances to determine the underly- ing facts—in other words, to look beneath the surface. From the Enron and WorldCom scandals of the early 2000s to the financial crisis of 2007–2008 to present-day issues and challenges related to significant estimation uncertainty, understanding the auditor’s responsibility related to fraud, maintaining a clear perspective, probing for details, and understanding the big picture are indispensable to effective auditing.

With the availability of greater levels of qualitative and quantitative information (“Big Data”), the need for technical skills and challenges facing today’s auditor is greater than ever. The Louwers, Bagley, Blay, Strawser, and Thibodeau team has dedi- cated years of experience in the auditing field to this new edition of Auditing & Assur- ance Services, supplying the necessary investigative tools for future auditors.

Cutting-Edge Coverage The eighth edition of Auditing & Assurance Services continues its tradition as the most up-to-date auditing text on the market. All chapters and modules have been revised to incorporate

∙ The latest professional standards, recodifications, and proposals from the Interna- tional Auditing and Assurance Standards Board, Auditing Standards Board, and Public Company Accounting Oversight Board.

∙ A list of the relevant professional standards that are covered in that chapter, including new AICPA reporting standards effective for 2020 fiscal years, as well as compre- hensive coverage of the new PCAOB standards on auditing estimates.

Data Analytics ∙ One trend has emerged as a potential sea change in the financial statement auditing

process: the data and analytics challenge.

We believe students should be prepared to make the best use possible of relevant data using state-of-the-art analytical tools. In fact, the terms big data and data and analytics are frequently being used to describe a growing movement among audit professionals. As the AICPA moves to add data and analytics onto the Uniform CPA Examination, our collective view is that students must be able to not only meet current requirements, but be ahead of the game.

To prepare students, the eighth edition of Auditing & Assurance Services has been revised deliberately to help students critically think about the use of increased data and analytical tools in the financial statement audit. In addition to changes within the main chapters of the book, we have added

∙ A new module specifically covering data and analytics in auditing, which follow- sthe AICPA Guide to Data Analytics.

∙ Author-Created Cases and Exercises (as part of Data Analytics Module) that cover the majority of uses of data analytics in the financial statement audit, along with extensive solutions to help instructors implement the materials in their classroom.

It is our belief that students should be trained in the process of data and analytics, and learn to think critically about situations they may face in an audit. We believe that the knowledge students attain should be software independent, particularly since software

Look Beneath the Surface . . .

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technology changes so rapidly. However, we also believe that it is important for stu- dents to become familiar with at least one specific data and analytic software tool, and recent AACSB standards echo this belief. Thus, an important goal of the eighth edition is to provide a clear and implementable method to fully integrate a leading data analysis tool, the IDEA Data Analysis software, into the auditing class. Many of our exercises, however, can be implemented using whatever technology an instructor chooses to use, like Excel.

We believe that IDEA provides an outstanding platform to illustrate the steps that auditors need to take related to data and data analysis while completing the financial statement audit. Leading auditing professionals have confirmed that using IDEA is an outstanding way for entry-level auditing professionals to begin the journey into the world of big data and data analytics. Simply stated, big data is manifested in the finan- cial statement auditing process through the use of tools like IDEA.

Overall, our revisions related to the big data challenge were designed to provide instructors a set of tools and mechanisms to bring data and analytics into the classroom in a meaningful way. Through the use of these tools, students can be sure they are pre- pared to enter practice with an appreciation for and knowledge of the increasing impor- tance of data and analytics in the auditing profession.

Perhaps most importantly, the eighth edition of Auditing & Assurance Services also continues to be the most up-to-date auditing text on the market. The book has fully inte- grated the new PCAOB and ASB reporting standards. In addition, we fully cover the PCAOB’s new standards on audits of estimates, including fair value estimates, and the use of specialists in an audit. In addition, all chapters and modules have been revised to incorporate the latest updates from the international standards of audit- ing (ISAs) and the Auditing Standards Board (ASB). With Auditing & Assurance Ser- vices, eighth edition, students are prepared to take on auditing’s latest challenges.

The Louwers author team uses a conversational, yet professional tone—hailed by reviewers as a key strength of the book.

Flexible Organization Auditing & Assurance Services teaches students auditing con- cepts by emphasizing real-life contexts when describing the auditing process. The authors use chapters and modules to

“The format allows you to integrate the modules into the chapter material in any way you would find useful.” —Frank J. Beil, University of Minnesota

Chapters Modules

The 12 chapters cover the auditing process extensively with a multitude of cases designed to give students a better understanding of how a best-practice concept developed from real-world situations.

Modules A–H provide instructors additional material that can be used throughout the course. Topics such as fraud, ethics, sampling, and technology are covered in the modules, which are designed to be taught whenever instruc- tors want to introduce the topic in their course.

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achieve this goal. Although the chapters follow a logical sequence that we recommend professors consider for their classes, the modules have been written to be used on a stand-alone basis. In essence, the modules have been deliberately prepared for entirely flexible implementation of these topics without excessive reliance on chapter sequenc- ing. We encourage you to integrate these modules into your syllabi in a manner that best suits your approach to the auditing course.

Engage Your Students with Real Examples An effective accounting textbook integrates real-world scenarios with theoretical discus- sion. Auditing & Assurance Services places the student in the role of a decision maker, by illustrating the application of auditing concepts using actual situations experienced by accounting firms and companies such as:

∙ Each chapter or module opens with a “real-world” example that draws upon concepts discussed within that chapter or module.

∙ A series of mini-cases available on the Instructor Resource Center have been devel- oped for use by instructors to further bring text material to life. These mini-cases fea- ture real situations experienced by companies, individuals, or accounting firms and are updated by the authors to include both timeless classics such as Arthur Andersen’s failure to detect fraud at Enron to more recent situations such as Lehman Brothers.

Fraud Awareness The fraud coverage in Auditing & Assurance Services is the most extensive available and is complemented by real-world examples chosen to engage students through the following tools:

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LEARNING OBJECTIVES The professional standards emphasize the importance of an auditor’s identification and assessment of the risks of material misstatement that exist related to an audit client. Once each of the risks is identified and assessed, the auditor needs to plan an appropriate response. Given the importance of risk assessment,

it is not surprising that the professional standards state that the risk assessment process underlies the entire audit process. In Chapter 3, we covered the engagement planning process, beginning with pre- engagement activities, supervision, and materiality. In this chapter, we provide comprehensive coverage of an auditor’s risk assessment and its impact on the audit process.

Risk comes from not knowing what you’re doing.

Warren Buffett.

Profit is the result of risks wisely selected.

Frederick Barnard Hawley.

The Audit Risk Model and Inherent Risk Assessment

C H A P T E R 4

Professional Standards References

Topic AU-C/ISA Section AS Section

Consideration of Fraud in a Financial Statement Audit 240 2401

Consideration of Laws and Regulations 250 2405

Communications with Audit Committees 260 1301

Audit Planning 300 2101

Identifying and Assessing the Risks of Material Misstatement 315 2110

Materiality 320 2105

Auditors’ Responses to Risks of Material Misstatement 330 2301

Audit Evidence 500 1105

Substantive Analytical Procedures 520 2305

Related Parties 550 2410

∙ Auditing Insights integrated throughout the text. ∙ Apollo Shoes Case, the only stand-alone fraud audit

case on the market (available online). ∙ Mini-cases that may be assigned to supplement

text chapters and modules that expose students to landmark fraud cases at Bernie Madoff Investment Securities, Enron, HealthSouth,

Parmalat, PTL Club, and Satyam Computer Services. ∙ Specific discussion of management fraud (Chapter 4), employee fraud (Chapter 6),

and the Certified Fraud Examiner Exam (Module D).

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Create a State-of-the-Art Learning Environment: Instructor Resources The author team and McGraw-Hill are dedicated to providing instructors with the best teaching resources available. In addition to the solutions manual, test bank, PowerPoint Presentations, and the Apollo Shoe Case, the following resources are also available.

The Updated Auditor The author team scrutinizes leading business and academic publications for relevant issues and research that sheds light on auditing and the audit process. Recent findings from academic research and discussions from professional literature are drawn from the following publications:

∙ Accounting Horizons ∙ Accounting Today ∙ Auditing: A Journal of Practice & Theory ∙ Behavioral Research in Accounting ∙ Bloomberg Businessweek ∙ CFO.com ∙ CPA Journal ∙ Journal of Accountancy ∙ Journal of Accounting and Economics ∙ The Accounting Review ∙ The Wall Street Journal

These excerpts are highlighted throughout the text as Auditing Insights to allow for easy identification and review by instructors and students.

In addition to the use of Auditing Insights, on a monthly basis, the author team pro- vides an Updated Auditor briefing, which summarizes the content of relevant business and academic publications on a chapter-by-chapter basis, to allow students to apply cur- rent developments in the profession with material discussed in class. The Updated Audi- tor briefing is available in Connect. With the Updated Auditor, instructors will always be at the cutting edge of auditing practice!

IDEA Software and Workbook With the availability of unprecedented amounts of quantitative and qualitative infor- mation and tools available to access and process that information, it is imperative that students learn and utilize the latest technologies used by auditing professionals. As previously stated, McGraw-Hill Education has forged a partnership with Caseware Analytics for the use of the IDEA data analysis tool. Chapters 3 (audit planning), 4 (risk assessment), 5 (internal control), 7–9 (operating cycle chapters), both modules on sam- pling (Modules E and F), and the new data and analytics module (Module G) have been revised to reference the use of IDEA within the chapter or module.

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In addition, the eighth edition includes end-of-chapter exercises utilizing author- developed databases exclusively for use with Auditing & Assurance Services as well as supplemental materials available in Connect to complement the IDEA workbook and provide hands-on instructions on using the IDEA software. The authors also provide

∙ Implementation guidance to instructors. ∙ Robust video walk-throughs. ∙ Detailed solutions and explanations on this new content.

Overall, the author team has provided significant resources to prepare students for the auditing environment in 2020 and beyond.

Roger CPA Review McGraw-Hill has partnered with Roger CPA Review (Powered by UWorld), a global leader in CPA Exam preparation, to provide students a smooth transition from the accounting classroom to successful completion of the CPA Exam. While many aspiring accountants wait until they have completed their academic studies to begin preparing for the CPA Exam, research shows that those who become familiar with exam content earlier in the process have a stronger chance of successfully passing the CPA Exam. Accordingly, students using these McGraw-Hill materials will have access to Roger CPA Review multiple choice questions supported by explanations written by CPAs focused on exam preparation. McGraw-Hill and Roger CPA Review are dedicated to supporting all accounting students along their journey, ultimately helping them achieve career success in the accounting profession. For more information about the full Roger CPA Review program, exam requirements, and exam content, visit www.rogercpareview.com.

TestGen TestGen is a complete, state-of-the-art test generator and editing application software that allows instructors to quickly and easily select test items from McGraw Hill’s Test- Gen testbank content and to organize, edit and customize the questions and answers to rapidly generate paper tests. Questions can include stylized text, symbols, graphics, and equations that are inserted directly into questions using built-in mathematical templates. With both quick-and-simple test creation and flexible and robust editing tools, TestGen is a test generator system for today’s educators.

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Association to Advance Collegiate Schools of Business (AACSB) Statement McGraw-Hill Education is a proud corporate member of AACSB International. Under- standing the importance and value of AACSB accreditation, Auditing & Assurance Services, 8e, recognizes the curricula guidelines detailed in the AACSB standards for business accreditation by connecting selected questions in the text and test bank to the eight general knowledge and skill guidelines in the AACSB standards. The statements contained in Auditing & Assurance Services, 8e, are provided only as a guide for the users of this textbook. The AACSB leaves content coverage and assessment within the purview of individual schools, their mission, and their faculty. Although Audit- ing & Assurance Services, 8e, and the teaching package make no claim of any specific AACSB qualification or evaluation, we have within Auditing & Assurance Services, 8e, labeled selected questions in Connect according to the eight general knowledge and skills areas.

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New to the Eighth Edition of

In response to feedback and guidance from numerous auditing accounting faculty, the authors have made many important changes to the eighth edition of Audit- ing & Assurance Services, including the following:

∙ The eighth edition of Auditing & Assurance Ser- vices features Connect and SmartBook.

∙ A new Module G has been added to include full cov- erage of the uses of Data and Analytics in auditing, including extensive Data Analytics Exercises with author-created data.

∙ All chapters and modules have been revised to incorporate professional standards adopted through January 2020.

∙ New Update to Apollo Shoes, Inc. case with Data Analytics content. Apollo Shoes, Inc. is an audit case designed to introduce students to the entire audit process. Newly created auto-gradable ques- tions, instructor implementation guide, and videos can be found online in Connect.

∙ Auditing Insight boxes have been added and updated throughout the textbook to place issues

The following breakdown shows the revisions we made on a chapter-by-chapter basis:

CHAPTER 1: Auditing and Assurance Services ∙ Updated the section on the importance of reliable

information for users by incorporating a discus- sion about Theranos, the blood-testing startup company that was recently featured in an HBO movie. In many cases, the informational package provided to potential investors did not include an independent audit report. The example reinforces why it is so important for investors and creditors to review audited financial statements as they consider whether to invest or loan money to a company.

∙ Included a new Auditing Insight featuring the most recent audit quality report published by KPMG. Importantly, the report highlighted the firm’s invest- ment in the audit of the future and included a dis- cussion of cognitive technologies such as IBM’s Watson and the importance of harnessing the emerg- ing power of Big Data.

∙ Included a new Auditing Insight that describes the role of EY, a Big Four accounting firm, in the the annual Hall of Fame voting for baseball. That is, while the the Baseball Writers’ Association of America is responsible for the voting, EY is respon- sible for verifying that eligible voters are properly registered and have signed a code of conduct, and that the actual count of votes is correct!

CHAPTER 2: Professional Standards ∙ Added opening vignette describing the Deloitte Bra-

zil audits of Gol Intelligent Airlines and alteration of documentation in response to a PCAOB inspection.

∙ Added Auditing Insights related to the Carillion audit failure, the United Kingdom Competition and Markets Authority recommendations for auditor independence, and the KPMG controversy related to advance notification of audits selected for PCAOB inspection.

∙ Included a summary of recent academic research relating to the impact of PCAOB inspection results

discussed within the text into a real-world context. These boxes incorporate numerous examples from business and academic publications as well as actual company annual reports and audit reports.

∙ Examples using the Caseware IDEA software are included in Chapters 3, 4, 5, 7, 8, 9, Module F, and the new Module G focusing on Data and Analytics. In addition, end-of-chapter exercises using author-devel- oped databases exclusively for use with Auditing & Assurance Services as well as supplemental materials to complement the IDEA workbook are provided.

∙ Tables in the cycle chapters have been fully standard- ized to focus on the risk assessment process for each relevant assertion. The chapters provide a consistent focus on how auditors respond to assessed risk of material misstatement, through the incorporation of easy-to-read tables throughout Chapters 6 through 10 to highlight the key issues and risks faced by audi- tors in the examination of different accounts. These tables take the students through the risk assessment process for each cycle on a step-by-step basis to mir- ror the methodology used in current audit practice.

Highlights of Auditing & Assurance Services, 8e

Part I: The Contemporary Auditing Environment

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on auditor dismissal, auditor market share and fees, auditor opinions, audit quality, and audit effort in years following the inspection.

∙ Included 2019 auditors’ report for Microsoft, one of the first major companies to be subject to disclosure of critical audit matters in the auditors’ report.

∙ Summarized PCAOB inspections of 2014, 2015, and 2016 audits conducted by Big Four firms and expanded analysis to summarize the number of audits in which the client’s report on internal control was revised as a result of the inspection.

Auditing & Assurance Services

CHAPTER 3: Engagement Planning ∙ Updated planning discussion for changes related to

the updated PCAOB Auditing Standard 1210: Using the Work of an Auditor-Engaged Specialist, effective for FYE 12/15/2020 and amendments to Auditing Standard 1105: Audit Evidence and Audit Standard 1201: Supervision of the Audit Engagement.

∙ Integrated discussion of matters of planning related to the client’s computer environment and the use of CAATs (former LO 3-5) into the chapter and remainder of the text.

∙ Introduced a new vignette reflecting current audit environment and independence concerns.

∙ Rearranged and updated discussions on Staffing the Audit Engagement and Materiality for readability and flow.

∙ Updated and replaced Audit Insights and examples throughout the chapter to reflect more recent events.

CHAPTER 4: The Audit Risk Model and Inherent Risk Assessment ∙ Renamed the chapter to better reflect the chapter

content. ∙ Introduced a new vignette discussing recent PCAOB

inspection reports and their continued focus on issues related to audit risk assessment.

∙ Added a discussion in Inherent Risk Assessment to reflect the need for the auditor to also understand the client’s computerized processing when gaining an understanding of the client’s business and environment.

∙ Replaced and updated Audit Insights and examples throughout the chapter to reflect more recent events.

CHAPTER 5: Risk Assessment: Internal Control Evaluation ∙ Revised the introduction to include the recent “cease

and desist” orders issued by the SEC (January 2019) against four public companies: Lifeway Foods Inc., Digital Turbine Inc., CytoDyn Inc., and Grupo Simec

S.A.B de C.V. After providing each of these compa- nies with as many as 10 years to address their prob- lems, the SEC finally had enough and decided to take action. In taking this action, the SEC made clear that “disclosure of material weaknesses is not enough without meaningful remediation. We are commit- ted to holding corporations accountable for failing to timely remediate material weaknesses.” The introduc- tion allows for instructors to emphasize the impor- tance of the internal control audit in their classes

∙ Added an Auditing Insight that featured, Elon Musk, the billionaire co-founder of Tesla Inc., who was fined $20 million by the SEC for a seemingly harmless tweet that he made on August 7, 2018. The tweet indicated that he had secured financing to take the company pub- lic, causing an increase of over six percent in the com- pany’s stock price. The basis of the SEC’s complaint against Tesla related back to a lack of internal controls.

∙ Replaced the dated Krispy Kreme management report on Internal Control over Financial Reporting with excerpts from a Costco Wholesale Corporation management report on internal control over financial reporting, which identified a material weakness in its system of internal control. The material weakness related to information technology general controls which serves to reinforce the importance of informa- tion technology controls in today’s audit environ- ment. The report was issued on October 26, 2018.

CHAPTER 6: Employee Fraud and the Audit of Cash ∙ Updated the discussion on bank cash confirmations

to include a detailed description of the process and an example of electronic confirmation using Confir- mation (formerly Confirmation.com).

∙ Added multiple new and current Auditing Insights focusing on recent interesting frauds involving the misuse of cash within an organization, including an insightful and somewhat humorous story involving lunch ladies at a school cafeteria.

Part II: The Financial Statement Audit

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∙ Revised the end-of-chapter content to address elec- tronic bank confirmations.

CHAPTER 7: Revenue and Collection Cycle ∙ Included a new section with details surrounding

the audit of revenue recognized in accordance with ASC 606. The section discusses the five-step rev- enue recognition process and how auditors approach the issues involved.

∙ Included a new introduction to the chapter that discusses the recent Carillion fraud and the issues involved with estimation of revenue under longer- term revenue contracts.

∙ Added a comprehensive end-of-chapter exercise involving a substantive analytical procedure for auditing ticket revenue for a university. The exercise requires students to consider issues related to suf- ficiency of evidence and precision of data.

∙ Updated PCAOB inspection findings through the latest inspection reports.

∙ Included several new data and analytics exercises in the new Module G related to revenue recogni- tion, along with several existing author-created and IDEA workbook exercises, enabling instructors to have many options for integration of data analytics into their courses.

CHAPTER 8: Acquisition and Expenditure Cycle ∙ Substantially revised all tables in the chapter to be

identical in format for all cycle chapters (6-10). This enables instructors to present a common format that matches the current method of auditing, from iden- tification of significant accounts and relevant asser- tions to substantive procedures to audit residual risks.

∙ Added multiple new auditing insights covering cur- rent news related to auditing the expenditure cycle.

∙ The end of chapter materials contain a new CPA Exam-style simulation that requires students to link audit issues to assertions, control procedures, and substantive procedures to match the new increase emphasis of these areas on the CPA Exam.

CHAPTER 9: Production Cycle and the Audit of Inventory ∙ Revised the chapter to focus on the audit of the

inventory account, no longer primarily focusing on the production cycle. The chapter addresses risks of material misstatement in the inventory account for companies ranging from manufacturers to retailers such as Target.

∙ Substantially revised all tables in the chapter to be identical in format for all cycle chapters (6–10). This enables instructors to present a common format that matches the current method of auditing, from identification of significant accounts and relevant assertions to substantive procedures to audit residual risks.

∙ End-of-chapter materials include a new CPA Exam– style simulation involving issues in an inventory count. An additional new end-of-chapter exercise involves fraud detection in an audit of inventory.

∙ New data and analytic exercises included with Module G focus on issues related to audits of the inventory account. The chapter continues to include a focus on data and analytics that integrates several IDEA exercises, including author-created content and end-of-chapter materials.

∙ Updated PCAOB inspection findings to focus on current issues being addressed in inspection reports.

CHAPTER 10: Finance and Investment Cycle ∙ Significantly expanded the discussion of audit-

ing accounting estimates, including fair values, to address the newly revised PCAOB standards. In addition, added a much more detailed discus- sion of the general approach to auditing accounting estimates.

∙ Updated tables throughout the chapter to include examples involving auditing accounting estimates in investment accounts.

∙ Included in the introduction a new discussion of the very recent (August 2019) accusations of GE by Harry Markopolos. The introduction allows students to consider the difficult issues involved in auditing the finance and investment cycle and how the audi- tor may have approached these issues.

CHAPTER 11: Completing the Audit ∙ Updated discussion of Ability to Continue as a

Going Concern for updates to PCAOB Auditing Standard 2415 and AICPA AU-C 570, The Audi- tor’s Consideration of an Entity’s Ability to Con- tinue as a Going Concern.

∙ Updated introductory vignette to reflect current state of Valeant (now Bausch Health).

∙ Abbreviated Attorney Letter and Written Represen- tations sections to include most relevant material.

∙ Replaced and updated Audit Insights and examples throughout the chapter to reflect more recent events.

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MODULE A: Other Public Accounting Services ∙ Significantly streamlined and reorganized presen-

tation into four major sections addressing special issues in GAAS audits, other attestation engage- ments, accounting and review service engagements, and assurance engagements.

∙ Expanded coverage of audits of financial statements prepared using a special purpose framework and prospective financial information.

∙ Added Auditing Insights relating to the required scope of agreed–upon-procedures engagements required by the National Collegiate Athletics Asso- ciation, PCAOB sanctions relating to broker–dealer compliance, deficiencies from a PCAOB inspection report related to the use of service auditor’s reports, trends in corporate responsibility reporting, and BDO’s assurance on Amazon Trust Services’ Certi- fication Authority operations.

∙ Incorporated tables and other pedagogical summa- ries throughout module to provide overview of key differences in scope of engagements and accoun- tants’ reports across different types of engagements.

∙ Significantly expanded end-of-chapter materials, including a number of Connect-gradable assignments.

MODULE B: Professional Ethics ∙ Added an Auditing Insight to illustrate the General-

ization argument featuring the data breach at Equi- fax, the largest data breach in history. The breach resulted in the names, addresses, and social secu- rity numbers of over 147 million Americans being stolen. The data breach occurred in May 2017 but

wasn’t discovered by Equifax until July 29th, nearly two months later. It took the company another six weeks to notify the public that names and Social Security numbers of millions had been stolen. In the aftermath, the SEC brought charges against for- mer Equifax Chief Information Officer Jun Ying in March of 2018 for using his knowledge of the breach to sell shares of the company’s stock before the breach was made public.

∙ Added two new key terms, independence in fact and independence in appearance. Article IV of the AIC- PA’s Professional Code of Conduct requires that “a member in public practice should be independent in fact and appearance when providing auditing and other attestation services.” As a result, it was impor- tant to feature these concepts as key terms.

∙ Added an Auditing Insight that describes how Price- waterhouseCoopers (PwC) lost Alteryx as an audit client over independence concerns. Alteryx is a soft- ware company that was being used by PwC. As a result of their promotion of the software to their cli- ents, executives at Alteryx became concerned about the independence of their auditing firm. As such, they replaced PwC with Deloitte.

MODULE C: Legal Liability ∙ Added a new introductory vignette on litigation

involving PwC for its audits of Colonial Bank and resulting settlement with the FDIC.

∙ Updated the summary of major settlements involv- ing Big Four accounting firms to include more recent settlements.

Part III: Stand-Alone Modules

CHAPTER 12: Reports on Audited Financial Statements ∙ Revised chapter and end-of-chapter materials to incor-

porate the revised auditors’ report for non-issuers required by Statement on Auditing Standards No. 134.

∙ Added Auditing Insight relating to recent issues regarding the use of component auditors (U.K. affiliate firms’ involvement in the audits of Amazon, Black- Rock, and Citigroup; KPMG, Deloitte, and BDO’s use of Zimbabwe affiliate firms; and Deloitte’s use of mul- tiple component auditors in the audit of Monsanto).

∙ Added examples from auditors’ reports issued for Alphabet, Caesars Entertainment Corporation,

DowDupont, Fannie Mae, Freddie Mac, General Electric, General Motors, Kraft Heinz Company, Tesla Inc., and YUM! Brands.

∙ Added appendix related to auditors’ reports on financial statements and reports on internal con- trol over financial reporting for issuers, including information relating to the topics included as criti- cal audit matters in the early round of auditors’ reports.

∙ Provided supplemental auditors’ reports and end-of- chapter materials in Connect for instructors wishing more extensive coverage of auditors’ reporting for issuers and the PCAOB audit report.

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∙ Expanded the discussion of academic research examining auditor litigation to include recent stud- ies that investigated the factors affecting the litiga- tion risk faced by audit firms.

∙ Replaced and updated Audit Insights and examples throughout the module to reflect more recent events.

MODULE D: Internal Audits, Governmental Audits, and Fraud Examinations ∙ New introductory vignette highlighting 2018 Atlanta

cyber attack and the importance of the internal audit role and recommendations.

∙ Restructured learning objectives to include only three similar objectives focused on each of the three areas highlighted in the module, Internal Audits, Governmental Audits, and Fraud Examinations.

∙ Reorganized discussions of Internal Audits and Governmental Audits. Aligned the discussions to include similar topic headings including definition, types of services, standards, and reports.

∙ Consolidated review checkpoints to appear at the end of each of the three major sections; added three new review checkpoints for Internal Audits.

∙ Replaced and updated Audit Insights and examples throughout the module to reflect more recent events.

MODULES E and F: Sampling ∙ Focused sampling modules on applications of attri-

butes (Module E) and variables (Module F) sampling, while integrating CPA-exam specific concepts and terminology from the former overview module as appropriate.

∙ Reoriented Modules E and F to illustrate how results from an attributes sampling application influence the necessary level of detection risk and variables sampling application.

∙ Included vignette in Module E to illustrate how polls in the 2017 United Kingdom “snap” election, 2016 Brexit vote, and 2016 United States presidential election were subject to sampling risk and emphasize the importance of controlling sampling risk in the audit examination.

∙ Included IDEA screen captures within modules to illustrate the identification and input of parameters as well as the evaluation of sample results.

∙ Expanded number of Connect-gradable assignments in end-of-chapter materials.

MODULE G: Data and Analytics in Auditing ∙ A new module addresses the key questions stu-

dents have about what Data and Analytics are in

an auditing context, and how audit procedures using these techniques should be conducted. The module follows the approach from the AICPA Guide to Data Analytics in Auditing.

∙ The module contains an extended discussion of infor- mation produced by the entity (IPE) and how the audi- tor should assess the completeness and accuracy of this information, as well as the precision of the infor- mation for the purposes of the auditing procedure.

∙ The end of chapter multiple choice, exercises and problems contain entirely author-created questions and examples, as well as significant assistance for instruc- tors for implementing the exercises in their classrooms.

∙ Exercises and problems are linked to learning objectives in other chapters in the book to enable instructors to appropriately integrate the important topic of data and analytics throughout the auditing curriculum.

MODULE H: Auditing and Information Technology ∙ Given that the use of information technology (IT)

is pervasive in the financial reporting process on largely all audit clients in today’s environment, audi- tors must gain an understanding of how IT is used in the internal control system. This is now explained in detail in Module H with a focus on three phases: (1) determining the scope of the IT testing plan by carefully identifying each of the IT dependencies; (2) understanding the IT controls and processes that need to be tested for each IT dependency; and (3) testing the IT controls.

∙ In today’s audit environment, to help facilitate the identification of IT dependencies, as key internal control activities are identified and understood by auditors, they are generally categorized as being: (1) purely manual control activities; (2) manual control activities that rely on a system generated report; or (3) entirely automated controls. Each of these cat- egories is now described in detail in Module H.

∙ We increased our coverage of a commonly used form of reperformance testing referred to as the test data approach. When using this approach, the audi- tor will create a set of data to simulate a series of transactions that contain known errors in order to test whether the client’s IT control activity is operat- ing effectively. In the revised module, we included a commonly used example known as the test of one where auditors test a three-way match control in either the revenue or the purchasing process.

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Dawn P. Addington Central New Mexico Community College

Michael D. Akers Marquette University

Fatima Alali California State University–Fullerton

Sylvia Anderson University of Maryland University College

Jeffrey J. Archambault Marshall University

Jack Armitage University of Nebraska–Omaha

MaryAnne Atkinson Central Washington University

Dereck D. Barr The University of Mississippi

LuAnn Bean Florida Institute of Technology

Frank J. Beil University of Minnesota

Marie Blouin Penn State University–Harrisburg

David Blum Moraine Park Technical College

Russell F. Briner University of Texas at San Antonio

Alexander K. Buchholz Brooklyn College of the City University of New York

Suzanne M. Busch California State University–East Bay

Eric Carlsen Kean University

OUR SINCEREST THANKS . . . The American Institute of Certified Public Accountants (AICPA) has generously given permission for liberal quotations from official pronouncements and other AICPA publi- cations, all of which lend authoritative sources to the text. In addition, several publish- ing houses, professional associations, and accounting firms have granted permission to quote and extract from their copyrighted material. Their cooperation is much appreci- ated because a great amount of significant auditing thought exists in this wide variety of sources.

A special acknowledgment is due to the Association for Certified Fraud Examiners (ACFE). It has been a generous contributor to the fraud auditing material in this text. The authors also acknowledge the valuable inclusion of the educational version of IDEA software in the eighth edition, which significantly enhances the practical application of the book.

Also, the authors are particularly grateful to Ryan Dunn (Auburn University), Meghann Cefaratti (Northern Illinois University), Brad Roof (James Madison Univer- sity), and Yigal Rechtman (Pace University) for their many insightful comments over the past several years. The feedback they contributed while teaching from our text has contributed greatly to the clarity and accuracy of subsequent editions. A special thanks to Michael K. Shaub for his valuable critique of Chapter 5 and to Cristina Alberti for her input on Module H. In addition, thanks to Steven Dwyer, Suzanne McLaughlin, and Frank Wimer for the example developed to help explain the difference between general and application controls in Module H. Thanks to Helen Roybark for her help with the preparation of the instructor PowerPoint presentations and Joleen Kremin for her contri- bution to the Apollo Shoes, Inc. case.

We are sincerely grateful for the valuable input of all those who helped guide our developmental decisions for the past seven editions of Auditing & Assurance Services:

Acknowledgments

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Acknowledgements xxiii

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Meghann Cefaratti Northern Illinois University

John Critchett Madonna University

Karl Dahlberg Rutgers University

John E. Delaney Southwestern Texas University

Marcus Mason Doxey University of Kentucky

Raymond Elson Valdosta State University

Tom English Boise State University

Patricia Feller Nashville State Community College

Marilyn Fisher Corinthian Colleges

Diana R. Franz University of Toledo

John Gabelman Columbus State Community College

Clyde Galbraith West Chester University

Andy Garcia Bowling Green State University

David Gelb Seton Hall University

Earl Godfrey Gardner-Webb University

Judith G. Grant Northern Virginia Community College at Annandale

Emily Elaine Griffith The University of Georgia

Richard Hale Midway College

James Hansen University of Illinois at Chicago

Aretha Hill Florida A&M University

Steven C. Hunt Western Illinois University

Venkataraman Iyer The University of North Carolina at Greensboro

Keith Jones George Mason University

Bonita K. Peterson Kramer Montana State University–Bozeman

Joseph M. Larkin St. Joseph’s University

Rose Layton University of Southern California

Pamela Legner College of DuPage

Philip Levine Berkeley College

R. D. Licastro Penn State University–University Park

Maureen Mascha Marquette University

Dorothy McMullen Rider University

Heidi H. Meier Cleveland State University

Bharat Merchant Baruch College

Eddie Metrejean Georgia Southern University

Charles Miller California Polytech University

Perry Moore Lipscomb University

Fowler A. Murrell Lehman College

Ramesh Narasimhan Montclair State University

Vincent Owhoso Northern Kentucky University

Dwight M. Owsen Long Island University Brooklyn

Gary Peters University of Arkansas

Byron Pike Minnesota State University–Mankato

Marshall Pitman University of Texas–San Antonio

Sharon Polansky Texas A&M University–Corpus Christi

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In addition, we would like to recognize our outstanding staff at McGraw-Hill: Manag- ing Director, Tim Vertovec; Brand Manager, Elizabeth Eisenhart; Marketing Manager, Kate Wheeler; Core Product Developer, Erin Quinones; Assessment Product Developer, Allie Kukla; Content Project Managers, Mary Powers and Angela Norris; Buyer, Laura Fuller; and Designer, Matt Diamond. For their encouragement, assistance, and guidance in the production of this book, we are grateful.

Kathy Pollock Indiana University–Purdue University Fort Wayne

Duane Ponko Indiana University of Pennsylvania

Dwayne Powell Arkansas State University

Abdul Qastin North Carolina A&T State

Linda Quick University of South Carolina

Hema Rao SUNY–Oswego

Jason T. Rasso University of South Florida

Yigal Rechtman Pace University

Tracy Reed Appalachian State University

Barbara Reider University of Montana

Raymond Reisig Pace University

John Rigsby Mississippi State University

Pamela Roush University of Central Florida

Maria Sanchez Rider University

Kristen Kelli Saunders University of South Carolina

Tammi Schaefer University of South Carolina

Bunney L. Schmidt Utah Valley State College

Timothy Andrew Seidel University of Arkansas

Carol Shaver Louisiana Tech University

Jaysinha Shinde Eastern Illinois University

Adrianne Slaymaker Metropolitan State University

Duane Smith Brescia University

Beverly Strachan Troy University at Montgomery

Iris Stuart California State University

Christine N. Todd Colorado State University–Pueblo

John Trussel Penn State University–Harrisburg

Jerry L. Turner University of Memphis

Frank Venezia State University at Albany

Barbara Vinciguerra Moravian College

Bobby Waldrup University of North Florida

Rick Warne University of Cincinnati

J. Donald Warren Jr. Rutgers University

Christian Wurst Temple University

Tu Xu Georgia State University

Xu Zhaohui University of Houston–Clear Lake

Lin Zheng Northeastern Illinois University

Douglas Ziegenfuss Old Dominion University

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Acknowledgements xxv

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Few understand the enormous commitment of time and energy that it takes to put together a textbook. As authors, we are constantly scanning The Wall Street Journal and other news outlets for real-world examples to illustrate theoretical discussions, reread- ing and rewriting each other’s work to make sure that key concepts are understandable, and double-checking our solutions to end-of-chapter problems. Among the few who do understand the time and energy commitment are our family members (Barbara Louwers; Matt, Garrett, and Julianne Bagley; Kristin, Jackson, Elijah, Jonah, Ansley, and Laney Grace Blay; Susan and Meghan Strawser; and Ellen, Jenny, Eric, and Jessica Thibodeau) who uncomplainingly endured endless refrains of, “I just need a couple more minutes to finish this section.” Words cannot express our gratitude to each of them for their patience and unending support.

Tim Louwers

Pennie Bagley

Allen Blay

Jerry Strawser

Jay Thibodeau

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12. Reports on Audited Financial Statements 537

PART THREE Stand-Alone Modules

Please refer to pages xviii–xxiii for guidance on when to best integrate these modules.

A. Other Public Accounting Services 593 B. Professional Ethics 631 C. Legal Liability 679 D. Internal Audits, Governmental Audits, and

Fraud Examinations 721 E. Attributes Sampling 757 F. Variables Sampling 796 G. Data and Analytics in Auditing 845 H. Information Technology Auditing 881 INDEX 922

PART ONE The Contemporary Auditing Environment

1. Auditing and Assurance Services 1 2. Professional Standards 41

PART TWO The Financial Statement Audit

3. Engagement Planning and Audit Evidence 78

4. The Audit Risk Model and Inherent Risk Assessment 117

5. Risk Assessment: Internal Control Evaluation 172

6. Employee Fraud and the Audit of Cash 220 7. Revenue and Collection Cycle 269 8. Acquisition and Expenditure Cycle 328 9. The Production Cycle and Auditing

Inventory 389 10. Finance and Investment Cycle 443 11. Completing the Audit 499

Brief Contents

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Chapter 2 Professional Standards 41 Introduction 42 Generally Accepted Auditing Standards (GAAS) 44

Organization of GAAS 45 Fundamental Principle: Responsibilities 46

Competence and Capabilities 47 Independence and Due Care 47 Professional Skepticism and Professional

Judgment 49 Fundamental Principle: Performance 50

Reasonable Assurance 51 Planning and Supervision 51 Materiality 52 Risk Assessment 53 Audit Evidence 54

Fundamental Principle: Reporting  56 Evaluating the Quality of Public Accounting Firms’ Practices 59

System of Quality Control 59 PCAOB Inspection of Firms 61

Summary 63 Key Terms 64 Multiple-Choice Questions for Practice and Review 65 Exercises and Problems 69 Appendix 2A Referencing Professional Standards 76

PART TWO THE FINANCIAL STATEMENT AUDIT

Chapter 3 Engagement Planning and Audit Evidence Introduction 79 Pre-Engagement Activities 80

Client Acceptance or Continuance 80 Compliance with Independence and Ethical

Requirements 83 Engagement Letters 84

Audit Plan 85 Staffing the Audit Engagement 86 Time Budget 89

Materiality 91 Materiality Calculation 92

PART ONE THE CONTEMPORARY AUDITING ENVIRONMENT

Chapter 1 Auditing and Assurance Services User Demand for Reliable Information 2

Information Risk in a Big Data World 3 Auditing, Attestation, and Assurance Services 4

Definition of Financial Statement Auditing 5 Auditing in a Big Data Environment 6 Attestation Engagements 7 Assurance Services 8 Examples of Assurance Services 10

Management’s Financial Statement Assertions 11

Existence or Occurrence (Existence, Occurrence, Cutoff) 14

Completeness (Completeness, Cutoff) 14 Valuation and Allocation (Accuracy or

Valuation) 15 Rights and Obligations (Rights and

Obligations) 15 Presentation and Disclosure (Classification,

Understandability) 16 Importance of Assertions 16

Professional Skepticism 18 Public Accounting 21

Assurance Services 21 Tax Services 23 Advisory Services 23

Other Kinds of Engagements and Information Professionals 24

Internal Auditing 24 Governmental Auditing 25 Regulatory Auditors 26

Become a Professional and Get Certified! 26 Education 27 Examination 27 Experience 28 State Certificate and License 29 Skill Sets and Your Education 30

Summary 31 Key Terms 31 Multiple-Choice Questions for Practice and Review 32 Exercises and Problems 38

Contents

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Audit Team Brainstorming Discussions 144 Inquiry of Audit Committee, Management, and Others

within the Company 144 Overall Assessment and Documentation of Inherent Risk Assessment 145

Document Risk Assessment 146 Fraud and Other Significant Risks 146 Communication of Fraud Risks 147

Auditors’ Responsibilities for Client Noncompliance with Laws and Regulations 148 Audit Strategy Memorandum 150 Summary 151 Key Terms 152 Multiple-Choice Questions for Practice and Review 153 Exercises and Problems 157 Appendix 4A Selected Financial Ratios 168 Appendix 4B Sample Audit Memorandum 169

Chapter 5 Risk Assessment: Internal Control Evaluation Introduction 173 Internal Control Defined 174 Management Versus Auditors’ Responsibility for Internal Control 175

Management’s Internal Control Responsibilities 175 Auditors’ Internal Control Responsibilities 176

Components of Internal Control 178 Control Environment 179 Risk Assessment 181 Control Activities 182 Information and Communication 187 Monitoring 189 Limitations of Internal Control 190

Internal Control Evaluation 191 Phase 1: Understand and Document the Client’s Internal

Control 191 Phase 2: Assess the Control Risk (Preliminary) 197 Phase 3: Identify Controls to Test and Perform Tests of

Controls 199 Responsibilities in the Audits of Issuers Required by PCAOB Auditing Standard No. 2201 204

Requirements 204 Internal Control Communications 207 Summary 209 Key Terms 209 Multiple-Choice Questions for Practice and Review 211 Exercises and Problems 214 Appendix 5A Audit Plan 219

Audit Procedures for Obtaining Audit Evidence 94 1. Inspection of Records and Documents 96 2. Inspection of Tangible Assets 99 3. Observation 99 4. Inquiry 99 5. Confirmation 100 6. Recalculation 101 7. Reperformance 101 8. Analytical Procedures 101

Audit Documentation 103 Permanent Files 103 Current Files 104 Audit Documentation Arrangement and Indexing 105

Summary 107 Key Terms 108 Multiple-Choice Questions for Practice and Review 109 Exercises and Problems 113

Chapter 4 The Audit Risk Model and Inherent Risk Assessment Introduction 118 Audit Risk 118

Audit Risk 118 Inherent Risk 119 Control Risk 120 Detection Risk 120 Audit Risk Model 120

Fraud Risk 124 Fraud 126 Types of Fraud 127

Inherent Risk Assessment—“What Could Go Wrong?” 130

Understanding the Client’s Business and Its Environment 132

Industry, Regulatory, and Other External Factors 132

The Nature of the Company 133 Related Parties 134 Client Computerized Processing 134 Selection and Application of Accounting Principles,

Including Related Disclosures 135 Company Objectives, Strategies, and Related Business

Risks 136 Company Performance Measures 136

Gathering Information and Preliminary Analytical Procedures 137

General Business Sources 137 Company Sources 138 Information from Client Acceptance or Continuance

Evaluation, Audit Planning, Past Audits, and Other Engagements 138

Preliminary Analytical Procedures 138

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Internal Control Activities and Design Evaluation 281

Entity-Level Controls in the Revenue and Collections Cycle 281

Control Considerations at the Account and Assertion Level 282

Tests of Operating Effectiveness of Internal Control 284

Summary: Control Risk Assessment 287 Substantive Analytical Procedures and Tests of Details 288

Analytical Procedures 291 Confirmation of Accounts and Notes Receivable 291 Alternative Procedures 296 Additional Notes about Confirmations 297 Dual-Purpose Nature of Accounts Receivable

Confirmations 297 Review for Collectability  297 Cutoff and Sales Returns 298

Audit Risk Model Applied 300 Application in the Field 300 Audit Cases: Extended Audit Procedures 301 Summary 308 Key Terms 309 Multiple-Choice Questions for Practice and Review 309 Exercises and Problems 314 Appendix 7A Internal Control Questionnaires 324 Appendix 7B Audit Plan 326

Chapter 8 Acquisition and Expenditure Cycle Introduction 329 Acquisition and Expenditure Cycle: Typical Activities 330

Purchasing Goods and Services 330 Receiving the Goods or Services 333 Recording the Asset or Expense and Related

Liability 333 Significant Accounts and Relevant Assertions 333

Accounts Payable 334 Expenses 335

Risk of Material Misstatement 336 Internal Control Activities and Design Evaluation 338

Entity-Level Controls 338 Control Considerations 338 Custody 340 Periodic Reconciliation 340

Chapter 6 Employee Fraud and the Audit of Cash Introduction 221

Employee Fraud Overview 222 Employee Fraud Red Flags 223 Characteristics of Fraudsters 223

The Fraud Triangle 225 Incentive/Pressure 226 Opportunity 226 Attitude/Rationalization 227

Fraud Prevention 228 Managing People and Pressures in the Workplace 228 Internal Control Activities and Employee

Monitoring 229 Tone at the Top 231

The Audit of Cash 232 Management Reports and Data Files in an Audit of

Cash 233 Significant Accounts and Relevant Assertions 236 Risk of Material Misstatement 236 Evaluating the Design and Operating Effectiveness of

Internal Controls 237 Substantive Procedures 243

“Extended Procedures” to Detect Fraud 248 Summary 252 Key Terms 253 Multiple-Choice Questions for Practice and Review 254 Exercises and Problems 258 Appendix 6A Internal Control Questionnaires 266 Appendix 6B Audit Plans 268

Chapter 7 Revenue and Collection Cycle Introduction 270 Revenue and Collection Cycle: Typical Activities 271

Receiving and Processing Customer Orders, Including Credit Granting 272

Delivering Goods and Services to Customers 272 Billing Customers and Accounting for Accounts

Receivable 273 System Generated Reports and Data Files in the Revenue

and Collection Cycle 273 Significant Accounts and Relevant Assertions 276 Risk of Material Misstatement 277

Revenue Recognition 277 Collectability of Accounts Receivable 280 Customer Returns and Allowances 280

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Financing the Entity through Debt and Stockholder Equity 447

Financial Planning 447 Raising Capital 447 Investing Transactions: Investments

and Intangibles 450 Significant Accounts and Relevant Assertions 452 Risk of Material Misstatement 453

Complex Transactions 454 Fair Market Value 455 Related-Party Transactions 455 Lease Accounting 456 Loan Covenants 456 Impairments 457 Presentation and Disclosure 457

Internal Control Activities and Design Evaluation 458

Control Considerations 460 Tests of Operating Effectiveness of Internal Control 460

Control over Accounting Estimates 463 Authorization 464 Record Keeping 464 Custody 465 Summary: Control Risk Assessment 465

Substantive Analytical Procedures and Tests of Details 466

Auditing Accounting Estimates, including Fair Value Measurements 472

Long-Term Liabilities and Related Accounts 475 Stockholders’ Equity: Substantive Procedures 476 Auditing Stock-Based Compensation Plans 477

Fraud Cases: Extended Audit Procedures 478 Summary 482 Key Terms 483 Multiple-Choice Questions for Practice and Review 484 Exercises and Problems 487 Appendix 10A Internal Control Questionnaires 495 Appendix 10B Substantive Audit Plans 496

Chapter 11 Completing the Audit Introduction 500 Audit Timeline 501 Procedures Performed During Fieldwork 503

Completing Substantive Procedures 503 Attorney Letters 504 Written Representations 507 Ability to Continue as a Going Concern 509 Adjusting Entries and Financial Statement

Disclosure 510

Testing of Operating Effectiveness of Internal Control 341

Tests of Controls 341 Substantive Analytical Procedures and Tests of Details 344

Open Purchase Orders 346 Audit Risk Model Applied 352 Fraud Cases: Extended Audit Procedures 354 Audit Issues in the Expense and Acquisition Cycle 357 Summary 358 Key Terms 358 Multiple-Choice Questions for Practice and Review 359 Exercises and Problems 362 Appendix 8A Internal Control Questionnaires 372 Appendix 8B Audit Plans 375 Appendix 8C The Payroll Cycle 377

Chapter 9 The Production Cycle and Auditing Inventory Keeping Count 390 Inventory Management: Typical Activities 391 Significant Accounts and Relevant Assertions 395 Risk of Material Misstatement 396 Internal Control Activities and Design Evaluation 399 Testing of Operating Effectiveness of Internal Control 403 Substantive Analytical Procedures and Tests of Details 408

Difficult Inventory Circumstances 415 Audit Risk Model Applied 420

Fraud Case: Extended Audit Procedures (AS 2301) 421 Summary 422 Key Terms 424 Multiple-Choice Questions for Practice and Review 425 Exercises and Problems 428 Appendix 9A Internal Control Questionnaires 439 Appendix 9B Audit Plans 441

Chapter 10 Finance and Investment Cycle Introduction 444 Finance and Investment Cycle: Typical Activities 446

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PART THREE STAND-ALONE MODULES

MODULE A Other Public Accounting Services Introduction 594 Introduction to Attestation Engagements 595 Attestation Engagements: Special Audit Reporting Considerations 596

Special Purpose Frameworks 597 Specified Elements, Accounts, or Items 598 Compliance with Contractual Agreements or Regulatory

Requirements 599 Other Attestation Engagements 600

Applying Agreed-Upon Procedures 600 Prospective Financial Information 601 Compliance Attestation 604 Service Organizations 606 Other Attestation Engagements and Summary 608

Accounting and Review Services for Historical Financial Information 609

Review Engagements 609 Compilation Engagements 611 Preparation Engagements 612 Summary of Engagements on Historical Financial

Information 613 Assurance Services Engagements 614

Scope of Assurance Services 614 Trust Services 615 The Future of Assurance Services 617

Summary 617 Key Terms 618 Multiple-Choice Questions for Practice and Review 619 Exercises and Problems 623

MODULE B Professional Ethics Introduction 632 General Ethics 633 An Ethical Decision Process 634 Philosophical Principles in Ethics 635

The Imperative Principle 635 The Principle of Utilitarianism 637 The Generalization Argument 637 Virtue Ethics 637

Ethical Codes of Conduct 638 U.S. Securities and Exchange Commission

(SEC) 639 The Public Company Accounting Oversight Board

(PCAOB) 639 The International Federation of Accountants

(IFAC) 640

Audit Documentation Review 513 Subsequent Events and Subsequently Discovered Facts 514

Subsequent Events 515 Subsequently Discovered Facts 516

Responsibilities Following the Audit Report Release Date 518

Omitted Procedures 518 Communications with Individuals Charged with

Governance  518 Management Letter 520 Summary of Audit Communications 520

Summary 521 Key Terms 521 Multiple-Choice Questions for Practice and Review 522 Exercises, Problems, and Simulations 526

Chapter 12 Reports on Audited Financial Statements Introduction 538 Overview of Auditors’ Reports 539

The Standard Report for Non-Issuers 540 Types of Opinions 542

Conditions that Require Modifications to the Auditors’ Standard (Unmodified) Report 543

Departures from GAAP 543 Scope Limitations 546

Audits of Group Financial Statements 550 Auditors’ Reports Referencing Other Matters Encountered During the Audit 553

Consistency 553 “Going-Concern” Uncertainties 554 Other Information Included in Annual

Reports 555 Required Supplementary Information 556 Other Modifications 556 Summary: Emphasis-of-Matter and Other-Matter

Paragraphs 557 Other Reporting Topics 557

Comparative Financial Statements 558 Summary Financial Statements 560 Supplementary Information 561 Disclaimers of Opinion 561

Summary 562 Key Terms 564 Multiple-Choice Questions for Practice and Review 565 Exercises and Problems 568 Appendix 12A Auditors’ Reports for Issuers (Public Entities) 581

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The Changing Landscape of Auditors’ Liability 698 Sarbanes–Oxley 699 Racketeer Influenced and Corrupt Organizations Act 700 Aiding and Abetting 700 Organization of Accounting Firms as Limited Liability

Partnerships 701 Proportionate Liability 701 Class-Action Suits 702 Auditors’ Liability Caps 703 Other Developments 703

Summary 704 Key Terms 705 Multiple-Choice Questions for Practice and Review 706 Exercises and Problems 711

MODULE D  Internal Audits, Governmental Audits, and Fraud Examinations 721 Introduction 722 Internal Audits, Governmental Audits, and Fraud Examinations 722 Internal Audits 723

Internal Auditing Defined 723 Types of Internal Audit Services 725 Internal Audit Standards 728 Internal Audit Reports 729

Governmental Audits 730 Governmental Auditing Defined 730 Types of Governmental Audits 731 GAO Government Auditing Standards 733 GAO Audit Reports 734 Single Audit Act of 1984 and Amendments of 1996 735

Fraud Examinations 737 The Art of Fraud Examinations 739 Fraud Examiner Responsibilities 741 Building a Fraud Case 742 Protecting the Evidence 742 Obtaining Litigation Support 742

Summary 743 Key Terms 744 Multiple-Choice Questions for Practice and Review 745 Exercises and Problems 748

MODULE E Attributes Sampling 757 Introduction 758 Planning (Steps 1-3) 759

Step 1: Determine the Objective of Sampling 759 Step 2: Define the Characteristic of Interest 759 Step 3: Define the Population 760

Performing (Steps 4-6) 761 Step 4: Determine the Sample Size 761

The Professional Ethics Executive Committee (PEEC) of the American Institute of CPAs (AICPA) 640

An Emphasis on Independence 642 American Institute of Certified Public Accountants 642 SEC and PCAOB Independence Rules 649 Other Effects of Sarbanes–Oxley on Auditor

Independence 652 Government Accountability Office (GAO) Independence

Requirements 652 AICPA Rules of Conduct: Integrity and Objectivity, Responsibilities to Clients, and Other Responsibilities 653

Integrity and Objectivity Rule 653 General Standards Rule 654 Compliance with Standards Rule 655 Accounting Principles Rule 655 Confidential Client Information Rule 656 Fees and Other Types of Remuneration 658 Acts Discreditable Rule 660 Advertising and Other Forms of Solicitation Rule 660 Form of Organization and Name Rule 661

Consequences of Violating the Code of Professional Conduct 662

Self-Regulatory Discipline 663 Public Regulation Discipline 664

Summary 665 Key Terms 666 Multiple-Choice Questions for Practice and Review 666 Exercises and Problems 671

MODULE C Legal Liability 679 The Legal Environment 681 Liability Under Common Law 683

Liability to Clients 683 Liability to Third Parties 684 Liability for Compilation and Review Services 688

Liability Under Statutory Law 689 The Securities Act of 1933 (Securities Act) 690

Section 11: Civil Liability 690 Auditors’ Defenses under the Securities Act 691 Section 13: Statute of Limitations 692 Section 17: Antifraud 692 Section 24: Criminal Liability 692

The Securities Exchange Act of 1934 (Securities Exchange Act) 693

Section 10 and Rule 10(b)-5: Antifraud 693 Section 18: Civil Liability 694 Auditors’ Defenses under the Securities Exchange Act 695 Section 32: Criminal Liability 695 Foreign Corrupt Practices Act (FCPA) 696

Summary of Auditors’ Liability to Clients and Third Parties 697

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Risk Assessment Procedures 850 Tests of Controls 852 Substantive Analytical Procedures 853 Tests of Details 855

Conducting Audit Data Analytics 857 Plan the ADA 857 Access and Prepare the Data 858 Consider the Relevance and Reliability of the Data

Used 859 Perform the ADA 861 Evaluate the Results and Draw Conclusions 861

Documentation Requirements 862 Common Tools Used in ADA 863

Professional Skepticism in ADA 864 The Next Generation of Auditing 864

External Big Data 865 Artificial Intelligence 865 Distributed Ledger Technology 865

Summary 866 Key Terms 867 Multiple-Choice Questions for Practice and Review 868 Exercises and Problems 870

MODULE H Information Technology Auditing 881 Information Technology (IT) Systems 882 Reliance on IT Controls 884

Scoping the IT Audit Procedures 885 Types of IT Control Activities 886 General IT Controls 887 Automated Application Controls 893 Output Controls 896

Assessing Control Risk in an IT Environment 898 Testing Controls in an IT Environment 900 End-User Computing and Other Environments 903

End-User Computing Control Considerations 903 Service Organizations 905

Computer Abuse and Computer Fraud 906 Preventive, Detective, and Damage-Limiting

Controls 907 Computer Forensics 909

Summary 909 Key Terms 910 Multiple-Choice Questions for Practice and Review 911 Exercises and Problems 913

Index 922

Step 5: Select the Sample Items 767 Step 6: Measure the Sample Items 767

Evaluating Sample Results (Step 7) 768 Calculating the Upper Limit Rate of Deviation 768 Making the Evaluation Decision 770 Qualitative Evaluation of Deviations 771

Documenting 773 Other Attributes Sampling Methods 774 Summary 775 Key Terms 776 Multiple-Choice Questions for Practice and Review 777 Exercises and Problems 780 Appendix E.A AICPA Sample Size Tables 793 Appendix E.B AICPA Sample Evaluation Tables 795

MODULE F Variables Sampling 796 Introduction 797

Role of Variables Sampling in the Audit 797 Definition of Variables Sampling 797 Monetary Unit Sampling (MUS): Planning 798

Steps 1–3: Planning 799 MUS: Performing 800

Step 4: Determine the Sample Size 800 Step 5: Select the Sample Items 804 Step 6: Measure the Sample Items 805

MUS: Evaluating 806 Step 7: Evaluating Sample Results 806

Other Variables Sampling Approaches 811 Documentation in Variables Sampling 812

Summary 813 Key Terms 813 Multiple-Choice Questions for Practice and Review 815 Exercises and Problems 818 Appendix F.A AICPA MUS Tables 829 Appendix F.B Classical Variables Sampling 831 Appendix F.C Nonstatistical Sampling 842

MODULE G Data and Analytics in Auditing 845 Introduction 846 Audit of the Future 848

Data and Analytics 849 Common Uses of Audit Data Analytics 850

Auditing & Assurance Services

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LEARNING OBJECTIVES You are about to embark on a journey of understanding how auditors work to keep the capital markets safe and secure for the investing public. You should know that students demonstrate success in the auditing course quite differently from the way they do in other accounting courses. For example, when taking financial accounting, students typically demonstrate success by correctly identifying the proper journal entry for a given set of facts and circumstances. In auditing, success is typically demonstrated by completing multiple-choice, short- answer, and simulation-type questions based on the professional standards that regulate the auditing process. Overall, this book provides you with a comprehensive set of materials that will allow you

to master these professional auditing standards. Chapter 1 provides an introduction to the auditing and assurance profession.

Your objectives are to be able to

LO 1-1 Define information risk and explain how the financial statement auditing process helps to reduce this risk, thereby reducing the cost of capital for a company.

LO 1-2 Define and contrast financial statement auditing, attestation, and assurance services.

LO 1-3 Describe and define the assertions that management makes about the recognition, measurement, presentation, and disclosure of the financial statements and explain why auditors use them as the focal point of the audit.

Doty, James R. Keynote Address: The Reliability, Role and Relevance of the Audit: A Turning Point. New York: Public Company Accounting Oversight Board, 2011.

Our system of capital formation relies upon the confidence of millions of

savers to invest in companies. The auditor’s opinion is critical to that trust.

Auditing and Assurance Services

C H A P T E R 1

Professional Standards References

Topic AU-C/ISA Section

AS Section

Overall Objectives of the Independent Auditor  200 1001 1005 1010 1015

Consideration of Fraud in a Financial Statement Audit 240 2401

Audit Evidence 500 1105

Attestation Standards AT 101 AT 101

Compliance Auditing Considerations in Audits of Recipients of Governmental Financial Assistance 935 6110

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USER DEMAND FOR RELIABLE INFORMATION When seeking capital to grow their business, management has an incentive to present their company’s financial statements and future prospects in a manner that will entice potential investors and creditors. As a result, it is essential that investors and creditors have assurance that they can rely on the information provided by management, which creates demand for the financial statement audit. If only investors in Theranos, a blood-testing startup company, had asked for an independent audit report. In March 2018, the Securi- ties and Exchange Commission (SEC) settled massive fraud charges against Theranos and their president, Sunny Balwani. The SEC’s complaint alleged that the materials provided to potential investors included a company overview, reports of clinical trials, and financial statement information and projections. However, the package did not include an indepen- dent audit report. Unfortunately the company, which was valued as high as $9 billion by investors back in 2009, barely had enough cash to pay the bills just five years later.1 This example helps to reinforce why it is so important for investors and creditors to review audited financial statements as they consider whether to invest or loan money to a com- pany. It also helps to explain why audit quality is so important to investors and creditors.

You may be asking, why is audit quality so important? Well, as we have just seen, both investors and creditors depend on reliable financial statement information to make their investment and lending decisions about a company. As a result, the confidence of investors and creditors is shaken each and every time that audit quality is compromised. To help ensure that audit quality is not compromised, the Sarbanes–Oxley Act of 2002 created the Public Company Accounting Oversight Board (PCAOB) to regulate the audit profession for public companies. In fact, the PCAOB is responsible for setting all audit standards to be followed on audits of public companies. In addition, the PCAOB is required to perform inspections of the audit work completed and the quality control pro- cesses employed by audit firms. As a direct result, accounting students should know that if they plan to work as financial statement auditors, they will be entering a world that is focused on audit quality. Consider the following Auditing Insight.

LO 1-1 Define information risk and explain how the financial statement auditing process helps to reduce this risk, thereby reducing the cost of capital for a company.

1https://www.marketwatch.com/story/the-investors-duped-by-the-theranos-fraud-never-asked-for-one-important- thing-2018-03-19

In January 2019, KPMG published its report on audit quality for 2018. In the report, the firm’s leaders affirmed their responsibility to the investing public for instilling confidence in the capital mar- kets. The key drivers of the firm’s audit quality efforts include a strong system of quality control, including the establishment of a firm culture with an unrelenting focus on delivering high quality audits. In addition, and perhaps most importantly, the report high- lighted the importance of developing its people and its investment

in the audit of the future. The report specifically discussed the firm’s investment in cognitive technologies such as IBM’s Wat- son and the importance of harnessing the emerging power of Big Data. The report is a clear indication to students that quality matters more than anything else in their future work as auditing professionals.

Source: https://home.kpmg/content/dam/kpmg/us/pdf/2019/01/progress- through-change-kpmg-2018-audit-quality-report.pdf?n=3.

Audit QualityAUDITING INSIGHT

LO 1-4 Define professional skepticism and explain its key characteristics.

LO 1-5 Describe the organization of public accounting firms and identify the various services that they offer.

LO 1-6 Describe the audits and auditors in governmental, internal, and operational auditing.

LO 1-7 List and explain the requirements for becoming a certified public accountant (CPA) and other certifications available to an accounting professional.

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Before we think about audit quality any further, we must first explain the vital role that financial statement auditors play in supplying key decision makers with useful, under- standable, and timely information. When you have a better understanding of why audit- ing is so critical to help ensure the liquidity of the world’s capital markets, we will then explore in detail the process auditors take to help ensure that audit quality is achieved. Because many of you are likely planning to enter the public accounting profession and work as an auditor, we hope that you will work hard to acquire this knowledge so that you may do your part in playing a key role in maintaining the public’s confidence in both the auditing profession and the capital markets.

Information Risk in a Big Data World All businesses make a countless number of decisions each and every day. Decisions to purchase or sell goods or services, lend money, enter into employment agreements, or buy or sell investments depend in large part on the quality of useful information. These decisions affect business risk, which is the risk that an entity will fail to meet its objec- tives. For example, business risk includes the chance a company takes that customers will buy from competitors, that product lines will become obsolete, that taxes will increase, that government contracts will be lost, or that employees will go on strike. If the company fails to meet its objectives enough times, the company may ultimately fail. To minimize these risks and take advantage of other opportunities presented in today’s competitive business environment, decision makers such as chief executive officers (CEOs) demand timely, relevant, and reliable information. Similarly, investors and creditors demand high- quality information to make educated financial decisions. Information professionals such as accountants and auditors help satisfy this demand.

In recent years, as a result of ever-increasing computing power, the decision-making environment is rapidly being transformed into one that is characterized by the availability of significant amounts of data and information. Let’s face it, the amount of informa- tion that organizations are seeking to manage is larger than anyone could have possibly imagined just 10 years ago. You are entering a world where upper management teams are placing more emphasis than ever on how to make sense of this seemingly ever-increasing availability of data and information. To help you prepare for this “big data” challenge, we will be drawing upon this theme in multiple chapters throughout this book.

There are at least four environmental conditions in this big data world that increase user demand for relevant and reliable information:

1. Complexity. Events and transactions in today’s global business environment are numer- ous and often very complicated. You may have studied derivative securities and hedging activities in other accounting courses, but investors and other decision makers may not have your level of expertise when dealing with these complex transactions. Furthermore, these decision makers are not trained to collect, compile, and summarize the key operat- ing information themselves. They need the services provided by information profession- als to help make the information more understandable for their decision processes.

2. Remoteness. Decision makers are usually separated from current and potential business partners not only by a lack of expertise but also by distance and time. Investors may not be able to visit distant locations to check up on their investments. They need to employ full-time information professionals to do the work they cannot do for themselves.

3. Time sensitivity. Today’s economic environment requires businesses, investors, and other financial information users to make decisions more rapidly than ever before. The ability to promptly obtain high-quality information is essential to businesses that want to remain competitive in our global business environment.

4. Consequences. Decisions can involve a significant investment of resources. The con- sequences are so important that reliable information, obtained and verified by infor- mation professionals, is an absolute necessity. Enron’s aftermath provides a graphic example of how decisions affect individuals’ (as well as companies’) financial secu- rity and well-being. Enron’s stock dropped from $90 to $0.90 in little more than a year, leaving employees who had invested their life savings in the company virtually

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penniless. To put this drop in perspective, an investor’s $5 million investment in Enron stock in 2000 (enough for an enjoyable retirement) was worth only $50,000 a year later.

A further complication in effective decision making is the presence of information risk. Information risk is the probability that the information circulated by a company will be false or misleading. Decision makers usually obtain their information from companies or organizations they want to conduct business with, provide loans to, or engage with in buy- ing or selling the company’s stock. Because the primary source of information is the target company itself, an incentive exists for that company’s management to make its business or service appear to be better than it actually is, to put its best foot forward. As a result, preparers and issuers of financial information (directors, managers, accountants, and other people employed in a business) might benefit by giving false, misleading, or overly opti- mistic information. This potential conflict of interest between information providers and users, along with financial statement frauds such as those of Enron and WorldCom, leads to a natural skepticism on the part of users. Thus, they depend on information profession- als to serve as independent and objective intermediaries who will lend credibility to the information. This lending of credibility to information is known as providing assurance. When the assurance is provided for specific assertions made by management, we refer to the assurance provided as attestation. When the assertions are embodied in a company’s financial statements, we refer to the attestation as auditing. More specifically, when their work is completed, the auditors supply an opinion as to whether the financial statements and related footnotes are presented fairly in all material respects. The actual compilation and creation of the financial statements is completed by the company’s accountants.

Bernard Madoff, a former chairman of the NASDAQ stock market and a respected Wall Street adviser and broker for 50 years, was arrested after his sons turned him in for running “a giant Ponzi scheme,” bilking investors out of billions of dollars. Many investors, including actors, investment bankers, politicians, and sports personalities, lost their life savings. Some who had already retired, now in their 70s and 80s, were forced to go back to work. Others lost their retirement homes. Charities and pensions that had invested heavily were wiped out.

Although some of the world’s most knowledgeable investors fell prey to the scam, numerous red flags were present for all who were wise enough to see them. First, Madoff’s fund returned 13–16 percent per year, every year, no matter how the markets performed. Second,

his stated strategy of buying stocks and related options to hedge downside risk could not have occurred because the number of options necessary for such a strategy did not exist. Third, although his firm claimed to manage billions of dollars, its auditing firm had only three employees, including a secretary and a 78-year-old accountant who lived in Florida.

Sources: “Fund Fraud Hits Big Names,” The Wall Street Journal, December 13, 2008, pp. A1, A7; “Fees, Even Returns and Auditor All Raised Flags,” The Wall Street Journal, December 13, 2008, p. A7; “Top Broker Accused of $50 Billion Fraud,” The Wall Street Journal, December 12, 2008, pp. A1, A14; “Probe Eyes Audit Files, Role of Aide to Madoff,” The Wall Street Journal, December 23, 2008, pp. A1, A14.

The Consequences of Fraudulent Financial Information

AUDITING INSIGHT

REVIEW CHECKPOINTS 1.1 What is a business risk? 1.2 What conditions increase the demand for reliable information? 1.3 What risk creates a demand for independent and objective outsiders to provide assurance to

decision makers?

AUDITING, ATTESTATION, AND ASSURANCE SERVICES Now that you understand why decision makers need independent information profession- als to provide assurance on key information, we further define auditing and expand the discussion of attestation and assurance services in this section, and explain their roles in today’s information economy.

LO 1-2 Define and contrast financial statement auditing, attestation, and assurance services.

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Definition of Financial Statement Auditing The focus of this book is on the financial statement auditing process, by far and away the most common type of auditing and assurance service provided in today’s market. Many years ago, the American Accounting Association (AAA) Committee on Basic Auditing Concepts provided a very useful general definition of auditing as follows:

Auditing is a systematic process of objectively obtaining and evaluating evidence regard- ing assertions about economic actions and events to ascertain the degree of correspon- dence between the assertions and established criteria and communicating the results to interested users.2

A closer look at the definition reveals several ideas that are important to any type of auditing engagement. Auditing is a systematic process. It is a purposeful and logical pro- cess and is based on the discipline of a structured approach to reaching final decisions. It has a logical starting point, proceeds along established guidelines, and has a logical conclusion. It is not haphazard, unplanned, or unstructured.

The process involves obtaining and evaluating evidence. Evidence consists of all types of information that ultimately guide auditors’ decisions and relate to assertions made by management about economic actions and events. When beginning a financial statement audit engagement, an independent auditor is provided with financial statements and other disclosures by management. In doing so, management essentially makes assertions about the financial statement balances (that the inventory on the balance sheet really does exist, that revenue transactions recorded on the income statement really did occur, that the list of liabilities on the balance sheet is complete, etc.) as well as assertions that the financial statement disclosures are fairly presented.

2American Accounting Association Committee on Basic Auditing Concepts. A Statement of Basic Auditing Concepts. American Accounting Association, 1973.

Although most of the largest public accounting firms trace their roots to the turn of the 19th century, auditing in the United States has a rich history. When the Pilgrims had a financial dispute with the English investors who financed their trip, an “auditor” was sent to resolve the difference. George Washington sent his financial records to the Comptroller of the Treasury to be audited before he could be reimbursed for expenditures he made during the Revolutionary War. One of the first Congress’s actions in 1789 was to set up an auditor

to review and certify public accounts. Even the “modern” concept of an audit committee is not so modern; the bylaws of the Potomac Company, formed in 1784 to construct locks on the Potomac River to increase commerce, required that three shareholders annually examine the company’s records. Flesher, Dale L., Gary John Previts, and William D. Samson. Auditing in the United States: A Historical Perspective. Abacus 41, John Wiley & Sons. Inc., 2008, 21–39.

AUDITING INSIGHT

External auditors generally begin their work with a focus on these assertions (explicit representations) made by management about the financial statement amounts and infor- mation disclosed in footnotes, and then they set out to obtain and evaluate evidence to prove or disprove these assertions or representations. Other types of auditors, however, often are not provided with explicit representations. For example, an internal auditor may be assigned to evaluate the cost effectiveness of the company’s policy to lease, rather than to purchase, heavy equipment. A governmental auditor may be assigned to determine whether goals of providing equal educational opportunities to all have been achieved with federal grant funds. Oftentimes, the latter two types of auditors must develop the explicit performance criteria or benchmarks for themselves.

The purpose of obtaining and evaluating evidence is to ascertain the degree of cor- respondence between the assertions made by the information provider and the estab- lished criteria. Auditors will ultimately communicate their findings to interested users.

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To communicate in an efficient and understandable manner, auditors and users must have a common basis for measuring and describing financial information. This basis is the established criteria essential for effective communication.

Established criteria may be found in a variety of sources. For independent auditors, the criterion is whatever the applicable financial reporting framework is, whether it is Gener- ally Accepted Accounting Principles (GAAP) in the United States or International Financial Reporting Standards (IFRS) in other jurisdictions. Internal Revenue Service (IRS) auditors rely heavily on criteria specified in the Internal Revenue Code. Governmental auditors may rely on criteria established in legislation or regulatory agency rules. Bank examiners and state insurance board auditors look to definitions, regulations, and rules of law. Internal and governmental auditors rely a great deal on financial and managerial models of efficiency and effectiveness. Of course, all auditors rely to some extent on the sometimes elusive criteria of general truth and fairness. Exhibit 1.1 depicts an overview of financial statement auditing.

The AAA definition already presented is broad and general enough to encompass external, internal, and governmental auditing. The more specific viewpoint of external auditors in public accounting practice is reflected in the following statement about the financial statement audit made by the American Institute of Certified Public Accountants (AICPA), the public accounting community’s professional association:

The purpose of an audit is to enhance the degree of confidence that intended users can place in the financial statements. This is achieved by the expression of an opinion by the auditor on whether the financial statements are prepared, in all material respects, in accor- dance with an applicable financial reporting framework. In the case of most general pur- pose frameworks, that opinion is on whether the financial statements are presented fairly, in all material respects, in accordance with the framework. An audit conducted in accordance with generally accepted auditing standards and relevant ethical requirements enables the auditor to form that opinion.* (AU-C 200.11)

Auditing in a Big Data Environment The auditing environment has been transformed into an environment that is characterized by the availability of significant amounts of data and cutting-edge analytical tools. As a direct result, entry-level professionals are being asked to join public accounting firms

EXHIBIT 1.1 Overview of Financial Statement Auditing

Other Communications

Independent Auditor

Objective third party

Obtains and evaluates evidence

Management assertions about economic actions and events

Ascertain degree of correspondence between financial statements and framework

Applicable financial reporting framework

Knowledge of client’s business, observation of physical assets, inquiry of managers, confirmations from third parties, inspection of documents

GAAP IFRS

Footnotes

Statement of Cash Flows

Income Statement

Balance Sheet

Audit Report

American Institute of Certified Public Accountants, Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance With Generally Accepted Auditing Standards, December 15, 2012, https://www.aicpa.org

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having completed coursework related to the use of data and analytical tools. The accom- panying Auditing Insight provides some examples.

A report published by PwC, “Data Driven: What Students Need to Suc- ceed in a Rapidly Changing Business World,” clearly indicates that the skills needed by entry-level auditing professionals must include profi- ciency in data analytics and technology.

But, the need for a digital mindset is hardly limited to entry-level professionals, and in 2018, PwC introduced a first of its kind app to help facilitate what they are calling a “Digital Workforce Transform- ation.” The app is designed to assess an individual’s digital fluency. Once the assessment is complete, the app then helps to “curate” training based on the individual’s needs.

It is now obvious that the world has changed and as a result the set of skills acquired by students must also change to adapt to the new digital world. Most importantly, while PwC is just one firm, our conversations with professionals across firms of varying size are in agreement with the need for a digital mindset to effectively operate in an audit environment characterized by Big Data and advanced analyti- cal tools.

Sources: “Data Driven—What Students Need to Succeed in a Rapidly Chang- ing Business World,” PwC, February 2015; https://www.pwc.com/us/en/press- releases/2018/digital-workforce-transformation.html.

Is there Really an “APP” for that?AUDITING INSIGHT

Among the critical issues for students to consider is how to identify the right set of data to analyze given a set of facts and circumstances. And, of course, how to present that analyses of such data in the most compelling format while documenting the results of their work. In addition, while analytical tools can rely on data sources that are both internal and external to the client, our current understanding is that entry-level audit pro- fessionals in today’s environment need to first learn how to make the best use of internal data and information produced by the entity, including system generated reports used by the client to execute its internal control activities and produce its financial statements.

Throughout this book, we will be providing examples of how to make the best use of such internal client data, which includes an emphasis on always verifying the complete- ness and accuracy of the underlying data set being used. There is even an entire module (Module G) that is dedicated to the use of Big Data and advanced analytical tools in the financial statement audit.

Attestation Engagements Many people appreciate the value of auditors’ attestations on historical financial state- ments, and as a result, they have found other types of information to which certified public accountants (CPAs) can attest. The all-inclusive definition of an attestation engagement is

An engagement in which a practitioner is engaged to issue a report on subject matter, or an assertion about subject matter that is the responsibility of another party.* (AT 101.01)

By comparing the AAA’s earlier definition of auditing with the definition of attesta- tion, you can see that the auditing definition is a specific type of attestation engagement. According to the earlier definition, in an audit engagement, an auditor (more specific than a practitioner) issues a report on assertions (financial statements) that are the responsibil- ity of management. For example, as more and more companies and organizations seek to demonstrate their efforts related to corporate social responsibility, demand is growing for attestation services related to sustainability reporting. The following Auditing Insight indicates the significance of this emerging market for public accounting firms.

In today’s global business environment, activist shareholders are increasingly pressur- ing board of director members and upper management teams regarding issues of social responsibility, the environment, and other matters related to sustainability. As a direct result, more companies than ever are directly integrating their sustainability initiatives into their overall business strategy and then seeking to quantify their sustainability and

American Institute of Certified Public Accountants, Attest Engagements, June 1, 2001, https://www.aicpa.org

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social responsibility efforts with measurable outputs. These measurements might help to quantify the company’s performance in areas such as the environment, labor, and human rights. For example, in the following Auditing Insight, students can see how BlackRock, Inc. on of the world’s largest asset managers, has recently toughened their standards related to climate change and environmental risk reporting for the corporations in their investment portfolio.

That is the clear message being sent by BlackRock, Inc. Indeed, the firm has made clear that it intends to take a much tougher stance against corporations that are unwilling to provide a “full accounting” of the envi- ronmental risks that they are facing in their business operations. In tak- ing these steps, BlackRock seeks to show the marketplace that they are doing what they can in relation to climate change. Of course, it is an open

question just how much influence BlackRock can have over companies, but their chief executive, Laurence Fink clearly believes that by doing so, he will position his firm to “win over younger investors and millennials whow want to invest money in line with personal values.”

Source: “BlackRock Tightens Standards for Firms On Climate Change.” Wall Street Journal, Wednesday January 15, 2020, Page B1.

Climate Change Does Matter!AUDITING INSIGHT

• Agreed-Upon Procedures Engagements (AT-C Section 215), such as verifying inventory quantities and locations.

• Prospective Financial Information (AT-C Section 305), such as analy- sis of prospective or hypothetical “what-if” financial statements for some time period in the future.

• Reporting on Pro Forma Financial Information (AT-C Section 310), such as retroactively analyzing the effect of a proposed or consum- mated transaction on the historical financial statements “as if” that transaction had already occurred.

• Compliance Attestation (AT-C Section 315), such as ascertaining a client’s compliance with debt covenants.

• Reporting on Controls at a Service Organization (AT-C Section 320), such as organizations that provide outsourced processes that are likely to be relevant to the user entities’ internal control over financial reporting.

• Examination of Management’s Discussion and Analysis (AT-C Sec- tion 395), prepared pursuant to the rules and regulations of the Secur- ities and Exchange Commission (SEC).

Examples of Attestation Engagements

On November 20, 2018, Tim Mohin, the CEO of the Global Reporting Ini- tiative (GRI) was invited to ring the closing bell at NASDAQ. Why does this matter? Well, since GRI is a nonprofit organization that was established to promote environmental sustainability to organizations throughout the world, NASDAQ’s invitation recognizes the growing importance of listed companies reporting on their environmental, social, and governance impacts. And of course, it helps to clearly demonstrate that sustainability

reporting is an emerging market for CPAs. In fact, KPMG LLP reported that as of the end of 2017, 93 percent of the 250 largest global compa- nies issue some type of corporate responsibility report.

Sources: https://www.globalreporting.org/information/news-and-press-center/ Pages/GRI-Rings-Bell-at-Nasdaq-November-2018.aspx; https://assets.kpmg/ content/dam/kpmg/xx/pdf/2017/10/kpmg-survey-of-corporate-responsibility- reporting-2017.pdf

Ringing The Bell At NASDAQAUDITING INSIGHT

Of course, whenever a management team makes an assertion about information, there is an opportunity to perform an attestation engagement. Importantly, although sustain- ability is a prominent example of an emerging attestation engagement completed by CPAs, other examples of attestation engagements completed by CPAs (discussed more in Module A) appear in the following box.

Assurance Services Although auditing refers specifically to expressing an opinion on financial statements and attestation refers more generally to expressing an opinion on any type of information or subject matter that is the responsibility of another party (such as sustainability measures),

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assurance services include an even broader set of information, including nonfinancial information. The following Auditing Insight indicates how the quality of information can assist both buyers and sellers in today’s market.

Exhibit 1.2 shows two 1961 Topps Mickey Mantle baseball cards. The card on the right was offered on eBay with the seller’s representation that the card was in Near Mint/Mint condition. This representation is a standard description and is the equivalent of a grade 8 on a standard 10-point scale used in grading the quality of a trading card. The card was purchased on eBay for $205.50.

Within a week, a second 1961 Topps Mickey Mantle baseball card was sold on eBay. Again, this card was offered with the seller’s representation that the card was in Near Mint/Mint condition (card on the left). The only difference was that this card had been sent to Professional Sports Authenticator (PSA), a company that verifies the authenticity and quality of sports items. Note that PSA does not buy or sell sports merchandise; it acts only as an independent third party expressing a professional opinion regarding the merchandise in ques- tion. This card sold for $585.

The only difference between the two transactions was that the buyers of the card on the left had more information concerning the risk inherent in the transaction. Why was the first transaction riskier? What were the buyers’ concerns? Were the concerns only from inten- tional misstatements? How did the grading of the card by PSA reduce these concerns? What are the incentives for PSA to grade the card

accurately? How does the business of PSA relate to the profession of auditing?

AUDITING INSIGHT

EXHIBIT 1.2 Professional Sports Authenticator as Third-Party Assuror

Courtesy of Allen Blay

Although the primary focus of our earlier discussion of information risk was in the context of economic decisions, information risk is present whenever someone must make a decision without having complete knowledge. The AICPA expanded the profes- sion’s traditional focus on accounting information to include all types of information, both financial and nonfinancial. The expanded services are collectively referred to as assurance services, which the AICPA defines as independent professional services that improve the quality of information, or its context, for decision makers. The major ele- ments, and boundaries, of the definition are

∙ Independence. CPAs want to preserve their attestation and audit reputations and com- petitive advantages by preserving integrity and objectivity when performing assurance services.3

∙ Professional services. Virtually all work performed by CPAs (accounting, auditing, data management, taxation, management, marketing, finance) is defined as a profes- sional service as long as it involves some element of judgment based on education and experience.

∙ Improving the quality of information or its context. The emphasis is on infor- mation, CPAs’ traditional stock in trade. CPAs can enhance quality by assuring

3A survey commissioned by the AICPA found that CPAs are viewed more positively than any other business professional by both business decision makers and investors. Sixty-nine percent of investors and 74 percent of business decision makers feel that “CPAs have a unique perspective that is valuable when making business and financial decisions, even when those decisions are not directly related to accounting.” In terms of attributes ascribed to CPAs, they are most associated with integrity, competence, and objectivity (“Brand Research Shows CPAs Viewed Positively in Marketplace,” AICPA News Update, October 20, 2008).

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users about the reliability and relevance of information, and these two features are closely related to the familiar credibility-lending products of attestation and auditing services. Context is relevance in a different light. For assurance services, improving the context of information refers not to the information itself but to how the information is used in a decision-making context. An example would be providing key information in a database that management could use to make impor- tant decisions.

∙ For decision makers. The decision makers are the consumers of assurance services, and they personify the consumer focus of different types of professional work. The decision makers are the beneficiaries of the assurance services. Depending upon the assignment, decision makers may be a very small, targeted group (e.g., managers of a database) or a large targeted group (e.g., potential investors interested in a mutual fund manager’s performance).

Examples of Assurance Services Although they are subsets of assurance services, attestation and auditing services are highly structured and intended to be useful for large groups of decision makers (e.g., investors, lenders). On the other hand, assurance services other than audit and attestation services tend to be more customized for use by smaller, targeted groups of decision mak- ers. For example, many companies and organizations have used public accounting firms to conduct a comprehensive assessment of risks the enterprise faces. This type of enter- prise risk assessment can then be used to show stakeholders that the management team understands and is properly managing risks the enterprise faces. We also present a few more examples of assurance services to illustrate the variety of services that fall under the assurance service umbrella. Some will look familiar and others may defy imagination. Be aware, however, that public accounting firms must pick and choose the services that they wish to provide to the market based on the expertise that resides within the firm. Nobody believes or maintains that all public accounting firms will want or be able to provide all types of assurance services.

∙ Cybersecurity risk assessment and assurance. ∙ XBRL (eXtensible Business Reporting Language) reporting. ∙ Information risk assessment and assurance. ∙ Regulatory compliance. ∙ Third-party reimbursement maximization. ∙ Customer satisfaction surveys. ∙ Evaluation of investment management policies. ∙ Fraud and illegal acts prevention and deterrence. ∙ Internal audit outsourcing.

Attestation and financial statement auditing services are special types of assurance services, but consulting services are not. In providing consulting services, CPAs use their professional skills and experiences to provide recommendations to a client for outcomes such as information system design and operation; in assurance services, the focus is entirely on the information that decision makers use. However, like consulting services, assurance services do have a “customer focus,” and CPAs develop assurance services that add value for customers (i.e., decision makers). Exhibit 1.3 depicts the relationships among assurance, attestation, and auditing services.

Although audits are specific types of assurance engagements and auditors can be described more generally as information assurors, hereafter we will use the term audi- tor instead of information assuror because of the specific responsibilities that auditors have under generally accepted accounting standards (GAAS) as well as under regulatory bodies such as the Securities and Exchange Commission (SEC) and the Public Company Accounting Oversight Board (PCAOB). However, many of the procedures that auditors

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perform as part of an audit engagement are similar to those performed as part of other information assurance engagements. Throughout this book, we will point out these shared procedures when appropriate.

EXHIBIT 1.3 The Relationships among Audit, Attestation, and Assurance Engagements

Assurance Engagements

Attestation Engagements

Audit Engagements

Advances in information technology have allowed for more efficient reporting platforms that better meet the needs of decision makers. In that spirit, the AICPA is currently focused on a number of initiatives to help auditors meet the needs of their clients. Among the initiatives, the need to help companies with XBRL implementations for SEC reporting has taken center stage. XBRL (also referred to by the SEC as interac- tive data) is an information format designed specifically for business reporting. Through the “tagging” of specific data items (cash, inven- tory, sales transactions, etc.), XBRL facilitates the collection, summa- rization, and reporting of financial information in a medium that users

can easily transform for their own decision-making purposes. The SEC now requires all U.S. public companies and foreign private issuers listed with the SEC to use XBRL for SEC filings. Recently, the AICPA helped to launch the XBRL U.S. Center for Data Quality in an attempt to improve the utility of XBRL financial data filed with the SEC even more.

Sources: AICPA SOP 13-02, “Performing Agreed-Upon Procedures Engage- ments That Address the Completeness, Mapping Consistency, or Structure of XBRL-Formatted Information”; SEC 2009 Release No. 33-9002, “Interactive Data to Improve Financial Reporting”; “XBRL US Center for Data Quality.” All three are available through the AICPA’s website (www.aicpa.org).

XBRL ReportingAUDITING INSIGHT

REVIEW CHECKPOINTS 1.4 Define and explain auditing. What would you answer if asked by a communications major, “What do

auditors do?” 1.5 What is an attestation engagement? 1.6 What is an assurance service engagement? 1.7 In what ways are assurance services similar to attestation services (including audits of financial

statements)? 1.8 What are the four major elements of the broad definition of assurance services?

MANAGEMENT’S FINANCIAL STATEMENT ASSERTIONS From your earlier studies, you know that accounting is the process of recording, classify- ing, and summarizing a company’s transactions into financial statements that will create assets, liabilities, equities, revenues, expenses, and related disclosures. It is the means of satisfying users’ demands for financial information that arise from the forces of complex- ity, remoteness, time sensitivity, and consequences.

Auditing does not include the function of producing financial reports. The function of financial reporting is to provide statements of financial position (balance sheets), results of operations (income statements, statements of shareholders’ equity, and statements of

LO 1-3 Describe and define the assertions that management make about the recognition, measurement, presentation, and disclosure of the financial statements and explain why auditors use them as the focal point of the audit.

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comprehensive income), changes in cash flows (statements of cash flows), and accom- panying disclosures to outside decision makers who do not have access to management’s internal sources of information. A company’s accountants, under the direction of its management team, perform this function. In fact, auditing standards emphasize that the financial statements are the responsibility of a company’s management. Thus, the finan- cial statements contain management’s assertions about the transactions and events that occurred during the period being audited (primarily the income statement, statement of shareholders’ equity, statement of comprehensive income, and statement of cash flows), assertions about the account balances at the end of the period (primarily the balance sheet), and assertions about the financial statement presentation and disclosure (primar- ily the footnote disclosures).

As the Auditing Insight about Sarbanes–Oxley makes clear, the upper management team at public companies must certify the correctness of the financial statements and the effectiveness of the internal control system for financial reporting. Given the current focus on internal controls, entry-level audit professionals are expected to understand the relationship between a company’s internal control activities and the relevant financial statement assertions about the financial statement account balances. We suggest that as a new auditing professional, a detailed understanding of this relationship will provide you with the opportunity to immediately contribute to the audit team. As a result, we are hopeful that this book can provide a foundation of knowledge to help simplify the rela- tionship, which is paramount in the post-Sarbanes–Oxley auditing environment.

Congress passed the Sarbanes–Oxley Act in 2002 in an attempt to address a number of weaknesses found in corporate financial reporting as a result of the frauds at companies such as WorldCom and Enron. Although the preparation of the financial statements has always been the responsibility of management, Sarbanes–Oxley has enhanced the disclosure provisions to create a heightened sense of accountability. One of its most important provisions (Section 302) states that key company officials must certify the financial statements. Certification means that the company’s chief execu- tive officer and chief financial officer must sign a statement indicating

1. They have read the financial statements. 2. They are not aware of any false or misleading statements (or any

key omitted disclosures).

3. They believe that the financial statements present an accurate pic- ture of the company’s financial condition.

Management must also make assertions regarding the effectiveness of the company’s internal controls over financial reporting. In addition, the auditors are required to issue an attestation report (Section 404) on the system of internal controls to provide assurance that the sys- tem of internal controls over financial reporting has been designed and is operating effectively.

Source: U.S. Congress, Sarbanes–Oxley Act of 2002, Pub. L. No. 107-204, 116 Stat. 745 (2002).

Sarbanes–Oxley and Management’s Responsibility for Financial Reporting

AUDITING INSIGHT

When planning the audit engagement, auditors use management’s assertions to assess external financial reporting risks by determining the different types of misstatements that could occur for each of the relevant management assertions identified and then develop auditing procedures that are appropriate in the circumstances. The auditing procedures are completed to provide the evidence necessary to persuade the auditor that there is no material misstatement related to each of the relevant assertions. Once the auditor is satis- fied that the evidence has supported each of the relevant assertions, the auditor issues a report to provide assurance to financial statement users that the financial statements are free of material misstatement in accordance with generally accepted accounting prin- ciples. As an auditor, you must keep in mind the importance of understanding manage- ment’s financial statement assertions and always remember that you are serving the entire public interest, including stakeholders such as bankers, investors, and employees when ultimately reporting that the financial statements are free of material misstatement.

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When studying and learning about the assertions, a student of auditing must always remember that each assertion gives rise to a question that can be answered with audit evi- dence. In that spirit, Exhibit 1.4 provides a list of all of management’s financial statement assertions and some of the key questions that the audit team must address, with evidence, about each assertion. Note that column 1 in Exhibit 1.4 denotes the assertions currently identified by the PCAOB for public company audits.4 The PCAOB auditing standards do allow auditors to use different management assertions at their discretion, provided that the assertions cover the pertinent risks in each significant account. In that spirit, the

4The Public Company Accounting Oversight Board (PCAOB) is a nonprofit corporation established by Congress to oversee the audits of public companies. The PCAOB is discussed in more detail in Chapter 2.

EXHIBIT 1.4 Management Assertions

  ASB Assertions  

(1) (2) (3) (4) (5)

PCAOB Assertions

Assertions about Events and Transactions

Assertions about Account Balances

Assertions about Presentation and Footnote Disclosures Key Questions

Existence or occurrence Occurrence Existence Occurrence Do the assets listed really exist?

        Did the recorded sales transactions really occur?

Completeness Completeness Completeness Completeness Are the financial statements (including footnotes) complete?

        Were all transactions recorded?

  Cutoff     Are transactions included in the proper period?

Valuation or allocation Accuracy

Valuation and allocation Accuracy Are the accounts valued correctly?

      Valuation and allocation

Are expenses allocated to the period(s) that were benefited?

Rights and obligations  

Rights and obligations

Rights and obligations

Does the company really own the assets?

        Are all legal responsibilities to pay the liabilities identified?

Presentation and disclosure Classification   Classification

Were all transactions recorded in the correct accounts?

      Understandability Are the disclosures understandable to users?

Throughout this book, we will use Apollo Shoes, Inc. (the “Com- pany”) as a comprehensive case example to help illustrate impor- tant auditing concepts. The company is a distributor of athletic shoes. The Company’s products are shipped to large and small

retail outlets in a six-state area. The Company operates from a large office, which includes a warehouse in the Shoetown, Maine area. In this chapter, we will illustrate the financial statement assertions using Apollo Shoes.

The CompanyAPOLLO SHOES

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Auditing Standards Board (ASB)5 provides an additional set of management assertions (columns 2, 3, and 4 in Exhibit 1.4). You will note that the ASB set of assertions, while in direct alignment with the PCAOB assertions, does provide greater detail and clarity for students of auditing to conceptualize. The key questions (column 5) indicate how each of these assertions must be thought about when evaluating specific aspects of management’s financial statements and disclosures. Each of the assertions is defined and described in detail in the following sections, organized along the lines of the PCAOB assertions iden- tified in column 1, with the aligned ASB assertion(s) following in parentheses.

Existence or Occurrence (Existence, Occurrence) The numbers listed on the financial statements have no meaning to financial statement users unless the numbers faithfully represent the actual transactions, assets, and liabilities of the company. Existence asserts that each of the balance sheet and income statement balances actually exist. Occurrence asserts that each of the income statement events and transactions actually did occur. As a general rule, the occurrence assertion relates to events, transactions, presentations, and footnote disclosures (as indicated in columns 2 and 4 of Exhibit 1.4), and the existence assertion relates to account balances (as indicated in column  3). Therefore, auditors must test whether the balance sheet amounts reported as assets, liabilities, and equities actually exist. To test the existence assertion, auditors typically verify cash with banks and count the physical inventory, verify accounts receivables and insurance policies with customers, and perform other procedures to obtain evidence whether management’s assertion is in fact supported. Similarly, management asserts that each of the revenue and expense transactions summarized on the income statement or disclosed in the financial statement footnotes really did occur during the period being audited. To test the occurrence assertion, auditors complete procedures to ensure that the reported sales transactions really did occur and were not created to fraudulently inflate the company’s profits.

5The ASB was established by the profession to issue auditing standards. Standards issued by the ASB apply to audits of private companies. The ASB is discussed in more detail in Chapter 2.

On Apollo Shoes, management would assert that their assets or liabilities all exist as of December 31st. For example, management asserts that its cash on the balance sheet really does exist. In addition,

management asserts that each revenue transaction on the income statement actually did occur.

Existence or OccurrenceAPOLLO SHOES

Completeness (Completeness, Cutoff) In the financial statements, management asserts that all transactions, events, assets, liabil- ities, and equities that should have been recorded have been recorded. In addition, man- agement asserts that all disclosures that should have been included in the footnotes have been presented. Thus, auditors’ specific objectives include obtaining evidence to deter- mine whether, for example, all inventory is included, all accounts payable are included, all notes payable are included, all expenses are recorded, and so forth. A verbal or written management representation saying that all transactions are included in the accounts is not considered a sufficient basis for deciding whether the completeness assertion is true. Auditors need to obtain persuasive evidence about completeness.

Cutoff is a more detailed expression of the completeness assertion. Cutoff refers to accounting for revenue, expense, and other transactions in the proper period (neither post- poning some recordings to the next period nor accelerating next-period transactions into the current-year accounts). Simple cutoff errors can occur when (1) a company records late December sales invoices for goods not actually shipped until early January; (2) a company records cash receipts through the end of the week (e.g., Friday, January 4) when the last batch of receipts for the year should have been processed on December 31; (3) a

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company fails to record accruals for expenses incurred but not yet paid, thus understating both expenses and liabilities; (4) a company fails to record purchases of materials shipped free on board (FOB) shipping point but not yet received and, therefore, not included in the ending inventory, thus understating both inventory and accounts payable; and (5) a company fails to accrue unbilled revenue through the fiscal year-end for customers on a cycle billing system, thus understating both revenue and accounts receivable. In auditor’s jargon, the cutoff date generally refers to the client’s year-end balance sheet date.

On Apollo Shoes, management would assert that their assets or liabili- ties were complete as of December 31st. For example, management asserts that its accounts payable on the balance sheet includes all

amounts currently payable. In addition, management would assert that all expenses that should be included on the income statement actually were included.

CompletenessAPOLLO SHOES

On Apollo Shoes, management would assert that their assets or liabilities were valued in accordance with GAAP as of December 31st. For example, management asserts that its accounts receivable balance, net of the allowance for doubtful accounts, was stated at

the amount they actually expect to collect. In addition, management would assert that depreciation expense on the income statement reflects the appropriate allocation of fixed assets to the period of benefit under GAAP.

Valuation and AllocationAPOLLO SHOES

Valuation and Allocation (Accuracy or Valuation) In the financial statements, management asserts that the transactions and events have been recorded accurately and that the assets, liabilities, and equities listed on the balance sheet have been valued in accordance with GAAP (or IFRS). The audit objective related to valuation and allocation is to determine whether proper values have been assigned to assets, liabilities, and equities. Allocation refers to the appropriate percentage of an asset or liability balance being recorded on the income statement in accordance with GAAP (or IFRS). For example, has the proper depreciation expense been calculated for each fixed asset amount? Accuracy refers to the appropriate recording of the transactions involving these items. Auditors obtain evidence about specific valuations and mathematical accuracy by comparing vendors’ invoices to inventory prices, obtaining lower-of-cost-or-market data, evaluating collectability of receiv- ables, recalculating depreciation schedules, and so forth. Many valuation, accuracy, and allo- cation decisions amount to reaching conclusions about the proper application of GAAP (or IFRS). For example, due to the complexity in the accounting standards related to fair value (i.e., ASC Topic 820), there has been an increased focus on the valuation assertion.

Rights and Obligations (Rights and Obligations) In the financial statements, management asserts that they have ownership rights for all amounts reported as assets on the company’s balance sheet and that the amounts reported as liabilities represent the company’s own obligations. In simpler terms, the objective for an auditor is to obtain evidence that the assets are really owned and that the liabilities are really owed by the company being audited. You should be careful about ownership, however, because the assertion extends to include assets for which a company may not actually hold title. For example, an auditor will have a specific objective of obtaining evidence about the amounts capitalized for leased property. Likewise, owing includes accounting liabilities a company may not yet be legally obligated to pay. For example, specific objectives would include obtaining evidence about the estimated liability for product warranties. The auditor also has an obligation to ensure that the details of the company’s obligations are properly disclosed in the footnotes to the financial statements.

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On Apollo Shoes, management would assert that they really do own and have the rights to the assets listed on the balance sheet, and that they really are obliged to pay the amount listed on the balance sheet

for liabilities as of December 31. For example, management asserts that it really owns its inventory of shoes. In addition, management asserts that it really does owe the amount listed for accrued expenses.

Rights and ObligationsAPOLLO SHOES

On Apollo Shoes, management would assert that they have com- pletely and accurately presented and disclosed all of their footnotes. For example, management asserts that its income tax footnote

disclosure is complete and accurately shows the breakdown of cur- rent and deferred income taxes.

Presentation and DisclosureAPOLLO SHOES

Presentation and Disclosure (Classification, Understandability) In the financial statements, management asserts that all transactions and events have been presented correctly in accordance with GAAP (or IFRS) and that all relevant information has been disclosed to financial statement users, usually in the footnotes to the financial statements. This assertion embodies several different components. First, disclosures must be relevant, reliable, and understandable or transparent to financial statement users. In addition, auditors will test to make sure that all have the proper disclosures made in accor- dance with GAAP (or IFRS). To complete this step, auditors will often use a disclosure checklist that highlights all the disclosures that should be made for a particular entity.

Second, transactions must be classified in the correct accounts (e.g., proper classifica- tion of transactions as assets or expenses). To test this assertion, auditors perform audit procedures such as analyzing repair and maintenance expenses to ensure that that they should in fact have been expensed rather than capitalized. Similarly, auditors will test from the opposite direction, examining additions to buildings and equipment to ensure that transactions that should have been expensed were not in fact capitalized in error (or fraud).

Third, to be useful to decision makers, information must be understandable. State- ment of Financial Accounting Concepts (SFAC) No. 2, “Qualitative Characteristics of Accounting Information,” defines understandability as “the quality of information that enables users to perceive its significance.” The responsibility levied on auditors is to make sure that the financial statements are “transparent.” In other words, investors should be able to understand how the company is doing by reading its financial statements and footnotes and should not have to rely on financial experts or lawyers to help them figure out what the fine print is saying. Another way to regard this assertion is to ask whether the disclosures have been written in plain English.

Importance of Assertions On each audit engagement, the auditor must identify each significant account or disclosure in the financial statements. An account or disclosure is significant if there is a reasonable possibility that the account or disclosure could contain a misstatement that is material. Once the significant accounts and disclosures have been identified, the auditor must then consider the relevance of each financial statement assertion, one at a time. An assertion is relevant, if there is a “reasonable possibility” that a material misstatement exists related to that assertion for the significant account being audited. As a result, the relevance of a par- ticular assertion is entirely dependent on the facts and circumstances on the audit engage- ment. For example, valuation may not be a relevant assertion for the cash account unless foreign currency translation is involved; however, the existence of cash is always relevant.

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The financial statement assertions are important and at times can be difficult to comprehend. A student of auditing must remember that the key questions that must be answered about each assertion become the focal points for the audit procedures to be performed. In other words, audit procedures are the means to answer the key questions posed by management’s financial statement assertions. When evidence-gathering audit procedures are specified, you need to be able to relate the evidence produced by each procedure to one or more specific assertions. In essence, the secret to writing and review- ing a list of audit procedures is to ask, “Which assertion(s) does this procedure produce evidence about?” Then ask, “Does the list of procedures (the audit plan) cover all the assertions?” Exhibit 1.5 illustrates how the assertions relate to the financial statements.

Although standards-setting bodies such as the PCAOB and ASB try to neatly catego- rize transactions, balances, and disclosures according to the different assertions, the real

EXHIBIT 1.5 Management Assertions and Their Relationship to the Financial Statements

Existence—Does this cash really exist?

Rights and Obligations—Does the company really own this inventory?

Valuation or Allocation—Are these investments properly valued?

Completeness—Does the accounts payable and accrued expenses balance include all amounts owed?

Presentation and Disclosure—Are these disclosures understandable? Has everything been disclosed that should be?

Occurrence—Did these sales transactions really take place?

STATEMENT OF FINANCIAL CONDITION APOLLO SHOES INC. in thousands

As of December 31 2020 2019

Assets Cash $3,245 $3,509 Accounts Receivable (Net of Allowances of $1,263 and 210, 15,I48 2,738 respectively) (Note 3) Inventory (Note 4) 15,813 13,823 Prepaid Expenses 951 352 Current Assets $35,157 $20,422 Property, Plant, and Equipment (Note 5) 1,174 300 Less Accumulated Depreciation (164) (31) $1,010 $269 Investments (Note 6) 613 613 Other Assets 14 0 Total Assets $36,794 $21,304

Liabilities and Shareholders’ Equity Accounts Payable and Accrued Expenses $4,675 $3,556 Short-Term Liabilities (Note 7) 10,000 0 Current Liabilities $14,675 3,556 Long-Term Debt (Note 7) 0 0 Total Liabilities $14,675 3,556 Common Stock 8,105 8,105 Additional Paid-in Capital 7,743 7,743 Retained Earnings 6,271 1,900 Total Shareholders’ Equity $22,119 $17,748 Total Liabilities and Shareholders’ Equity $36,794 $21,304 The accompanying notes are an integral part of the consolidated financial statements.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS APOLLO SHOES, INC.

1. Summary of Significant Accounting Policies

Business activity The Company develops and markets technologically superior podiatric athletic products under various trademarks, including SIREN, SPOTLIGHT, and SPEAKERSHOE.

Marketable Securities Investments are valued using the market value method for investments of less than 20%, and by the equity method for investments greater than 20% but less than 50%.

Cash equivalents Cash equivalents are defined as highly liquid investments with original maturities of three months or less at date of purchase.

Inventory valuation Inventories are stated at the lower of First-in, First-out (FIFO) or market.

Property and equipment and depreciation Property and equipment are stated at cost. The Company uses the straight-line method of depreciation for all additions to property, plant, and equipment.

Intangibles Intangibles are amortized on the straight-line method over periods benefited.

Net Sales Sales for 2017 and 2016 are presented net of sales returns and allowances of $4.5 million, and $0.9 million, respectively, and net of warranty expenses of $ 1.1 million, and $0.9 million, respectively.

Income taxes Deferred income taxes are provided for the tax e�ects of timing di�erences in reporting the results of operations for financial statements and income tax purposes, and relate principally to valuation reserves for accounts receivable and inventory, accelerated depreciation and unearned compensation.

Net income per common share Net income per common share is computed based on the weighted average number of common and common equivalent shares outstanding for the period.

Reclassification Certain amounts have been reclassified to conform to the 2016 presentation.

2. Significant Customers

Approximately 15%, and 11% of sales are to one customer for years ended December 31, 2017 and 2016, respectively.

STATEMENTS OF INCOME APOLLO SHOES INC. in thousands (except per share data)

For year ended December 31, 2020 2019

Net Sales (Note 2) $240,575 $236,299 Cost of Sales $141,569 $120,880 Gross Profit $99,006 $115,419 Selling, General and Administrative Expenses $71,998 $61,949 Interest Expense (Note 7) $875 0 Other Expense (Income) ($204) ($1,210) Earnings from Continuing Operations Before Taxes $26,337 $54,680 Income Tax Expense (Note 10) $10,271 $21,634 Earnings from Continuing Operations $16,066 $33,046 Discontinued Operations, Net of tax benefit ($31,301) Extraordinary Item, Net of tax benefit (Note 11) ($11,695) Net Income $4,371 $1,745

Earnings Per Common Share From Continuing Operations $1.98 $4.08 Other ($1.44) ($3.86) Net Income $0.54 $0.22

Weighted shares of common stock outstanding 8,105 8,105

The accompanying notes are an integral part of the consolidated financial statements.

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world is seldom as orderly. For example, although cutoff procedures provide evidence about completeness, they also provide evidence about valuation and existence. Prema- turely recording sales transactions inflates revenue and/or asset values because the trans- action did not occur by the income statement date. Similarly, if a cutoff test shows a delay in recording a liability, the liability is not only incomplete but undervalued as well. Thus, errors in financial statements may affect multiple management assertions.

REVIEW CHECKPOINTS  1.9 What is the difference between financial statement auditing and financial accounting? 1.10 List and briefly explain each of the Auditing Standards Board’s (ASB) management assertions. List

at least one key question that auditors must answer with evidence related to each management assertion.

1.11 Why is the ASB’s set of management assertions important to auditors? Do these assertions differ from those included in PCAOB standards? If so, how are they different?

When Lehman Brothers filed for bankruptcy in September 2008, it was reportedly the largest bankruptcy in U.S. history. How could such a large firm seem to collapse so suddenly? Some observers blamed the audi- tors. In fact, in a civil fraud lawsuit filed by the attorney general of New York back in 2010, auditors at Ernst & Young (EY) were identified, along with other investment bankers and senior Lehman executives, as hav- ing played a role in the bank’s demise. The lawsuit described a “cozy” relationship between Lehman and EY because “two of Lehman’s chief

financial officers were former EY employees” and “Ernst & Young charged Lehman $150 million in audit fees over a seven-year period of time.” EY settled the lawsuit in April 2015 for $10 million without the admission of any wrongdoing by its professionals. However, the lawsuit serves as a reminder for auditors to always exhibit professional skepticism.

Sources: “Ernst Accused of Lehman Whitewash,” The Wall Street Journal, December 22, 2010, p. C1; “Ernst & Young Reaches Settlement with N.Y. Attorney General,” The Wall Street Journal, April 16, 2015, p. C1.

Why Be Skeptical?AUDITING INSIGHT

PROFESSIONAL SKEPTICISM

“Doveryai, no Proveryai” (Trust, but Verify) Ronald Reagan, “Doveryai, no proveryai: Trust but verify.” November 28, 2017, https://www.c-span.org

LO 1-4 Define professional skepticism and explain its key characteristics.

Professional skepticism is defined in the professional auditing standards as having an atti- tude that “includes a questioning mind and a critical assessment of evidence.” Essentially, it is an auditor’s responsibility to not accept management assertions without corroboration. Stated differently, an auditor must ask management to “prove” each of the relevant asser- tions with documentary evidence. The occurrence of errors and fraud in financial reports highlights the following basic premise, which underlies the importance of professional skepticism: A potential conflict of interest always exists between the auditors and the man- agement of the company being audited. This potential conflict arises because management wants to present the company in the best possible light whereas auditors must ensure that the information about the company’s financial condition is “presented fairly.”

With full awareness of this potential conflict of interest, auditors must always remain professionally skeptical in their relationships with management, but not

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adversarial or confrontational. Nevertheless, knowing that a potential conflict of inter- est always exists causes auditors to perform procedures to search for errors and frauds that could have a material effect on the financial statements. And, even though the vast majority of audits do not contain fraud, auditors have no choice but to exercise professional skepticism at all times and on all audits because of misdeeds perpetrated by just a few people in a few companies. The professional standards emphasize the importance of maintaining and then applying an attitude of professional skepticism throughout the entire audit process.

Auditing firms have long recognized the importance of exercising professional skepti- cism when making professional judgments. In fact, as illustrated in the following Audit- ing Insight, firms have increasingly stressed the importance of being skeptical when evaluating documentary evidence. You can definitely expect to encounter difficult eco- nomic transactions as an auditor. When auditors encounter a difficult transaction, they must take the time to fully understand the economic substance of that transaction and then critically evaluate, with skepticism, the evidence provided by the client to justify its accounting treatment. No shortcuts are allowed. Rather, auditors are required to be unbi- ased and objective when making their professional judgments.

Judgment and decision-making researchers in auditing have long known about common biases that can interfere with or obstruct aud- itors from making excellent professional judgments. One example is the anchoring bias, which recognizes the possibility that an aud- itor might “anchor” on a number provided by a client manager (e.g., an estimate for the allowance for doubtful accounts) and then have difficulty adjusting to the economically correct amount. In its mono- graph, entitled “Elevating Professional Judgment in Accounting and Auditing,” KPMG (2011) outlines a professional judgment framework designed to help auditors to mitigate professional judgment biases like the anchoring bias. In order to do so, auditors must first be aware

of the possibility that these biases might interfere with their profes- sional judgment. Beyond awareness, the monograph argues that auditors must follow a disciplined process that includes (1) clarifying the issues and objectives, (2) considering the possible alternatives, (3) gathering and evaluating the relevant evidence, (4) reaching an audit conclusion, and (5) carefully documenting their rationale for the professional judgment reached. And, perhaps most importantly, the monograph emphasizes the importance of an auditor exercising pro- fessional skepticism throughout the entire process.

Source: “Elevating Professional Judgment in Accounting and Auditing: The KPMG Professional Judgment Framework” (Montvale, NJ: KMPG, 2011).

Overcoming Judgment Biases: The Importance of Professional Judgment

AUDITING INSIGHT

Persuading a skeptical auditor is not impossible, just somewhat more difficult than persuading a normal person in an everyday context. Skepticism is a manifestation of objectivity, holding no special concern for preconceived conclusions on any side of an issue. In fact, the auditor should not care about the impact that an economic transaction has on the “bottom line” of a company, only that the accounting rules were followed and were properly applied and that the financial statements are appropriate for the user’s needs. Skepticism is not being cynical, hypercritical, or scornful. The properly skeptical auditor asks questions such as the following: (1) What do I need to know? (2) How well do I know it? (3) Does it make sense? and (4) What could go wrong?

Auditors understand that receiving explanations from an entity’s management is merely the first step in the professional judgment process, not the last. Auditors must listen to the explanation, and then always test it by examining sufficient competent audit evidence. The familiar phrase “healthy skepticism” should be viewed as a show-me attitude, not a predisposition to accepting unsubstantiated explanations. Auditors must gather the evi- dence needed, uncover all the implications from the evidence, and then arrive at the most appropriate and supportable conclusion. Time pressure to complete a financial statement audit engagement is no excuse for failing to exercise professional skepticism. Too many auditors have gotten themselves into trouble by accepting a manager’s glib explanation and stopping too early in an investigation without seeking corroborating evidence.

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In its Staff Audit Practice Alert about professional skepticism, the PCAOB expressed serious concern about “whether auditors consistently and diligently apply professional skepticism.” The alert recognizes that there are a number of factors that could “impede” the application of professional skepticism but stresses the importance of taking what- ever actions are necessary to make sure that professional skepticism is applied in an appropriate manner throughout the audit process.

THE HURTT SKEPTICISM SCALE How skeptical are you? Answer the following 30 questions to find out. As a benchmark, business students typically fall between 90 to 150 points; auditors score much higher.

Professional SkepticismAUDITING INSIGHT

Questions Strongly Disagree        

Strongly Agree

 1. I often accept other people’s explanations without further thought. 1 2 3 4 5 6  2. I feel good about myself. 1 2 3 4 5 6  3. I wait to decide on issues until I can get more information. 1 2 3 4 5 6  4. The prospect of learning excites me. 1 2 3 4 5 6  5. I am interested in what causes people to behave the way that they do. 1 2 3 4 5 6  6. I am confident of my abilities. 1 2 3 4 5 6  7. I often reject statements unless I have proof that they are true. 1 2 3 4 5 6  8. Discovering new information is fun. 1 2 3 4 5 6  9. I take my time when making decisions. 1 2 3 4 5 6 10. I tend to immediately accept what other people tell me. 1 2 3 4 5 6 11. Other people’s behavior does not interest me. 1 2 3 4 5 6 12. I am self-assured. 1 2 3 4 5 6 13. My friends tell me that I usually question things that I see or hear. 1 2 3 4 5 6 14. I like to understand the reason for other people’s behavior. 1 2 3 4 5 6 15. I think that learning is exciting. 1 2 3 4 5 6 16. I usually accept things I see, read, or hear at face value. 1 2 3 4 5 6 17. I do not feel sure of myself. 1 2 3 4 5 6 18. I usually notice inconsistencies in explanations. 1 2 3 4 5 6 19. Most often I agree with what the others in my group think. 1 2 3 4 5 6 20. I dislike having to make decisions quickly. 1 2 3 4 5 6 21. I have confidence in myself. 1 2 3 4 5 6 22. I do not like to decide until I’ve looked at all of the readily available information. 1 2 3 4 5 6 23. I like searching for knowledge. 1 2 3 4 5 6 24. I frequently question things that I see or hear. 1 2 3 4 5 6 25. It is easy for other people to convince me. 1 2 3 4 5 6 26. I seldom consider why people behave in a certain way. 1 2 3 4 5 6 27. I like to ensure that I’ve considered most available information before making a decision. 1 2 3 4 5 6 28. I enjoy trying to determine if what I read or hear is true. 1 2 3 4 5 6 29. I relish learning. 1 2 3 4 5 6 30. The actions people take and the reasons for those actions are fascinating. 1 2 3 4 5 6

Sources: Kathy Hurtt, “Development of a Scale to Measure Professional Skepticism,” Auditing: A Journal of Practice & Theory 29, no. 1 (May 2010), pp. 149–171; Public Company Accounting Oversight Board, Staff Audit Practice Alert No. 10: Maintaining and Applying Professional Skepticism in Audits (Washington, DC: PCAOB, 2012).

Although the SEC places constraints on the common practice of auditors’ joining public clients that they have previously audited, close relationships often exist between former colleagues now employed by the client and members of the audit team. In these cases, the audit team must guard against being too trusting in accepting representations about the client’s financial statements. Of more concern is the fact that former colleagues have inside knowledge of the firm’s practices and procedures, knowing where the audit team will probably look (and where they might not look).

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To summarize, due care requires an auditor to be professionally skeptical and question all material representations made by management (whether written or oral) during the professional judgment process. Although this attitude must be balanced by maintaining healthy client relationships, auditors should never assume management to be perfectly honest. The key lies in auditors’ skeptical attitude toward gathering and evaluating the evidence necessary to reach supportable conclusions.

EXHIBIT 1.6 Public Accounting Firm Organization

Chair and CEO

Local O�ces O�ce Managing

Partner

Assurance Services Consulting ServicesTax Services

Partner Partner

Manager

Senior (in-charge) accountants Sta� accountants (or associates)

Senior (in-charge) accountants Sta� accountants (or associates)

ManagerManager ManagerManager Manager

REVIEW CHECKPOINT 1.12 Why should auditors act as though there is always a potential conflict of interest between the

auditor and the management team of the organization being audited?

PUBLIC ACCOUNTING The practice of public accounting is conducted in thousands of practice units ranging in size from sole proprietorships (individuals who “hang out a shingle” in front of their homes) to the largest international firms with thousands of professionals. Furthermore, many public accounting firms no longer designate themselves as CPA firms. Many of them describe their businesses and their organizations as professional services firms or some variation on this term. Exhibit 1.6 shows an organization for a typical public accounting firm. However, some firms differ in their organization. For example, some have other departments such as small business advisory and forensic accounting. Other firms may be organized by industry (e.g., entertainment, oil and gas, health care, finan- cial institutions) to take advantage of firmwide expertise. And still some other firms have different names for their staff and management positions.

Assurance Services Generally speaking, assurance services involve lending credibility to information, whether that information is financial or nonfinancial. While financial statement auditing services remain the dominant service area, CPAs have also provided assurance to vote counts (Academy Awards), dollar amounts of prizes that sweepstakes have claimed to award, accuracy of advertisements, investment performance statistics, and characteristics claimed for computer software programs. Although assurance services (separate and dis- tinct from auditing) currently represent a fairly small part of a normal firm’s operating revenues, the AICPA continues to make an effort to market these additional services to the public and businesses.

LO 1-5 Describe the organization of public accounting firms and identify the various services that they offer.

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At the present time, assurance services primarily include financial statement audit engagements and other nonaudit and attestation engagements. We discuss these services as key examples of assurance services that public accounting firms offer.

Financial Statement Auditing Services Most of the large, international accounting (Big Four) firms were founded around the turn of the 20th century (late 1800s/early 1900s) during the Industrial Revolution as European financiers sent representatives (individuals whom we now refer to as auditors) to check up on their investments (mostly railroads) in the United States. As such, the primary focus of many large international accounting firms’ practice has been traditional accounting and auditing services. Audits of traditional financial statements remain the most frequent type of assurance engagement that public companies (and most large and medium nonpublic companies) demand. Exhibit 1.7 shows the auditing (and other assur- ance services) revenues of the Big Four accounting firms based on their 2018 annual reports. This level of auditing activity usually drops as the size of the public accounting firm decreases. In other words, smaller firms usually provide more nonaudit and attesta- tion services for their clients.

Nonaudit and Attestation Engagements Basic accounting and review services are “nonaudit” services, performed frequently for medium and small businesses and not-for-profit organizations. Small public accounting firms perform a great deal of this type of nonaudit work. For example, CPAs can perform a compilation, which consists of preparing financial statements from a client’s books and records, without performing any evidence-gathering work. They can also perform a review, in which limited evidence-gathering work is performed but which is narrower in scope than an audit. Although these are the most common attestation engagements, CPAs

For baseball fans, the annual Hall of Fame vote has always been a source of fun and entertainment which is quite often accompanied by spirited conversation regarding the criteria that a player needs to meet to gain admittance into the Hall.

The Baseball Writers’ Association of America is responsible for the voting and only those writers that maintain 10 consecutive years fol- lowing a team are eligible to vote. But, do you know who verifies that

eligible voters are properly registered, have signed a code of conduct, and verifies the actual count of votes? You may have guessed it, one of the largest audit firm in the world, EY. So, although you might dis- agree with the final outcome from time to time, you can be assured that the appropriate process was followed and an accurate count was conducted each and every year!

Source: www.baseballhall.org

Baseball Hall of FameAUDITING INSIGHT

EXHIBIT 1.7 Revenues for the Big Four CPA Firms

  Deloitte EY KPMG PwC

Total revenues (in billions) $ 46.2 $ 36.4 $ 29.8 $ 42.5

Auditing and assurance services revenues $ 10.2 $ 12.6 $ 11.2 $ 17.4

(in billions and as a percent of revenue) 22% 35% 38% 41%

Tax revenues (in billions and as a percent of revenue) $ 8.3 $ 9.5 $ 6.6 $ 10.7

  18% 26% 22% 25%

Consulting services revenues $ 27.7 $ 14.3 $ 12.0 $ 14.4

(in billions and as a percent of revenue) 60% 39% 40% 34%

Sources:

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also can attest to the accuracy of management’s discussion and analysis (MD&A) that accompanies the financial statements in an annual report, an entity’s internal controls, and hypothetical “what-if” projections relating to mergers or acquisitions.

Tax Services Local, state, national, and international tax laws are often called “accountant and attor- ney full-employment acts.” The laws are complex, and CPAs perform tax planning services and tax return preparation in the areas of income, gift, estate, property, and other taxation. A large proportion of the practice in small public accounting firms is tax related. Tax laws change frequently, and tax practitioners must spend considerable time in continuing education and self-study to keep current. Exhibit 1.7 shows the tax revenues of the Big Four accounting firms based on their 2018 annual reports. Smaller public accounting firms tend to conduct more tax consulting engagements and fewer audit engagements.

The role of tax consulting in a professional services firm has at times faced scrutiny. The Statements on Responsibilities in Tax Practice specifically state that “A CPA has both the right and responsibility to be an advocate for the client” in arguing tax positions with the IRS [TX 112.04]. Can the CPA be an advocate for the client with respect to tax matters and maintain objectivity with regard to other audit matters? Recent guidance from the Public Company Accounting Oversight Board (PCAOB) prohibits an account- ing firm from providing auditing services to a public company if the accounting firm provides tax consulting on aggressive interpretations of tax laws or “listed” transactions (those included on the U.S. Treasury Department’s list of questionable tax strategies), if contingent fees (i.e., fees depending on a certain outcome) are involved, or if the public accounting firm provides tax services for key company executives. In all three cases, the PCAOB argues that auditor independence would be impaired. Providing normal cor- porate tax return preparation and advice is permissible as long as the audit committee discusses with the accounting firm the implications of the tax consulting fees on auditor independence and preapproves the relationship in writing. As a result, this remains a common service area for firms to provide to their audit clients, but the firm must always maintain its independence and objectivity.

Advisory Services Prior to the turn of this century (the 1990s), the largest public accounting firms handled a great deal of advisory services for their auditing clients. In fact, advisory services pro- vided a great new revenue opportunity for firms and the potential for even more business appeared at times to be unlimited. Public accounting firms tried to become “one-stop shopping centers” for clients’ auditing, taxation, and business advice needs.

The Securities and Exchange Commission (SEC), the governmental agency charged with investor protection, expressed reservations as to whether the performance of non- audit services (such as advisory) impaired a public accounting firm’s ability to conduct an independent audit. The SEC’s concern was that the large amount of revenues gener- ated from advisory services might sway the auditor’s opinion on the company’s financial statements. The public accounting firms, on the other hand, argued that the provision of advisory services allowed them a closer look at the client’s operations, providing a syner- gistic, positive effect on the audit.

In response to the spate of corporate frauds, Congress resolved this difference of opinion, in part, by passing the Sarbanes–Oxley Act of 2002 (hereafter referred to as Sarbanes–Oxley), a broad accounting and corporate governance reform measure. Sarbanes–Oxley prohibits public accounting firms from providing any of the follow- ing services to a public audit client: (1) bookkeeping and related services; (2) design or implementation of financial information systems; (3) appraisal or valuation services; (4) actuarial services; (5) internal audit outsourcing; (6) management or human resources services; (7) investment or broker/dealer services; and (8) legal and expert services

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(unrelated to the audit). As already stated, public accounting firms may provide general corporate tax return preparation and advice and other nonprohibited services to public audit clients if the company’s audit committee has approved them in advance.

To briefly summarize these restrictions, Sarbanes–Oxley prohibits public accounting firms from performing any consulting or advisory services in which the auditors may find themselves making managerial decisions or that would result in the firm auditing its own work (e.g., completing a financial information system implementation for its audit client). As a result of Sarbanes–Oxley, most of the large firms now provide consulting only for companies that they do not audit. However, the Big Four firms have still been able to dramatically increase the size of their advisory services in recent years. As shown in Exhibit 1.7, firm advisory revenues ranged between 28 and 58 percent of the Big Four firms’ total revenues in 2018. Of course, public accounting firms are not required to fol- low Sarbanes–Oxley guidelines for their non-SEC clients, and in those situations, firms can provide an array of consulting and advisory services provided they maintain their independence and objectivity when completing the financial statement audit.

REVIEW CHECKPOINTS 1.13 What are some examples of assurance services performed on nonfinancial information? 1.14 What are some of the major areas of public accounting services?

OTHER KINDS OF ENGAGEMENTS AND INFORMATION PROFESSIONALS

The AAA and the AICPA definitions of auditing clearly apply to the independent finan- cial statement auditors who work in public accounting firms. The word audit, however, is also used in other contexts to describe broader types of work. The variety of engagements performed by different kinds of information assurors causes some problems with termi- nology. In this textbook, independent auditor, external auditor, and CPA will refer to people doing financial statement audit work with public accounting firms. In the internal and governmental contexts discussed here, auditors are identified as operational audi- tors, internal auditors, and governmental auditors. Although all of these professionals are information assurors (and many are certified public accountants), the term CPA in this book will refer to financial statement auditors engaged in public practice.

Internal Auditing The Board of Directors of the Institute of Internal Auditors (IIA) defines internal auditing and states its objective as follows:

Internal auditing is an independent, objective assurance and consulting activity designed to add value and improve an organization’s 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 processes.6

Internal auditors are employed by organizations such as banks, hospitals, city govern- ments, and industrial companies or work for CPA firms that provide internal auditing services. Internal auditors often perform operational audits. Operational auditing refers to the study of business operations for the purpose of making recommendations about the efficient and effective use of resources, effective achievement of business objectives, and

LO 1-6 Describe the audits and auditors in governmental, internal, and operational auditing.

6The Institute of Internal Auditors. Definition of Internal Audit. Accessed May 17, 2019. https://na.theiia.org

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compliance with company policies. The goal of operational auditing is to help managers discharge their management responsibilities and improve profitability.

Internal auditors also perform audits of financial reports for internal use or limited external distribution (e.g., reports to regulatory agencies) much like external auditors audit financial statements distributed to outside users. Thus, some internal auditing work is sim- ilar to the auditing described elsewhere in this textbook. In addition, the services provided by internal auditors include (1) reviews of internal control systems to ensure compliance with company policies, plans, and procedures; (2) compliance with laws and regulations; (3) appraisals of the economy and efficiency of operations; and (4) reviews of effectiveness in achieving program results in comparison to established objectives and goals.

It should be noted that the AICPA defines operational auditing performed by inde- pendent CPA firms as a distinct type of management consulting service whose goal is to help a client improve the use of its capabilities and resources to achieve its objectives. So, internal auditors consider operational auditing integral to internal auditing and external auditors define it as a type of assurance service offered by public accounting firms. In fact, providing these types of internal auditing services continues to be a growing busi- ness for many large CPA firms. However, both the SEC and the PCAOB prohibit CPA firms from providing these services to their own public audit clients.

Governmental Auditing The U.S. Government Accountability Office (GAO) is an accounting, auditing, and investigating agency of the U.S. Congress, headed by the U.S. Comptroller General. In one sense, GAO auditors are the highest level of internal auditors for the federal govern- ment. Many states have audit agencies similar to the GAO. These agencies answer to state legislatures and perform the same types of work described in this section for GAO audi- tors. In another sense, GAO and similar state agencies are really external auditors with respect to government agencies they audit because they are organizationally independent.

Many government agencies have their own internal auditors and inspectors general. Well-managed local governments also have internal audit departments. For example, most federal agencies (Department of Defense, Department of Human Resources, Department of the Interior), state agencies (education, welfare, controller), and local governments (cities, counties, tax districts) have internal audit staffs. Governmental and internal audi- tors have much in common.

The GAO shares with internal auditors the same elements of expanded-scope ser- vices. The GAO, however, emphasizes the accountability of public officials for the effi- cient, economical, and effective use of public funds and other resources. The generally accepted government auditing standards (GAGAS) define and describe three broad types of audits that may be performed. They are financial audits, attestation engagements, and performance audits.

Financial-related audits include determining whether financial information is pre- sented in accordance with the established and applicable financial reporting framework. There are many types of attestation engagements, including whether the governmental entity’s internal control system is suitably designed and implemented to achieve the applicable control objectives.

Attestation engagements would also include a compliance audit function applied with respect to applicable laws and regulations. All government organizations, programs, activ- ities, and functions are created by law, and most are surrounded by regulations that govern the things they can and cannot do. For example, a program established to provide school meals to low-income students must comply with regulations about the eligibility of recipi- ents. A compliance audit of such a program involves a study of schools’ policies, proce- dures, and actual performance in determining eligibility and handing out meal tickets.

Performance audits refer to a wide range of governmental audits that include (1) econ- omy and efficiency audits and (2) program audits. Governments are concerned about accountability for the appropriate use of taxpayers’ resources; performance audits are a means of seeking to improve accountability for the efficient and economical use of

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resources and the achievement of program goals. In addition, the program audit helps determine whether the financial resources being spent are truly helping the government achieve its stated objectives for a particular program. Performance audits, like internal auditors’ operational audits, involve studies of the management of government organiza- tions, programs, activities, and functions.

• Improper Payments: Selected Agencies Need Improvements in Their Assessments to Better Determine and Document Risk Susceptibility (GAO-19-714, January 10, 2019).

• Information Technology: IRS Needs to Take Additional Actions to Address Significant Risks to Tax Processing (GAO-18-298, June 28, 2018).

• Civil Penalties: Certain Federal Agencies Need to Improve Efforts to Comply with Inflation Adjustment Requirements (GAO-17-634, August 31, 2017).

• Management Report: Improvements Needed in Controls over the Pro- cesses Used to Prepare the U.S. Consolidated Financial Statements (GAO-17-524, July 12, 2017).

• Maritime Administration: Proceeds from the Sale of Obsolete Vessels Were Accounted for, Allocated, and Disbursed Consistent with Applic- able Law (GAO-17-280, February 23, 2017).

GAO Engagement Examples

Regulatory Auditors For the sake of clarity, other kinds of auditors deserve separate mention. The U.S. Inter- nal Revenue Service employs auditors. They take the “economic assertions” of taxable income made by taxpayers on tax returns and determine their correspondence with the standards found in the Internal Revenue Code. They also audit for fraud and tax evasion. Their reports can either clear a taxpayer’s return or claim that additional taxes are due.

State and federal bank examiners audit banks, savings and loan associations, and other financial institutions for evidence of solvency and compliance with banking and other related laws and regulations. As a result of the financial crisis of 2008/2009 and the resulting Dodd-Frank Act of 2010, these examiners have been in the news frequently as they work to help ensure the safety and security of the U.S. banking system.

REVIEW CHECKPOINTS 1.15 What is operational auditing? How does the AICPA view operational auditing? 1.16 What are the three broad types of governmental audits described by the GAGAS issued by the

GAO? 1.17 Define what is meant by compliance auditing. 1.18 Name some other types of auditors in addition to external, internal, and governmental auditors.

BECOME A PROFESSIONAL AND GET CERTIFIED! If you plan to begin your career in accounting (which we hope you do since you are reading this book!), you are on your way to being known as an accounting professional. Congratulations! Being part of a profession implies a higher level of societal responsi- bility. In order to meet this responsibility, it is absolutely essential that you acquire the knowledge required to do your job; and certification indicates that you have acquired that knowledge. In that spirit, being certified as a CPA is generally regarded as the high- est mark of distinction and is required to practice as a financial statement auditor in the United States. In Australia, Canada, and the United Kingdom, the chartered accountant

LO 1-7 List and explain the requirements for becoming a certified public accountant (CPA) and other certifications available to an accounting professional.

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(CA) designation is required to practice as a financial statement auditor. For an informa- tion technology (IT) audit professional, a certified information systems auditor (CISA) is the key mark of distinction. In fact, depending on your area of professional service within public accounting, a certified fraud examiner (CFE), certified forensic accoun- tant (CFA), certified information systems security professional (CISSP), or even a cer- tified internal auditor (CIA), certification may be just as important. Outside of public accounting, certification as a certified management accountant (CMA) or as a certified information technology professional (CITP) may be the most appropriate. Regardless of your career choice, a certification adds credibility that will assist you throughout your entire career.

Education While education requirements vary across the different certifying organizations, we focus on the CPA certification in this book because of its importance to financial statement auditors. For the CPA, the specific education requirements vary by state for both having permission to take the CPA examination and for receiving a CPA certificate. As a result, students must visit the website of their own state’s board of accountancy and search for the exact regulations that apply in their home state. As we approach 2020, most states are requiring you to take 150 semester hours of college education before you receive a CPA certificate, but many states now allow you to take the CPA examination after only 120 semester hours of college education. Still other certifications (such as the CIA) allow you to take the exam before you have graduated.

In addition to entry-level education requirements, all certifying organizations have reg- ulations about continuing professional education (CPE). Indeed, once certified, account- ing professionals obtain CPE hours in a variety of ways: continuing education courses, in-house training, and even college courses. These types of courses range in length from one hour to two weeks, depending on the subject. Many CPE providers offer courses online. If in-house training is not an option, many CPAs obtain their CPE by taking part in training sessions offered by their home state’s professional accounting organization or other industry conferences.

Examination When working as a financial statement auditor, CPAs have a critically important role in protecting the public interest when they attest to the reliability of a company’s financial statements. As a result, the profession needs to make sure that only qualified individuals can become certified and then licensed as CPAs. To do so, the AICPA creates and then administers the Uniform CPA Examination. When creating the exam, the AICPA works hard to ensure that the knowledge and skills covered on the exam are aligned with those that are needed to protect the public interest in current practice. In fact, back in 2017, the AICPA conducted a thorough practice analysis to “ensure that the exam measures the right knowledge and skills to protect the public interest and meet the needs of the boards of accountancy as they license CPAs.”7 The practice analysis revealed that due primarily to the outsourcing of routine tasks and significant advances in information technology, the job of a newly licensed CPA has changed and the AICPA decided to make substantial changes to the CPA exam as of April 1, 2017. The new CPA exam is now described.

The CPA exam now has an increased emphasis on higher-order skills like problem solving, critical thinking, and analytical ability. The exam still covers Auditing and Attestation (AUD), Financial Accounting and Reporting (FAR), Regulation (REG), and Business Environment and Concepts (BEC). However, the exam is now 16 hours, instead of 14, and the emphasis has shifted toward the completion of more task-based

7Tysiac, Ken. 2016. What Will Be Tested on the Next CPA Exam. Journal of Accountancy, Association of International Certified Professional Accountants.

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simulations, which allows higher-order skills to be more accurately tested and measured. In the required AUD section, candidates will have four hours to complete 72 multiple- choice questions and eight to nine task-based simulations. The exam score is equally weighted between the multiple-choice questions and task-based simulations. To help can- didates prepare for the exam, the AICPA has published detailed blueprints for each of the four sections. Each blueprint is designed to provide clarity about the knowledge content, skills, and types of tasks that might be tested for each exam. The summary blueprint for the AUD section is provided in the accompanying table (with rough approximations of weights given to each content area and skill allocation*):

Association of International Certified Professional Accountants, “Uniform CPA Examination® Auditing and Attestation (AUD).” May 31, 2018, https://www.aicpa.org/

Content Area Allocation Weight

Ethics, Professional Responsibilities, and General Principles 15–25% Assessing Risk and Developing a Planned Response 20–30% Performing Further Procedures and Obtaining Evidence 30–40% Forming Conclusions and Reporting 15–25%

Skill Allocation Weight

Evaluation 5–15% Analysis 15–25% Application 30–40% Remembering and Understanding 30–40%

Source: http://www.aicpa.org/BECOMEACPA/CPAEXAM/NEXTEXAM/Pages/next-cpa-exam.aspx. Summary blueprints for REG, FAR, and BEC can also be found at this site.

Generally speaking, each section of the new CPA exam consists of multiple-choice question and task-based simulations (except for BEC, which also includes graded writ- ten communication). The task-based simulations are short case studies in which you will be asked to apply your auditing and accounting knowledge. A simulation may involve identifying a potential problem, electronically researching the topic using a database of authoritative standards, and reporting your findings. Each section’s exam blueprint is designed specifically for candidates to help prepare for the exam. Throughout this book, you will have many opportunities to acquire the knowledge necessary to pass the AUD section of the exam.

General information about the CPA exam can be obtained from a special site set up by the AICPA (available at www.aicpa.org). Because qualifications for taking the CPA examination vary from state to state, you will need to contact your state board of accoun- tancy for an application or more information. You can find your state board of accccof Accountancy (NASBA) website (www.nasba.org). Exhibit 1.8 lists the requirements for the most commonly recognized professional certifications.

Experience Although not required to sit for a professional exam, experience is required to become certified. Most states and territories require a person who has attained the education level and passed the CPA examination to have a period of experience working under a practic- ing CPA before awarding a CPA certificate. Experience requirements vary across states, but most jurisdictions require one to two years of experience. A few states require that the experience be obtained in a public accounting firm, but most of them accept experience in other organizations (GAO, internal audit, management accounting, Internal Revenue Service, and the like) as long as the applicant performs work requiring accounting judg- ment and is supervised by a competent accountant, preferably a CPA. Other certifying organizations also have experience requirements.

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EXHIBIT 1.8 Certification Requirements

  Certified Public Accountant (CPA)

Certified Information Systems Auditor (CISA)

Certified Internal Auditor (CIA)

Certified Fraud Examiner (CFE)

Certified Management Accountant (CMA)

Education Level Varies by state; Generally 150 hours. However, Check with your state board of accountancy

No specific degree requirement

Bachelor’s degree or its educational equivalent

Bachelor’s degree or its educational equivalent

Bachelor’s degree, or pass the CPA, CFA, CIA or CFE examination

Experience Varies by state; Generally 1-2 years working under a CPA. Check with your state board of accountancy

5 years of professional information system (IS) auditing, control, or security work experience for certification

Generally 2 years of internal auditing experience or its equivalent for certification. May be less with a Master’s degree

2 years of professional experience for certification

2 continuous years of professional experience in management accounting and/ or financial management

Exam Coverage 1. Auditing and attestation (AUD)

2. Financial accounting and reporting (FAR)

3. Regulation (REG) 4. Business

environment and concepts (BEC)

1. The process of auditing information systems

2. Governance and management of IT

3. Information systems acquisition, development, and implementation

4. Information systems operations, maintenance, and service management

5. Protection of information assets

1. Essentials of Internal Auditing

2. Practice of Internal Auditing

3. Business Knowledge of Internal Auditing

1. Fraud prevention and deterrence

2. Financial transactions and fraud schemes

3. Investigation 4. Law

1. Financial reporting, planning, performance, and control

2. Financial decision making

Test Length 4 parts, 16 hours 1 part, 4 hours (150 mc questions)

3 parts, 6.5 hours (325 mc questions)

4 parts (2 hours each part - 100 questions each); 8 total hours

2 parts (100 mc questions and two 30-minute essays, each) 8 hours

Passing Score 75% 450 (on an 800-point scale)

600 (on a 750-point scale)

75% 360 per part (on a 500-point scale)

Test Dates On demand in 1st two months of each calendar quarter

Two testing windows: Feb.-May & Oct.-Jan.

On demand Self-administered On demand during the months of Jan, Feb, May, Jun, Sep, and Oct

Administering Body American Institute of Certified Public Accountants

Information Systems Audit and Control Association

Institute of Internal Auditors

Association of Certified Fraud Examiners

Institute of Management Accountants

Website www.aicpa.org www.isaca.org www.theiia.org www.acfe.com www.imanet.org

State Certificate and License The AICPA does not issue CPA certificates or licenses to practice. Rather, all states and territories have state accountancy laws and state licensing boards to administer them. After satisfying state requirements for education and experience, successful candidates receive their CPA certificate from their state board of accountancy. At the same time, new CPAs must pay a fee to obtain a state license to practice or work for a CPA firm that

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is licensed to practice in their state. Thereafter, state boards of accountancy regulate the behavior of CPAs under their jurisdiction (enforcing state codes of ethics) and supervise the continuing education requirements.

After becoming a CPA licensed in one state, a person can obtain a CPA certificate and license in another state by filing the proper application with the second state board of accountancy, meeting that state’s requirements, and obtaining another CPA certificate. Many CPAs hold certificates and licenses in several states. From a global perspective, individuals must be licensed in each country. Similar to CPAs in the United States, char- tered accountants (CAs) practice in Australia, Canada, Great Britain, and India.

Efforts are currently under way through the AICPA and the National Association of State Boards of Accountancy (NASBA) to streamline the licensing process so that CPAs can practice across state lines without having to have 50 different licenses. Under the concept of substantial equivalency, as long as the licensing (home) state requires (1) 150 hours of education, (2) successful completion of the CPA exam, and (3) one year of experience, a CPA can practice (either in person or electronically) in another substantial equivalency state

without having to obtain a license in that state. The super majority of states and the District of Columbia have enacted provisions to allow CPAs licensed in other states to practice without notification (but agreeing to be under the state’s automatic jurisdiction). This uniform mobility arrangement is temporary though, because a CPA who relo- cates to another state must ultimately seek licensing in that state.

Source: AICPA State Regulation and Legislation Team at www.aicpa.org.

Auditors Make a Run for the BorderAUDITING INSIGHT

Skill Sets and Your Education The requirements to become certified are rather strenuous, but they may not be enough! Let us take you on a brief tour of the core competencies listed by the AICPA, the Asso- ciation of Certified Fraud Examiners (ACFE), the Institute of Internal Auditors (IIA), the Institute of Management Accountants (IMA), the Information Systems Audit and Control Association (ISACA), and other guidance-providing groups: mathematics, international culture, psychology, economics, statistics, political science, inductive and deductive rea- soning, ethics, group dynamic processes, finance, capital markets, managing change, his- tory of accounting, regulation, information systems, taxation, and (oh, yes) accounting and auditing. Add administrative capability, analytical skills, business knowledge, communica- tion skills (writing and speaking), efficiency, intellectual capability, marketing and selling, model building, people development, capacity for putting client needs first, and more.

We hope you are suitably impressed by this recitation of virtually all of the world’s knowledge. You will be very old when you accomplish a fraction of the skill development and education suggested. Now the good news: (1) not everyone needs to be completely knowledgeable in all of these areas upon graduation from college, (2) learning and skill development evolve over a lifetime, and (3) no one expects you to know everything on the job. In fact, we have observed that audit teams composed of members specializing in some areas with other members specializing in other areas seem to work best in practice. We do, however, stress the need to continue your education even after you leave school. Learning should be a lifelong pursuit, not something that ends when you receive your diploma.

REVIEW CHECKPOINTS 1.19 Why is continuing education required to maintain certification? 1.20 Why do you think experience is required to become certified? 1.21 What are some of the functions of a state board of public accountancy? 1.22 What are some of the limitations to practicing public accounting across state and national boundaries?

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Decision makers need more than just information; they need reliable and credible infor- mation that they can rely upon. Internet buyers rely on website information when pur- chasing online. Financial analysts and investors use financial reports to help make stock investment decisions. Suppliers and creditors use financial reports to decide whether to grant credit and bank loans. Labor organizations use financial reports to help determine a company’s ability to pay wages. Government agencies and Congress use financial infor- mation in preparing analyses of the economy and in making laws concerning taxes, sub- sidies, and the like. These various users rely on independent information assurors such as CPAs to reduce information risk. Auditors (and other information assurance providers) assume the role of certifying (or attesting to) published financial information, thereby offering users the valuable service of providing assurance that information risk is low.

This chapter began by defining information risk and explained how auditing and assur- ance services play a role in minimizing this risk. The financial statements were explained in terms of the primary assertions that management makes in them, and these assertions were identified as the focal points of the auditors’ evidence-gathering work. Auditing is practiced in numerous forms by various practice units, including public accounting firms, the Internal Revenue Service, the U.S. Government Accountability Office, internal audit departments in companies, and several other types of regulatory auditors. Fraud examiners, many of whom are internal auditors and inspectors, have also found a niche in auditing-related activities.

The public accounting profession recognizes that, in today’s information economy, information risk exists in areas outside of financial transactions. Assurance services is a broad category of information-enhancement services that build on CPAs’ auditing, attes- tation, accounting, and consulting skills to create products useful to a wide range of deci- sion makers (customers). While reliable information helps make capital markets efficient and helps people know the consequences of a wide variety of economic decisions, CPAs practicing the assurance function are not the only information professionals at work in the economy. Bank examiners, IRS auditors, state regulatory agency auditors (e.g., auditors in a state’s insurance department), internal auditors employed by a company, and federal government agency auditors all practice information assurance in one form or another.

Most financial statement auditors aspire to become certified public accountants, which involves successfully completing a rigorous examination, obtaining practical experience, and maintaining competence through continuing professional education. Auditors also obtain credentials as certified internal auditors, certified management accountants, certi- fied information systems auditors, and certified fraud examiners. Each of these fields has large professional organizations that govern the professional standards and quality of practice of its members.

Summary

assurance: The lending of credibility to information, 4 assurance services: The independent professional functions that improve the quality of information, or its context, for decision makers, 9 attestation: An accounting service resulting in a report on subject matter or an assertion about subject matter that is the responsibility of another party, 4 attestation engagement: An engagement in which a practitioner is engaged to issue a report on subject matter, or an assertion about subject matter that is the responsibility of another party, 7 auditing: The systematic process of objectively obtaining and evaluating evidence regarding assertions about economic actions and events to ascertain the degree of correspondence between the assertions and established criteria and communicating the results to interested users, 4 business risk: Those factors, events, and conditions that could prevent the organization from achieving its business objectives, 3 completeness: Management assertion that all of the transactions, events, assets, liabilities, equity interests, and other disclosures that should have been recorded in the financial statements have been recorded, 13

Key Terms

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cutoff: Management assertion that refers to accounting for revenue, expense, and other transactions in the proper period. The cutoff date generally refers to the audit client’s year-end balance sheet date, 14 existence: Management assertion that all assets, liabilities, and equity interests do actually exist, 13 financial reporting: Process of providing statements of financial position (balance sheets), results of operations (income statements, statements of shareholders’ equity, and statements of comprehensive income), changes in cash flows (statements of cash flows), and accompanying disclosure to outside decision makers who do not have access to management’s internal sources of information; a company’s accountants, under the direction of its management, perform this function, 11 information risk: The probability that the information circulated by an entity will be false or misleading, 4 internal auditing: An examination service provided to a company to assist the company to meet its corporate goals and objectives by evaluating and recommending risk management, control, and governance processes, 24 occurrence: Management assertion that all of the transactions and events that have been recorded are valid, pertain to the entity, and have actually taken place, 13 operational auditing: An examination designed to evaluate the processes and procedures of an organization or an area within an organization to ensure the process or area is operating efficiently and effectively, 24 presentation and disclosure: Management assertion that all transactions and events have been presented correctly and that all relevant information has been disclosed to financial statement users, usually in the footnotes to the financial statements, 13 professional skepticism: A state of mind that is characterized by appropriate questioning and a critical assessment of audit evidence, 18 relevant assertion: A management assertion is relevant if there is a reasonable possibility that a material misstatement exists related to that assertion for the significant account or footnote disclosure being audited, 16 rights and obligations: The entity is entitled to all rights of the assets, the liabilities are the legal responsibility of the entity, and all of the disclosed events and transactions pertain to the entity, 13 significant accounts: A financial statement account or footnote disclosure is considered significant if there is a chance that the account or footnote disclosure could contain a material misstatement. As a result, an auditor will have to conduct some procedures on each significant account or disclosure, 16 system generated reports: Any report that is generated by the audit client’s information system that is used to execute its internal control procedures or produce its financial statements. It is important to test that each system generated report is complete and accurate if it is being used for either of these purposes, 7 substantial equivalency: The process through which CPAs licensed in one state can practice in another state, 30 valuation or allocation: Management assertion that all assets, liabilities, and equity interests of the entity have been valued in accordance with the relevant financial reporting standards (e.g., GAAP) and are listed in the financial statements at the proper amount, and any resulting valuation adjustments have been appropriately recorded in the financial statements, 13

1.23 Which of the following would be considered an assurance engagement? a. Giving an opinion on a prize promoter’s claims about the amount of sweepstakes prizes

awarded in the past. b. Giving an opinion on the conformity of the financial statements of a university with gen-

erally accepted accounting principles. c. Giving an opinion on the fair presentation of a newspaper’s circulation data. d. Giving assurance about the average drive length achieved by golfers with a client’s golf balls. e. All of the above.

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Multiple-Choice Questions for Practice and Review

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1.24 It is always a good idea for auditors to begin an audit with the professional skepticism char- acterized by the assumption that a. A potential conflict of interest always exists between the auditor and the management of

the enterprise under audit. b. In audits of financial statements, the auditor acts exclusively in the capacity of an auditor. c. The professional status of the independent auditor imposes commensurate professional

obligations. d. Financial statements and financial data are verifiable.

1.25 In an attestation engagement, a CPA practitioner is engaged to a. Compile a company’s financial forecast based on management’s assumptions without

expressing any form of assurance. b. Prepare a written report containing a conclusion about the reliability of a management

assertion. c. Prepare a tax return using information the CPA has not audited or reviewed. d. Give expert testimony in court on particular facts in a corporate income tax controversy.

1.26 A determination of cost savings obtained by outsourcing cafeteria services is most likely to be an objective of a. Environmental auditing. b. Financial auditing. c. Compliance auditing. d. Operational auditing.

1.27 The primary difference between operational auditing and financial auditing is that in opera- tional auditing a. The operational auditor is not concerned with whether the audited activity is generating

information in compliance with financial accounting standards. b. The operational auditor is seeking to help management use resources in the most effec-

tive manner possible. c. The operational auditor starts with the financial statements of an activity being audited

and works backward to the basic processes involved in producing them. d. The operational auditor can use analytical skills and tools that are not necessary in finan-

cial auditing.

1.28 According to the AICPA, the purpose of an audit of financial statements is to a. Enhance the degree of confidence that intended users can place in the financial

statements. b. Express an opinion on the fairness with which they present financial position, results of

operations, and cash flows in conformity with accounting standards promulgated by the Financial Accounting Standards Board.

c. Express an opinion on the fairness with which they present financial position, results of operations, and cash flows in conformity with accounting standards promulgated by the U.S. Securities and Exchange Commission.

d. Obtain systematic and objective evidence about financial assertions and report the results to interested users.

1.29 Bankers who are processing loan applications from companies seeking large loans will probably ask for financial statements audited by an independent CPA because a. Financial statements are too complex for the bankers to analyze themselves. b. They are too far away from company headquarters to perform accounting and auditing

themselves. c. The consequences of making a bad loan are very undesirable. d. They generally see a potential conflict of interest between company managers who want

to get loans and the bank’s needs for reliable financial statements.

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1.30 The Sarbanes–Oxley Act of 2002 prohibits public accounting firms from providing which of the following services to an audit client? a. Bookkeeping services. b. Internal auditing services. c. Valuation services. d. All of the above.

1.31 Independent auditors of financial statements perform audits that reduce a. Business risks faced by investors. b. Information risk faced by investors. c. Complexity of financial statements. d. Timeliness of financial statements.

1.32 The primary objective of compliance auditing is to a. Give an opinion on financial statements. b. Develop a basis for a report on internal control. c. Perform a study of effective and efficient use of resources. d. Determine whether client personnel are following laws, rules, regulations, and policies.

1.33 What requirements are usually necessary to become licensed as a certified public accountant? a. Successful completion of the Uniform CPA Examination. b. Experience in the accounting field. c. Education. d. All of the above.

1.34 The organization primarily responsible for ensuring that public officials are using public funds efficiently, economically, and effectively is the a. Governmental Internal Audit Agency (GIAA). b. Central Internal Auditors (CIA). c. Securities and Exchange Commission (SEC). d. Government Accountability Office (GAO).

1.35 Performance audits usually include [two answers] a. Financial audits. b. Economy and efficiency audits. c. Compliance audits. d. Program audits.

1.36 The objective in an auditor’s review of credit ratings of a client’s customers is to obtain evi- dence related to management’s assertion about a. Completeness. b. Existence. c. Valuation and allocation. d. Rights and obligations. e. Occurrence.

1.37 Jones, CPA, is planning the audit of Rhonda’s Company. Rhonda verbally asserts to Jones that all expenses for the year have been recorded in the accounts. Rhonda’s representation in this regard a. Is sufficient evidence for Jones to conclude that the completeness assertion is supported

for expenses. b. Can enable Jones to minimize the work on the gathering of evidence to support Rhonda’s

completeness assertion. c. Should be disregarded because it is not in writing. d. Is not considered a sufficient basis for Jones to conclude that all expenses have been

recorded.

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1.38 The risk to investors that a company’s financial statements may be materially misleading is called a. Client acceptance risk. b. Information risk. c. Moral hazard. d. Business risk.

1.39 When auditing merchandise inventory at year-end, the auditor performs audit procedures to ensure that all goods purchased before year-end are received before the physical inventory count. This audit procedure provides assurance about which management assertion? a. Cutoff. b. Existence. c. Valuation and allocation. d. Rights and obligations. e. Occurrence.

1.40 When auditing merchandise inventory at year-end, the auditor performs audit procedures to obtain evidence that no goods held on consignment are included in the client’s ending inven- tory balance. This audit procedure provides assurance about which management assertion? a. Completeness. b. Existence. c. Valuation and allocation. d. Rights and obligations. e. Occurrence.

1.41 When an auditor reviews additions to the equipment (fixed asset) account to make sure that fixed assets are not overstated, she wants to obtain evidence as to management’s assertion regarding a. Completeness. b. Existence. c. Valuation and allocation. d. Rights and obligations. e. Occurrence.

1.42 The Sarbanes–Oxley Act of 2002 generally prohibits public accounting firms from a. Acting in a managerial decision-making role for an audit client. b. Auditing the firm’s own work on an audit client. c. Providing tax consulting to an audit client without audit committee approval. d. All of the above.

1.43 Substantial equivalency refers to a. An auditor’s tendency not to believe management’s assertions without sufficient

corroboration. b. Providing consulting work for another firm’s audit client in exchange for the other firm’s

providing consulting services to one of your clients. c. The waiving of certification exam parts for an individual holding an equivalent certifica-

tion from another professional organization. d. Permitting a CPA to practice in another state without having to obtain a license in that

state.

1.44 Which of the following best describes the relationship between auditing and attestation engagements? a. Auditing is a subset of attestation engagements that focuses on the certification of finan-

cial statements. b. Attestation is a subset of auditing that provides lower assurance than that provided by an

audit engagement.

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c. Auditing is a subset of attestation engagements that focuses on providing clients with advice and decision support.

d. Attestation is a subset of auditing that improves the quality of information or its context for decision makers.

1.45 During an audit of a company’s cash balance on a company with operations in only one country, the auditor is most concerned with which management assertion? a. Existence. b. Rights and obligations. c. Valuation or allocation. d. Occurrence.

1.46 When auditing an investment in a publicly-traded company, an auditor most likely would seek to conduct which audit procedure to help satisfy the valuation assertion? a. Inspect the stock certificates evidencing the investment. b. Examine the audited financial statements of the investee company. c. Review the broker’s advice or canceled check for the investment’s acquisition. d. Obtain market quotations from The Wall Street Journal or another independent source.

1.47 Cutoff tests designed to detect valid sales that occurred before the end of the year but have been recorded in the subsequent year would provide assurance about management’s asser- tion of a. Presentation and disclosure. b. Completeness. c. Rights and obligations. d. Existence.

1.48 Which of the following audit procedures probably would provide the most reliable evidence related to the entity’s assertion of rights and obligations for the inventory account? a. Trace test counts noted during physical count to the summarization of quantities. b. Inspect agreements for evidence of inventory held on consignment. c. Select the last few shipping advices used before the physical count and determine whether

the shipments were recorded as sales. d. Inspect the open purchase order file for significant commitments to consider for

disclosure.

1.49 In auditing the accrued liabilities account on the balance sheet, an auditor’s procedures most likely would focus primarily on management’s assertion of a. Existence or occurrence. b. Completeness. c. Presentation and disclosure. d. Valuation or allocation.

1.50 Which of the following best describes the focus of the following engagements?

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Auditing Engagement Attestation Engagement

Assurance Engagement

Consulting Services Engagement

a. Any information Financial statements Advice and decision support

Financial information

b. Financial information Advice and decision support

Financial statements Any information

c. Advice and decision support

Any information Financial information Financial statements

d. Financial statements Financial information Any information Advice and decision support

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1.51 Which of the following is a reason to obtain professional certification? a. Certification provides credibility that an individual is technically competent. b. Certification often is a necessary condition for advancement and promotion within a pro-

fessional services firm. c. Obtaining certification is often monetarily rewarded by an individual’s employer. d. All of the above.

1.52 During an audit of an entity’s stockholders’ equity accounts, the auditor determines whether there are restrictions on retained earnings resulting from loans, agreements, or state law. This audit procedure most likely is intended to verify management’s assertion of a. Existence or occurrence. b. Completeness. c. Valuation or allocation. d. Presentation and disclosure.

1.53 When auditing the accounts receivable account on the balance sheet, an auditor’s procedures most likely would focus primarily on management’s assertion of a. Existence. b. Completeness. c. Presentation and disclosure. d. Rights and obligations.

1.54 An auditor selected items for test counts from the client’s warehouse during the physical inventory observation. The auditor then traced these test counts into the detailed inventory listing that agreed to the financial statements. This procedure most likely provided evidence concerning management’s assertion of a. Rights and obligations. b. Completeness. c. Existence. d. Valuation.

1.55 An auditor’s purpose in auditing the information contained in the pension footnote most likely is to obtain evidence concerning management’s assertion about a. Rights and obligations. b. Existence. c. Presentation and disclosure. d. Valuation.

1.56 Which of the following would best be described as an attest engagement? a. An engagement to implement an ERP system. b. An engagement to develop a more efficient payroll process. c. An engagement to assess the effectiveness of an internal control system. d. An engagement to assist the client in an IRS audit.

1.57 An auditor seeks to test the accuracy of the amount recorded as revenue on a contract with a customer under ASC 606. Which PCAOB assertion is most likely being tested? a. Rights and Obligations. b. Valuation and Allocation c. Presentation and Disclosure. d. Completeness.

1.58 In testing the goodwill at an audit client in the retail industry, an auditor may seek to deter- mine whether the account balance had been impaired. Such impairment procedures would be designed to test which financial statement assertion? a. Existence. b. Completeness. c. Presentation and Disclosure. d. Valuation.

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1.59 In testing inventory at an audit client in the retail industry, you note that some of the inven- tory is contracted to be held on consignment. As a result, which financial statement assertion is now relevant? a. Rights and obligations. b. Completeness. c. Existence or occurrence. d. Valuation or allocation.

1.60 Audit, Attestation, and Assurance Services. Following is a list of various professional ser- vices. Identify each by its apparent characteristics as audit engagement, attestation engage- ment, or assurance engagement. Because audits are a subset of attestation engagements, which are a subset of assurance engagements, choose the most specific description. In other words, if you believe the engagement is an audit engagement, select only audit engagement rather than checking all three. Similarly, the choice of assurance engagement for an audit, while technically correct, would not be the best choice.

LO 1-2

Select Exercises and Problems are available with Connect.

Exercises and Problems

  Audit Engagement Attestation Engagement Assurance Engagement

Real estate demand studies      

Ballot for awards show      

Utility rates applications      

Newspaper circulation audits      

Third-party reimbursement maximization      

Annual financial report to stockholders      

Rental property operation review      

Examinations of financial forecasts and projections      

Customer satisfaction surveys      

Compliance with contractual requirements      

Benchmarking/best practices      

Evaluation of investment management policies      

Information systems security reviews      

Productivity statistics      

Internal audit strategic review      

Financial statements submitted to a bank loan officer      

1.61 Controller as Auditor. The chairman of the board of Hughes Corporation proposed that the board hire as controller a CPA who had been the manager of the team that conducted Hughes Corporation’s audit engagement. The chairman thought that hiring this person would make the annual audit unnecessary and would consequently result in saving the professional fee paid to the auditors. The chairman proposed to give this new controller a full staff to conduct such investigations of accounting and operating data as necessary. Evaluate this proposal.

1.62 Management Assertions. Complete the following chart indicating the corresponding Audit- ing Standards Board assertions and whether the assertion relates to transactions, balances, or disclosures.

LO 1-4

LO 1-3

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1.63 Management Assertions. Your audit manager has asked you to explain the PCAOB asser- tions by using an account on the balance sheet at your audit client. For the accounts receiv- able account, please define each of the PCAOB assertions, using the accounts receivable account as a way to illustrate each assertion. You are encouraged to reference Exhibit 1.5 to help you answer this question.

1.64 Operational Auditing. Bigdeal Corporation manufactures paper and paper products and is trying to decide whether to purchase Smalltek Company. Smalltek has developed a process for manufacturing boxes that can replace containers that use fluorocarbons for expelling a liquid product. The price may be as high as $45 million. Bigdeal prefers to buy Smalltek and integrate its products while leaving the Smalltek management in charge of day-to-day operations. A major consideration is the efficiency and effectiveness of Smalltek’s opera- tions. Bigdeal wants to obtain a report on the operational efficiency and effectiveness of the Smalltek sales, production, and research and development departments.

Required: Who can Bigdeal engage to produce the report resulting from this operational audit? Several possibilities exist. Are there any particular advantages or disadvantages in choosing from among them?

1.65 Auditor as Guarantor. Your neighbor, Loot Starkin, invited you to lunch yesterday. Sure enough, it was no “free lunch” because Loot wanted to discuss the annual report of Dodge Corporation. He owns Dodge stock and just received the annual report. Loot says, “Our auditors prepared the audited financial statements and gave an unqualified opinion, so my investment must be safe.”

Required: What misconceptions does Loot Starkin seem to have about the auditor’s role with respect to Dodge Corporation?

1.66 Identification of Audits and Auditors. Audits may be characterized as (a) financial state- ment audits, (b) compliance audits, (c) economy and efficiency audits, and (d) program results audits. The work can be done by independent (external) auditors, internal auditors, or governmental auditors (including IRS auditors and federal bank examiners). Following is a list of the purposes or products of various audit engagements:

LO 1-3

LO 1-5, 1-6

LO 1-1, 1-2

LO 1-6

PCAOB Assertion Corresponding ASB Assertion Nature of Assertion

Existence or Occurrence    

     

   

 

Rights and Obligations    

 

Completeness    

 

 

 

Valuation and Allocation    

 

 

   

Presentation and Disclosure    

 

   

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Required: For each of the engagements listed, indicate (1) the type of audit (financial statement, com- pliance, economy and efficiency, or program results) and (2) the type of auditors you would expect to be involved.

1.67 Financial Assertions and Audit Objectives. You are engaged to examine the financial state- ments of Spillane Company for the year ended December 31. Assume that on November 1, Spillane borrowed $500,000 from Second National Bank to finance plant expansion. The long-term note agreement provided for the annual payment of principal and interest over five years. The existing plant was pledged as security for the loan. Due to the unexpected difficulties in acquiring the building site, the plant expansion did not begin on time. To use the borrowed funds, management decided to invest in stocks and bonds and on November 16, invested the $500,000 in publicly traded securities.

Required: Identify the relevant financial statement assertions for the publicly traded securities account (an asset) based on the PCAOB’s five management assertions about the financial statements.

1.68 Internet Exercise: Professional Certification. Each state has unique rules for certifica- tion concerning education, work experience, and residency. Visit the website for your state board of accountancy and download a list of the requirements for becoming a CPA in your state. Although not all of the state boards of accountancy have websites, you can find those of most states by accessing the National Association of State Boards of Accountancy at its website (www.nasba.org).

1.69 Internet Exercise: Professional Certification. Visit the website of the Institute of Inter- nal Auditors (www.theiia.org), the Institute of Management Accountants (www.imanet.org), the Association of Certified Fraud Examiners (www.acfe.com), or the Information Systems Audit and Control Association (www.isaca.org). Review the information regarding the cer- tifications available. Does the organization explain the benefits of having its certification? What topics are covered on the certification exam? What are the minimum requirements to take the exam? What additional experience is required to receive the certification?

LO 1-3

LO 1-7

LO 1-7

  Type of Audit

Type of Auditor

 1. Analyze proprietary schools’ spending to train students for low-demand occupations.    

 2. Determine whether an advertising agency’s financial statements are fairly presented in conformity with GAAP.    

 3. Study the effectiveness of the Department of Defense’s expendable launch vehicle program.    

 4. Compare costs of municipal garbage pickup services to comparable services subcontracted to a private business.    

 5. Investigate financing terms of tax shelter partnerships.    

 6. Study a private aircraft manufacturer’s test pilot performance in reporting on the results of test flights.    

 7. Conduct periodic examinations by the U.S. Comptroller of Currency of a national bank for solvency.    

 8. Evaluate the promptness of materials inspection in a manufacturer’s receiving department.    

 9. Report on the need for the states to consider reporting requirements for chemical use data.    

10. Render a public report on the assumptions and compilation of a revenue forecast by a sports stadium/racetrack complex.

   

Apollo Shoes Audit Planning Part One You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Water- shed and have been assigned to the engagement team of a new client, Apollo Shoes Inc. As part of the planning process, you need to familiarize yourself with Apollo Shoes. To do so, you will want to review the prior year 10-K, Board of Directors meeting minutes, and CEO letter to the shareholders. Detailed instructions can be found in Connect.

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LEARNING OBJECTIVES Chapter 2 discusses the standards that govern the conduct of audit examinations (generally accepted auditing standards) and how these standards offer the explicit guidance that must be followed during audits. In addition, Chapter 2 identifies important policies and procedures implemented by auditing firms (through a system of quality control) to ensure that the firms’ audits comply with appropriate professional standards and can withstand scrutiny

by regulatory bodies. Finally, the chapter discusses external monitoring efforts that evaluate the quality of audit firms’ work.

Your objectives are to be able to

LO 2-1 Understand the development and source of generally accepted auditing standards.

LO 2-2 Describe the fundamental principle of responsibilities and how this principle relates to the characteristics and qualifications of auditors.

Bernard Madoff, money manager, approximately one year prior to being arrested for embezzling $50 billion from investors in a Ponzi scheme

In today’s regulatory environment, it’s virtually impossible to

violate rules.

Professional Standards

C H A P T E R 2

Professional Standards References

Topic AU-C/ISA Section

AS Section

Overall Objectives of the Independent Auditor 200 1001 1005  1010 1015

Quality Control for an Audit Engagement 220 1220

Audit Planning 300 2101

Supervision of the Audit Engagement 300 1201

Identifying and Assessing the Risks of Material Misstatement 315 2110

Materiality 320 2105

Audit Evidence 500 1105

Reporting on Financial Statements 700 3101

Modifications to Reports on Financial Statements 705 3105

Quality Control QC 10 1110, QC 20

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INTRODUCTION The introductory quote from Bernie Madoff suggests that a strong regulatory environ- ment results in compliance with established rules (despite the fact that Madoff himself did not do so!). Who sets the rules and standards for audits? Until 2002, the accounting profession was self-regulated; that is, the standards governing audits were established by members of the profession themselves through the American Institute of Certified Public Accountants (AICPA). Although critics indicated that self-regulation was akin to having university students establish the systems used to determine their grades, this practice con- tinued for more than 60 years and, although some concerns were raised during this time, remained largely unchanged.

Motivated to a great extent by the audit failures related to Enron and WorldCom, Con- gress passed the Sarbanes–Oxley Act of 2002 (Sarbanes–Oxley). Among other reforms, this act created the Public Company Accounting Oversight Board (PCAOB) to provide external and independent oversight over the audits of public entities, or issuers. (An issuer is an entity that offers registered securities, such as stocks and bonds, for sale to the general public.) Among other matters, the PCAOB is responsible for registering public account- ing firms, establishing and enforcing standards for audit engagements, and inspecting the quality of audits conducted by registered public accounting firms.

The PCAOB’s inspection process and public reporting of results have received a great deal of media attention. As one of the “Big Four” accounting firms along with EY, KPMG, and PwC, Deloitte is a premier provider of accounting and auditing ser- vices. With worldwide revenues of more than $43 billion in 2018 and more than 286,200 employees operating in more than 150 countries, Deloitte’s professionals provide ser- vices to leading organizations throughout the world.1 Clearly, it is important for firms such as Deloitte to implement policies, procedures, and standards to ensure the quality of their work to their clients as well as others who rely on their work in making economic decisions.

Since 2009, an international affiliate of Deloitte (Deloitte Touche Tohmatsu Auditores Independentes, also known as Deloitte Brazil) served as the auditor of Gol Intelligent Airlines (a low-cost Brazilian airline).2 In its 2010 audit of Gol’s financial statements, Deloitte Brazil was found to have violated generally accepted auditing standards with respect to obtaining evidence regarding Gol’s maintenance deposit assets and revenues; in addition, Deloitte Brazil failed to address several issues that suggested Gol’s internal control over financial reporting was not operating effectively. As a result, Deloitte Brazil issued false and misleading opinions on Gol’s financial statements and internal control over financial reporting.

In 2012, the PCAOB selected the 2010 Gol audit for review as part of its inspec- tion process. In anticipation of the possibility of receiving a negative inspection report, Deloitte Brazil altered the documentation related to the Gol audit and provided other

1Data are drawn from Deloitte’s 2018 Global Impact Report. 2Much of the factual information in this vignette is drawn from PCAOB Release No. 105-2016-031, In the Matter of Deloitte Touche Tohmatsu Auditores Independentes, December 5, 2016 and the PCAOB enforcement actions related to individual Deloitte personnel.

LO 2-3 Describe the fundamental principle of performance and identify the major activities performed in an audit.

LO 2-4 Understand the fundamental principle of reporting and identify the basic contents of the auditors’ report.

LO 2-5 Understand the role of a system of quality control and monitoring efforts in enabling public accounting firms to meet appropriate levels of professional quality.

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misleading documents and information to the PCAOB inspectors. The following record- ing maintained by one of Deloitte Brazil’s auditors illustrates the nature of these efforts:

Person 1: Any evidence that you have of this, remove it from your machine. Keep it in a – if you have that, keep it somewhere else, but not in your machine, not in the office. Okay?

Person 2: No. Okay. Person 1: Okay? Another thing, considering that he [the partner in charge of the Gol

audit] will take the responsibility for all this, everything you told me, every- thing we discussed, never happened.

Person 2: Okay. Person 1: Never! Whatever happens – I, if somebody says, “No, [other staff at

Deloitte Brazil] said to you-”, I will say “No, there must be a mistake!” I will never admit it was said.

So what was the outcome? Deloitte Brazil settled, with the following sanctions:

∙ Censure ∙ Civil monetary penalty of $8 million (to date, the largest ever levied by the PCAOB;

the second largest was a $2 million penalty assessed to EY in 2012) ∙ Prohibitions from accepting new audit engagements ∙ Required reviews of all work on existing audit clients by Deloitte Global member or

affiliate firms. ∙ Appointment of an independent monitor to review and assess Deloitte Brazil’s quality

control system and evaluate implementation of other sanctions.

In addition to these firmwide sanctions, 12 individuals affiliated with Deloitte Brazil were censured and sanctioned through monetary penalties, disbarment from affiliating with PCAOB-registered accounting firms (for periods ranging from one year to perma- nent), suspensions, or other restrictions on audit-related responsibilities. Then-PCAOB Director of Enforcement Claudius Modesti commented that Deloitte’s actions were “the most serious misconduct we’ve discovered.”3

The preceding vignette illustrates the powerful role of the PCAOB and its significant impact on regulation in the accounting profession. The following summarizes PCAOB enforcement activity for the three-year period 2016–2018.4

3“Bother in Brazil,”The Economist, December 10, 2016, pp. 63-64. 4Disciplinary orders drawn from PCAOB website (https://pcaobus.org/enforcement/Pages/default.aspx).

Settled Actions Adjudicated Actions

Number of cases 128 7 Disbarment of CPA/revocation of firm registration 84 7 Suspension of CPA/suspension of firm registration 13 0 Withdrawal of firm registration from PCAOB 8 0 Cases involving Big Four firms 18 1 # / total monetary penalties  83 / $15.4 million 7 / $842,500 Range of monetary penalties $1,000–$8 million $2,500–$150,000

This vignette illustrates the public scrutiny placed on policies and procedures imple- mented by firms to conduct quality audits. Although situations like these, as well as the Madoff fraud referenced in the opening quote to this chapter, are exceptions rather than the rule, accounting firms clearly are being held to a higher standard for the quality of their work, and failures are receiving intense attention in the media. The development of professional auditing standards, actions taken by audit firms to ensure that their audits comply with these standards, and monitoring efforts by external bodies (such as the PCAOB) to evaluate the quality of audit firms’ work are the focal points of this chapter.

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GENERALLY ACCEPTED AUDITING STANDARDS (GAAS) At least two historical milestones had a significant impact on the development of audit- ing standards. In 1938, a scandal of epic proportions broke at McKesson & Robbins, a large pharmaceutical company. Price Waterhouse & Co. (now PwC), the company’s auditor for more than 10 years, failed to discover that the company had inflated inven- tory and receivables through the falsification of supporting documents (including one phony shipment from the United States to Australia by truck!). Auditors merely accepted management’s assertions about inventory and receivables balances without verifying their existence. The accounting profession reacted quite strongly to the scandal by task- ing the AICPA to develop standards that served as the basis for audits of both issuers and non-issuers (nonpublic entities). From 1939 through 2002, the AICPA’s Auditing Standards Board issued Statements on Auditing Procedures (1939–1972) and State- ments on Auditing Standards (SASs) (1972–present) to provide guidance for the conduct of audits.5

A second defining moment in the development of auditing standards was the mas- sive frauds at Enron and WorldCom (and the inability of those entities’ auditors to identify the frauds). In response to these failures, Sarbanes–Oxley (which was passed by a vote of 99-0 in the U.S. Senate!) created the PCAOB and delegated the respon- sibility for developing standards for the audits of issuers to this body. The PCAOB issues Auditing Standards, which are subject to the formal approval of the Securities and Exchange Commission (SEC). The authorization for developing standards for the audits of non-issuers continues to remain with the Auditing Standards Board of the AICPA.

Until 2016, PCAOB standards consisted of a combination of Auditing Standards issued by the PCAOB and standards issued by the AICPA that had not been superseded by the PCAOB (referred to as Interim Auditing Standards). Effective December 31, 2016, the PCAOB has reorganized and combined these standards into a single body of pronouncements. Appendix 2A illustrates how auditors utilize the PCAOB and ASB standards in providing appropriate professional guidance.

The relevant pronouncements of the AICPA and PCAOB are collectively referred to as generally accepted auditing standards (GAAS).6 GAAS are auditing standards that identify necessary qualifications and characteristics of auditors and guide the conduct of the audit examination. The purpose of GAAS is to meet the objectives of an audit examination, which are (AU-C 200.12):

∙ To obtain reasonable assurance about whether the financial statements as a whole are free of material misstatement, whether due to fraud or error.

∙ To issue a report on the financial statements.

Generally, auditors who do not follow the guidance provided in GAAS are presumed to have performed deficient audits. The auditing standards also includes interpretive pub- lications (which includes Interpretations, exhibits, AICPA Audit and Accounting Guides, and AICPA Auditing Statements of Position). Although officially considered less authori- tative and less binding than the guidance in the SASs and Auditing Standards, auditors still must justify any departures from these publications, which provide guidance on the application of GAAS in specific circumstances, including engagements for entities in certain industries. The relationship among these various pronouncements is summarized in the following graphic.

LO 2-1 Understand the development and source of generally accepted auditing standards.

5Statements on Auditing Standards (SAS) are authoritative AICPA pronouncements on auditing theory and practice. Statements on Auditing Procedure (SAP) Nos. 1–54 were codified into SAS 1 in 1972. 6The auditing standards for public entities are sometimes referred to as PCAOB Standards to distinguish them from the standards for nonpublic entities.

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Auditing standards are quite different from audit procedures. Audit procedures are the particular and specialized actions that auditors take to obtain evidence in a specific audit engagement. Auditing standards, on the other hand, are quality guides to the audit that apply to all audits. For example, auditing standards indicate that auditors must determine that recorded accounts receivable are based on actual sales to customers. An audit proce- dure used to satisfy that standard is to confirm accounts receivable with the company’s customers. This difference is the reason auditors’ reports refer to an audit “conducted in accordance with standards of the Public Company Accounting Oversight Board” [emphasis added] rather than in accordance with audit procedures.

In addition to the standards for U.S. issuers and non-issuers, it is important to note that separate auditing standards have been developed for governmental and foreign entities. A summary of the body charged with establishing standards as well as the standards themselves for various types of audits follows.

Collectively Referred to as GAAS

Guide general conduct of audit engagements

Provide requirements supporting fundamental principles

Provide guidance on the application of GAAS

Fundamental Principles

PCAOB Auditing Standards and ASB Statements on Auditing Standards

Interpretive Publications

  Issuers Non-issuers Governmental Entities Foreign Entities

Rule-making body Public Company Accounting Oversight Board (PCAOB)

AICPA Auditing Standards Board (ASB)

U.S. Government Accountability Office (GAO)

International Auditing and Assurance Standards Board (IAASB)

Standards Auditing Standards (ASs)

Statements on Auditing Standards (SASs)

Government Auditing Standards (The Yellow Book)

International Standards on Auditing (ISAs)

Website www.pcaobus.org www.aicpa.org www.gao.gov www.ifac.org

If an accounting firm audits issuers and non-issuers throughout the world, that firm may be subject to multiple (sometimes conflicting) standards issued by the ASB, PCAOB, and IAASB, among others. For this reason, auditors and regulators have a great interest in convergence—that is, making the standards coordinated, if not uniform, throughout the world. The ISAs are a first step in the development of one consistent set of guidelines that auditors worldwide can follow. Although the focus in this text will be on audits of U.S. issuers and non-issuers (and therefore pronouncements of the PCAOB and ASB), it is important that students be aware that additional standards exist related to the audits of governmental and foreign entities.

Organization of GAAS The body of GAAS is based on three fundamental principles identified by the ASB that underlie all audits. These fundamental principles relate to (1) responsibilities of the audit team, (2) performance of the audit, and (3) reporting the results of the engagement. They

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are established to meet the objectives of an audit and are supported by objectives and requirements of specific SASs. While these principles have been issued by the ASB and are not formally applicable to the audits of issuers, they are consistent with and reflect the requirements of GAAS for audits of issuers.

Recall from Chapter 1 the definition of auditing as

REVIEW CHECKPOINTS 2.1 Define generally accepted auditing standards (GAAS). What is the purpose of GAAS? 2.2 Who is responsible for developing standards for the audits of issuers? Who is responsible for devel-

oping standards for the audits of non-issuers? 2.3 Identify the role of the following bodies in the auditing standards-setting process: (1) the AICPA; (2)

the PCAOB; (3) the SEC. 2.4 Identify the three fundamental principles underlying GAAS.

Auditors are responsible for:

• Having appropriate competence and capabilities to perform the audit.

• Complying with relevant ethical requirements. • Maintaining professional skepticism and exercising professional

judgment throughout the planning and performance of the audit.

Closer examination of the fundamental principles reveals that they closely parallel that definition. For example, the responsibilities principle defines objectivity and identifies the important role that objectivity plays in the audit. The performance principle requires, among other things, auditors to plan the work (i.e., conduct the audit using a “systematic process”) and to “obtain and evaluate evidence” through assessing the risk of material misstatement and gathering sufficient appropriate evidence. Finally, the reporting principle provides guidance for “communicating the results” of the audit about whether the financial statements are pre- pared using “established criteria” (an applicable financial reporting framework, or GAAP).

. . . a systematic process of objectively obtaining and evaluating evidence regarding assertions about economic actions and events to ascertain the degree of correspondence between the assertions and established criteria and communicating the results to interested users.

FUNDAMENTAL PRINCIPLE: RESPONSIBILITIES The fundamental principle of responsibilities relates to the personal integrity and profes- sional qualifications of auditors. This principle addresses the following responsibilities of auditors:

LO 2-2 Describe the fundamental principle of responsibilities and how this principle relates to the characteristics and qualifications of auditors.

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As shown in the following figure, most of the issues related to responsibilities are addressed before a firm accepts a prospective client. However, professional skepticism and professional judgment must be considered and exercised by the auditor throughout the entire engagement.

Competence and capabilities

Relevant ethical requirements (independence)

Professional skepticism and professional judgment Relevant ethical requirements (due care)

STAGES OF AN AUDIT

Obtain (or Retain)

Engagement

Engagement Planning

Risk Assessment

Audit Evidence Reporting

Competence and Capabilities Competence and capabilities begin with education in accounting because auditors hold themselves out as experts in accounting standards, financial reporting, and auditing. In addition to university-level education prior to beginning their careers, auditors are required to participate in continuing professional education throughout their careers to ensure that their knowledge keeps pace with changes in the accounting and auditing pro- fession. In fact, one of the important requirements for maintaining a CPA license is suf- ficient continuing professional education.

Education is only one element of competence and capabilities. Another important dimension is experience, which is gained with hands-on practice and on-the-job train- ing. An important component of this experience is the ability to develop and apply professional judgment in real-world audit situations. These situations include various judgments related to gathering evidence as to the fairness of an entity’s financial state- ments and evaluating whether that evidence indicates that the financial statements are prepared according to generally accepted accounting principles. (Professional judg- ment is also an important component of the performance principle, which will be dis- cussed later.)

Independence and Due Care The responsibilities principle requires auditors to comply with appropriate ethical requirements; two important requirements relate to independence and due care. Audi- tors must maintain independence in mental attitude; that is, auditors are expected to be unbiased and impartial with respect to the financial statements and other informa- tion they audit. This “state of mind” is often referred to as the auditor possessing inde- pendence in fact. This independence allows auditors to form an opinion on the entity’s financial statements without being affected by influences that might compromise that opinion.

It is not only important for auditors to be unbiased; they must also appear to be unbi- ased. Independence in appearance relates to others’ (particularly financial statement users’)

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perceptions of auditors’ independence. For example, imagine that the son or daughter of your professor was enrolled in your class. While your professor may truly be unbiased and evaluate the child fairly, it is unlikely that you and your classmates would believe your professor to be independent.

Although independence is a complex concept and many different threats to indepen- dence exist, two general types of relationships that are believed to jeopardize (or compro- mise) independence are

1. Financial relationships, such as owning shares of stock in a client or having a loan outstanding to or from a client.

2. Managerial relationships, such as the ability to act in a decision-making capacity on behalf of a client or to provide advice on systems or information that will subsequently be audited. (For example, some questions were raised when the lead audit partner of PwC on the Mattel audit recommended candidates for senior-level finance positions within Mattel).7

Clearly, the relationships just listed would impair perceptions of auditors’ indepen- dence, but other considerations are necessary. For example, although it seems safe to conclude that an audit team member’s spouse should be restricted from the preceding types of relationships for a client for which the team member is providing services, could that spouse have these types of relationships with respect to a client served by a distant office of the team member’s firm? Could the audit team member’s third cousin have such relationships?

It is difficult to think of a matter more fundamental to the value of an audit than independence. Without independence, third-party users are not able to rely on the auditor’s work and opinion on the entity’s financial statements. The preceding discus- sion identifies some of the major factors affecting independence, but the possible rela- tionships involving auditors, entities, and their personnel are endless; the complexities of these relationships have resulted in a number of interpretations and ethics rulings regarding auditor independence. Many individuals fundamentally question whether auditors can be independent given the fee arrangement they have with their clients. (Imagine the situation if you directly paid your professor instead of the university for your tuition!) In addition, the often long-standing relationships between auditors and their clients have resulted in some attempts to require periodic rotation of audit firms to lessen the impact of financial relationships between these two parties and enhance independence.

Issues related to auditor independence may provide some significant challenges in practice. For example, an investigation in 2000 of independence violations at PwC revealed that “.  .  . approximately 86.5 percent of PwC partners and 10.5 percent of all other PwC professionals had independence violations.”8 The Auditing Insight “Carillion and Independence” summarizes a case that raised concerns about auditor independence.

This section introduces the concept of auditor independence and provides a limited overview of issues that impact auditor independence. A detailed discussion of AICPA and SEC rules related to independence (and various interpretations of those rules) is provided in Module B.

A second ethical requirement identified by the responsibilities principle is that of due care. Due care reflects a level of performance that would be exercised by reasonable auditors in similar circumstances. This standard is often referred to as that of a prudent auditor; auditors are expected to possess the skills and knowledge of others in their pro- fession but are not expected to be infallible. This aspect relates to the competence and

7“Mattel’s Finance Chief to Leave,” The Wall Street Journal, October 30, 2019, p. B5. 8“Independent Consultant Finds Widespread Independence Violations at PricewaterhouseCoopers,” SEC Press Release 2000–4, January 6, 2000.

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capabilities of the auditor to perform the engagement and issue appropriate reports. One specific element of due care noted by the standards is the need for auditors to plan and perform the audit with an appropriate level of professional skepticism as discussed in the following section.

Professional Skepticism and Professional Judgment Professional skepticism and professional judgment are necessary responsibilities of audi- tors throughout the entire audit process. Professional skepticism (which was introduced in Chapter 1) is a state of mind that is characterized by appropriate questioning and a critical assessment of audit evidence. When exhibiting professional skepticism, auditors do not assume that management is dishonest, nor do they assume that management is unques- tionably honest. Rather, auditors evaluate and consider

∙ Contradictory audit evidence obtained through different procedures. ∙ The reliability of documentary evidence. ∙ The reliability of information obtained from management and those charged with gov-

ernance of the entity (e.g., the audit committee).

Although the preceding discussion suggests that professional skepticism is a relatively straightforward concept, situations occur during the audit that could impede auditors’ abil- ity to apply appropriate levels of professional skepticism. A PCAOB Staff Practice Alert9 identified the following conditions that present challenges for auditors maintaining appro- priate levels of professional skepticism; these conditions may result in auditors failing to appropriately question, assess, and evaluate evidence, and, ultimately, reach the correct conclusion during their engagement:

∙ Financial incentives and pressures (such as building or maintaining a long-term audit engagement, facing pressures to keep audit fees low, achieving high levels of client satisfaction, and providing other fee-related services to clients).

∙ Time pressures (such as completing the audit and report prior to deadlines and sched- uling and workload demands on partners and other audit team members).

∙ Personal relationships developed with clients that provide auditors with an inappropri- ate level of trust or confidence in management.

Professional judgment is the application of relevant training, knowledge, and experience in making informed decisions about appropriate courses of action during the audit engagement.

9Staff Audit Practice Alert No. 10, “Maintaining and Applying Professional Skepticism in Audits,” PCAOB, December 4, 2012.

Issues related to the importance of independence have been raised following the collapse of Carillion, the second largest United Kingdom (U.K). construction company with over 43,000 worldwide employees. Two U.K. House of Commons committees noted that “. . . conflicts of interest at every turn” resulted in KPMG’s failure to challenge ques- tionable accounting practices at Carillion.

The U.K.’s Competition and Markets Authority (CMA) has rec- ommended that the Big Four split their auditing and nonauditing functions into separate operating entities (currently, nonauditing services account for over 75 percent of total firm revenues and unlike U.S. firms, U.K. firms can provide significant levels of

consulting services to audit clients). In addition, the CMA recom- mends that the audit of larger companies be conducted by two firms (one of which is a non-Big Four firm), in an effort to spur competition. In response to these recommendations, two Big Four firms (PwC and KPMG) have announced restructuring of their audit practices.

Sources: “Big Four Auditors Face New U.K. Calls to Break Part,” The Wall Street Journal Online, May 16, 2018; “U.K. Toughens Auditor Rules,” The Wall Street Journal, December 19, 2018, p. B11; “KPMG to Restructure Audit Business in U.K.,” CFO.com, May 17, 2019; “PwC Revamps Audit Business in Britain,” The Wall Street Journal, June 6, 2019, p. B10.

Carillion and IndependenceAUDITING INSIGHT

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These judgments relate to the evidence obtained during the audit and the conclusions reached based on this evidence. Auditors are required to demonstrate this characteristic throughout the entire audit process as they do professional skepticism. Professional judgment is required as auditors gather evidence, evaluate evidence, and draw conclusions based on evidence. Professional judgment is particularly important in evaluating the reasonableness of various management estimates required in preparing the entity’s financial statements.

In addition to demonstrating appropriate levels of professional judgment, auditors are required to carefully document their professional judgment in such a manner that experi- enced auditors with no previous relationship with the audit can understand the judgments made in reaching conclusions on significant issues.

A preliminary investigation of the actions of David Friehling (the indi- vidual responsible for the audits of Bernard L. Madoff Investment Securities LLC) illustrated the following potential violations of ele- ments of the responsibilities principle:

• Friehling did not verify the existence of assets or securities trades made by Madoff’s company, suggesting a lack of professional skepticism and a lack of due care.

• Friehling was the sole auditor at Friehling and Horowitz, raising the question as to whether a “one-man” firm has the capability to effectively audit a company as large as Madoff’s.

• Friehling and his family had investment accounts at Madoff’s com- pany worth more than $14 million, a conflict of interest that raises questions about his independence.

Source: “Accountant Arrested for Sham Audits,” The Wall Street Journal, March 19, 2009, p. C1.

Madoff and the Responsibilities PrincipleAUDITING INSIGHT

REVIEW CHECKPOINTS 2.5 Distinguish between independence in fact and independence in appearance. Can auditors be inde-

pendent in fact yet not be perceived to be independent in appearance? 2.6 What is due care? To what standards are auditors held with respect to due care? 2.7 Define professional skepticism and professional judgment. During what stages of the audit are

auditors required to demonstrate these characteristics?

FUNDAMENTAL PRINCIPLE: PERFORMANCE The fundamental principle of performance sets forth general quality criteria for con- ducting an audit. As noted in the preceding section, in addition to the elements of this principle, the performance of the audit is influenced by the need for auditors to exercise professional skepticism and professional judgment throughout the audit process. The performance principle states that

LO 2-3 Describe the fundamental principle of performance and identify the major activities performed in an audit.

To express an opinion, the auditor obtains reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error. To obtain reasonable assurance, which is a high but not absolute level of assurance, the auditor:

• Plans the work and properly supervises any assistants.

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As the preceding reflects, the performance principle contains five elements: (1) rea- sonable assurance, (2) planning and supervision, (3) materiality, (4) risk assessment, and (5) audit evidence. These are discussed in the remainder of this section.

Reasonable Assurance The concept of reasonable assurance recognizes that a GAAS audit may not detect all material misstatements and auditors are not “insurers” or “guarantors” regarding the fair- ness of the entity’s financial statements. However, auditors should provide a high level of assurance (or confidence) regarding their work. Auditors provide reasonable assurance through considering various risks relating to the likelihood of material misstatement in the financial statements and performing audit procedures to limit the overall risk to an acceptably low level. This is done through the risk assessment process, an additional ele- ment of the performance principle.

Planning and Supervision After obtaining or retaining the engagement, the next major stage of the audit is planning, as in the following figure. The professional standards contain several considerations for planning and supervising an audit. They are concerned with (1) preparing an audit plan and supervising the audit work, (2) obtaining knowledge of the client’s business, and (3) dealing with differences of opinion among the accounting firm’s own personnel.

Obtain (or Retain)

Engagement

Engagement Planning

Risk Assessment

Audit Evidence Reporting

STAGES OF AN AUDIT

• Determines and applies appropriate materiality level or levels throughout the audit.

• Identifies and assesses risks of material misstatement, whether due to fraud or error, based on an understanding of the entity and its environment, including the entity’s internal control.

• Obtains sufficient appropriate audit evidence about whether material misstatements exist, through designing and imple- menting appropriate responses to the assessed risks.

GAAS require the preparation of a written audit plan. An audit plan is a list of the audit procedures that auditors need to perform to gather sufficient appropriate evidence on which to base their opinion on the financial statements. The procedures in an audit plan should be stated in enough detail to instruct the assistants about the work to be done. (You will see detailed audit plans later in this textbook.)

Auditors are also required to obtain an understanding of the client’s business and indus- try. This knowledge helps auditors identify areas for special attention (the accounts or classes of transactions where frauds or errors might exist), evaluate the reasonableness of accounting estimates made by management, evaluate management’s responses to inqui- ries, and make judgments about the appropriateness of management’s choices among

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accounting principles. Auditors gain this understanding of a business through discussions with management and other client personnel; through experience with other entities in the same industry; and by reviewing AICPA accounting and audit guides, industry publi- cations, other entities’ financial statements, business periodicals, and textbooks.

Just as having advance notice of assignments and examinations makes it easier for you (as a student) to perform better on those assignments, timing is important for audit planning. To have time to plan an audit, auditors should be engaged before the client’s fiscal year-end. The more advance notice auditors have, the better they are able to pro- vide enough time for planning. The audit team may be able to perform part of the audit at an interim date—a date some weeks or months before year-end—and thereby make the rest of the audit work more efficient. For example, in examining property, plant, and equipment, auditors may evaluate activity in the account balance up to some date during the year (say, September 30) prior to year-end (December 31) and then evaluate activ- ity occurring between that date and December 31 following year-end (the roll-forward period), as shown in the following graphic. Essentially, at December 31, auditors have evaluated the account balance through the interim date (in this case, September 30) and will evaluate the remainder of the activity following year-end. Doing so permits audit work to be “shifted” from after year-end to prior to year-end and allows the audit to be completed on a more timely basis.

December 31January 1

Evaluate activity from January 1 through September 30

Evaluate activity from November 10 through December 31

Normal year-end workPlanning and interim work

Engagement planning is discussed in greater detail in Chapter 3. In addition, planning activities related to the audit of various accounts and cycles are discussed in Chapters 6, 7, 8, 9, and 10.

In its Form 12b-25 filing with the SEC, U.S. Premium Beef LLC dis- closed that it dismissed KPMG as its auditor and engaged PwC on February 28, 2012. Because of the late appointment of PwC and its inability to plan and perform the audit on a timely basis (U.S. Premium

Beef had a December 31 year-end), the company was unable to meet the deadline for filing its financial statements with the SEC. Sources: U.S. Premium Beef LLC Form 12b-25 (dated March 29, 2012); U.S. Premium Beef LLC Form 8-K (dated February 28, 2012).

Too LateAUDITING INSIGHT

Materiality The concept of materiality recognizes that auditors should focus on matters that are impor- tant to financial statement users. One common way of viewing materiality is the dollar amount that would influence the lending or investing decisions of financial statement users. Auditors and users do not expect account balances to be accurate to the penny; after all, many entities round their financial statements to the thousands, or even millions, of dollars! For example, Apple reported net income of $59.5 billion in 2018; clearly, a mis- statement of $1 million (less than 0.2 percent of net income) would not likely affect users’ decisions, but a misstatement of $10 billion (16.8 percent of net income) probably would. Materiality is recognized as part of the objective of an audit, which is “to obtain reason- able assurance about whether the financial statements as a whole are free of material misstatement” [emphasis added] (AU-C 200.12). Materiality is commonly established

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based on percentages of key financial statement subtotals, such as net income, sales or revenues, and total assets.

The audit team considers materiality in planning the audit, performing the audit, and evaluating the effect of misstatements on the entity’s financial statements. Auditors are responsible only for providing reasonable assurance that misstatements material to the entity’s financial statements are identified. Stated another way, auditors are not respon- sible for detecting misstatements that are not material to the financial statements.

Although the concept of materiality appears to be relatively straightforward, imple- mentation of materiality during the audit requires high levels of professional judgment. For example, suppose a small dollar misstatement (in absolute terms) resulted in an entity meeting its earnings expectations or resulted in an entity reporting higher earnings than in the previous year. Certainly, these impacts would likely influence investment decisions, even if the dollar amount is relatively small. Circumstances such as these are referred to as qualitative materiality factors and should also be considered by auditors. The role of materiality in the planning stages of the audit is discussed in more detail in Chapter 3.

Risk Assessment An important part of the performance principle is for auditors to identify important con- cerns (or risks) they face in the audit. This process is referred to as risk assessment:

The risk assessment process requires an understanding of the client, its operating envi- ronment, and its industry. This includes internal controls operating within the client’s accounting information systems that ultimately produce the client’s financial statements. Internal control may be defined as the policies and procedures implemented by an entity to prevent or detect material accounting frauds or errors and provide for their correction on a timely basis. Satisfactory internal control reduces the probability of frauds or errors in the accounts. This understanding provides the foundation for the work auditors do in assessing the risk of material misstatement, a combination of inherent risk (the probability that a material misstatement, either an error or fraud, will occur) and control risk (the probability that a material misstatement, either an error or fraud, will not be prevented or detected on a timely basis by the entity’s internal controls). One way to think of the risk of material misstatement is the likelihood that an error or fraud will exist in the financial statements prior to considering the auditors’ work.

The primary purpose of assessing the risk of material misstatement is to help auditors determine the nature, timing, and extent of further audit procedures necessary for gather- ing evidence about the fairness of the entity’s financial statements. The process of risk assessment presumes two necessary relationships:

1. Effective internal control reduces the control risk, and auditors thus have a reasonable basis for reducing the necessary effectiveness of further audit procedures.

2. Ineffective internal control increases control risk, and auditors must increase the nec- essary effectiveness of further audit procedures.

Because these audit procedures are used to obtain evidence with respect to the fairness of the account balance (i.e., to “substantiate” the account balance), they are referred to

STAGES OF AN AUDIT

Obtain (or Retain)

Engagement

Engagement Planning

Risk Assessment

Audit Evidence Reporting

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as substantive procedures. The auditors’ substantive procedures are reflected in the deter- mination of detection risk, which is discussed in the next section. A depiction of this relationship follows:

E�ective Internal Control Allows auditors to evaluate less evidence and/or use less e�ective substantive procedures

Ine�ective Internal Control Requires auditors to evaluate more evidence and/or use more e�ective substantive procedures

Lower Level of Control Risk

Higher Level of Control Risk

STAGES OF AN AUDIT

Obtain (or Retain)

Engagement

Engagement Planning

Risk Assessment

Audit Evidence Reporting

The importance of internal control in the audit examination is evidenced by an increase in auditors’ responsibility for internal control in the audit of issuers that auditors evalu- ate (through testing the operating effectiveness of specific controls) and report on the effectiveness of an issuer’s internal control over financial reporting. This is one example of auditors’ responsibility in the audit of an issuer exceeding that for the audit of a non- issuer. Internal control is discussed in more detail in Chapter 5; in addition, important elements of internal control related to the audit of various accounts and cycles are dis- cussed in Chapters 6, 7, 8, 9, and 10.

REVIEW CHECKPOINTS  2.8 Define reasonable assurance. How does the audit team provide reasonable assurance in the

engagement?  2.9 What is an audit plan? During which stage of the audit is an audit plan prepared? 2.10 What is an interim date? How do audit procedures conducted prior to an interim date impact the

audit examination? 2.11 What is materiality? During what stages of the audit do auditors consider materiality? 2.12 For what reasons do auditors obtain an understanding of a client’s internal control? 2.13 What is the basic relationship between the effectiveness of the client’s internal control and the

necessary effectiveness of substantive procedures?

Audit Evidence The final element of the performance principle requires that the audit team collects and evaluates sufficient appropriate evidence to provide a reasonable basis for their opinion.

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Evidence is the information that auditors use in arriving at the conclusions on which to base the audit opinion and includes the underlying accounting data and all available corroborating information. Examples of evidence include minutes of meetings, confirma- tions with independent third parties, invoices, analyst reports, and all other information that permits auditors to reach valid, logical conclusions. As noted, the methods auditors use to gather and evaluate this evidence are referred to as substantive procedures, which are performed following the auditors’ risk assessment process.

The performance principle requires auditors to gather “sufficient appropriate” evi- dence. To be considered appropriate, evidence must be trustworthy (reliable) and must provide the audit team with information of interest (relevant). Professional standards note the following with respect to the reliability of evidence:

∙ Evidence created by sources external to the entity is more reliable than that created by the entity. From most to least reliable, sources of evidence are auditors (direct personal knowledge), parties external to the entity (external evidence), and parties internal to the entity (internal evidence).

∙ Evidence created by sources outside the entity is more reliable when received directly from the external source (direct external evidence) than when received from sources internal to the entity (external-internal evidence).

∙ Evidence obtained from entities with more effective internal controls is more reliable than that obtained from entities with less effective internal controls.

∙ Evidence obtained from original source documents is more reliable than that obtained from photocopies, facsimiles, or electronic documents.

Relevance refers to the nature of information provided by the audit evidence; for example, when auditors confirm accounts receivable with customers, this audit procedure provides evidence that the account is legitimate (i.e., the sale actually took place) but does not provide evidence that the account will ultimately be collectible. The nature of information provided by evidence is operationalized through the management assertions identified and discussed in Chapter 1.

Appropriateness relates to evidence quality, and sufficiency relates to evidence quan- tity. For large entities, auditors do not audit all of the transactions and components but examine a sample of these items in drawing their conclusions. Sufficiency relates to the number of transactions or components evaluated.

The sufficiency and appropriateness of evidence are reflected in the necessary level of detection risk. Detection risk represents the risk that the audit team’s substantive pro- cedures will fail to detect a material misstatement. As auditors require a higher quality of evidence (lower detection risk), they must gather more relevant and reliable evidence (appropriateness) and evaluate more transactions or components (sufficiency). Evidence- gathering procedures are discussed in more detail in Chapter 3. In addition, specific approaches to gathering evidence in the examination of various accounts and cycles are discussed in Chapters 6, 7, 8, 9, and 10.

“The level of fraud and financial deception that took place at Health- South is a blatant violation of investor trust, and Ernst & Young is as outraged as the investing public.” In a public statement, the account- ing firm asserted that HealthSouth, one of its largest clients, tried to deceive the firm’s audit team by creating false documents to support fraudulent journal entries. To support the firm’s claim, the statement

cited a court hearing in which a former HealthSouth employee tes- tified that “he knew of at least three occasions where company executives prepared false documents specifically to conceal fraud from Ernst.” Source: WeilStaff, Jonathan. 2003. Did HealthSouth Auditor Ernst Miss Key Clues to Fraud Risks? The Wall Street Journal.

Whom Can You Trust?AUDITING INSIGHT

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Exhibit 2.1 summarizes the key characteristics of evidence just discussed. Note that both the sufficiency and the appropriateness of audit evidence affect detection risk. Also note that the appropriateness is affected by both the relevance of the evidence and its reliability.

EXHIBIT 2.1 Key Characteristics of Audit Evidence

Su�ciency (quantity of evidence)

Detection Risk

Appropriateness (quality of evidence)

Relevance (What does evidence tell

the auditor?)

Reliability (Can the auditor trust the

evidence?)

REVIEW CHECKPOINTS 2.14 Define audit evidence. 2.15 Define external, external-internal, and internal documentary evidence. 2.16 Distinguish between relevance and reliability as these concepts relate to audit evidence. How are

relevance and reliability associated with the appropriateness of audit evidence? 2.17 How does the source of evidence affect its reliability? 2.18 How are the sufficiency and appropriateness of evidence related to detection risk?

FUNDAMENTAL PRINCIPLE: REPORTING  The ultimate objective of the audit—the report on the audit—is guided by the fundamen- tal principle of reporting, which states

LO 2-4 Understand the fundamental principle of reporting and identify the basic contents of the auditors’ report.

Based on evaluation of the evidence obtained, the auditor expresses in the form of a written report, an opinion in accordance with the auditor’s findings, or states that an opinion cannot be expressed. The opinion states whether the financial statements are presented fairly, in all material respects, in accordance with the applicable financial reporting framework.

As the following graphic shows, reporting is the final stage of an audit and occurs following the gathering of audit evidence.

STAGES OF AN AUDIT

Obtain (or Retain)

Engagement

Engagement Planning

Risk Assessment

Audit Evidence Reporting

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Report of Independent Registered Public Accounting Firm

The Board of Directors and Shareholders of Microsoft Corporation

Opinion on the Financial Statements

We have audited the accompanying consolidated balance sheets of Microsoft Corporation and subsidiaries (the “Company”) as of June 30, 2019 and 2018, the related consolidated statements of income, comprehensive income, stockholders’ equity, and cash flows, for each of the three years in the period ended June 30, 2019, and the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Company as of June 30, 2019 and 2018, and the results of its operations and its cash flows for each of the three years in the period ended June 30, 2019, in conformity with accounting principles generally accepted in the United States of America.

We have also audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (“PCAOB”), the Company’s internal control over financial reporting as of June 30, 2019, based on criteria established in Internal Control — Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission and our report dated August 1, 2019, expressed an unqualified opinion on the Company’s internal control over financial reporting.

Basis for Opinion

These financial statements are the responsibility of the Company’s management. Our responsibility is to express an opinion on the Company’s financial statements based on our audits. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

Critical Audit Matters

The critical audit matters communicated below are matters arising from the current-period audit of the financial statements that were communicated or required to be communicated to the Company’s Audit Committee and that: (1) relate to accounts or disclosures that are material to the financial statements and (2) involved our especially challenging, subjective, or complex judgments. The communication of critical audit matters does not alter in any way our opinion on the financial statements, taken as a whole, and we are not, by communicating the critical audit matters below, providing separate opinions on the critical audit matters or on the accounts or disclosures to which they relate.

[Auditors’ report provided description and method of addressing Critical Audit Matters related to Revenue Recognition and Uncertain Tax Positions Related to Transfer Pricing Issues]

DELOITTE & TOUCHE LLP Seattle, Washington

August 1, 2019 We have served as the Company’s auditor since 1983

United States Securities and Exchange Commission. “McDonald’s Corporation 2018 Annual Report.” Accessed February 22, 2019. https://www.sec.gov

EXHIBIT 2.2 Example Auditors’ Report for Issuer (Microsoft Corporation)

An example of an auditors’ report is shown in Exhibit 2.2, and you should review it in relation to the following discussion.

The report in Exhibit 2.2 is the report form used for issuers; differences in wording exist, but the report for non-issuers conveys essentially the same information. You should understand the term financial statements to include not only the traditional financial statements, but also all footnote disclosures and additional information (e.g., earnings per share calculations) that are integral elements of the basic financial presentation required by GAAP.

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The reporting principle requires the auditor to express an opinion on the entity’s financial statements (or indicate that an opinion cannot be expressed). With respect to this requirement, the last sentence in the first paragraph of Deloitte & Touche’s report begins with the phrase “In our opinion,” which represents the expression of an opinion.

In expressing this opinion, the auditor is required to assess the financial statements against an applicable financial reporting framework. A financial reporting framework is a set of criteria used to determine the measurement, recognition, presentation, and disclo- sure of material items in the financial statements; three examples of financial reporting frameworks are GAAP, International Financial Reporting Standards (IFRS), or a special purpose framework (such as cash or tax bases). Again, referring to Deloitte & Touche’s report in Exhibit 2.2, the first paragraph concludes that Microsoft’s financial statements present its financial condition, results of operations, and cash flows “. . . in conformity with U.S. generally accepted accounting principles” (GAAP). In this case, GAAP are the applicable financial accounting framework.

The report in Exhibit 2.2 is an example of an unmodified (or unqualified) opinion, which concludes that the entity’s (in this case, Microsoft’s) financial statements present its financial condition, results of operations, and cash flows in conformity with GAAP. Other types of opinions that can be expressed include the following:

∙ An adverse opinion concludes that the entity’s financial statements are not presented in conformity with GAAP (or other financial reporting framework such as IFRS).

∙ A qualified opinion concludes that except for a relatively isolated (usually limited) departure, the entity’s financial statements are presented in conformity with GAAP (or other financial reporting framework, such as IFRS).

∙ In some cases (e.g., if the auditors lack independence), auditors may choose not to express an opinion on the entity’s financial statements. This type of report is referred to as a disclaimer of opinion. (A disclaimer of opinion is an indication that an opinion cannot be expressed.)

When these situations are encountered, auditors add an explanatory paragraph to their report and would then modify some of the paragraphs of the report shown in Exhibit 2.2. These and other report modifications are discussed further in Chapter 12.

One important phrase in the first paragraph is “in all material respects. . . .” The con- cept of materiality has been discussed previously as part of the performance principle; used in a reporting context, it communicates that the audit team is unaware of any mate- rial misstatements in the financial statements. The choice of report (unqualified, quali- fied, or adverse) depends on the nature and materiality (significance) of the effect of the GAAP departure.

The report shown in Exhibit 2.2 expresses the auditors’ conclusion on the fairness of Microsoft’s financial statements. The second paragraph of this report references a report on Microsoft’s internal control over financial reporting. This report is also pre- sented along with Microsoft’s financial statements and expresses the auditors’ conclusion regarding the effectiveness of Microsoft’s internal control over financial reporting. Audit reporting is discussed in greater detail in Chapter 12.

REVIEW CHECKPOINTS 2.19 What is a financial reporting framework? How is it related to the auditors’ reporting

responsibilities? 2.20 What are the four types of audit opinions? What is the conclusion of each one?

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EVALUATING THE QUALITY OF PUBLIC ACCOUNTING FIRMS’ PRACTICES

To this point in the chapter, we have discussed the professional standards related to audit engagements. Many organizations are interested in ensuring that public accounting firms meet these engagement standards and maintain high levels of quality in their practices. For example, the SEC provides general oversight of the accounting and auditing pro- fessions, investigates audit failures (situations in which auditors fail to detect material financial statement misstatements), and levies fines against firms that have been found negligent in conducting audits. In addition, the PCAOB inspects the work of audit firms to ensure that their audits comply with professional standards.10

However, one important issue that has not been addressed is the nature of actions that firms themselves routinely take to ensure that their work is of high quality and meets the professional standards discussed in this chapter. For example, how do firms ensure that the personnel assigned to engagements are independent with respect to the client and have the appropriate level of competence to handle the assignment? What process do firms use when deciding either to accept or continue an audit engagement? The answers to these and other questions are reflected in policies and procedures that firms implement as part of a system of quality control, which is the focus of this section.

System of Quality Control Statement on Quality Control Standards No. 8 (SQCS 8), “A Firm’s System of Quality Control,” notes that the purpose of a system of quality control is to provide the firm reason- able assurance that the firm and its personnel

∙ Comply with professional standards and applicable regulatory and legal requirements. ∙ Issue reports that are appropriate in the circumstances.

Simply stated, a system of quality control is implemented by firms to ensure that their work is of high quality and meets the expectations of professional standards. Section 103 of Sarbanes–Oxley established broad areas of quality control standards that were required of registered public accounting firms. These areas serve as the basis for the following six elements of a system of quality control identified by SQCS 8:

1. Leadership responsibilities for quality within the firm (“tone at the top”). Undoubtedly, you have heard the phrase “leadership by example.” In order for qual- ity control standards to be effective, it is important that the firm’s management take a lead role in clearly and consistently demonstrating its own commitment to quality control and high-quality work. Doing so will make it clear to all personnel that high- quality work is valued and will be rewarded. Some examples of how this can be done include

∙ Assigning management responsibilities in such a manner that financial consider- ations do not override the quality of work performed.

∙ Basing performance evaluation, compensation, and promotion opportunities for personnel on the quality of work performed.

∙ Devoting sufficient resources for developing, communicating, and supporting the firm’s quality control policies and procedures.

LO 2-5 Understand the role of a system of quality control and monitoring efforts in enabling public accounting firms to meet appropriate levels of professional quality.

10Firms auditing only nonpublic entities undergo a peer review process conducted by the AlCPA’s National Peer Review Committee.

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It may seem unusual to specify that personnel decisions should be based on the qual- ity of work performed. After all, what other basis should be used? Both the Enron and WorldCom cases provided anecdotal evidence that suggested the fear of losing a key client (and the impact of that loss on individual auditors’ performance evalu- ations and opportunities within the firm) contributed to the audit failures in those cases.

2. Relevant ethical requirements. Earlier in this chapter, we discussed indepen- dence and the importance of independence to the auditing profession. Firms should take various actions to ensure that personnel assigned to engagements are both independent in fact and independent in appearance with respect to the firm’s clients, such as

∙ Communicating independence requirements to personnel. ∙ Identifying circumstances and relationships that create threats to independence and

taking appropriate action to eliminate those threats or reduce them to an acceptable level.

∙ Obtaining written confirmation from all firm personnel with respect to their com- pliance with appropriate independence requirements.

3. Acceptance and continuance of client relationships and specific engagements. As discussed in Chapter 3, one of the most important decisions facing an audit firm is that of accepting an engagement (for a new client) or continuing to perform an engagement (for an existing client). When making this decision, firms should focus on three impor- tant issues:

1. The integrity and business reputation of the client. 2. The firm’s ability to adequately perform the engagement with an appropriate level

of professional competence. 3. The firm’s ability to comply with legal and ethical requirements related to the

engagement.

The purpose of this process is to avoid association with a client whose manage- ment lacks integrity and to ensure that the firm can perform the engagement at an appropriate level.

If firms decide to withdraw from an engagement after considering the preced- ing matters, SQCS 8 notes that the firm should document significant issues, con- sultations, conclusions, and the basis for any conclusions related to its decision to withdraw.

4. Human resources. The quality of any professional services organization (such as an audit firm) is based on the quality of its people. Effective quality control policies and procedures should be implemented to ensure that firms hire quality personnel, assign these personnel to engagements for which they have the appropriate capabilities, provide professional development opportunities to those individuals, and effectively evaluate, compensate, and promote them. These practices will increase the likeli- hood that a high-quality audit is conducted by ensuring that the firm has high-quality personnel and that these individuals have the ability to assume the responsibilities assigned to them.

5. Engagement performance. The performance principle (discussed earlier in this chap- ter) addressed a number of significant issues related to the conduct of an audit engage- ment. Firms frequently use manuals and other standardized forms of documentation to meet the preceding objectives.

An important element of quality control is the practice of conducting engagement quality control reviews for engagements meeting specified criteria identified by the firm (for example, engagements in a highly volatile industry or engagements that

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meet certain risk criteria). An engagement quality control review includes an internal evaluation of the significant judgments made by the audit team and the conclusions reached in formulating its report.

6. Monitoring. The purpose of monitoring is to provide the firm with reasonable assur- ance that policies and procedures composing the system of quality control are operat- ing effectively and complied with in practice. Examples of procedures used to monitor quality control include

∙ Reviews of selected administrative and personnel records. ∙ Reviews of engagement documentation, reports, and the client’s financial

statements. ∙ Discussions with firm personnel. ∙ Assessments of the (1) appropriateness of the firm’s guidance materials and

professional aids, (2) compliance with policies and procedures on indepen- dence, (3) effectiveness of continuing professional education, and (4) decisions regarding the acceptance and continuance of client relationships and specific engagements.

Firms may accomplish these monitoring activities through either an ongoing post- issuance review of engagement documentation or targeted inspection procedures for a sample of engagements conducted by the firm.

PCAOB Inspection of Firms Earlier in this chapter, we addressed the role of the PCAOB in establishing auditing stan- dards. In addition to this role, the PCAOB is charged with monitoring the quality of work performed by firms auditing issuers and bringing appropriate action against those firms if substandard work is identified. This monitoring is referred to as an inspection11 and is conducted as follows:

∙ For firms performing audits of more than 100 issuers, inspections are conducted on an annual basis.

∙ For firms performing audits of 100 or fewer issuers, inspections are conducted at least every three years.

Based on information from the PCAOB’s website, more than 1,800 accounting firms are registered with the PCAOB. As of January 1, 2019, 506 of these firms issue audit reports but only 11 were required to have annual inspections because they conducted audits for more than 100 companies.

Inspections are conducted by full-time employees of the PCAOB. These inspections consist of a review of a sample of audit engagements conducted by the firm as well as an overall evaluation of the firm’s system of quality control (policies related to audit performance, training, compliance with independence requirements, and client manage- ment). Copies of the PCAOB’s inspection reports can be found (on a firm-by-firm basis) on the PCAOB’s website. These reports detail the deficiencies identified by the PCAOB on the sample of audit engagements (the name of the client is not identified); information regarding deficiencies in the firm’s quality control are not publicly disclosed and will be disclosed only if the firm fails to address those deficiencies within a year following the inspection.

The importance of these inspections are evidenced by a recent scandal involving KPMG noted in the Auditing Insight “Stealing the Exam”.

11The AICPA has a similar type of process (referred to as peer review) for firms auditing non-issuers.

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The Auditing Insight “Grading the Firms” provides a summary of reported deficien- cies for audits conducted by Big Four firms. Although that information summarizes audits conducted by large accounting firms, evidence suggests that a significant number of deficiencies has also been observed in audits conducted by smaller firms.12

12“Smaller Auditors Get So-So Grades,” The Wall Street Journal, February 26, 2013, p. C2.

AUDITING INSIGHT

A PCAOB employee (who was hoping to join KPMG) leaked confiden- tial information related to planned PCAOB inspections to executives at KPMG, which would allow the firm to prepare for the inspections and receive more favorable reports. In the two years preceding the leak, KPMG had the highest percentage of inspected audits found to be deficient, (38% and 54% in 2016 and 2015, respectively). In April 2017, KPMG terminated five executives (including the national man- agement partner for audit quality and professional practice, national partner in charge for inspections, and co-leader of the Banking and Capital Markets Group) for their roles in this scandal.

On June 18, 2019, KPMG agreed to a $50 million settlement with the SEC related to this matter. Six individuals (the five KPMG execu- tives and the PCAOB employee) have been charged with conspiracy and wire fraud for their roles in this scheme. As of October 2019, four

of the individuals have pleaded guilty and two were convicted on con- spiracy and wire fraud charges. While the maximum penalties range from 65 to 85 years in prison, one individual received a prison sen- tence of eight months and the other a sentence of 366 days.

Ironically, PCAOB inspections following of KPMG audits following the revelation of this scheme found deficiencies in nearly 50% of the audits inspected.

Sources: “KPMG Fires Partners Over Leak,” The Wall Street Journal, April 12, 2017, p. B1; “KPMG Ex-Partner Convicted in Scheme to Steal Information,” The Wall Street Journal, March 12, 2019, p. B3; “KPMG to Pay Penalty Over Cheat- ing Scandal,” The Wall Street Journal, June 18, 2019, p. B1-B2; “Auditor Sen- tenced in KPMG Case,” The Wall Street Journal, September 12, 2019, p. B10; “Another Former KPMG Executive Pleads Guilty in ‘Steal the Exam’ Scheme,” Wall Street Journal Online, October 4, 2019.

Stealing the Exam

Overall, these results indicate the following:

• 29% of all inspected audits had deficiencies • For audits having deficiencies, the average number of deficiencies

per audit was 2.1

• 0.6% and 2.3% of all inspected audits failed to identify a departure from GAAP and modified the opinion on internal control over finan- cial reporting, respectively.

Public Company Accounting Oversight Board. “PCAOB Firm Inspection Reports.” https://pcaobus.org/

Grading the FirmsAUDITING INSIGHT

Year

Number of Audits Inspected

Audits in Which Deficiencies Were Identified

Number of Deficiencies Identified

Audits in Which Departure from GAAP Not Identified by Firms

Audits in Which Report on Internal Control Was Revised

2018 reports (2017 audits) 217 67 138 0 2

2017 reports (2016 audits) 217 61 129 1 6

2016 reports (2015 audits) 217 61 127 3 7

The very public nature of the PCAOB inspection process and controversies surround- ing that process raise the question as to whether inspection reports measure audit quality and are useful to various parties in their decision processes. The following Auditing Insight summarizes academic research that examined how the inspection process and results influence the behavior of both audit firms and their clients. The PCAOB recently indicated that it is considering shifting the focus of its investigations from evaluating audit deficiencies to assessing the firms’ systems of quality control.13

13“Auditing the Auditors: U.S. Rethinks Approach,” The Wall Street Journal Online, May 6, 2016.

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• Abbott et al. concluded that clients were more likely to dismiss smaller (triennially inspected) audit firms when those firms received PCAOB inspection reports indicating that they failed to detect a departure from GAAP.

• Gramling et al. found that audit firms receiving a PCAOB inspection report that identified deficiencies were more likely to issue more severe audit opinions for clients experiencing financial difficulties following the inspection report compared to prior to the inspection report.

• Nagy concluded that audit firms receiving public disclosure of quality control criticisms suffered a significant loss in market share, consistent with perceptions that these reports are credible signals of audit quality.

• Lamoreaux found that audit firms subject to PCAOB inspections in a nonmandatory inspection regime conducted higher qual- ity audits (as measured by a greater incidence of issuing going- concern opinions and reporting material weaknesses in internal control and lower client earnings management activities).

• Boone et al. found that the PCAOB’s censure of Deloitte resulted in market share loss and reduced levels of audit fee growth, suggest- ing that the censure had a significant reputational effect on Deloitte.

• Aobdia found that audits identified with PCAOB report deficien- cies had a 9 percent increase in total audit hours in the year fol- lowing the reported deficiency. In addition, companies audited by firms with PCAOB report deficiencies were 18 percent more likely to switch auditors, while those without deficiencies were 17  percent less likely to switch auditors compared to non- inspected audits.

Sources: L. J. Abbott, K. A. Gunny, and T. C. Zhang, “When the PCAOB Talks, Who Listens? Evidence from Stakeholder Reaction to GAAP-Deficient PCAOB Inspection Reports of Small Auditors,” Auditing: A Journal of Practice & Theory, May 2013, pp. 1–31; A. A. Gramling, J. Krishnan, and Y. Zhang, “Are PCAOB- Identified Audit Deficiencies Associated with a Change in Reporting Decisions of Triennially Inspected Audit Firms?” Auditing: A Journal of Practice & Theory, August 2011, pp. 59–79; A. L. Nagy, “PCAOB Quality Control Inspection Reports and Auditor Reputation,” Auditing: A Journal of Practice & Theory, August 2014, pp. 87–104; P. T. Lamoreaux, “Does PCAOB Inspection Access Improve Audit Quality? An Examination of Foreign Firms Listed in the United States,” Journal of Accounting and Economics, April–May 2016, pp. 313–337; J.P. Boone, I.K. Khurana, and K.K. Raman, “Did the 2007 PCAOB Disciplinary Order Against Deloitte Impose Actual Costs on the Firm or Improve Its Quailty,” The Accounting Review, March 2015, pp. 405-441; D. Aobdia, “The Impact of the PCAOB Individual Engagement Inspection Process – Preliminary Evidence,” The Accounting Review, July 2018, pp. 53-80.

Academic Research on PCAOB InspectionsAUDITING INSIGHT

REVIEW CHECKPOINTS 2.21 What is a system of quality control? Identify the six elements of a system of quality control. 2.22 What factors should auditors consider in deciding whether to accept or continue the engagement

with a particular client? What should firms do if they decide to withdraw from an engagement? 2.23 Provide examples of procedures that firms have used to monitor their quality control policies and

procedures. 2.24 What role does the PCAOB play in connection with monitoring and regulating public accounting

firms? 2.25 How frequently are firms required to have PCAOB inspections?

This chapter discussed the professional standards that apply to audit engagements and identified important mechanisms that enable public accounting firms to provide profes- sional services to meet those standards. From an auditing standpoint, generally accepted auditing standards form the basis for professional engagements and the necessary quali- fications and characteristics of auditors. These standards are based on three basic prin- ciples, which reflect the overall conduct of the audit examination:

1. Responsibilities, which require auditors to possess competence and capabilities, com- ply with relevant ethical requirements, maintain professional skepticism, and exercise professional judgment.

2. Performance, which involves planning the work and supervising assistants, determin- ing and applying appropriate materiality levels, identifying and assessing the risk of material misstatement, and obtaining sufficient appropriate audit evidence.

Summary

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3. Reporting, which requires that auditors express an opinion about the fairness of the entity’s financial statements.

To provide reasonable assurance of compliance with these standards, firms develop sys- tems of quality control that prescribe policies and procedures related to (1) the responsibili- ties of firm leadership for quality, (2) ethical requirements, (3) acceptance and continuance of client relationships and specific engagements, (4) human resources, (5) engagement performance, and (6) monitoring of the effectiveness of the system of quality control. Under Sarbanes–Oxley, firms conducting audits of issuers are required to have inspections of selected engagements and their systems of quality control by the PCAOB. The purpose of these inspections is to identify deficiencies in engagements conducted by the firms and provide suggestions for improvements in their systems of quality control.

Following is a summary of the professional standards and monitoring activities for audits of issuers and non-issuers.

  Professional Standards Monitoring Requirements

Issuer Auditing Standards issued by the PCAOB Annual or triennial inspections conducted by the PCAOB (frequency depends upon number of audits performed by the firm)

Non-issuer Statements on Auditing Standards issued by the ASB of the AICPA

Triennial peer reviews conducted through the AICPA National Peer Review Committee

American Institute of Certified Public Accountants (AICPA): As related to professional auditing standards, the body charged with establishing auditing standards for the audits of nonpublic entities through Statements on Auditing Standards (SASs) issued by the Auditing Standards Board, 42 appropriate (audit evidence): Characteristics related to the quality (relevance and reliability) of audit evidence, 55 audit plan: A comprehensive list of the specific audit procedures that the audit team needs to perform to gather sufficient appropriate evidence on which to base their opinion on the financial statements, 51 audit procedures: The specialized actions auditors take to obtain evidence in an engagement, 45 auditing standards: The audit quality guides that apply to all audits, 45 control risk: The likelihood that the client’s internal control policies and procedures fail to prevent or detect a material misstatement, 53 detection risk: The likelihood that the auditors’ substantive procedures will fail to detect a material misstatement that exists within an account balance or class of transactions, 55 due care: A level of performance that would be exercised by reasonable auditors in similar circumstances; auditors are expected to possess the skills and knowledge of others in their profession and are not expected to be infallible, 48 engagement quality control review: An internal evaluation of the significant judgments made by the audit team and the conclusions reached in formulating its report on an engagement conducted by that firm, 60 evidence: The information used by auditors in arriving at the conclusion on which the audit opinion is based, which includes the underlying accounting data and all available corroborating information, 55 financial reporting framework: The financial reporting standards (i.e., GAAP, IFRS, etc.) adopted by management and, when appropriate, those charged with governance (audit committee or board of directors) in the preparation of the financial statements, 58 generally accepted auditing standards (GAAS): Standards that identify necessary qualifications and characteristics of auditors and guide the conduct of the audit examination, 44

Key Terms

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independence in appearance: The extent to which others (particularly financial statement users) perceive auditors to be independent, 47 independence in fact: Auditors’ mental attitude and impartiality with respect to the client, 47 inherent risk: The probability that in the absence of internal controls, material errors or frauds could enter the accounting system used to develop financial statements, 53 inspection: An evaluation of an accounting firm’s audit engagements and system of quality control conducted by the PCAOB and required for any firms providing auditing services to public entities, 61 internal control: A process, effected by an entity’s board of directors, management, and other personnel, designed to provide reasonable assurance regarding the achievement of objectives in the reliability of financial reporting, the effectiveness and efficiency of operations, and compliance with applicable laws and regulations, 53 issuer: An entity that offers registered securities, such as stocks and bonds, for sale to the general public (also known as a public entity). Issuers are subject to mandatory audit requirements, 42 materiality: An amount or event that has a substantial likelihood to influence financial statement users’ decisions. Thus, material information is a synonym for important information. The emphasis is on the financial statement users’ point of view, not on the auditors’ or managers’ points of view, 52 professional judgment: The application of relevant training, knowledge, and experience in making informed decisions about appropriate courses of action during the audit engagement, 49 professional skepticism: A state of mind that is characterized by appropriate questioning and a critical assessment of audit evidence, 49 Public Company Accounting Oversight Board (PCAOB): As related to professional auditing standards, the body charged with establishing auditing standards for the audits of public entities through the issuance of Auditing Standards. The PCAOB is also responsible for inspecting firms that perform audits of public entities, 42 reasonable assurance: The concept that recognizes that the costs of control activities should not exceed the benefits that are expected from the control activities, 51 risk of material misstatement: The combined probability that a material misstatement (error or fraud) will occur and not be prevented or detected on a timely basis by the entity’s internal controls. The risk of material misstatement is a combination of inherent and control risk, 53 substantive procedures: The detailed audit and analytical procedures designed to detect material misstatements in account balances and footnote disclosures, 54 sufficiency (audit evidence): The measure of the quantity of audit evidence (the number of transactions or components evaluated), 55 system of quality control: The policies and procedures implemented by a firm to provide with reasonable assurance that the firm and its personnel (1) comply with professional standards and applicable regulatory and legal requirements and (2) issue reports that are appropriate in the circumstances, 59

All applicable questions are available with Connect.

Multiple-Choice Questions for Practice and Review

2.26 Which of the following categories of principles is most closely related to gathering audit evidence? a. Performance b. Reasonable assurance c. Reporting d. Responsibilities

2.27 Which of the following is not related to ethical requirements of auditors? a. Due care b. Independence in appearance c. Independence in fact d. Professional judgment

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2.28 One of an accounting firm’s basic objectives is to provide professional services that conform to professional standards. Reasonable assurance of achieving this objective can be obtained by following a. Generally accepted auditing standards. b. Standards within a system of quality control. c. Generally accepted accounting principles. d. International auditing standards.

2.29 Which of the following best demonstrates the concept of professional skepticism? a. Relying more extensively on external evidence rather than internal evidence. b. Focusing on items that have a more significant quantitative effect on the entity’s financial

statements. c. Critically assessing verbal evidence received from the entity’s management. d. Evaluating potential financial interests held by auditors in the client.

2.30 The primary purpose for obtaining an understanding of the entity’s environment (including its internal control) in a financial statement audit is a. To determine the nature, timing, and extent of substantive procedures to be performed. b. To make consulting suggestions to the entity’s management. c. To obtain direct sufficient appropriate audit evidence to afford a reasonable basis for an

opinion on the financial statements. d. To determine whether the entity has changed any accounting principles.

2.31 Ordinarily, what source of evidence should least affect audit conclusions? a. External documentary evidence. b. Inquiry of management. c. Documentation prepared by the audit team. d. Inquiry of entity legal counsel.

2.32 The most reliable evidence regarding the existence of newly acquired computer equipment is a. Inquiry of management. b. Documentation prepared externally. c. Evaluation of the client’s procedures. d. Physical observation.

2.33 Which of the following procedures would provide the most reliable audit evidence? a. Inquiries of the client’s internal audit staff. b. Inspection of prenumbered client purchase orders filed in the vouchers payable department. c. Inspection of vendor sales invoices received from client personnel. d. Inspection of bank statements obtained directly from the client’s financial institution.

2.34 Breaux & Co. CPAs require that all audit documentation indicates the identity of the pre- parer and the reviewer. This procedure provides evidence relating to which of the following? a. Independence. b. Adequate competence and capabilities. c. Adequate planning and supervision. d. Sufficient appropriate evidence gathered.

2.35 Which of the following concepts is least related to the standard of due care? a. Independence in fact b. Professional skepticism c. Prudent auditor d. Reasonable assurance

2.36 The evidence considered most appropriate by auditors is best described as a. Internal documents such as sales invoice copies produced under conditions of strong

internal control. b. Written representations made by the president of the entity.

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c. Documentary evidence obtained directly from independent external sources. d. Direct personal knowledge obtained through physical observation and mathematical

recalculation.

2.37 Auditors’ understanding of the internal control in an entity provides information for a. Determining whether members of the audit team have the required competence and capa-

bilities to perform the audit. b. Ascertaining the independence in mental attitude of members of the audit team. c. Planning the professional development courses the audit staff needs to keep up to date

with new auditing standards. d. Planning the nature, timing, and extent of substantive procedures on an audit.

2.38 Which of the following elements of a system of quality control is related to firms receiving independence confirmations from its professionals with respect to clients? a. Acceptance and continuance of client relationships and specific engagements. b. Engagement performance. c. Monitoring. d. Relevant ethical requirements.

2.39 Which of the following is most closely related to the responsibilities principle? a. The auditors’ responsibility to issue a report as a result of their examination. b. The requirement that auditors gather sufficient, appropriate evidence upon which to base

an opinion on the financial statements. c. The auditors’ compliance with relevant ethical requirements of independence and due care. d. The auditors’ responsibility to plan the audit and properly supervise assistants.

2.40 Kramer, CPA, consulted an independent appraiser regarding the valuation of fine art for a not-for-profit museum. Consultation with the appraiser in this case would a. Be considered as exercising proper due care. b. Be considered a failure to follow generally accepted auditing standards because Kramer

should have known how to value fine art before accepting the engagement. c. Not be considered a violation of generally accepted auditing standards because generally

accepted auditing standards does not apply to not-for-profit entities. d. None of the above.

2.41 Which of the following topics is not addressed in the auditors’ report for an issuer? a. Responsibilities of the auditor and management in the financial reporting process. b. Absolute assurance regarding the fairness of the entity’s financial statements in accor-

dance with GAAP. c. A description of an audit engagement. d. A summary of the auditors’ opinion on the effectiveness of the entity’s internal control

over financial reporting.

2.42 Which of the following recognizes that an audit conducted under generally accepted audit- ing standards may not detect all material misstatements? a. Absolute assurance b. Professional judgment c. Reliability of audit evidence d. Reasonable assurance

2.43 Which of the following combinations would provide the auditor the most reliable evidence?

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Source of Evidence Effectiveness of Internal Control

a. Internal More effective

b. Internal Less effective

c. External More effective

d. External Less effective

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2.44 Which of the following is most closely related to the relevance of audit evidence? a. Auditors decide to physically inspect investment securities held by a custodian instead of

obtaining confirmations from the custodian. b. In addition to confirmations of accounts receivable, auditors perform an analysis of the

aging of accounts receivable to evaluate the collectability of accounts receivable. c. In response to less effective internal control, auditors increase the number of customer

accounts receivable confirmations mailed compared to that in the prior year. d. Because of a large number of transactions occurring near year-end, auditors decide to

confirm a larger number of receivables following year-end instead of during the interim period.

2.45 Which of the following statements is not true with respect to the performance principle? a. Auditors are required to prepare a written audit plan during the planning stages of initial

audits but are not required to do so in continuing audits. b. Audit teams consider materiality in planning the audit, performing the audit, and evaluat-

ing the effect of misstatements on the entity’s financial statements. c. In assessing the risk of material misstatements, the audit team considers the effectiveness

of the entity’s internal controls in preventing and detecting misstatements. d. Auditors are required to consider both the relevance and the reliability of evidence in

evaluating whether the evidence they have gathered is appropriate.

2.46 Which of the following is true with respect to PCAOB inspections of accounting firms? a. All firms performing audits of issuers are required to have annual inspections conducted

by the PCAOB. b. PCAOB inspections review a sample of audits conducted by firms as well as the firm’s

systems of quality control. c. All results of PCAOB inspections are made available to the public following the inspection. d. Firms performing audits of 100 or fewer issuers may elect to have a peer review con-

ducted through the AICPA in lieu of a PCAOB inspection.

2.47 The particular and specialized actions that auditors take to obtain evidence during a specific engagement are known as a. Audit procedures. b. Audit standards. c. Interpretive publications. d. Statements on Auditing Standards.

2.48 Which of the following combinations of standards and types of audits are most closely related to the activities of the Public Company Accounting Oversight Board? a. Develop Auditing Standards for the audits of non-issuers. b. Develop Auditing Standards for the audits of issuers. c. Develop Statements on Auditing Standards for the audits of non-issuers. d. Develop Statements on Auditing Standards for the audits of issuers.

2.49 Which of the following best describes the general contents of the first paragraph of the “Basis for Opinion” section of the auditors’ report? a. A description of an audit examination, including the fact that the audit was conducted

under standards established by the PCAOB. b. The auditors’ conclusion with respect to the fairness of the entity’s financial statements. c. Statements identifying the responsibility of auditors and management in the financial

reporting process. d. The auditors’ conclusion with respect to the effectiveness of the entity’s internal control

over financial reporting.

2.50 Which of the following opinions would be issued if auditors believed that the entity’s finan- cial statements were not presented in conformity with GAAP? a. Adverse opinion b. Disclaimer of opinion

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c. Qualified opinion d. Unmodified opinion

2.51 Which of the following principles is most closely associated with the auditors’ conclusion as to the fair presentation of the entity’s financial statements? a. Communication principle b. Performance principle c. Reporting principle d. Responsibilities principle

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2.52 AICPA and PCAOB Responsibilities. The creation of the PCAOB by the Sarbanes–Oxley Act has affected both the standards-setting process and the periodic review of the quality of an audit firm’s work.

Required: a. Identify the responsibilities of the AICPA, PCAOB, and SEC in the auditing standards-

setting process. b. Which standard(s) provide guidance for the audits of issuers? Which standard(s) provide

guidance for the audits of non-issuers? c. What role do the AICPA and PCAOB play in the periodic review of the quality of audit

firms’ work?

2.53 Professional Guidance. A challenge facing auditors is the wide array of professional guid- ance available to them in the audits of different types of entities.

Required: For each of the following, identify whether it is most appropriately associated with State- ments on Auditing Standards (SAS), Auditing Standards (AS), both (B), or neither (N). a. Issued by the American Institute of Certified Public Accountants. b. Issued by the Public Company Accounting Oversight Board. c. Provide guidance for services lesser in scope than an audit engagement. d. Apply to the audit of non-issuers. e. Require auditors to gather sufficient, appropriate evidence to support their opinion. f. Apply to the audit of issuers. g. Address quality control standards developed within the accounting firm. h. Become effective upon approval by the Securities and Exchange Commission.

2.54 Independence. You are meeting with executives of Cooper Cosmetics Corporation to arrange your firm’s engagement to audit the corporation’s financial statements for the year ending December 31. One executive suggests the audit work be divided among three staff members. One person would examine asset accounts, a second would examine liability accounts, and the third would examine income and expense accounts to minimize audit time, avoid duplication of staff effort, and curtail interference with entity operations. Advertising is the corporation’s largest expense, and the advertising manager suggests that a staff member of your firm whose uncle owns the advertising agency that handles the corporation’s advertising be assigned to examine the Advertising Expense account because the staff member has a thorough knowledge of the complex contact between Cooper Cos- metics and the advertising agency.

Required: a. To what extent should auditors follow the client’s suggestions for the conduct of an audit?

Discuss. b. List and discuss the reasons that audit work should not be assigned solely according to

asset, liability, and income and expense categories.

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All applicable questions are available with Connect.

Exercises and Problems

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c. Should the staff member of your accounting firm whose uncle owns the advertising agency be assigned to examine advertising costs? Discuss.

2.55 Independence. Generally accepted auditing standards require auditors to be independent. Included within this standard are the concepts of independence in fact and independence in appearance.

Required: a. Define independence in fact and independence in appearance. b. What two general types of relationships would normally compromise auditors’

independence? c. For each of the following separate situations, discuss whether you believe the auditors’

independence has been compromised. 1. The auditors’ firm provides extensive consulting services to the client; these services

provide revenues to the firm that exceed revenues received from the audit engagement. 2. The spouse of the partner in charge of the audit engagement occupies an executive-

level position within the client. 3. A distant relative of a partner within the firm occupies an entry-level position within

a client of the firm. (The audit is conducted by another office of the firm with which the partner has infrequent contact.)

4. A staff member within the firm owns shares of stock of one of that firm’s clients. (She is not a member of the engagement team serving that client.)

2.56 Professional Skepticism. An important principle for auditors is the need to maintain an appropriate level of professional skepticism.

Required: a. Define professional skepticism. b. During which stages of the audit are auditors required to exhibit professional skepticism? c. How does each of the following independent issues potentially relate to the principle of

professional skepticism? 1. The auditor’s firm has served the client for a long period of time, and strong friend-

ships have developed between the firm personnel and client’s officers. 2. Auditors are anxious to complete the audit shortly because of other workload demands

and deadlines related to other engagements. 3. The client has mentioned on a number of occasions its desire to reduce (or limit) the

audit fee.

2.57 Responsibilities Principle. Martin is considering submitting a proposal to conduct the audit examination of Phillip Inc., a manufacturer and distributor of automotive parts to large auto- mobile manufacturers. The following are some notes related to Martin’s initial consideration of this potential engagement. a. Martin learned of this client opportunity through one of its staff accountants, who is a

cousin of Phillip’s chief financial officer. b. Phillip is a particularly attractive engagement for Martin because it would allow the firm

to enter into the manufacturing market (most of Martin’s clients are in the services indus- try and are much smaller than Phillip).

c. Martin inquired with Phillip as to the reason for a change in auditors and was assured that the former auditors decided not to continue auditing Phillip Inc. because they no longer possessed the necessary expertise to audit clients in the automotive parts industry (this explanation was confirmed by the former auditors).

d. Martin is concerned about the numerous locations of Phillip’s warehouses and the ability to conduct an appropriate observation of Phillip’s year-end inventory balances.

e. When asked about inventory observation, Phillip indicated that its previous auditors observed physical inventory at different warehouses on different days and obtained a written statement from Phillip that transfers between locations did not occur.

f. If Martin obtains the engagement, it will take appropriate actions to ensure that firm per- sonnel are independent in fact and in appearance with respect to Phillip.

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Required: For each of the above, identify the component of the responsibilities principle (competence and capabilities, ethical requirements, or professional skepticism and professional judgment) most closely related to that factor.

2.58 Performance Principle: Planning. Your public accounting practice is located in a city of 15,000 people. The majority of your work, conducted by you and two assistants, consists of compiling clients’ monthly statements and preparing income tax returns for individuals from cash data and partnership returns from books and records. You have a small number of audit clients; given the current size of your practice, you generally consider it a challenge to accept new audit clients. One of your corporate clients is a retail hardware store. Your work for this client has been limited to preparing the corporate income tax return from a trial balance submitted by the bookkeeper. On December 26, you receive from the president of the corporation a letter containing the following request:

We have made arrangements with First National Bank to borrow $500,000 to finance the purchase of a complete line of appliances. The bank has asked us to furnish our auditors’ certi- fied statement as of December 31, which is the closing date of our accounting year. The trial balance of the general ledger should be ready by January 10, which should allow ample time to prepare your report for submission to the bank by January 20. In view of the importance of this certified report to our financing program, we trust you will arrange to comply with the preced- ing schedule.

Required: From a theoretical viewpoint, discuss the difficulties that are caused by such a short notice audit request.

(AICPA adapted)

2.59 Performance Principle: Evidence. Generally accepted auditing standards (the perfor- mance principle) require auditors to gather sufficient appropriate evidence on which to base an opinion.

Required: a. Briefly define the characteristics “sufficient” and “appropriate” as they relate to audit

evidence. b. What are relevance and reliability (as they relate to audit evidence)? How do these con-

cepts relate to the auditors’ requirement to gather sufficient appropriate evidence? c. How does the source of evidence affect its reliability? d. How does the effectiveness of the entity’s internal control affect the sufficiency and

appropriateness of evidence gathered by auditors?

2.60 Performance Principle. You have accepted the engagement of auditing the financial state- ments of the C. Reis Company, a small manufacturing firm that has been your client for several years. Because you were busy writing the report for another engagement, you sent a staff accountant to begin the audit with the suggestion that she start with accounts receiv- able. Using the prior year’s audit documentation as a guide, she prepared a trial balance of the accounts, aged them, prepared and mailed positive confirmation requests, examined underlying support for charges and credits, and performed other work she considered neces- sary to obtain evidence about the validity and collectability of the receivables. At the con- clusion of her work, you reviewed the audit documentation she prepared and found she had carefully followed the prior year’s audit documentation.

Required: The opinion rendered by auditors states that the audit was made in accordance with gen- erally accepted auditing standards. Identify the important components of the performance principle and relate them to the audit of C. Reis Company by indicating how they were ful- filled or, if appropriate, how they were not fulfilled.

(AICPA adapted)

LO 2-3

LO 2-3

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2.61 Performance Principle. Identify how each of the following statements relates to the perfor- mance principle by considering which element(s) of the principle are related to that state- ment. (A statement may be related to more than one element.) Use the following elements in providing your response: ∙ Reasonable assurance ∙ Planning and supervision ∙ Materiality ∙ Risk assessment ∙ Audit evidence a. Evaluating the effectiveness of the client’s internal control in preventing or detecting

misstatements. b. Obtaining an understanding of the client’s business and industry. c. Acknowledging that the risk of failing to detect a material misstatement cannot be

reduced to zero. d. Obtaining confirmations from the client’s customers as to the ending balances in

accounts receivable. e. Preparing a written audit plan. f. Designing audit procedures to identify misstatements that would have a significant

effect on financial statement users’ decisions. g. Considering the likelihood that the account balance contains a material misstatement. h. Failing to detect material misstatements because of audit team mistakes and misinter-

pretations in evaluating evidence.

2.62 Responsibilities and Performance Principles. Respond to each of the following comments that you heard related to the audit of Swan Company, an issuer. a. “We don’t need to consider the risk of material misstatement in our work because we

really can’t do anything to reduce that risk.” b. “Because the client has not implemented effective internal controls, we need to gather

more reliable evidence. This means we need to test a greater number of transactions and obtain more reliable forms of evidence.”

c. “We will really need to spend a lot of time and effort on this audit. Because this client has just filed for a bond offering, we can’t allow for any misstatements in the financial state- ments. We need to guarantee the accuracy of the client’s financial statements.”

d. “Because this company has $140 million in revenues, we really shouldn’t be concerned about smaller accounts because they are not likely to have a major impact on the financial statements.”

e. “I know it will be more time consuming and expensive, but we are required to physi- cally inspect the stock certificates held by the client rather than obtain confirmation from the custodian. After all, our own direct observation is more reliable than receiving a confirmation.”

2.63 Reporting Principle. The reporting principle requires auditors to express their opinion through the issuance of a written report.

Required: a. What is the purpose of the auditors’ opinion and report? b. What are the major sections in the auditors’ report on the examination of an issuer? What

are the major contents of each of these sections? c. What are the four types of opinions that auditors can issue? d. How does the concept of materiality influence the auditors’ report?

2.64 Fundamental Principles. For each of the following related to audit engagements, identify whether the action is most closely related to the responsibilities, performance, or reporting principle. a. Evaluating the audit firm personnel’s independence with respect to a prospective client. b. Gathering sufficient, appropriate evidence. c. Exercising an appropriate level of professional skepticism.

LO 2-3

LO 2-2, 2-3

LO 2-4

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d. Issuing a qualified opinion on the financial statements because of a material, yet not per- vasive, departure from GAAP.

e. Establishing materiality levels for use in determining the amount of evidence to be gathered.

f. Considering the susceptibility of the account balance to misstatement to assess the risk of material misstatement.

g. Possessing the appropriate competence and capabilities to perform the audit. h. Considering whether a scope limitation precludes sufficient evidence to allow an opinion

to be expressed on the entity’s financial statements. i. Planning the audit to provide reasonable assurance that the financial statements are free

of material misstatement. j. Evaluating the potential relationships between the auditor and family who are employed

by the entity.

2.65 Comprehensive Principles Case Study. Ray, the owner of a small entity, asked Holmes, CPA, to conduct an audit of the entity’s records. Ray told Holmes that the audit was to be completed in time to submit audited financial statements to a bank as part of a loan appli- cation. Holmes immediately accepted the engagement and agreed to provide an auditors’ report within three weeks. Ray agreed to pay Holmes a fixed fee plus a bonus if the loan was granted. Holmes hired two accounting students to conduct the audit and spent several hours telling them exactly what to do. Holmes told the students not to spend time reviewing the controls but instead to concentrate on proving the mathematical accuracy of the ledger accounts and on summarizing the data in the accounting records that support Ray’s financial statements. The students followed Holmes’ instructions and, after two weeks, gave Holmes the financial statements, which did not include footnotes. Holmes studied the statements and prepared an unmodified auditors’ report. The report, however, did not refer to generally accepted accounting principles or to the fact that Ray had changed to the accounting standard for capitalizing interest.

Required: Briefly describe each of the principles and indicate how the action(s) of Holmes resulted in a failure to comply with these principles.

(AICPA adapted)

2.66 Fundamental Principles (Comprehensive). In each of the following, identify which of the elements of the fundamental principles (responsibilities, performance, or reporting) is most applicable. In addition, discuss what action(s) (if any) you believe auditors should take with respect to these issues. a. An entity has contacted you about performing its audit engagement. You have not previ-

ously served a client in the entity’s industry, which has many industry-specific account- ing issues that are both technical and complex.

b. An entity has entered into a number of lease agreements. Based on the requirements of GAAP, you believe that these obligations meet the criteria for being classified as capital leases; however, the entity has elected to treat these leases as operating leases, providing full and complete disclosure of this treatment in the footnotes to the financial statements.

c. Because of a disagreement with its current auditors, an entity has contacted you about conducting its current-year audit. However, because the previous auditors have just recently resigned from the engagement, you have some questions as to whether an audit can be completed in time to meet the entity’s deadlines for providing audited financial statements to a lender.

d. Based on the effectiveness of the entity’s internal control, you have assessed control risk at low levels and decided that a smaller number of customer accounts need to be confirmed.

e. An entity has contacted you about performing its audit engagement. This entity became aware of your firm because the husband of one of your partners is currently serving as the entity’s chief financial officer.

f. One of your clients is currently a potential defendant in several cases because of the dam- age caused by one of its products. Because this entity does not believe that it is likely to

LO 2-2, 2-3, 2-4

LO 2-2, 2-3, 2-4

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receive an unfavorable outcome from this litigation, it did not disclose the potential litiga- tion in the footnotes accompanying their financial statements.

g. You are performing tests of the client’s controls over the processing of revenue transac- tions to determine whether these controls are operating effectively and can be relied upon to prevent or detect misstatements.

h. One of your supervisors has requested a number of clarifications based on her review of your work on an audit engagement. A subsequent meeting with her has resolved these clarifications, and you both have concluded that your work supports the opinion on the client’s financial statements.

2.67 Fundamental Principles (Comprehensive). Identify which of the major fundamental prin- ciples (responsibilities, performance, or reporting) is most closely related to each of the following: a. The need for auditors to consider their financial relationships with prospective clients. b. An auditor has raised some questions with respect to management’s response to various

inquiries concerning pending litigation facing the client. c. The auditors’ consideration of the effectiveness of the entity’s internal control on the

nature, timing, and extent of substantive procedures. d. The auditors’ evaluation of the magnitude of a misstatement that would impact percep-

tions of the entity’s profitability. e. The auditors’ issuance of a disclaimer of opinion because of a significant scope limitation. f. Relevant education and experience requirements for CPA licensure. g. The inability of an audit examination to provide absolute assurance with respect to

detecting all material misstatements. h. The requirement that auditors possess the skills and knowledge of others in their

profession. i. The preparation of a written audit plan that guides the conduct of the audit engagement. j. The auditors’ issuance of a qualified opinion because of a departure from GAAP.

2.68 Fundamental Principles (Comprehensive). Comment upon each of the following state- ments you heard in a conversation between two newly hired staff auditors. a. “Of course, I’m qualified to be assigned to this engagement. I have an accounting degree

from a top university and was an honors graduate. I know some of the accounting rules have changed since I graduated, but I’ll be able to figure that out as we go through the audit.”

b. “It doesn’t really matter what others think.  .  .  . I’m completely independent of Acme Industries and should be a member of the audit team. While I own some stock, it’s a small amount and I’m holding it for the long term, anyway.”

c. “You really have to question everything the client tells you. That’s what professional skepticism is all about. It’s a shame you can’t believe a word they say.”

d. “The evidence is lower in quality, but we typically use internal evidence when we audit property, plant, and equipment. It just takes too much time and costs too much to get more reliable evidence.”

e. “On that last job, we really planned the audit well. We were able to finish everything by November 1 and didn’t need to do any work after year-end.”

f. “We’re not too worried about internal control. We always do the same substantive proce- dures anyway, so why take the time to look at the client’s controls?”

g. “Because the client isn’t accounting for its leases properly, we need to issue either a qualified opinion or a disclaimer of opinion. Just how large a dollar impact does this have on the financial statements?”

h. “When we evaluate items for materiality, the only thing we need to worry about is the absolute dollar amount. There really isn’t anything else we need to consider.”

2.69 System of Quality Control. Each of the following quality control policies and procedures is typical of ones that can be found in public accounting firms’ systems of quality control. Identify each of them with one of the six elements of quality control identified by SQCS 8. a. Assign management responsibilities in such a manner that commercial considerations do

not override the quality of work performed.

LO 2-2, 2-3, 2-4

LO 2-2, 2-3, 2-4

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b. Establish policies and procedures for resolving differences of opinion among firm per- sonnel that arise during professional engagements.

c. Develop policies and procedures to ensure that professionals are provided appropriate professional development opportunities.

d. Review engagement documentation, reports, and the client’s financial statements. e. Develop effective performance evaluation, compensation, and advancement procedures. f. Identify circumstances and relationships that create threats to independence and take

appropriate action to eliminate those threats or reduce them to an acceptable level. g. Identify whether the firm possesses the competency, capability, and resources to appro-

priately serve a specific client. h. Devote sufficient resources to develop, communicate, and support the firm’s quality con-

trol procedures. i. Retain engagement documentation for a sufficient period of time to satisfy the needs of

the firm, professional standards, laws, and regulations.

2.70 Evaluating Quality Control. Firms auditing issuers are required to have periodic inspec- tions conducted by the PCAOB.

Required: a. What are the major characteristics of PCAOB inspections? b. What types of firms typically have PCAOB inspections? How frequently are these evalu-

ations conducted?

2.71 Internet Exercise: Public Company Accounting Oversight Board Inspection Reports. Refer to the website of the Public Company Accounting Oversight Board (PCAOB) (www. pcaobus.org), review the information under “Inspections,” and select the most current inspection report for one of the Big Four firms (Deloitte, EY, KPMG, and PwC).

Required: a. What information is contained in the “public” version of the PCAOB’s inspection

reports? Is there any additional information that you would like to see? b. What categories of practices, policies, and procedures are evaluated in the PCAOB’s

inspection of the firm’s quality control system? c. For the firm you selected, how many practice offices had audits inspected by the PCAOB? d. For the firm you selected, for how many audits (issuers) did the PCAOB find deficiencies? e. Identify five deficiencies that were cited in the PCAOB’s inspection report. For each

deficiency, to which of the elements of the principles does it most closely relate? (If the firm had fewer than five deficiencies, evaluate all of the deficiencies identified in the report.)

f. Briefly summarize the firm’s response (if any) to the PCAOB’s inspection report.

LO 2-5

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Referencing Professional Standards Shown here is a comparison of the categories of standards issued by the PCAOB and Auditing Standards Board (ASB). (Section numbers are shown in parentheses for each category.) These general categories parallel the majors stages of an audit engagement and serve as an appropriate starting point when researching the professional auditing literature with respect to an issue that may be encountered during the audit examination.

ASB PCAOB

General Principles and Responsibilities (200–299) General Auditing Standards (1000–1300)

Risk Assessment and Response to Assessed Risks (300–499)

Audit Procedures (2100–2900)

Audit Evidence (500–599) Audit Procedures (2100–2900)

Using the Work of Others (600–699) Incorporated in General Auditing Standards and Audit Procedures

Audit Conclusions and Reporting (700–799) Auditor Reporting (3100–3300)

Special Considerations (800–899) Other Matters Associated with Audits (6101–6115)

Special Considerations in the United States (900–999) Other Matters Associated with Audits (6101–6115) Matters Related to Filings Under Federal Securities Laws (4101–4105)

EXAMPLE: AUDITING REPORTING Assume that you were seeking guidance on the contents of the portion of the auditors’ report related to the opinion on the financial statements. For issuers, “Auditor Reporting” is covered under AS sections 3100–3300. Reviewing AS 3101 (“The Auditor’s Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion”), paragraph 8 provides a detailed summary of the contents of the section of the report related to the financial statement opinion (the actual wording of this section is shown in Appendix B of AS 3101). In documenting your reference to the professional standards, you would cite AS 3101.08 or AS 3101 (Appendix B) as the appropriate source of profes- sional guidance.

For non-issuers, “Audit Conclusions and Reporting” are covered under AU-C sections 700–799. AU-C section 700 (“Forming an Opinion and Reporting on Financial State- ments”) specifically relates to the content of auditors’ reports. When you access AU-C section 700, you will see the source identified as SAS No. 134. If future pronouncements issued by the ASB affect audit reporting, AU-C section 700 will be updated to include those pronouncements. In this way, auditors can find all of the appropriate professional guidance for an area under one AU-C section rather than needing to reference several individual pronouncements.

Each AU-C section includes a number of paragraphs that address various matters related to that topic. AU-C section 700 has 61 paragraphs outlining the professional guidance for reporting and 81 other paragraphs (referred to as Application and Other Explanatory Material) to provide more specific guidance for applications of the standard. Paragraphs 21 through 37 provides the content related to the opinion on the financial statements; paragraph A81 (the “A” refers to application material) provides the actual wording of the report. In documenting your reference to the professional standards, you could refer to either SAS No. 134, AU-C 700.21-700.37, or AU-C 700.A81.

Appendix 2A

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EXAMPLE: AUDIT CONFIRMATIONS You are seeking guidance for the use of confirmations in the audit of an issuer; spe- cifically, you want to know what alternative procedures should be performed for non- responses to confirmations. Reviewing the categories of standards, “Audit Procedures” (AS sections 2100–2900) appears to be most applicable; a review of standards within this category allows you to identify AS 2310, “The Confirmation Process.” Reviewing this standard, paragraphs 31 and 32 describe the auditors’ responsibility for performing alternative procedures if replies to confirmations are not received. In documenting your reference to the professional standards, you would cite AS 2310.31-32.

For the audits of non-issuers, audit evidence is covered under AU-C sections 500–599. AU-C section 505 (“External Confirmations”) specifically relates to the use of external confirmations. When you access section 505, you will see the source identified as SAS No. 122. Paragraphs A24–A26 provide guidance for auditors’ responsibility for nonresponses to confirmations. In documenting your response, you could cite either SAS No. 122 or AU-C 505.A24–A26.

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LEARNING OBJECTIVES During the planning phase of an engagement, the professional standards emphasize that risk assessment underlies the entire audit process. Motivated by the importance of risk assessment, standards setters at both the PCAOB and ASB have each adopted a suite of standards related to the auditor’s assessment of, and response to, risk in a financial statement audit. Collectively, the standards also include guidance pertaining to audit planning, supervision, materiality, and other

related topics. In this chapter, we cover engagement planning, beginning with pre-engagement activities, supervision, and materiality. Next, we cover the types of audit procedures that can be completed and audit documentation. In Chapter 4, we provide a comprehensive explanation of an auditor’s assessment of risk.

Your objectives are to be able to:

LO 3-1 List and describe the required pre- engagement activities that auditors under- take before beginning an audit engagement.

Engagement Planning and Audit Evidence

Vision without action is a daydream;

action without vision is a nightmare. Japanese proverb

Professional Standards References

Topic AU-C/ISA Section AS Section

Overall Objectives of the Independent Auditor 200 1001, 1005, 1010, 1015

Terms of Engagement 210 1301

Communication between Predecessor and Successor Auditors 510 2610

Supervision of the Audit Engagement 220, 300 1201

Audit Documentation 230 1215

Audit Planning 300 2101

Materiality 320 2105

Audit Evidence 500 1105

Substantive Analytical Procedures 520 2305

Consideration of the Internal Audit Function in a Financial Statement Audit

610 2605

Using the Work of an Auditor-Engaged Specialist 620 1210

C H A P T E R 3

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INTRODUCTION Since its existence, the PCAOB has been concerned about auditor compliance with inde- pendence requirements. The concern lies mostly with lengthy auditor client relationships, in particular that auditors may become too familiar with the client and ignore manage- ment issues or even allow for more “creative” accounting practices. The Sarbanes-Oxley act partially addressed this by requiring a mandatory rotation of the lead engagement part- ner every 5 years. Despite this, the independence concern remains. In 2011, the PCAOB issued a concept release statement that alluded to the possibility of audit firm rotation to help mitigate the issue. The concept statement was met with such staunch resistance from firms and issuers (i.e., public companies) that it has not (yet) come to fruition.1

In June of 2017, the PCAOB finalized their audit reporting standard and in doing so made some headway in the auditor independence arena. The new standard, which was effective beginning year-end December 15, 2017, requires auditors to include on the report the year the firm began to serve consecutively as the auditor. Supporters of the standard believe this could be an important point of consideration for investors. The 2018 annual filings revealed some long-standing auditor-client relationships among the Big 4 firms, including the following:

∙ KPMG had been auditing General Electric Company (GE) since 19092

∙ EY had been Coca Cola’s auditor since 1921 ∙ PwC had been Kellogg’s auditor since at least 1937 (PwC indicated in the audit report

that they could not determine the specific year the audit began) ∙ Deloitte served as General Motor’s auditor for 100 years, from 1918 – 2018, EY took

over in 2019.

This chapter is devoted to the audit planning process, beginning with the pre- engagement activities of client acceptance and continuance procedures, including determining compliance with independence requirements. The above described recent initiatives of the PCAOB underscore the importance, and difficulty, of determining com- pliance with independence in particular.

Once a client acceptance or a continuance decision is made, the auditor must develop a detailed audit plan documenting the audit testing procedures to be performed. The testing procedures, outlined later in this chapter, are designed in response to the risk of material misstatement for each of the relevant financial statement assertions in signifi- cant accounts. In this chapter we discuss how materiality is calculated, further discus- sion of the risk of material misstatement is included in Chapter 4. The audit plan and any work done related to the plan must be documented, as further discussed at the end of the chapter.

1Nicole H. Strydom, “Recent developments in Auditor Tenure and Independence,” Governance and Compliance Insider, May 8, 2018, https://governancecomplianceinsider.com/recent-developments-in-auditor-tenure-and-independence/ 2As of March 2019, the SEC was investigating accounting improprieties at GE. GE was undergoing scrutiny for the longstanding relationship with KPMG and therefore announced a plan to solicit bids for a new auditor for 2019 year-end. (Sources: Tammy Whitehouse, “SEC expands probe at GE after $22B impairment,” Compliance Week, October 31 2018,https://www .complianceweek.com/blogs/accounting-auditing-update/sec-expands-probe-at-ge-after-22b-impairment-charge; Aisha Al- Muslim, “GE to explore replacing KPMG as auditor,” The Wall Street Journal, December 14, 2018,https://www.wsj.com/articles/ ge-to-solicit-bids-for-independent-auditor-11544798014)

LO 3-2 Understand the importance of planning the audit engagement so that it is conducted in accordance with professional standards.

LO 3-3 Define materiality and explain its importance in the audit planning process.

LO 3-4 List and describe the eight general types of audit procedures for gathering evidence.

LO 3-5 Define what is meant by the proper form and content of audit documentation.

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PRE-ENGAGEMENT ACTIVITIES Public accounting firms try to reduce their own business risks by carefully managing their audit engagements. To do so, public accounting firms undertake several activities before beginning any audit engagement. In general, these activities can be called risk management activities. Risk in an audit engagement generally refers to the probability that the firm could issue a clean, unmodified audit opinion when in fact a material mis- statement does exist in the financial statements and the opinion should have been modi- fied. Because of the importance of these activities, professional standards state that the auditor should perform the following activities: (1) perform procedures regarding the acceptance or continuance of the audit client relationship, (2) determine compliance with independence and ethics requirements, and (3) reach a contractual understanding with the client for the terms and conditions of the audit engagement. Each of these areas is now discussed.

Client Acceptance or Continuance An important element of a public accounting firm’s quality control policies and proce- dures is a system for deciding whether to accept a new client and, on a continuing basis, whether to continue providing services to existing clients. Public accounting firms are not obligated to accept undesirable clients, nor are they obligated to continue to serve clients when relationships deteriorate or when the management comes under a cloud of suspicion. The process activities are clearly focused on understanding and managing risk to the audit firm. In fact, to mitigate their business risk, public accounting firms devote substantial time to make sure that the audit clients that they serve do not become the focus of the next big accounting scandal.

LO 3-1 List and describe the required pre-engagement activities that auditors undertake before beginning an audit engagement.

Obtain (or Retain)

Engagement

Engagement Planning

Risk Assessment

Substantive Procedures Reporting

STAGES OF AN AUDIT

Auditing a client that has integrity generally results in a problem-free engagement. Conversely, despite conducting an audit in accordance with generally accepted audit- ing standards, it is difficult for a public accounting firm to avoid appearing “guilty by

After Sarbanes–Oxley was passed in 2002, the most prestigious public accounting firms became far more vigilant about walking away from clients that they believed posed a high risk to the firm. When deciding whether to accept a new engagement or continue with an existing client, firms undertake a process to carefully inves- tigate the management team’s reputation and integrity. Audit firms typically perform criminal background checks on the important members of the management team and the audit committee. This process is completed to reduce the possible risk of working with a

client that would be willing to engage in illegal or unethical financial reporting practices.

Performing audits of public companies involves significant reputa- tion and litigation risks to public accounting firms because they are lending their credibility to the client’s financial statements filed with the SEC. As a result, each of the large firms takes dramatic steps to protect its reputation and avoid working with risky clients.

Source: “In-Depth Guide to Public Company Auditing: The Financial Statement Audit,” Center for Audit Quality, May, 2011 (available at www.thecaq.org).

Accounting Firms Will Walk Away from Risky Client

AUDITING INSIGHT

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association” with a client that lacks integrity. The public accounting firm that has been terminated or has voluntarily withdrawn from the engagement (whether the audit has been completed or not) is known as the predecessor auditor. To reduce the risk of accept- ing a problem client, auditing standards require a prospective auditor to initiate contact with and attempt to obtain basic information directly from the predecessor regarding issues that reflect directly on the integrity of management. The audit client must grant its approval before the communication can occur between the prospective auditor and the predecessor auditor. Once approval is obtained, the prospective auditor should ask the predecessor auditor for information on management’s integrity; on disagreements with management about accounting principles, audit procedures, or similar matters; and the reasons for a change of auditors. Companies are free to, and often do, change audi- tors periodically, sometimes as a result of corporate policy to rotate auditors, sometimes because of fee considerations, and sometimes because of arguments about the scope of the audit or the acceptability of accounting principles. It is possible that a change in auditors occurred for the purpose of procuring new auditors who will agree with manage- ment’s treatment of questionable accounting practices. Not surprisingly, these types of disagreements between auditors and management would be of interest to investors and future auditors.

As a result, when a public company changes auditors, the company must file a Form 8-K report with the SEC and disclose that the board of directors approved the change. Form 8-K, the “special events report,” is required whenever certain significant events such as changes in control and legal proceedings occur. Public companies also must report any disagree- ments with the former auditors concerning matters of accounting principles, financial statement disclosures, or auditing procedures. At the same time, the former auditor must submit a letter stating whether the auditors agree with the explanation and, if not, provide particulars. These documents are available to the public through the SEC’s Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system, available on the SEC’s web- site (www.sec.gov). The purpose of these public disclosures is to make information avail- able about client–auditor conflicts that have occurred.

Not as often as you would think. Form 8-K filings show that large companies rarely switch auditors. From the beginning of 2016 to October of 2017, only seven S&P 500 index companies switched auditors. The seven companies and audit firms impacted are listed below:

• American Electric Power changed auditors from Deloitte to PwC, after a 106-year relationship!

• After 100 years, General Motors (GM) switched auditors from Deloitte to EY.

• Leucadia National Corp ended an 81-year audit relationship with PwC, switching to Deloitte.

• Marten Marietta switched from EY to PwC after 23 years. • Hershey switched from KPMG to EY after a 15-year relationship.

• Newell Brands switched auditors from EY to PwC after 14 years. • Johnson Controls International changed auditors from Deloitte to

PwC after 12 years.

This may seem like an unusually small number, however, switching auditors, especially for a large company, is no easy task. Consider, for example, that GM paid Deloitte $26 million in audit fees and an addi- tional $6 million in audit-related fees for the 2017 audit. The amount of resources (time, personnel, etc.) a firm would need available to take on a client of this size would be substantial, to say the least. This says nothing of the time and resources needed by GM to facilitate an auditor switch. Source: John Pakaluk, “After 100 Years, General Motors Switches Auditors,” Audit Analytics, https://www.auditanalytics.com/blog/after-100-years-general- motors-switches-auditor/; General Motors 2018 Proxy Statement, https://media. gm.com/static/proxy-statement/HTML1/general_motors-proxy2018_0077.htm

How Often Do Companies Switch Auditors?AUDITING INSIGHT

If you read closely, professional standards require only that the auditors attempt to communicate with the predecessor auditors. The AICPA Code of Professional Conduct does not permit the predecessor to provide information obtained during any audit engage- ments without the explicit consent of the client. Confidentiality remains even when the auditor–client relationship ends. Therefore, auditing standards require the prospective

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public accounting firm to ask that the consent be given to permit the predecessor auditor to speak. If this consent is refused, the refusal should be regarded as a red flag, and the prospective auditor should be cautious about accepting the engagement.

In addition to communication with the predecessor auditor, client acceptance and con- tinuance policies and procedures generally include

∙ Obtaining and reviewing financial information about the prospective client: annual reports, interim statements, registration statements, Form 10-Ks, and reports to regu- latory agencies.

∙ Acquiring detailed criminal background checks of all senior managers. ∙ Requesting the prospective client’s bankers, legal counsel, underwriters, analysts, or

other persons who do business with the entity to provide information about it and its management.

∙ Considering whether the engagement would require special attention or involve unusual risks to the public accounting firm.

∙ Evaluating the public accounting firm’s independence with regard to the prospective client. ∙ Considering the need for individuals possessing special skills or knowledge to com-

plete the audit (e.g., IT auditor, valuation specialist, industry specialist).

The firms also search for news articles, lawsuits, and bankruptcy court outcomes nam- ing the entity, the chairman of the board, the CEO, the CFO, and other high-ranking offi- cers. In fact, the firms often engage private investigators to conduct additional searches for information when the prospective clients are financial institutions, companies accused of fraud, companies under SEC or other regulatory investigation, companies that have changed auditors frequently, and companies showing recent losses. These characteristics are red flags of potential problems, and public accounting firms want to know as much as they can about the companies and their officers before entering into a relationship with them. Without a doubt, management integrity (or lack thereof) is the primary reason for accepting (or not accepting) an audit engagement.

Client continuance decisions are similar to acceptance decisions except that the firm will have more firsthand experience with the entity. These types of client retention reviews are typically done annually and also with the occurrence of major events such as changes in management, directors, ownership, legal counsel, financial condition, litiga- tion status, nature of the client’s business, or scope of the audit engagement. In general, conditions that would have caused a public accounting firm to reject a prospective client can develop and lead to a decision to discontinue the engagement. For example, a cli- ent company could expand and diversify on an international scale so that a small public accounting firm might not have the resources to continue the audit. In addition, it would not be unusual to see newspaper stories about public accounting firms dropping clients after directors or officers admit to falsification of financial statements, theft and misuse of corporate assets, or other improprieties.

In December of 2017, KPMG announced their decision to resign as Liberty Tax’s auditor, three months after the firing of CEO John Hewitt. Hewitt was fired for having romantic relationships with female employ- ees and giving them preferential treatment, yet remained the chairman of the board due to his status as controlling shareholder of the com- pany. When announcing the decision, KPMG cited concerns around internal controls over financial reporting, more specifically related to

management integrity and the tone at the top. Ultimately Hewitt did agree to resign as chairman of the board and sell his ownership shares of the company in July 2018, following delayed earnings reports and violation warnings of listing requirements from the NASDAQ exchange.

Sources: “KPMG Resigns from Auditing Liberty Tax,” Accounting Today, December 11, 2017, M. Cohn; “Liberty Tax Soars After Founder Involved in Sex Scandal Agrees to Leave Firm,” Accounting Today, July 24, 2018, A. Melin.

KPMG Severs Relationship with Liberty TaxAUDITING INSIGHT

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Compliance with Independence and Ethical Requirements If you recall from Chapter 2, the responsibilities principle requires auditors to comply with appropriate ethical requirements for each audit engagement; two important require- ments relate to independence and due care. Auditors must maintain independence in mental attitude; that is, auditors are expected to be unbiased and impartial with respect to the financial statements and other information they audit. This “state of mind” is often referred to as the auditor possessing independence in fact. This independence allows auditors to form an opinion on the entity’s financial statements without being affected by influences that might compromise that opinion. Not only is it important for auditors to be unbiased, but they must also appear to be unbiased. Independence in appearance relates to others’ (particularly financial statement users’) perceptions of auditors’ independence.

In fact, if the auditor is not independent, the financial statements are considered unaudited for all practical purposes. A lack of independence can result in disciplin- ary action by regulators and/or professional organizations and litigation by those who relied on the financial statements (e.g., clients and investors). The profession as a whole depends on the value of independence in that the auditor’s opinion on the financial statements loses its value if the auditor is not considered to be independent from the management of the firm. As a result of the importance placed on independence, public accounting firms must have a process in place to ensure that they are independent of the company being audited.

Because public accounting firms are subject to strict independence rules, they actively monitor the key relationships and the investment portfolios of their individual partners. These processes are in place to help ensure that the firm is independent of any relationship that might impact the firm’s professionals from maintaining objec- tivity when making professional judgments on each audit. In fact, even after an audit client has passed the client acceptance process, independence rules must continue to be rigorously maintained. The importance of this process is exemplified by the way that KPMG handled a recent situation involving a rogue partner, described in the fol- lowing Auditing Insight.

KPMG LLP was forced to resign from two large audit clients, Herbalife Ltd. and Skechers USA Inc., because Scott London, the partner assigned to each client, admitted to providing stock tips about the two audit clients to a friend in exchange for cash and gifts. The friend is believed to have made more than $1 million from trading on the insider information. By providing confidential insider information, Lon- don directly violated the AICPA Code of Professional Conduct regard- ing confidential client information. As a result, the firm immediately fired him and resigned as the external auditor for the two clients. The resignation was necessary because London “violated the firm’s rig- orous policies and protections, betrayed the trust of clients as well as colleagues, and acted with deliberate disregard for KPMG’s long- standing culture of professionalism and integrity.”* There was a fear that the firm’s independence and objectivity toward the clients would potentially be compromised as a result of this partner’s actions. In addition to resigning from the two audits, KPMG decided to withdraw its audit report on the financial statements of Herbalife for the three

previous years and for Skechers for the previous two years. In doing so, KPMG stated that it did not believe there were any errors in the financial statements. However, because of London’s actions, the firm believed doing so was appropriate. London pleaded guilty to a federal insider-trading charge on July 1, 2013, publicly admitting that he did reveal confidential information about his clients to a friend. The friend used the information to make over $1 million. London was sentenced to serve 14 months in a federal prison in April 2014.

Sources: J. Eaglesham, J. Chung, and H. Karp, “Trading Case Embroils KPMG,” The Wall Street Journal, April 10, 2013, p. A1; M. Geller and E. Flitter, “FBI Probes Trading as KPMG Quits Herbalife, Skechers Audits.” Reuters.com, April 9, 2013, available at www.reuters.com/article/2013/04/09/us-herbalife- auditor-idUSBRE9380N920130409; S. Pfeifer, “Former KPMG Partner Scott London Pleads Guilty to Insider Trading.” Los Angeles Times, July 1, 2013, available at http://articles.latimes.com/2013/jul/01/business/la-fi-mo-kpmg- scott-london-insider-trading-20130627; S. Pfeifer, “Former KPMG Partner Sentenced for Insider.” Los Angeles Times, April 24, 2014, available at http://www.latimes.com/business/la-fi-kpmg-london-20140425-story.html.

Compromised Independence?AUDITING INSIGHT

Geller, Martinne, and Emily Flitter. “FBI probes trading as KPMG quits Herbalife, Skechers audits.” Reuters, April 9, 2013. https://www.reuters.com/article/ us-herbalife-auditor/fbi-probes-trading-as-kpmg-quits-herbalife-skechers-audits-idUSBRE9380N920130409.

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Engagement Letters Professional standards require auditors to reach a mutual understanding with clients concern- ing engagement requirements and expectations and to document this understanding, usually in the form of a written letter. When a new client is accepted or when an audit engagement continues from year to year, an engagement letter should be prepared. This letter sets forth the understanding with the client, including in particular (1) the objectives of the engagement, (2) management’s responsibilities, (3) the auditors’ responsibilities, and (4) any limitations of the engagement. Other matters of understanding, such as the ones shown in Exhibit 3.1, also may be included in the letter. For example, the additional internal control considerations required by the Public Company Accounting Oversight Board are specifically mentioned in the example engagement letter. In fact, a close review of this exhibit reveals the importance of an auditor being quite detailed when completing the engagement letter.

EXHIBIT 3.1 Engagement Letter

September 15, 2020

Mr. Matt Lancaster Chair, Audit Committee Dunder-Mifflin Inc. P.O. Box 349 Scranton, Pennsylvania 18503

Dear Mr. Lancaster:

This letter will confirm our understanding of the arrangement for our audit of the financial statements of Dunder-Mifflin Inc. for the year ending December 31, 2020.

We will audit the Company’s balance sheet at December 31, 2020, and the related statements of income, comprehensive income, stockholders’ equity, and cash flows for the year then ended, for the purpose of expressing an opinion on them. We will also audit whether Dunder-Mifflin Inc. maintained effective internal control over financial reporting as of December 31, 2020, based on criteria established in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO criteria). Dunder-Mifflin Inc.’s management is responsible for these financial statements and for maintaining effective internal control over financial reporting. Management is also responsible for making financial records and related information available for audit and for identifying and ensuring that the company complies with the laws and regulations that apply to its activities. Our responsibility is to express an opinion on these financial statements and an opinion on the effectiveness of the company’s internal control over financial reporting based on our audits. If, for any reason, we are unable to complete the audit or are unable to form or have not formed an opinion, we may decline to express an opinion or decline to issue a report as a result of the engagement.

We will conduct our audits in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement and whether effective internal control over financial reporting was maintained in all material respects. Our audit of the financial statements includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements, assessing the accounting principles used and significant estimates made by management, and evaluating the overall financial statement presentation. Our audit of internal control over financial reporting includes obtaining an understanding of internal control over financial reporting, testing and evaluating the design and operating effectiveness of internal control, and performing such other procedures as we considered necessary in the circumstances. We believe that our audits provide a reasonable basis for our opinions.

Our fee for these services will be at our regular hourly rates, plus travel and other out-of-pocket costs. Invoices will be rendered on a monthly basis and are payable on presentation. If this letter correctly expresses your understanding, please sign the enclosed copy where indicated and return it to us.

Very truly yours,

Michael Scarn, LLP

DUNDER-MIFFLIN Inc.

By

Date

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AUDIT PLAN An audit plan is a comprehensive list of the specific audit procedures that the audit team needs to perform to gather sufficient appropriate evidence on which to base their opin- ion on the financial statements. The professional standards require that the auditor plan each audit engagement, including the establishment of an overall strategy for each audit engagement. Specifically, when planning the engagement, the auditor needs to develop and document a plan that describes the nature, timing, and extent of further audit pro- cedures to be performed to assess the risk of material misstatement at the financial statement and the assertion level. Next, the auditor must carefully plan the nature, tim- ing, and extent of control tests and substantive tests that are designed to mitigate these risks to an acceptable level. This planning process is required to be led by the assigned engagement partner.

LO 3-2 Understand the importance of planning the audit engagement so that it is conducted in accordance with professional standards.

In effect, the engagement letter acts as a contract. Thus, it serves as a means for reduc- ing the risk of misunderstandings with the client and as a means of avoiding legal liability for claims that the auditors did not perform the work promised.

Many public accounting firms also have policies about sending a termination letter to former clients. Such a letter is a good idea because it provides an opportunity to deal with the subject of future services, in particular, (1) access to audit documentation by successor auditors, (2) reissuance of the auditors’ report when required for SEC report- ing or comparative financial reporting, and (3) fee arrangements for such future services. The termination letter also may include a report of the auditors’ understanding of the circumstances of termination (e.g., disagreements about accounting principles and audit procedures, fees, or other conflicts). These matters can be of great interest to prospective auditors who should always remember to ask for a copy of the termination letter.

REVIEW CHECKPOINTS 3.1 What sources of information can auditors use in connection with deciding whether to accept a new

client? 3.2 Why do predecessor auditors need to obtain the client’s consent to give information to prospective

auditors? What information should prospective auditors try to obtain from predecessor auditors? 3.3 What benefits are obtained by having an engagement letter? What is a termination letter?

Obtain (or Retain)

Engagement

Engagement Planning

Risk Assessment

Substantive Procedures Reporting

STAGES OF AN AUDIT

The professional standards are absolutely clear that the nature and extent of work completed during engagement planning will depend on the company’s size, complexity, and industry. In addition, the auditor’s prior experience with the company, including any major changes from prior years, will have an impact on the nature and extent of plan- ning activity. Furthermore, the client’s information technology system used to process accounting transactions will also have an impact on planning activities. As a result, audit

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firms spend a considerable amount of time on risk assessment at both the financial state- ment level and the management assertion level for the client being audited.

Importantly, this process begins with a detailed understanding of the client’s business, industry, and strategy to achieve a competitive advantage in its marketplace. During this process, the auditor should obtain an understanding of important events that have affected the client, its operations, and its accounting information system. When understanding the accounting information system, the auditor should pay particular attention to:

∙ The complexity of the computer operations used by the entity (e.g., batch processing, online processing, outside service centers).

∙ The organizational structure of the computerized processing activities. ∙ The availability of data for the auditor. ∙ The need for specialized skills.

Relatedly, the auditor should obtain an overall understanding of the financial state- ments, and ultimately the management assertions. This understanding provides the base of knowledge necessary to assess audit risk, providing the underlying basis to construct the audit plan.

For example, the evaluation of the risk of material misstatement is likely to vary for different financial statement accounts and may even vary for different classes of signifi- cant transactions related to the same financial statement account. Ultimately, the audit plan will need to identify each of the relevant financial statement assertions (i.e., exis- tence, occurrence, completeness, cutoff, rights and obligations, valuation and allocation, accuracy, classification, and understandability) for each of the significant financial state- ment accounts and disclosures identified at an audit client.

The risk assessment process provides the basis to determine the nature, timing, and extent of internal control tests and substantive tests of account balances and disclosures at an audit client. That is, for each relevant assertion, the auditor must determine the combi- nation of control and substantive tests that will be necessary to gather enough evidence to persuade the auditor that no material misstatement exists for the relevant assertion being audited. When the tests have been completed, audit team members will often indicate the date that the procedure was performed and where the evidence is documented in the audit plan. Thus, audit plans are used not only for quality control and supervision but also as documentation to show that the audit engagement was planned and supervised in accor- dance with professional standards.

Risk assessment is absolutely critical in the audit planning process. Remember that the professional standards require that when planning, the auditor should establish the overall audit strategy for the company being audited, which includes the risk assessment proce- dures that will be performed and ultimately the auditor’s plan to respond to each of the assessed risks of material misstatement with specific auditing procedures. Because of the importance of risk assessment to the financial statement audit process, we devote exclu- sive attention to this subject in Chapter 4.The remainder of this chapter will focus on all other aspects of engagement planning. Essentially, there are three goals of audit planning:

∙ To make sure that the firm has the requisite staff to conduct the audit in accordance with professional standards in a timely and profitable manner;

∙ To determine materiality; and ∙ To outline the specific audit procedures, including tests of control and substantive

tests that need to be executed properly in order to mitigate assessed risks of material misstatement and be in compliance with professional standards.

Staffing the Audit Engagement When a new client is obtained, most public accounting firms assign a full-service team to the engagement. For a typical audit engagement, this team usually consists of the audit engagement partner (the person with final responsibility for the audit, usually an industry specialist), an audit manager, an information technology (IT) auditor, a tax specialist, a

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quality assurance partner (the second audit partner who reviews the audit team’s work in critical audit areas), and audit staff. The assignment of staff depends on the riskiness of the engagement. For new clients, companies with complex significant transactions and public companies, more experienced staff members are typically assigned. No matter the type of engagement, planning meetings should include all team members and focus on the financial statement accounts that represent the highest risk of material misstatement.

The Center for Audit Quality (CAQ) is a nonprofit organization that is dedicated to promoting “high quality performance by public company auditors,” which helps to ensure the highest level of “investor confi- dence” in the capital markets. In providing the financial support for the CAQ, the public company auditing firms recognize the importance of working together to achieve audit quality.

The importance of planning was recently elevated by the CAQ when it released its own set of Audit Quality Indicators. In fact, one of the four key themes of audit quality outlined by the CAQ was the “engagement team knowledge, experience, and workload.” Among other issues, the report stressed that “The knowledge, experience, and workload of the audit engagement partner and certain other mem- bers of the engagement team are important elements in the execution

of an audit. It is the responsibility of the engagement partner to deter- mine that, collectively, the engagement team has the appropriate experience and competencies, and that specialists are engaged, as needed. The level of detail that may be provided on changes in the composition of the engagement team is dependent on the audit com- mittee’s needs and expectations, size of the engagement team, and other considerations.”*

Sources: CAQ Approach to Audit Quality Indicators, April 24, 2014, available at http://www.thecaq.org/reports-and-publications/caq-approach-to-audit-quality- indicators/caq-approach-to-audit-quality-indicators; Audit Quality Indicators: Journey and Path Ahead, January 12, 2016, available at http://www.thecaq .org/reports-and-publications/audit-quality-indicators-journey-and-path-ahead/ audit-quality-indicators-journey-and-path-ahead.

Plan for QualityAUDITING INSIGHT

These planning meetings help to ensure that the engagement is properly planned and that the audit team (especially new) members are properly supervised. The meetings also are intended to be brainstorming sessions to (1) ensure that all audit team members are informed about potential risks in the engagement and (2) increase team members’ awareness for poten- tial fraud. This required brainstorming session is discussed in more detail in Chapter 4.

In the sections below are further discussions of specific engagement staffing issues, including the role of IT auditors on the engagement team, relying on the work of internal auditors, and the use of audit specialists.

Use of IT Auditors When planning the engagement, the audit team members should consider their train- ing and experience relative to the methods of information processing. A review of the client’s computer hardware could show the extent of complexity involved. Whenever a complex computing environment exists, specialized information technology skills are needed to evaluate the effect of computerized processing on the audit process. IT audi- tors are members of the audit team who are specially trained to evaluate computerized controls and processes. The audit team could need their specialized skills relating to various methods of data processing and extraction, programming languages, software packages, or computer-assisted audit techniques. For audits of large companies in today’s environment, IT auditors will be required and included on the engagement team.

If the client outsources significant accounting applications (e.g., payroll), the audit team might need to coordinate audit procedures with service auditors at the processing center. This topic is covered in more detail in Module A.

Considering the Work of Internal Auditors External auditors must obtain an understanding of a client’s internal audit department and its work as part of the understanding of the client’s internal control system. Internal audi- tors were discussed briefly in Chapter 1 and will be discussed in more detail in Module D,

Center for Audit Quality. “CAQ Approach to Audit Quality Indicators.” Accessed June 24, 2019. https://www.thecaq.org/ wp-content/uploads/2019/03/caq-approach-to-audit-quality-indicators-april-2014.pdf.

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but here we talk about the working relationship between internal and external auditors. Audit efficiency can be realized when the two groups work together. However, prior to relying on the work of internal auditors, external auditors should consider internal audi- tors’ objectivity and competence:

∙ Objectivity. Internal auditors can never be considered independent in the same sense that external auditors are because internal auditors are either directly employed or paid as contractors by the client; however, they can (and should) be objective.3 Internal auditors’ objectivity is investigated by learning about their organizational status and lines of com- munication in the company. Objectivity is enhanced when the internal auditors report directly to the audit committee of the board of directors. Objectivity is questioned when

∙ internal auditors report to divisional management, line managers, or other persons with a stake in the outcome of their findings.

∙ managers have some power over the pay or job tenure of the internal auditors. ∙ individual internal auditors have relatives in audit-sensitive areas or are scheduled to

be promoted to positions in the activities under internal audit review. ∙ Competence. Internal auditors’ competence is investigated by obtaining evidence

about their educational and experience qualifications, their certifications (CPA, CIA, CISA, etc.) and continuing education status, the department’s policies and procedures for work quality and for making personnel assignments, the supervision and review activities, and the quality of reports and audit documentation. This evidence enables the external auditors to evaluate internal auditors’ performance.

Favorable conclusions about competence and objectivity enable external auditors to rely on the work completed by the internal audit department related to gaining an under- standing of and testing of a company’s internal control system. Internal auditors also can assist (under the supervision of the independent audit team) with performing some substantive testing of balances on the audit, reducing the external auditors’ work, and avoiding duplication of effort. As an example, internal auditors can conduct observations and make test counts during physical inventory counts thereby allowing auditors to be able to reduce the nature, timing, or extent of their own procedures for these accounts. This utilization of internal auditors’ work, however, cannot be a complete substitute for the external auditors’ own procedures, as it is the work of the external auditors that must always provide the basis for the auditors’ opinion.

The external auditors can never delegate responsibility for audit decisions to the internal auditors. Rather, they must supervise, review, evaluate, and perform independent testing of all the work performed by internal auditors. Internal auditors should never be delegated tasks that require the external auditors’ professional judgment. Following is an illustra- tion of how one Big Four firm addresses the use of internal auditors on its engagements. Note that internal auditors’ work can be utilized more extensively without reperforming a percentage of the work when the account balance involves low professional judgment and risk, and internal auditors are considered to be more competent and objective.

3Internal auditors refer to their level of objectivity as independence. This concept is discussed further in Module D.

Reliance on Internal Auditors

  Objectivity and Competence

  Low High

High judgment/risk Auditor should not rely on internal auditors’ work

Auditor should not rely on internal auditors’ work

Low judgment/risk Auditor can rely on internal auditors’ work but should reperform some of the work

Auditor can rely on internal auditors’ work and may want to reperform some of the work

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Using the Work of a Auditor-Employed or Auditor-Engaged Specialist  Gaining an understanding of the business can often lead to acquiring information that reveals the need to employ audit specialists on the audit. Audit specialists are persons skilled in fields other than accounting and auditing—actuaries, appraisers, attorneys, environmental engineers, and geologists—who are not members of the audit team. Audi- tors are not expected to be experts in all fields of knowledge that can contribute infor- mation to the financial statements. Audit specialists can be employed by the auditor’s firm (i.e., auditor-employed specialists) or engaged from an outside provider, referred to simply as an auditor-engaged specialist. In other words they should typically be involved in planning meetings and supervised as other team members under AS 1201 (unlike auditor-engaged or company specialists covered by AS 1210). When an auditor-engaged specialist is used, the audit engagement partner should assess the specialist’s knowledge, skill, and ability in that particular area. This includes gaining knowledge about his or her professional qualifications, experience, and reputation. The engagement team must also assess the objectivity of the auditor-engaged specialist. An auditor-engaged special- ist should be unrelated to the company under audit if possible. Regardless of whether the specialist is auditor-employed or auditor-engaged, the engagement partner and team should clearly inform the audit specialist of the work to be performed and of any matters that may affect his or her work. The engagement partner and audit team must also evalu- ate the work of the specialist. The extent of the evaluation is contingent upon the reliance on the specialist’s work, the risk of material misstatement in the area, the experience and skill of the specialist, and the objectivity of the specialists. Provided that some additional auditing work is done on the data that the audit specialist uses in reaching his or her conclusions, auditors may rely on the work of an audit specialist in connection with audit decisions. Normally, audit specialists are not referred to in the auditor’s report unless they are involved in addressing a critical audit matter disclosed in the audit report or unless their findings (e.g., a difference in an estimate from that of management) cause the audi- tors’ report to be modified (e.g., because of a GAAP departure). In these cases, references to the findings of the audit specialists may facilitate a better understanding of the nature of the GAAP departure.

Using the Work of a Company’s Specialist Auditors may also use the work of a company’s specialist as audit evidence. Much like when using the work of internal auditors, external auditors must consider the objectivity and competence, specifically the knowledge, skill, and ability, of the company special- ist. As with the auditor-engaged specialist, the auditor must evaluate the work of the company specialist, including evaluating any data, methods, or assumptions made by the specialist. Similarly, the extent of the evaluation is contingent upon the risk of material misstatement in the area, the significance of the company specialist’s work to the audi- tor’s conclusion, the knowledge, skill, and ability of the specialist, and the objectivity of the specialist’s judgment.

Time Budget The timing of the work and the number of hours that each segment of the engagement is expected to take are detailed in a preliminary time budget. Time budgets are used to main- tain control of the audit by identifying problem areas early in the engagement, thereby ensuring that the engagement is completed on a timely basis. Time budgets are usually based on the prior-year’s performance for continuing clients while considering changes in the client’s business. In a first-time audit, the budget may be based on a predecessor audi- tor’s experience or on general experience with similar companies. Extra time also may be assigned to those accounts containing the highest amount of audit risk. A simple time budget for an audit engagement follows.

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  Audit Time Budget (Hours)

  Interim Year-End (Final)

Gain an understanding of business 15   Evaluate internal audit function 10   Understand internal control system 30 10 Prepare audit plan 25   Investigate related party transactions 5 15 Meet with client personnel 10 18 Complete cash substantive testing 10 15 Complete accounts receivable substantive testing 15 5 Complete inventory substantive testing 35 20 Complete accounts payable substantive testing 5 35 Evaluate legal letters   20 Review financial statement   25 Prepare audit report   12

This time budget is illustrative—actual time budgets are much more detailed and com- plex. Most budgets specify the expected time according to the level of staff people on the team (partner, manager, in-charge accountant, staff assistant, IT specialist, tax specialist). The illustration shows time at interim and at year-end. Interim audit work refers to procedures performed several weeks or months before the date of the financial statements. (Account balances audited during interim are later rolled forward at year-end.) Year-end audit work refers to procedures performed shortly before and after the date of the financial statements. Public accounting firms typically spread the workload during the year by scheduling interim audit work so they will have enough time and people available when several audits have year- ends on the same date. (December 31 is quite common.) For many public accounting firms, the auditing “busy season” runs from September through March of the following year. The interim work typically consists of risk assessment work, internal control testing, and substan- tive testing of balances as they exist at the interim date.

Everyone who works on the audit engagement is typically required to report the time taken to perform procedures for each phase of the audit. These time reports are recorded by budget categories for the purposes of (1) evaluating the efficiency of the audit team members, (2) compiling a record for billing the client, and (3) compiling a record for planning the next audit. Although the purposes of a time budget are straightforward, these budgets create job pressures. Staff members are under pressure to meet the budget, and beginning auditors often experience frustration over learning how to complete their audit work in an efficient manner.

REVIEW CHECKPOINTS 3.4 What is the purpose of a planning memorandum? 3.5 List some items normally documented in a planning memorandum. 3.6 What must external auditors do to use the work of internal auditors in the audit of an entity’s finan-

cial statements? 3.7 What must external auditors do to use the work of audit specialists in the audit of an entity’s finan-

cial statements? 3.8 For a typical audit engagement, describe the people and skills that are normally assigned to a full-

service audit team.

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MATERIALITY As you know, financial statement measurements and information in some footnote disclo- sures are not flawlessly accurate. As noted in the auditors’ report, the financial statements are a function of the “accounting principles used and significant estimates made by man- agement.” The choices of depreciation method, inventory valuation method, or classifica- tion of marketable securities, for example, all affect final financial statement numbers. Furthermore, many financial measurements are based on estimates such as the estimated depreciable lives of fixed assets or the estimated amount of uncollectible accounts receiv- able. Thus, net income is not necessarily the one “true” figure but one possibility in a range of potential net income figures allowable under the relevant reporting framework (e.g., GAAP or International Financial Reporting Standards [IFRS]).

Given this range permitted, some amount of inaccuracy is allowed in financial state- ments. This is because (1) unimportant inaccuracies do not affect users’ decisions and hence are not material, (2) the cost of finding and correcting small misstatements is too high, and (3) the time taken to find them would delay issuance of the financial state- ments. Although not absolutely accurate, accountants and auditors do want to maintain that financial reports are materially accurate and do not contain material misstatements.

As a result, to plan the nature, timing, and extent of further audit procedures to be performed, an auditor “should establish a materiality level for the financial statements as a whole that is appropriate in light of the particular circumstances. This includes consid- eration of the company’s earnings and other relevant factors.” The professional standards also require that the “materiality level for the financial statements as a whole needs to be expressed as a specified amount.”4

Information is considered material if it is likely to influence financial statement users’ decisions. When referring to materiality in the auditing standards, PCAOB AS No. 2105 cites the definition as established by the Supreme Court, that a fact is material if there is “a substantial likelihood that the .  .  . fact would have been viewed by the reasonable investor as having significantly altered the ‘total mix’ of information made available.” The emphasis in this definition is on the financial statement users’ point of view, not on the auditors’ or managers’ point of view. Although financial statement users are expected to have a basic knowledge of business and financial statements as well as an understand- ing of the limitations of the audit process, auditors remain conservative when setting the materiality level.5

Given this, the engagement partner needs to think carefully about the appropriate level of materiality during the planning process. By doing so, the auditor helps to avoid unnec- essary surprises on the audit engagement. Suppose that near the end of an audit, the part- ner decided that all misstatements of more than $50,000 should be considered material but then realized that the nature, timing, and extent of substantive procedures had been completed assuming a materiality level of $250,000! As a result, the nature, timing, and extent of further audit procedures would have to be modified significantly, which would likely be an unpleasant surprise for the engagement team.

The professional standards also require the auditor to evaluate the facts and circum- stances of each engagement carefully to determine whether there are particular accounts or disclosures where amounts lower than established materiality might influence the judgment of a reasonable financial statement user. If that is the case, the auditor must determine an amount that would be considered a tolerable misstatement for that account or disclosure when completing risk assessment procedures and further planning and per- forming the necessary audit procedures in that area.6

LO 3-3 Define materiality and explain its importance in the audit planning process.

4Public Company Accounting Oversight Board. “AS 2105: Consideration of Materiality in Planning and Performing an Audit.” Accessed June 24, 2019. https://pcaobus.org/Standards/Auditing/Pages/AS2105.aspx. 5Ibid. 6Ibid.

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Therefore, auditors use performance materiality (an amount less than materiality for the financial statements as a whole) to make sure that the aggregate of uncorrected and undetected immaterial misstatements does not exceed materiality for the financial state- ments as a whole. For example, auditors may use different amounts (smaller than overall financial statement materiality) when auditing particular classes of significant transac- tions, account balances, or disclosures. The audit team cannot look at every significant transaction, so the concept of performance materiality takes this risk into account. When auditors use sampling, performance materiality is referred to as tolerable misstatement.

The extent to which performance materiality is based on the overall materiality is a mat- ter of professional judgment and, as a result, the amount may vary from auditor to audi- tor, as could the methods for assigning performance materiality to accounts. The auditing standards do not even require that the overall materiality amount be assigned to individual accounts in dollar amounts. While there may be many different processes for determin- ing performance materiality, most auditors start with a top-down approach: judging an overall material amount for the financial statements and then determining performance materiality to particular accounts to help determine the amount of work to be done in each area. Such a top-down approach is considered theoretically preferable because this method requires the audit team to think first about the financial statements taken as a whole.

Materiality Calculation Although some accountants wish that standard setters could issue definitive, quantitative materiality guidelines, many fear the rigidity that such guidelines would impose. There- fore, in the end, materiality is a matter of professional judgment that the engagement partner must decide on each audit engagement. However, on each audit engagement, the planning process begins with a calculation of a preliminary materiality amount that is based on a relevant benchmark and a rule of thumb percentage applied to that benchmark.

The choice of appropriate benchmark relates directly back to what is most important for the financial statement users and the industry in which the client operates. Auditors most commonly use profit before tax (PBT), total net assets, or total revenues as the benchmark for their initial determination of materiality, depending on the client industry. Some examples of commonly used benchmarks per industry are noted below:

∙ Asset based entities – total net assets. ∙ Profit based companies, such as manufacturing - PBT. ∙ High technology start-up companies – total revenue. ∙ Nonprofit entities – gross revenue or total contributions.

The rule of thumb percentages applied to the benchmarks often range from 3–5 percent of PBT or 1/2–1 percent of revenue or total assets.

As noted, the percentages and benchmarks per industry are only rules of thumb and will not be appropriate for all clients. If, for example, the PBT for a profit-based company fluc- tuates widely, an average PBT over recent years may be a more appropriate benchmark for materiality. Alternatively, if a profit-based company experienced a net loss, an alternative benchmark may be more appropriate to use to determine materiality. Amazon, the internet retail giant, provides an example of both of these scenarios. For the fiscal year 2018, Ama- zon reported $11.2 billion in income before taxes (i.e., profit before tax). For the years ended 2017 and 2016, Amazon reported $3.8 and $3.9 billion PBT, respectively. Using the rule of thumb of 3% of PBT, the overall materiality set for the 2018 Amazon audit would be approximately $337 million dollars, which is close to 10% of Amazon’s PBT in each of the prior years! In a situation like this, auditors may decide to use the average PBT of the prior years to determine materiality. Although hard to believe today, in 2002, Amazon reported a net loss of $149 million and net sales of $3.9 billion. In a loss scenario such as this, auditors may decide using a percentage of sales or total assets is a more appropriate benchmark for materiality. Of course, in the end, materiality is a matter of professional judgment, keeping in mind what matters most to the financial statement users.

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Although standards require materiality be expressed as a quantitative amount, auditors must consider qualitative factors as well. The SEC cautions auditors about overreliance on certain quantitative benchmarks to assess materiality, noting that “misstatements are not immaterial simply because they fall beneath a numerical threshold.”7 Thus, auditors must examine both quantitative and qualitative factors when assessing materiality. Some of the more common qualitative factors that auditors use in making materiality judgments are the nature of the item or issue, engagement circumstances, and possible cumulative effects—all discussed in the following paragraphs.

Nature of the Item or Issue An important qualitative factor is the descriptive nature of the item or issue. An illegal pay- ment is important primarily because of its nature as well as because of its absolute or relative amount. In addition, the auditor would consider any type of fraud committed by a member of management material regardless of the amount. Finally, generally speaking, potential errors in the more liquid assets (cash, receivables, and inventory) are considered more important than potential errors in other accounts (such as fixed assets and deferred charges).

Engagement Circumstances An auditor’s legal liability is always a relevant consideration when determining material- ity. That is, auditors generally place extra emphasis on the detection of misstatements in financial statements that will be widely used (such as those of public companies) or used by important outsiders (such as bank loan officers). The likelihood of an engagement being selected for inspection by the PCAOB is also a relevant consideration. In addition, troublesome political events in foreign countries can cause auditors to try to be more accurate with measurements and disclosures. Other circumstances that affect quantitative materiality involve amounts that could turn a net loss into a profit or allow a company to meet earnings expectations. In these circumstances, when management can exercise discretion over an accounting treatment, auditors tend to exercise more care and use a more stringent quantitative materiality criterion. Finally, matters surrounded by uncer- tainty about the outcome of future events usually come under more stringent quantitative materiality considerations.

Possible Cumulative Effects At the end of each audit engagement, auditors must also evaluate the aggregate sum of known or potential misstatements. For example, consider an audit for which overall mate- riality is set at $50,000. If the audit test work revealed five individual $15,000 misstate- ments, they would each, on their own, be considered immaterial. However, what if all five misstatements each had the effect of increasing net income? In that situation, the auditor must factor in the probability that the aggregate of uncorrected and undetected misstatements could exceed overall materiality for the financial statements.

7SEC Staff Accounting Bulletin No. 99, “Materiality,” August 12, 1999.

In early 2019, Hertz, the rental car company giant, agreed to pay a $16 million penalty to the SEC over accounting errors that lead to material misstatements in the audited financial statements for 2012 and 2013, as well as portions of the unaudited 2011 financial state- ments. Hertz identified 17 areas with material accounting errors across several business units, including one misstatement valued at

$48 million. The cumulative effect of the misstatements resulted not only in the hefty SEC fine, but a reduction in previously reported pre- tax income of $235 million.

Source: “SEC Penalizes Hertz $16M for Accounting Violations,” Accounting Today, January 12, 2019, M. Cohn.

Costly Cumulative EffectsAUDITING INSIGHT

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Although we have presented a number of different factors affecting overall materiality, decisions about materiality ultimately remain a function of auditors’ professional judg- ment. Many experienced auditors will state that these judgments are among the most difficult they make. And materiality is one of the most important audit concepts you will learn about because of its pervasive effect on the audit engagement. To summarize, on an audit engagement, the audit team uses materiality three ways:

1. As a guide to planning substantive testing procedures—directing attention and audit work to those items or accounts that are important, uncertain, or susceptible to mate- rial misstatements.

2. As a guide for determining performance materiality to help make sure that the aggre- gate of uncorrected and undetected immaterial misstatements does not exceed the materiality level for the financial statements as a whole. For example, auditors may use an amount smaller than overall financial statement materiality when auditing par- ticular classes of significant transactions, account balances, or disclosures.

3. As a guide for making decisions about the audit report. An account such as inven- tory can be material in an audit context because of its size or its place in the financial statements.

AUDIT PROCEDURES FOR OBTAINING AUDIT EVIDENCE Auditors use audit procedures for three purposes. First, they use audit procedures to gain an understanding of the client and the risks associated with the client (risk assessment procedures). These procedures are covered in detail in Chapter 4. Second, auditors use audit procedures to test the operating effectiveness of client internal control activities (tests of controls) discussed in Chapter 5. Finally, auditors use audit procedures to pro- duce evidence about management’s assertions (i.e., relating to existence, occurrence, completeness, cutoff, rights and obligations, valuation and allocation, accuracy, classifi- cation, and understandability) related to the amounts and disclosures in a client’s finan- cial statements. Exhibit 3.2 shows the relationship among the assertions, the types of evidence available to the auditor, and the procedures most closely related to each.

Once the risk assessment procedures have been completed and the relevant financial statement assertions have been identified, an auditor then considers whether specific con- trol activities are in place to prevent or detect a misstatement related to each of the rel- evant financial statement assertions. Ultimately, the audit plan needs to specify a list of procedures that must be completed to gather sufficient and appropriate evidence directed toward achieving particular audit objectives. For example, an internal control audit plan would contain the specific procedures needed to obtain an understanding of the client’s internal control system and test that understanding for those controls that relate to the relevant financial statement assertions. If the auditor decides to rely on specific internal control activities, the plan would also identify the specific types of tests of controls that would need to be completed to validate the operating effectiveness of the internal control activities.

A substantive audit plan would contain a list of audit procedures for gathering evidence related to the relevant assertions identified for an audit client’s significant financial state- ment accounts and disclosures. The substantive audit plan (i.e., the nature, timing, and

LO 3-4 List and describe the eight general types of audit procedures for gathering evidence.

REVIEW CHECKPOINTS  3.9 What is meant by material information in accounting and auditing? 3.10 How does an audit team use materiality on an audit engagement?

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EXHIBIT 3.2 Assertions, Evidence, and Audit Procedures

PCAOB Assertions ASB Assertions What Could Go Wrong? Examples of Evidence Available

Representative Audit Procedures

Existence or occurrence

Existence Do the assets recorded really exist?

The physical presence of the assets

Inspection of tangible assets

  Occurrence Did the recorded sales transactions really occur?

Client shipping documents Inspection of records or documents (vouching)

Rights and obligations Rights and obligations

Does the entity really own the assets? Are related legal responsibilities identified?

Statements by independent parties

Confirmation

Completeness Completeness Are the financial statements (including footnotes) complete?

Documents prepared by the client

Inspection of records or documents (tracing)

  Cutoff Were all transactions recorded in the proper period?

Client receiving, shipping reports

Inspection of records or documents (tracing or vouching)

Valuation and allocation

Valuation or allocation

Are the accounts valued correctly?

Client-prepared accounts receivable aging schedule

Reperformance

  Accuracy Were transactions recorded accurately?

Vendor invoices Inspection of records or documents (tracing or vouching)

Presentation and disclosure

Classification Were all transactions recorded in the proper accounts?

Comparisons of current-year amounts with those from the prior year

Analytical procedures

  Understandability Are the presentations and disclosures understandable to users?

Management-prepared financial statements and footnotes

Inquiry

extent of further procedures) depends almost exclusively upon the assessment of risk at an audit client. As an example, consider the nature of procedures. There are two ways to conduct substantive tests: (1) substantive analytical procedures and (2) tests of details.

When completing analytical procedures to gather evidence, the auditor must develop an independent expectation of what he or she thinks the account balance should be. Once this is developed, the expectation is compared to the recorded amount. Any significant differences must be investigated and then corroborated with evidence. When applying substantive test of details, the auditor must seek to understand the account balance and/or economic transaction to ensure, based on valid and reliable evidence, that the amount was recorded in accordance with the applicable financial reporting framework. In general, analytical procedures are considered more efficient while a test of details is considered more effective. Thus, an auditor must take great care in determining the nature of the testing procedure (i.e., substantive analytical procedure or test of detail) to specify in the audit plan.

To simplify the audit plan, auditors typically group the accounts into cycles (see Exhibit 3.3A). A cycle is a set of accounts that are logically grouped in the internal con- trol system, which has been designed to produce the financial statements and notes (see Exhibit 3.3B). Most audit firms recognize four cycles, and each of these cycles is featured in a chapter of this book: (1) the revenue and collection cycle (Chapter 7), (2) the acquisi- tion and expenditure cycle (Chapter 8), (3) the production cycle (Chapter 9), and (4) the finance and investment cycle (Chapter 10). Using the revenue and collection cycle as an

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example, the idea of the cycle organization is to group accounts (sales, accounts receiv- able, cash) related to one another by the transactions that normally affect them all. This cycle starts with a sale to a customer along with recording an account receivable, which is later collected in cash or provided for in the allowance for doubtful accounts.

REVIEW CHECKPOINTS 3.11 What are the two primary ways to conduct substantive tests? Explain how the tests are different. 3.12 Identify the four cycles featured in Dunder-Mifflin’s accounting system featured in Exhibit 3.3A.

Next, list the financial statement accounts that can be identified within each of the cycles identi- fied as featured in Exhibit 3.3B.

As a rule, auditors use eight general audit procedures to gather evidence: (1) inspection of records and documents (vouching, tracing, scanning), (2) inspection of tangible assets, (3) observation, (4) inquiry, (5) confirmation, (6) recalculation, (7) reperformance, and (8) analytical procedures. Many of these procedures are performed or aided by the use of computer assisted audit techniques (CAATs) such as the IDEA or ACL programs. In this book, we have integrated the IDEA software package, a CAAT program used by many audit professionals, to help students understand how these procedures are performed in practice. The “Using IDEA in the Audit” excerpt following the discussion of the various audit procedures is designed to help you get started in IDEA.

In the following sections, we discuss each of the eight aforementioned audit proce- dures in more detail.

1. Inspection of Records and Documents Much auditing work involves gathering evidence by examining authoritative documents prepared by independent parties and by the client. Auditors frequently inspect such documents to ensure they contain the correct information and/or authorization. Such

EXHIBIT 3.3A Dunder-Mifflin Trial Balance, December 31, 2020

Revenue and collection cycle Acquisition and expenditure cycle

Production cycle Finance and investment cycle

X X X X X X

X X X X X X X

X X X X X X X X

X X

X X X Cash Accounts receivable Allowance for doubtful accounts Sales Sales returns Bad debt expense Inventory Fixed assets Accumulated depreciation Accounts payable Accrued expenses General expense Cost of goods sold Depreciation expense Bank loans Long-term notes Accrued interest Capital stock Retained earnings Dividends declared Interest expense Income tax expense

Debit Credit

14,620,000 120,000

300,000 6,296,000 2,000,000

1,500,000 44,000 200,000

500,000 600,000

3,000,000

60,000 0

14,620,000

720,000 2,000,000 60,000

50,000

40,000

450,000 1,500,000

9,200,000

0 600,000

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EXHIBIT 3.3B Dunder-Mifflin Unaudited Financial Statements

FINANCIAL POSITION Cash Accounts receivable Inventory Current Assets Fixed assets (net) Accum. depreciation Fixed Assets (net)

Total Assets

Accounts payable Accrued expenses Current debt Current Liabilities

Long-term debt Capital stock Retained earnings Total Liabilities and Stockholder Equity$4,060,000

$1,500,000

1,500,000

$ 600,000 460,000

$2,560,000 $3,000,000 (1,500,000)

$4,060,000

900,000

200,000

$ 450,000 110,000

$ 760,000

$ 400,000 2,000,000

RESULTS OF OPERATIONS Sales (net) $9,000,000

$ 180,000

Cost of goods sold Gross Profit General expenses

Net Income

Income tax expense before taxes Operating income Interest expense Depreciation expense

$2,044,000 $2,704,000 6,296,000

300,000 60,000

$ 300,000 120,000

CASH FLOWS Operations: Net income Depreciation Increase in accounts receivable Decrease in inventory Decrease in accounts payable Decrease in accrued expenses Decrease in accrued interest Cash Flow from Operations Investing Activities: Purchase Fixed Assets Financing Activities: Repay bank loan Repay notes payable Financing Activities

Ending Balance

Beginning balance Increase (decrease) in cash

$ 600,000

746,500 $(146,500)

$(475,000) (200,000) $(275,000)

$ 328,500 ( 20,500) ( 15,000)

(141,500)

( 25,000) 50,000

300,000 $ 180,000

$ 0

NOTES TO FINANCIAL STATEMENTS 1. Accounting Policies 2. Inventories 3. Plant and Equipment 4. Long-Term Debt 5. Stock Options 6. Income Taxes 7. Contingencies Etc.

Revenue and collection cycle Acquisition and expenditure cycle

Production cycle Finance and investment cycle

X X X X X X

X X X X X X X

X X X X X X X X

X X

X X X Cash Accounts receivable Allowance for doubtful accounts Sales Sales returns Bad debt expense Inventory Fixed assets Accumulated depreciation Accounts payable Accrued expenses General expense Cost of goods sold Depreciation expense Bank loans Long-term notes Accrued interest Capital stock Retained earnings Dividends declared Interest expense Income tax expense

Debit Credit

14,620,000 120,000

300,000 6,296,000 2,000,000

1,500,000 44,000 200,000

500,000 600,000

3,000,000

60,000 0

14,620,000

720,000 2,000,000 60,000

50,000

40,000

450,000 1,500,000

9,200,000

0 600,000

documents can provide “evidence of varying degrees of reliability, depending on their nature and source,” regarding many of management’s financial statement assertions.

Documents Prepared by Independent Outside Parties The most reliable form of documentary evidence is external, which means that the document was received directly from an independent outside third party (e.g., a bank). Formal external documents that may have seals, engraving, or other distinctive attri- butes are less susceptible to alteration and are therefore more reliable than ordinary external documents. Examples of formal external documents include bank statements, title papers, and insurance policies, whereas ordinary external documents include ven- dor invoices, simple contracts, and written correspondence. Regardless, when either type of document is received directly from an independent outside party, the evidence is considered reliable.

In addition, a great deal of documentary evidence is considered external-internal, which means that the documents were initially prepared by an external third party but

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they were received by the client first and then given to the auditor. Since the client had possession of the documents, there is always a possibility that the client altered the docu- ments. As a result, external-internal documents are not as reliable as external documents.

Documents Prepared and Processed by the Client Documentation of this type is referred to as internal evidence. Some of these documents may be quite informal and not very authoritative or reliable. When such documents are prepared by the client but are mailed to third parties, they become slightly more reliable. However, as a general proposition, the reliability of these documents depends on the quality of internal control under which they were produced and processed. Because the client produces the evidence, an auditor must perform additional testing on this type of information before placing any reliance at all on the internal evidence. Some of the most common of these documents are:

Internal Documents

1. Sales invoice copies 2. Sales summary reports 3. Cost distribution reports 4. Loan approval memos 5. Budgets and performance reports 6. Documentation of significant transactions with

subsidiaries

7. Shipping documents 8. Receiving reports 9. Requisition slips 10. Purchase orders 11. Credit memos 12. Transaction logs

Vouching—Examination of Documents When testing the existence or the occurrence assertion, the auditor will take the vouch- ing direction when examining documents. The important point about vouching is that the auditor begins the search for evidence by focusing on transactions that have already been recorded in the financial statements. In vouching, an auditor selects an item in the financial records, usually from a journal or ledger, and follows its path back through the processing steps to its origin (i.e., the source documentation that supports the item selected from the ledger). Consider a revenue entry made in the financial statements. For that entry, the auditor will find the journal entry, the sales summary, the sales invoice copy, the shipping documents, and, finally, the sales order from the customer. Vouch- ing of documents can help auditors decide whether all recorded significant transactions are adequately supported (the existence and occurrence assertions), but vouching does not provide evidence to show whether all significant transactions were actually recorded (the completeness assertion). However, if the auditors verify amounts during their test- ing, evidence regarding valuation and allocation also may be obtained while vouching documents.

Tracing—Examination of Documents When testing the completeness assertion, the auditor will take the tracing direction when examining documents. When taking the tracing direction, the auditor selects a basic source document and follows its processing path forward to find its final recording in a summary journal or ledger and ultimately the financial statements. For example, samples of ship- ping documents can be obtained from the warehouse and then traced to sales invoices, the sales journal, and ultimately their recording in the financial statements as revenue earned.

Using tracing, an auditor can decide whether all significant transactions and events that should have been recorded actually were recorded (the completeness assertion). In doing so, the auditor complements the evidence obtained by vouching. This implies that an auditor must always be alert to events that were not entered into the accounting sys- tem. For example, the search for unrecorded liabilities for raw materials purchases must include examination of invoices received in the period following the fiscal year-end and examination of receiving reports dated near the year-end. In practice, it is important to

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remember that the direction of the examination of documents is critical in relation to the assertion being tested.

Summary Listing (Sales Journal)

Source Documents (Shipping Documents)

Vouching (Would be used to test the existence or occurrence assertion. The audit test would be designed to answer the following question: Did all recorded sales occur?)

Tracing (Would be used to test the completeness assertion. The audit test would be designed to answer the following question: Were all shipments made to customers actually recorded as sales?)

Scanning—Examination of Documents Scanning is the way auditors exercise their general alertness to unusual items and events in clients’ documentation. A typical scanning directive in an audit plan is: “Scan the expense accounts for credit entries; vouch any to source documents.”

In general, scanning is an “eyes-open” approach of looking for anything unusual. The scanning procedure usually does not produce direct evidence itself, but it can raise ques- tions related to other evidence that must be obtained. Scanning can be accomplished on digital records by using CAATs to select records that are exceptions to the auditors’ criteria. For example, CAATs can easily scan client’s data for (1) accounts receivable balances for amounts over the credit limit, (2) inventory quantities for negative balances or unreasonably large balances, (3) payroll files for terminated employees, (4) loan files for loans with nega- tive balances, (5) debits in revenue accounts and (6) credits in expense accounts, to name a few. Scanning can contribute some evidence related to the existence of assets and the completeness of accounting records, including the proper cutoff of significant transactions.

2. Inspection of Tangible Assets Inspection of tangible assets includes examining property, plant, and equipment; inven- tory; and securities certificates. Physical inspection of tangible assets provides compel- ling evidence of existence and may provide tentative evidence of valuation. For example, audit team members can verify the existence of specific pieces of equipment listed on the client’s fixed asset register by locating them and noting their condition (valuation). However, inspection does not necessarily provide evidence that the entity owns the assets (rights). For example, fixed assets on the client’s premises may be leased under operating lease agreements, and inventory inspected by auditors may be held on consignment.

3. Observation Although inventory observation often refers to the physical inspection of inventory (i.e., tangible assets), auditors use observation when they view the client’s physical facilities and personnel on an inspection tour, when they watch personnel carry out accounting and control activities (such as observing client inventory counts), and when they participate in a surprise payroll distribution. Observation also can produce a general awareness of events in the client’s offices. In this sense, observation is commonly used as a test of controls.

4. Inquiry Inquiry is a procedure that generally involves the collection of verbal evidence from independent parties and management (commonly referred to as management represen- tations). Important inquiries and responses should be documented by the auditor in the

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workpapers. Auditors typically use inquiry procedures during the early planning stages of the engagement. Evidence gathered by formal and informal inquiry generally cannot stand alone as convincing, and auditors must corroborate responses with independent findings based on other procedures. In fact, the professional standards state that “inquiry alone” is never enough to reach an audit conclusion. An exception to this general rule might be a negative statement in which someone volunteers adverse information such as an admission of theft, fraud, or use of an accounting policy that is misleading. However, even in such a situation, an auditor would most likely follow up to obtain documentary evidence to support the negative statement.

Auditors conduct interviews almost every day. Sometimes these seem more like casual conversations than “interviews.” Nevertheless, the following guidelines for the inquiry/interview procedure can help you obtain good information and maintain good relations with client personnel.

1. Prepare. Think about the information you want to obtain, the ques- tions to ask, and the best person to interview.

2. Make an appointment. Call in advance for a time or at least ask permission to interrupt: “Do you have time to talk with me about [subject]?” Introduce yourself and make enough conversation to warm up the person without wasting time.

3. Be conversational. Try to get the person to describe the account- ing, the controls, or whatever the subject in his or her own words. You will get more information. Just firing off questions makes the meeting an interrogation. Most auditors find it difficult to think of all of the right questions ahead of time anyway. Don’t exhibit

a questionnaire or checklist; doing so makes the interview too mechanical. You can take informal notes to remember the sub- stance of the interview.

4. Ask questions. Fill in the gaps in the person’s description or expla- nation by asking prompting questions to elicit additional descrip- tions and explanations. Start with broad, open-ended questions and use specific questions to obtain more detail.

5. Listen carefully. Repeat items you don’t completely understand. 6. Be noncommittal. Refrain from expressing your own value judg-

ments or criticisms while you talk with the client personnel. Don’t reveal any audit-sensitive information.

7. Close gracefully. Thank the person for the time and information. Ask permission to return later for “anything I forgot.”

8. Document the interview. Write a memorandum for the audit docu- mentation. Now you can get out the questionnaire or checklist, complete it, and see whether you overlooked anything important.

Verbal Inquiry = InterviewAUDITING INSIGHT

5. Confirmation Confirmation by direct correspondence with independent parties is a procedure widely used in auditing. It can produce evidence of existence and rights and obligations and sometimes of valuation and cutoff. Auditors typically limit their use of confirmation to significant transactions and balances about which outside parties could be expected to provide information. A selection of confirmation applications includes the following:

∙ Banks—cash and loan balances. ∙ Customers—receivables balances. ∙ Borrowers—note terms and balances. ∙ Agents—inventory on consignment or in warehouses. ∙ Lenders—note terms and balances. ∙ Policyholders—life insurance contracts. ∙ Vendors—accounts payable balances. ∙ Registrar—number of shares of stock outstanding. ∙ Attorneys—litigation in progress. ∙ Trustees—securities held, terms of agreements. ∙ Lessors—lease terms.

Several points about confirmations are important to remember. First, confirmation let- ters are typically printed on the client’s letterhead and signed by a client officer; third

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parties usually do not release information without client permission. Second, confirma- tion requests should seek information the recipient can supply, such as the amount of a balance or the amounts of specified invoices or notes. Third, the audit firm should control confirmations rather than giving them to client personnel for mailing. The audit team should be very careful that the recipient’s address is reliable and not subject to alteration by the client in such a way as to misdirect the confirmation. Fourth, responses should be returned directly to the audit firm, not to the client. And last, auditors are increasingly using technology to aid and improve the confirmation process.

Auditors are using technology in both the confirmation selection and execution pro- cess. Auditors can use CAATs to program statistical or judgmental criteria for selecting customers’ accounts receivable, loans, and other receivables for confirmation. In addi- tion, the use of electronic confirmations by auditors (e.g., confirmation.com) has led to improvements in both the effectiveness and the efficiency of the confirmation process. The use of electronic confirmations is covered in detail in Chapter 6.

6. Recalculation Auditor recalculation of computations previously performed by client personnel produces compelling evidence. A client calculation must always be mathematically accurate. Cli- ent calculations performed by computer programs can be recalculated using CAATs with differences printed out for further audit investigation. Mathematical evidence can serve the objectives of existence and valuation for financial statement amounts that exist prin- cipally as calculations, for example, depreciation, interest expense, pension liabilities, actuarial reserves, bad debt reserves, and product guarantee liabilities. Recalculation, in combination with other procedures, is also used to provide evidence of valuation for all other financial data.

7. Reperformance Although similar to recalculation, reperformance is much broader in approach. As dis- cussed in Chapter 4, reperformance is commonly used by auditors while completing walkthroughs when gaining an understanding of a client’s internal control system. In fact, reperformance can generally be completed for any client control procedure such as matching vendor invoices with supporting purchase orders and receiving reports. Reper- formance may be done either manually or with the assistance of CAATs. An auditor, for example, can verify that an accounts receivable aging schedule was prepared properly by sorting accounts receivable by due date.

8. Analytical Procedures Auditors can evaluate financial statement accounts by developing expectations about what an account balance should be based on an analysis of relevant financial and nonfi- nancial data. When an auditor compares the expectation to a recorded balance, analytical procedures are being performed. Auditors are required to use them when planning the audit and when performing the review of the financial statements near the end of the audit before the audit report is issued. In addition, auditors use analytical procedures to provide evidence about management’s financial statement assertions during the testing phase of the audit.

Analytical procedures take the five general forms shown in the following table. Audi- tors need to be careful to use independent, reliable information for analyses. The sources of information shown for the analytical procedures are very important, and auditors must gain comfort over the information that is used to develop expectations during analytical procedures. CAATs are useful when developing expectations as they can match data in separate files to help extract the data necessary to make comparisons between financial and nonfinancial information. In addition, CAATs can be used to extract the data neces- sary to make comparisons to other companies in the same industry.

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Because analytical procedures completed during planning are required and used only to direct attention to unusual relationships, some auditors are reluctant to use analytical procedures during the substantive testing of balances. Instead, many auditors feel more comfortable with tests of details such as recalculation, observation, confirmation, and the inspection of documents. However, you should resist this temptation. In fact, the professional standards clearly indicate that a well-planned analytical procedure con- ducted during the substantive testing phase can be quite effective if executed properly. Most importantly, when applying substantive analytical reviews to gather evidence in this manner, any significant differences must be investigated and corroborated with evidence.

Because of their effectiveness in directing attention to high-risk areas, professional standards require that analytic procedures be used during planning and during final evaluation phases of the audit. Although not required to be used during the substantive testing phase of the engagement, auditors must consider the value of analytical proce- dures, especially because they are usually less costly than more detailed, document- oriented procedures. Consequently, analytical procedures often take a prominent place in the audit plan.

Analytical Procedures Sources of Information

1.  Comparison of current-year account balances to balances of one or more comparable periods

Financial account information for comparable period(s) Example: Current-year cost of goods sold compared to last year’s balance

2.  Comparison of current-year account balances to anticipated results found in the company’s budgets and forecasts

Company budgets and forecasts Example: Current-year cost of goods sold compared to the company’s budgeted amount

3.  Evaluation of the relationships of current-year account balances to other current-year balances for conformity with predictable patterns based on the company’s experience

Financial relationships among accounts in the current period Example: Relationship between inventory and cost of goods sold

4.  Comparison of current-year account balances and financial relationships (e.g., ratios) with similar information for the industry in which the company operates

Industry statistics Example: Comparing inventory and cost of goods sold levels to comparable companies in the industry

5.  Study of the relationships of current-year account balances with relevant nonfinancial information (e.g., physical production statistics)

Nonfinancial information such as physical production statistics Example: Comparing the number of unfilled orders to inventory and cost of goods sold levels

The first step in using a CAAT like IDEA is to gain access to the cli- ent’s data. The data may be available in multiple forms, depending on the audit client’s unique computing environment. However, IDEA is designed to be flexible enough to handle multiple computing envi- ronments. Your instructor will provide you with access to the IDEA software and the latest electronic version of the IDEA Data Analysis Workbook. Your instructor will also provide you with access to the data

files for the audit procedures to be completed for Accounts Receiv- able, Accounts Payable, and Inventory.

For each set of files, your first step is to import the client’s data into the IDEA software. We suggest that you complete this step for each of the areas that have been assigned by your instructor. To pro- ceed, please refer to the IDEA workbook provided by your instructor for step by step instructions on how to properly import each file.

Accessing Client Data USING IDEA IN THE AUDIT

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AUDIT DOCUMENTATION An engagement is not complete without preparation of proper documentation. PCAOB AS 1215 defines audit documentation as

The written record of the basis for the auditor’s conclusions that provides the support for the auditor’s representations, whether those representations are contained in the auditor’s report or otherwise.*

In other words, audit documentation provides the auditors’ record of compliance with generally accepted auditing standards. The documentation (often referred to as work- papers despite that it is typically in electronic format) should contain support for the decisions regarding planning and performing the audit, procedures performed, evidence obtained, and overall conclusions reached near the end of the audit. Even though the auditors legally own the audit documentation, professional ethics require that the files not be transferred without the client’s consent because of the confidential information recorded in them.

Audit documentation can be classified in two categories: (1) permanent files (which contain information that is relevant to ongoing client relationships) and (2) current files (which relate to just one year of the client relationship). The following sections describe the information contained in each file in more detail.

Permanent Files The permanent files (or continuing audit files) contain information of continuing audit significance over many years’ audits of the same client. The audit team may use this file year after year, but each year’s current audit documentation is stored after the

LO 3-5 Define what is meant by the proper form and content of audit documentation.

REVIEW CHECKPOINTS 3.13 What is meant by (a) vouching, (b) tracing, and (c) scanning? What is the difference between

vouching and tracing? 3.14 Identify and then briefly explain the eight general audit procedures used to gather evidence. Next,

please provide an example for each of the eight procedures. 3.15 What are the five types of general analytical procedures? List five sources of information for ana-

lytical procedures. 3.16 When are analytical procedures required during an audit engagement?

Technology is changing the look of the traditional inventory observa- tions and asset inspections for the better. The Big 4 audit firms have recently begun using drone technology to help make the audit more efficient and effective. One way drones are being used is to get a bet- ter view of hard to count inventory items, such as crops, livestock, and coal reserves. Inventory observations that would have taken auditors hours to perform now take a fraction of the time with more reliable

results. This allows auditors to focus their attention on identifying and responding to areas of risk.

Sources. “EY Scaling the use of Drones in the Audit Process”, EY.com, June 13, 2017. “PwC uses drone in audit for first time” Economia, January 2, 2019. “How Drones are Being Used in Audit”, Discoveraudit. org, Dec 14, 2017.

Fly-by Audit Procedures?AUDITING INSIGHT

Public Company Accounting Oversight Board. “AS 1215: Audit Documentation.” Accessed June 24, 2019. https://pcaobus.org/ Standards/Auditing/Pages/AS1215.aspx.

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files have served their purpose. Documents of permanent interest and applicability include

1. Copies or excerpts of the corporate or association charter, bylaws, or partnership agreement.

2. Copies or excerpts of continuing contracts such as leases, bond indentures, and royalty agreements.

3. A history of the company, its products, markets, and background. 4. Copies or excerpts of minutes of meetings of stockholders and/or directors on matters

of lasting interest. 5. Continuing schedules of accounts with balances that are carried forward for several

years, such as owners’ equity, retained earnings, partnership capital, and the like. 6. Copies of prior-years’ financial statements and audit reports. 7. Client organization chart.

Copies of financial statements and auditors’ reports from prior years also may be included. Public accounting firms collect articles and other information regarding a client and key personnel throughout the year. This information is often placed in the permanent file to facilitate a review of the client prior to continuing the relationship. Because of the importance of the documents contained and summarized in this one place, the permanent file is a ready source of information for familiarization with the client by new personnel on the engagement.

Current Files The current files include all client acceptance or continuance documentation along with planning documentation for the year under audit. They usually include the engagement letter, staff assignment notes, conclusions related to understanding the client’s business, results of preliminary analytical procedures, assessments of audit risks, and determination of audit materiality. Many public accounting firms follow the practice of summarizing these data in a planning memorandum with specific directions about the impact on the audit.

Basically, the planning memo summarizes all important overall planning information and documents that the audit team is following generally accepted auditing standards. All planning becomes a basis for preparing the audit plan, which is a list of the audit procedures to be performed by the audit team to gather sufficient appropriate evidence on which to base the opinion on the financial statements. Auditing standards require a documented audit plan for each relevant assertion on the audit.

The planning documentation must include a listing of each significant account and disclosure in the client’s financial statement. According to the professional standards, if there is a chance the account could contain a misstatement that is material, it should be identified as significant. The documentation also must include a listing of each relevant financial statement assertion related to the significant accounts and disclosures. Accord- ing to the professional standards, if the assertion has “a reasonable possibility of contain- ing a misstatement that would cause the financial statements to be materially misstated,”* it must be categorized as relevant. Documentation of the significant accounts and disclo- sures, along with the relevant assertions, forms the basis of the current file documentation.

Audit documentation should be prepared in sufficient detail to provide a clear under- standing of its purpose, its source, and the overall conclusions reached near the end of the audit. The audit documentation communicates the quality of the audit, so it must be clear, concise, complete, neat, well indexed, and informative. Each workpaper must be com- plete in the sense that it can be removed from the audit documentation file and considered on its own with proper cross-references available to show how the document coordinates

Public Company Accounting Oversight Board. “AS 2201: An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements.” Accessed June 24, 2019. https://pcaobus.org/Standards/Auditing/Pages/AS2201.aspx.

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with other audit documentation. In other words, the documentation must be sufficient to enable an experienced auditor, having no previous connection with the engagement, to understand (1) the nature, timing, extent, and results of procedures; (2) the overall conclusions reached with respect to the area covered by the audit documentation; and (3) the audit team member performing the work, the date of work, the audit team member reviewing the work, and the date of review. The audit documentation should also be suf- ficient to allow another auditor to reperform the work if necessary.

The most important facet of the current audit evidence documentation files is the requirement that they show the auditors’ conclusions. The documentation must record the management assertions that were audited, the evidence gathered about them, and final conclusions. Professional audit standards require the audit documentation show that (1) the client’s accounting records agree or reconcile with the financial statements, (2) the work was adequately planned and supervised, (3) a sufficient understanding of the client’s internal control was obtained, and (4) sufficient appropriate audit evidence was obtained as a reasonable basis for an audit opinion. Common sense also dictates that the audit documentation be sufficient to show that the financial statements conform to the relevant accounting framework and that the disclosures are adequate. The audit documen- tation also should explain how exceptions, unusual accounting questions, and findings contradictory to the audit team’s final conclusions were resolved or treated. In addition, the resolution of any differences among audit team members must be documented. Taken altogether, these features should demonstrate that all auditing standards were observed and executed.

Audit Documentation Arrangement and Indexing Each public accounting firm has a different method of arranging and indexing audit doc- umentation files. In general, however, the documentation is electronically hyperlinked and numbered in order behind the trial balance according to balance-sheet and income- statement captions. Usually, the current assets are numbered (or indexed) first, followed by fixed assets, other assets, liabilities, equities, income, and expense accounts. A lead schedule is a summary of the accounts or components in an account group. For cash, the lead schedule includes all of the company’s cash accounts. For inventory, the lead sched- ule may include inventory amounts by product line, cost of goods sold, and reserves for obsolescence. The amounts on the lead schedule should agree with prior-year numbers, the current-year general ledger amounts, and, after any adjustments, the audited finan- cial statements. To help better visualize, the typical arrangement is shown in writing in Exhibit 3.5.

Several audit documentation preparation techniques are quite important for the quality of the finished product. The points explained here are illustrated in Exhibit 3.6.

∙ Indexing. Each document (for example, each worksheet an Excel workbook) is given an index number, like a book page number, so it can be found, removed, and replaced without loss.

∙ Cross-referencing. Numbers or memoranda related to other documents carry the index of the other documents so the connections can be followed. Electronic documents will include hyperlinks to documents cross-referenced.

∙ Heading. Each document is titled with the name of the company, the balance-sheet date, and a descriptive title of the document’s contents.

∙ Signatures and initials. The auditor who performs the work and the supervisor who reviews it must sign the audit documentation so personnel can be identified.

∙ Dates of audit work. The dates of performance and review are recorded on the docu- ments so reviewers of the documentation can tell when the work was performed.

∙ Audit marks and explanations. Audit marks (or “tick marks”) are the auditor’s shorthand for abbreviating comments about work performed. Audit marks always must be accompanied by a full explanation of the auditing work. (Notice in

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Exhibit 3.6 the auditor’s confirmation of the disputed account payable liability.) On electronic documents, comments can be hyperlinked so that reviewers can find additional explanations of audit procedures performed.

AS 1215 requires that audit documentation, including workpapers and other docu- ments that form the basis of the engagement, be retained for seven years following the conclusion of the engagement (usually the audit report release date). AS 1215 also stresses that audit documentation to be retained include those workpapers that document any discussions and subsequent resolution of differences in professional judgment among the audit team members. PCAOB regulations also require that all documentation be final- ized within 45 days of the audit report’s release date. With sufficient (documented) jus- tification, auditors may subsequently add, but may not remove, documentation after the 45-day period. Although the AS 1215 requirements are only for public companies, most public accounting firms use the same requirements for their nonpublic clients.

EXHIBIT 3.5 Current Audit Documentation File

Dunder-Mi�in Inc. Adjusting Entries

12/31/20

Cash Expenses

C-1Dunder-Mi�in Inc. Inventory Lead Schedule

12/31/20

B-1Dunder-Mi�in Inc. Accounts Receivable Lead Schedule

12/31/20

A-2-1Dunder-Mi�in Inc. Bank Confirmation—First National Bank

12/31/20

A-2Dunder-Mi�in Inc. Bank Reconciliation—1st National Bank

12/31/20

A-1

Ref Account Unaudited AJE Audited Balance

A-2 1st National $484,000 $484,000 $50,000

$486,000 $536,000$50,000

A-3 2nd National 2,000 52,000

Dunder-Mi�in Inc. Cash Lead Schedule

12/31/20

Other Lead Schedules

Supporting Schedules

TB-3

$50,000

Dr. Cr.

$50,000

TB-1

TB-1

Ref Account Unaudited AJE Audited Balance- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

A-1 Cash B-1 A/R C-1 Inventory

$486,000 $536,000$50,000

Dunder-Mi�in Inc. Working Trial Balance

12/31/20

- - - - - -- - - - - - - -

REVIEW CHECKPOINTS 3.17 What information would you expect to find in a permanent audit file? 3.18 What information would you expect to find in a current audit file? 3.19 What is considered the most important content of the auditor’s current audit documentation files? 3.20 What are the documentation retention requirements of AS 1215?

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EXHIBIT 3.6 Illustrative Audit Documentation

DUNDER-MIFFLIN INC.

(12/31/20) General Account Reviewed

BANK RECONCILIATION—FIRST NATIONAL BANK

(Prepared by client)

Balance per bank statement

Deduct outstanding checks:

Balance per book

Deposit in transit as of 12/31/17

11/30/17 11/31/17 12/15/17 12/28/17 12/30/17 12/30/17 12/30/17 12/30/17

Add:

Prepared

A-2 Indexnumber

Company Name Initials of auditors and dates of work

- - - - - - - - -

Footed. Confirmed by bank standard back confirmation.

Vouched to cutoff bank statement, deposit recorded by bank on 1 3 18. Vouched to duplicate deposit slip validated 1 03 18.

Vouched to paid check cleared with cutoff bank statement. Vouched to statement from attorneys. Amount agrees. Amount in dispute per controller. Confirmation from supplier claims liability of $5,000. See

Note: Obtained cutoff bank statement 1 9 18

Date

842 1280 1372 1412 1417 1418 1419 1420

- - - - - No.

500 1,800 30,760 7,270 20,000 2,820 2,030 8,160 - - - - - - - -

506,100

51,240

557,340

- - - - - - - -

- - - - - - - -

Ace Supply Company Ace Supply Company Northwest Lumber Co. Gibson & Johnson First National payroll Ace Supply Company Windy City Utilities Howard Hardware Supply

- - - - - - - - - - - - - - - - - - - - - - - - - - - - Payee

A-1 A-2-2

A-2-1

K-4 for recommended adjustment.

“Tick mark” symbols

Arithmetic footed

Cross-reference to lead schedule

Cross-index to other workpapers

Explanations of audit work performed

73,340

484,000 - - - - - - - -

F.D. 1 10 21 JRA 1 10 21

This chapter contains a description of the specific set of planning activities that audi- tors undertake when completing an engagement. Pre-engagement activities start with the work of deciding whether to accept a new client and, on an annual basis, whether to continue the engagement for existing clients. Public accounting firms are not obligated to provide audit services to every company or organization that requests them, and they regularly exercise discretion when deciding which they choose to undertake. For audit engagements, the investigation may involve the cooperative task of communicating with the organization’s former (predecessor) auditors. In addition, firms need to make sure that they are in compliance with both independence and ethical requirements before deciding whether to accept a new client or continue with an existing client.

Summary

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The audit plan is a comprehensive list of the specific audit procedures that the audit team needs to perform to gather sufficient appropriate evidence on which to base its opin- ion on the financial statements. Although risk assessment (discussed in Chapter 4) pro- vides the basis to determine the nature, timing, and extent of procedures to be performed at an audit client, many other aspects of audit planning are also discussed in this chapter. Other planning issues include properly staffing the audit, including using IT auditors, considering the work of audit specialists and using the work of internal auditors, and creating the time budget.

Because financial statement measurements and footnote disclosure information are not flawlessly accurate, auditors need to ultimately ensure that the financial statements are materially accurate and do not contain material misstatements. Information is mate- rial if it is likely to influence financial statement users’ decisions. As a result, the engage- ment team needs to think carefully about the appropriate level of materiality during the planning process. The auditor will then use this materiality as a guide to (1) plan and execute substantive testing procedures, (2) evaluate audit evidence, and (3) make final decisions about the auditor’s report.

Auditors then use a variety of procedures to gather evidence about management’s assertions related to the amounts and disclosures in a client’s financial statements. In general, auditors use eight different types of audit procedures to gather evidence: (1) inspection of records and documents (vouching, tracing, scanning), (2) inspection of tan- gible assets, (3) observation, (4) inquiry, (5) confirmation, (6) recalculation, (7) reperfor- mance, and (8) analytical procedures. One or more of these procedures may be used no matter what account balance, control procedure, class of transactions, or other informa- tion is under audit. Auditors must consider a number of factors when planning based on the audit client’s computing environment. And of course, the selection of procedures to be completed must always be tailored to the exacting nuances of the client’s computing environment. Finally, CAATs can improve both engagement effectiveness and efficiency and are used by auditors on most engagements.

The closing topic in this chapter is a brief overview of audit documentation with some basic pointers about their form, content, and overall purpose. At this stage in the audit process, we have accepted (or retained) the client, considered the types of audit proce- dures that might be performed to gather evidence, and thought about the impact of a cli- ent’s technological environment. The next step in the audit process is the assessment of inherent risk in both the financial statement account balances and footnote disclosures, which serves as the focus of the next chapter.

analytical procedures: Procedures that allow auditors to evaluate financial information by studying relationships among both financial and nonfinancial data. When used near the end of the audit, analytical procedures allow auditors to assess the conclusions reached during the audit and evaluate the overall financial statement presentation, 101 audit documentation: The written basis for the auditor’s conclusions that provides the necessary support for the auditor’s assertions and representations made in the auditor’s report, 103 audit engagement partner: The person with the final responsibility for the audit, usually an industry specialist, 86 audit plan: A comprehensive list of the specific audit procedures that the audit team needs to perform to gather sufficient appropriate evidence on which to base their opinion on the financial statements, 85 continuing audit files (or permanent files): The audit documentation containing information of continuing audit significance for current and past audits of the same client, 103 engagement letter: This letter sets forth the understanding with the client, including in particular (1) the objectives of the engagement, (2) management’s responsibilities, (3) the auditors’ responsibilities, and (4) any limitations of the engagement, 84

Key Terms

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Form 8-K: The “current events” report filed periodically at the occurrence of major events, such as earnings releases, major asset sales, acquisitions, and auditor changes, 81 independence in appearance: The extent to which others (particularly financial statement users) perceive auditors to be independent, 83 independence in fact: Auditors’ mental attitude and impartiality with respect to the client, 83 interim audit work: The procedures performed several weeks or months before the balance- sheet date, 90 internal control audit plan: A plan that would contain a list of the specific procedures needed to obtain an understanding of the client’s internal control system and test that understanding for those controls that relate to the relevant financial statement assertions, 94 lead schedule: A summary of the accounts in or components of an account group, 105 materiality: An amount or event that has a substantial likelihood to influence financial statement users’ decisions. Thus, material information is a synonym for important information. The emphasis is on the financial statement users’ point of view, not on the auditors’ or managers’ points of view, 91 permanent files (or continuing audit files): The audit documentation containing information of continuing audit significance for current and past audits of the same client, 103 planning memorandum: The document summarizing the preliminary analytical procedures and the materiality assessment with specific directions about the effect on the audit, 104 predecessor auditor: The public accounting firm that has been terminated or has voluntarily withdrawn from an audit engagement (whether the audit has been completed or not), 81 quality assurance partner: The second audit partner on the audit team as required for audits of financial statements filed with the SEC who reviews the audit team’s work in critical audit areas (those areas with the highest potential audit risk), 87 specialists: The persons skilled in fields other than accounting and auditing—actuaries, appraisers, attorneys, engineers, and geologists—who are not members of the public accounting firm, 89 substantive audit plan: Document that contains a list of audit procedures for gathering evidence related to the relevant assertions identified for the significant financial statement accounts and disclosures on an audit client, 94 termination letter: The documentation provided to former clients dealing with the subject of future services, in particular (1) access to audit documentation by new auditors, (2) reissuance of the auditors’ report when required for SEC reporting or comparative financial reporting, and (3) fee arrangements for such future services. The termination letter also can contain a report of the auditor’s understanding of the circumstances of termination (e.g., disagreements about accounting principles and audit procedures, fees, or other conflicts), 85 tracing: An audit procedure in which the auditor selects a basic source document and follows its processing path forward to find its final recording in a summary journal or ledger. In practice, however, the term tracing may be used to describe following the path in either direction, 98 vouching: An audit procedure in which an auditor selects an item of financial information, usually from a journal or ledger, and follows its path back through the processing steps to its origin (i.e., the source documentation that supports the item selected), 98 year-end audit work: The procedures performed shortly before and after the balance-sheet date, 90

3.21 When initiating communications with predecessor auditors, prospective auditors should expect a. To take responsibility for obtaining the client’s consent for the predecessor to give infor-

mation about prior audits. b. To conduct interviews with the partner and manager in charge of the predecessor public

accounting firm’s engagement. c. To obtain copies of some or all of the predecessor auditors’ audit documentation. d. All of the above.

LO 3-1

All applicable questions are available with Connect.

Multiple-Choice Questions for Practice and Review

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3.22 Generally accepted auditing standards require that auditors always prepare and use a. A written planning memorandum explaining the auditors’ understanding of the client’s

business. b. A written client consent to discuss audit matters with prospective auditors. c. A written audit plan. d. The written time budgets and schedules for performing each audit.

3.23 When planning an audit, which of the following is not a factor that affects auditors’ deci- sions about the quantity, type, and content of audit documentation? a. The auditors’ need to document compliance with generally accepted auditing standards. b. The auditors’ need to verify the existence of new sales contracts important for the client’s

business. c. The auditors’ judgment about their independence with regard to the client. d. The auditors’ judgments about materiality.

3.24 Audit documentation that shows the detailed evidence and procedures regarding the balance in the accumulated depreciation account for the year under audit will be found in the a. Current file audit documentation. b. Permanent file audit documentation. c. Administrative audit documentation in the current file. d. Planning memorandum in the current file.

3.25 An auditor’s permanent file audit documentation most likely will contain a. Internal control analysis for the current year. b. The most recent engagement letter. c. Memoranda of conference with management. d. Excerpts of the corporate charter and bylaws.

3.26 Which of the following is not a benefit claimed for the practice of determining materiality in the initial planning stage of an audit? a. Being able to fine-tune the audit work for effectiveness and efficiency. b. Avoiding the problem of doing more work than necessary (overauditing). c. Being able to decide early what type of audit opinion to issue. d. Avoiding the problem of doing too little work (underauditing).

3.27 Which of the following is an advantage of computer-assisted audit techniques (CAATs)? a. All the CAATs programs are written in one computer language. b. The software can be used for audits of clients that use differing computer equipment and

file formats. c. The use of CAATs has reduced the need for the auditor to study input controls for

computer-related procedures. d. The use of CAATs can be substituted for a relatively large part of the required testing.

3.28 An audit engagement letter should normally include which of the following matters of agree- ment between the auditor and the client? a. Schedules and analyses to be prepared by the client’s employees. b. Methods of statistical sampling the auditor will use. c. Specification of litigation in progress against the client. d. Client representations about availability of all minutes of meetings of the board of directors.

3.29 When auditing Vandalay Jewelry, Costanza, CPA, was not familiar with the quality and cut of the company’s precious jewel inventory. To address this shortcoming, Costanza hired Benes, an expert in jewel valuation, to assist as an audit specialist for the inventory valua- tion. Should Costanza refer to Benes’s work in the audit report? a. Yes, the auditors’ report should mention the fact that an audit specialist was used. b. The auditors’ report should mention the use of the audit specialist only when the audit

specialist’s findings affect the auditors’ conclusions.

LO 3-2

LO 3-2

LO 3-5

LO 3-5

LO 3-3

LO 3-4

LO 3-2

LO 3-2

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c. The use of an audit specialist need not be mentioned if the auditors decide not to take responsibility for the audit specialist’s findings.

d. The auditors’ report should mention the audit specialist only if Vandalay agrees with the audit specialist’s findings.

3.30 Which of the following engagement planning procedures would most likely assist the audi- tor in identifying related-party transactions before the balance-sheet date? a. Interviewing internal auditors about their reporting responsibilities. b. Reviewing accounting records for recurring transactions occurring near year-end. c. Inspecting communications with the client’s legal counsel regarding recorded contingent

liabilities. d. Scanning the minutes for significant transactions with members of the board of

directors.

3.31 Which of the following communications is most likely to be written before the balance- sheet date? a. A report to the audit committee on the results of testing of internal control over cash

receipts. b. Confirmation letters to vendors confirming the amounts they owe to the client. c. An attorney’s letter regarding contingent liabilities. d. An engagement letter.

3.32 Which of the following procedures would most likely be performed during planning? a. Surprise counting of the client’s petty cash fund. b. Reporting internal control deficiencies to the audit committee. c. Performing a search for unrecorded liabilities. d. Identifying related parties.

3.33 Prior to accepting a new audit engagement, a public accounting firm should a. Attempt to contact the predecessor auditors. b. Evaluate the integrity of management. c. Assess the firm’s resources to ensure that they are sufficient to permit the firm to accept

the engagement. d. All of the above.

3.34 An audit plan contains a. Specifications of audit standards relevant to the financial statements being audited. b. Specifications of procedures the auditors believe appropriate for the financial statements

under audit. c. Documentation of the assertions under audit, the evidence obtained, and the conclusions

reached. d. Reconciliation of the account balances in the financial statements with the account bal-

ances in the client’s general ledger.

3.35 The revenue cycle of a company generally includes which accounts? a. Inventory, accounts payable, and general expenses. b. Inventory, general expenses, and payroll. c. Cash, accounts receivable, and sales. d. Cash, notes payable, and capital stock.

3.36 When auditing the existence assertion for an asset, auditors proceed from the a. Financial statement amounts back to the potentially unrecorded items. b. Potentially unrecorded items forward to the financial statement amounts. c. General ledger back to the supporting original transaction documents. d. Supporting original transaction documents to the general ledger.

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3.37 Confirmations of accounts receivable provide evidence primarily about which two assertions? a. Completeness and valuation. b. Valuation and rights and obligations. c. Existence and rights and obligations. d. Existence and completeness.

3.38 With respect to the concept of materiality, which of the following statements is correct? a. Materiality depends only on the dollar amount of an item relative to other items in the

financial statements. b. Materiality depends on the nature of a transaction rather than the dollar amount of the

transaction. c. Materiality is determined by reference to AICPA guidelines. d. Materiality is a matter of professional judgment.

3.39 When evaluating whether accounting estimates made by management are reasonable, the audit team would be most concerned about which of the following? a. Key factors that are consistent with prior periods. b. Assumptions that are similar to industry guidelines. c. Measurements that are objective and not susceptible to bias. d. Evidence of a conservative systematic bias.

3.40 Which of the following would be considered an analytical procedure? a. Testing purchasing, shipping, and receiving cutoff activities. b. Comparing inventory balances to recent sales activities. c. Projecting the deviation rate of a statistical sample to the population. d. Reconciling physical counts to perpetual records and general ledger balances.

(AICPA adapted)

3.41 Which of the following procedures would a CPA most likely perform in planning a financial statement audit? a. Make inquiries of the client’s lawyer concerning pending litigation. b. Perform cutoff tests of cash receipts and disbursements. c. Compare financial information with nonfinancial operating data. d. Recalculate the prior-years’ accruals and deferrals.

(AICPA adapted)

3.42 Which of the following statements is correct concerning analytical procedures used in plan- ning an audit engagement? a. They often replace the tests of controls that are performed to assess control risk. b. They typically use financial and nonfinancial data aggregated at a high level. c. They usually involve the comparison of assertions developed by management to ratios

calculated by an auditor. d. They are often used to develop an auditor’s preliminary judgment about materiality.

(AICPA adapted)

3.43 The company being audited has an internal auditor who is both competent and objective. The independent auditor wants to assign tasks for the internal auditor to perform. Under these circumstances, the independent auditor may a. Allow the internal auditor to perform certain tests of internal controls. b. Allow the internal auditor to audit a major subsidiary of the company. c. Not assign any task to the internal auditor because of the internal auditor’s lack of

independence. d. Allow the internal auditor to perform analytical procedures but not be involved with any

tests of details. (AICPA adapted)

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3.44 Which of the following conditions most likely would pose the greatest risk in accepting a new audit engagement? a. Staff will need to be rescheduled to cover this new client. b. There will be a client-imposed scope limitation. c. The firm will have to hire a specialist in one audit area. d. The client’s financial reporting system has been in place for 10 years.

(AICPA adapted)

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3.45 General Audit Procedures and Financial Statement Assertions. The eight general audit procedures produce evidence about the principal management assertions in financial state- ments. However, some procedures are useful for producing evidence about certain asser- tions, and other procedures are useful for producing evidence about other assertions. The assertion being audited can influence the auditors’ choice of procedures.

Required: Opposite each general audit procedure, write the management assertions best tested by using each procedure.

Audit Procedures PCAOB Assertions ASB Assertions

a. Inspection of records or documents (vouching)    

b. Inspection of records or documents (tracing)    

c. Inspection of records or documents (scanning)    

d. Inspection of tangible assets    

e. Observation    

f. Confirmation    

g. Inquiry    

h. Recalculation    

i. Reperformance    

j. Analytical procedures    

3.46 Audit Procedures. Auditors use different types of audit procedures to gather the evidence necessary to conclude that the risk of material misstatement for each relevant assertion has been reduced to an acceptably low level. List eight different types of procedures auditors can use during an audit of financial statements and give an example of each.

3.47 Confirmation Procedure. A CPA accumulates various types of evidence on which to base the opinion on financial statements. Among this evidence is confirmations from third parties.

Required: a. What is an audit confirmation? b. What characteristics of the confirmation process and the recipient are important if a CPA

is to consider the confirmation evidence appropriate?

3.48 Potential Audit Procedure Failures. For each of the general audit procedures of (a) recal- culation, (b) observation, (c) confirmation (accounts receivable, securities, or other assets), (d) inquiry, (e) inspection of internal documents, (f) recalculation, (g) reperformance, and (h) analytical procedures, discuss one way the procedure could be misapplied or the auditors could be misled in such a way as to render the work (audit evidence) misleading or irrel- evant. Give examples that are different from the examples in the chapter.

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All applicable Exercises and Problems are available with Connect.

Exercises and Problems

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3.49 Audit Documentation. The preparation of audit documentation is an integral part of an auditor’s examination of financial statements. On a recurring engagement, auditors review the audit plans and audit documentation from the prior audit while planning the current audit to determine their usefulness for the current-year work.

Required: a. (1) What are the purposes or functions of audit documentation? (2) What records may be included in audit documentation? b. What factors affect the auditors’ judgment of the type and content of the audit documen-

tation for a particular engagement? c. What should be included in audit documentation to support auditors’ compliance with

generally accepted auditing standards? d. How can auditors make the most effective use of the prior-year audit plans in a recurring

audit? (AICPA adapted)

3.50 Communications between Predecessor and Successor Auditors. Assume that Smith & Smith, CPAs, audited Apollo Shoes Inc., last year. Now CEO Larry Lancaster wishes to engage Anderson, Olds, and Watershed, CPAs (AOW) to audit its annual financial state- ments. Lancaster is generally pleased with the services provided by Smith & Smith, but he thinks the audit work was too detailed and interfered excessively with normal office routines. AOW has asked Lancaster to inform Smith & Smith of the decision to change audi- tors, but he does not wish to do so.

Required: List and discuss the steps AOW should follow with regard to dealing with a predecessor auditor and a new client before accepting the engagement.

3.51 Predecessor and Successor Auditors. The president of Allpurpose Loan Company had a genuine dislike for external auditors. Almost any conflict generated a towering rage. Conse- quently, the company changed auditors often. The firm of Wells & Ratley (W&R), CPAs, was recently hired to audit the 2020 financial statements. W&R succeeded the firm of Canby & Company (C&C), which had obtained the audit after Albrecht & Hubbard (A&H) had been fired. A&H audited the 2019 financial statements and rendered a report that contained an additional paragraph explaining an uncer- tainty about Allpurpose Loan Company’s loan loss reserve. Goodbye A&H! The president then hired C&C to audit the 2020 financial statements, and Chris Canby started the work, but before the audit could be completed, Canby was fired and W&R was hired to complete the audit. C&C did not issue an audit report because the audit was not finished.

Required: Does the Wells & Ratley firm need to initiate communications with Canby & Company? With Albrecht & Hubbard? With both? Explain your response in terms of the purposes of communications between predecessor and successor auditors.

3.52 Client Selection. You are a CPA in a regional public accounting firm that has 10 offices in three states. Mr. Shine has approached you with a request for an audit. He is president of Hitech Software and Games Inc., a five-year-old company that has recently grown to $500 million in sales and $200 million in total assets. Shine is thinking about going public with a $25 million issue of common stock, of which $10 million would be a secondary issue of shares he holds. You are very happy about this opportunity because you know Shine is the new president of the Symphony Society board and has made quite a civic impression since he came to your medium-size city seven years ago. Hitech is one of the growing employers in the city.

Required: a. Discuss the sources of information and the types of inquiries that you and the firm’s part-

ners may make in connection with accepting Hitech as a new client. b. Do professional audit standards require any investigation of prospective clients? c. Suppose Shine also told you that 10 years ago his closely held hamburger franchise busi-

ness went bankrupt, and on investigation, you learn from its former auditors (your own

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firm in another city) that Shine was fraudulent in its application of franchise-fee income recognition rules and presented such difficulties that your firm resigned from the audit (before the bankruptcy). Do you think the partner in charge of the audit practice should accept Hitech as a new client?

3.53 Using the Work of Internal Auditors. North, CPA, is planning an independent audit of the financial statements of General Company. In determining the nature, timing, and extent of the audit procedures, North is considering General’s internal audit function, which is staffed by Tyler.

Required: a. In what ways can the internal auditor’s work be relevant to North, the independent

auditor? b. What factors should North consider, and what inquiries should North make in deciding

whether to use Tyler’s internal audit work? (AICPA adapted)

3.54 Using the Computer to Discover Intentional Financial Misstatements in Transactions and Account Balances. AMI International is a large office products company. Headquarters management imposed pressure on operating division managers to meet profit forecasts. The division managers met these profit goals using several accounting manipulations involving the record-keeping system that maintained all transactions and account balances on com- puter files. Employees who operated the computer accounting system were aware of the modifications of policy the managers ordered to accomplish the financial statement manipu- lations. The management and employees carried out these activities: 1. Deferred inventory write-downs for obsolete and damaged goods. 2. Kept open the sales entry system after the quarterly and annual cutoff dates, recording

sales of goods shipped after the cutoff dates. 3. Recorded as sales transactions that had been coded as leases of office equipment. 4. Recorded shipments to branch offices as sales. 5. Postponed recording vendors’ invoices for parts and services until later, but the actual

invoice date was faithfully entered according to accounting policy.

Required: Describe one or more procedures that could be performed with CAATs to detect signs of each of these transaction manipulations. Limit your answer to the actual work accomplished by the computer software.

3.55 Inspection of Documents and Records. A large portion of audit evidence is gathered through inspection of documents and records. External documents, documents that are gen- erated outside of the organization, provide more reliable evidence than documents generated and maintained at the client.

Required: a. For each of the documents below, indicate if the document is a strictly external document

(obtained from an external party), an external-internal document (generated outside of the organization but given to the auditor by the client), or an internal document (gener- ated and maintained by client). 1. Receiving report. 2. Customer purchase order. 3. Bank statements received directly from the bank. 4. Copies of sales invoices. 5. Utility bill. 6. Departmental budget. 7. Insurance policy. 8. Remittance advice.

b. Why are external documents considered more reliable evidence than internal documents? What aspects of internal documents would help to increase their reliability?

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3.56 Audit Documentation - Permanent or Current Year Files. Audit documentation can be clas- sified in two categories: (1) permanent files (which contain information that is relevant for many years’ audits for the client) and (2) current files (which contain information that is relevant to supporting the current year’s audit).

Required: For each of the documents listed below, indicate whether they would appear in the perma- nent or current year files.

1. Audit planning memorandum 2. Client organizational chart 3. Prior years’ financial statements and audit reports 4. Engagement letter 5. Bank confirmations 6. Schedule for current year depreciation calculation 7. Royalty agreements

3.57 Pre-engagement activities - Client acceptance policies and procedures generally include obtaining and reviewing financial information from prospective clients.

Required: Your firm is considering accepting Apple Inc. as a new audit client. You are helping to per- form client acceptance procedures by reviewing prior financial information. Go to the sec. gov website and search for Apple Inc.’s most recent 10-K filing. Read through the Item 1, Business, and Item 1A, Risk Factors, sections. What characteristics are red flags for poten- tial problems? What characteristics would make Apple a desirable client?

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Apollo Shoes Audit Planning Part Two You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Water- shed and have been assigned to the engagement team of a new client, Apollo Shoes Inc. You have been asked to begin the planning process for the audit. This includes making decisions about the use of audit resources and further familiarizing yourself with the engagement and the client. Detailed instructions regarding the information needed, as well as other procedures you need to perform in this planning phase of the audit, can be found in Connect.

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LEARNING OBJECTIVES The professional standards emphasize the importance of an auditor’s identification and assessment of the risks of material misstatement that exist related to an audit client. Once each of the risks is identified and assessed, the auditor needs to plan an appropriate response. Given the importance of risk assessment,

it is not surprising that the professional standards state that the risk assessment process underlies the entire audit process. In Chapter 3, we covered the engagement planning process, beginning with pre- engagement activities, supervision, and materiality. In this chapter, we provide comprehensive coverage of an auditor’s risk assessment and its impact on the audit process.

Risk comes from not knowing what you’re doing.

Warren Buffett.

Profit is the result of risks wisely selected.

Frederick Barnard Hawley.

The Audit Risk Model and Inherent Risk Assessment

C H A P T E R 4

Professional Standards References

Topic AU-C/ISA Section AS Section

Consideration of Fraud in a Financial Statement Audit 240 2401

Consideration of Laws and Regulations 250 2405

Communications with Audit Committees 260 1301

Audit Planning 300 2101

Identifying and Assessing the Risks of Material Misstatement 315 2110

Materiality 320 2105

Auditors’ Responses to Risks of Material Misstatement 330 2301

Audit Evidence 500 1105

Substantive Analytical Procedures 520 2305

Related Parties 550 2410

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118 Part Two The Financial Statement Audit

Your objectives are to be able to:

LO 4-1 Define audit risk and describe how it can be broken down into the three separate compo- nents of the audit risk model to help assess and respond to such risks during the audit planning process.

LO 4-2 Explain auditors’ responsibility for fraud risk assessment and define and explain the differences among several types of fraud and errors that might occur in an organization.

LO 4-3 Explain an auditor’s responsibility to assess inherent risk, including a description of the type of risk assessment procedures that should be performed

when assessing inherent risk on an audit engagement.

LO 4-4 Understand the different sources of information and the audit procedures used by auditors when assessing risks, including analytical procedures, brainstorming, and inquiries.

LO 4-5 Explain how auditors complete and document the overall assessment of inherent risk.

LO 4-6 Explain auditors’ responsibilities with respect to a client’s failure to comply with laws or regulations.

LO 4-7 Describe the content and purpose of an audit strategy memorandum.

INTRODUCTION In October 2015, the PCAOB released a report titled “Inspection Observations Related to PCAOB “Risk Assessment” Auditing Standards,” where they provide information based on their 2012–2014 inspections regarding how well firms were following the risk assessment standards.1 According to the report, firms were not doing too good of a job. In  26% of the audits inspected in 2012 and 27% inspected in 2013, the PCAOB found firms had not complied with one or more of the risk assessment standards. Consistent with that trend, preliminary results from the 2014 inspections indicated that the percent- age still remained high. One of the more common issues noted was that firms did not perform appropriate tests in response to fraud and other risks identified.

Fast-forward to November 2017. The PCAOB released their Staff Inspection Brief, with a preview of observations from the 2016 PCAOB inspections.2 The brief highlights three “key” areas with the most observed audit deficiencies. The first key area mentioned in the brief is “assessing and responding to risks of material misstatement.”

Risk assessment is the foundation of the audit process. It is the auditor’s risk assess- ment that should drive what audit procedures to perform in order for the auditor to obtain reasonable assurance that the financial statements are free of material misstatement. Improper risk assessment can lead to improper audit responses which, in turn, can lead to audit failure. Proper risk assessments yet failure to respond to those assessments can also lead to audit failure. Given the importance of risk, why do auditors continue to struggle with the assessment and response to risk? One reason may be the difficulty and great level of care required by the auditor to simply assess risk, let alone to craft the proper audit response to that risk. In this chapter, we will describe how auditors identify, assess, and then properly respond to the risks of material misstatement that exist at their audit clients.

AUDIT RISK Audit Risk Audit risk is the probability that an audit team will express an inappropriate audit opinion when the financial statements are materially misstated (i.e., give an unmodified opinion on financial statements that are misleading because of material misstatements that the auditors failed to discover). Such a risk always exists, even when audits are well planned

1PCAOB Release No. 2015-007, “Inspection Observations Related to PCAOB “Risk Assessment” Auditing Standards (No. 8 through No. 15),” PCAOB, October 15, 2015 2“Staff Inspection Brief Vol. 2017/4,” PCAOB, November 2017

LO 4-1 Define audit risk and describe how it can be broken down into the three separate components of the audit risk model to help assess and respond to such risks during the audit planning process.

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and carefully performed. Of course, the risk is much higher in poorly planned and care- lessly performed audits. The auditing profession has no official standard for an acceptable level of overall audit risk except that it should be “appropriately” low. In practice, audit risk is evaluated at both the overall financial statement level (as a whole) and for each sig- nificant account and disclosure through a focus on the relevant assertions identified. A significant account or disclosure is an account or disclosure that has a reasonable possibility of containing a material misstatement regardless of the effect of internal controls. A rel- evant assertion is a management assertion that has a reasonable possibility of containing a material misstatement without regard to the effect of internal controls. The concern an auditor has regarding any particular assertion depends on the significant account that the auditor is testing (or to which the assertion relates). For example, an auditor may deem the occurrence assertion to present more risk when testing revenue than the completeness assertion presents. Most companies want to report a healthy stream of revenue, so it is unlikely that they will omit sales that would violate the completeness assertion. It is more likely that a company reports sales that did not occur to present more revenue, which would violate the occurrence assertion.

To help better understand and ultimately mitigate audit risk, the professional standards break down overall audit risk (see Exhibit 4.1) into the risks (1) that a material misstatement will even occur (inherent risk), (2) that it would not be prevented or detected by client internal controls (control risk), and (3) that is not detected by the auditor’s own procedures (detection risk). Because inherent risk and control risk are related to the company and its overall envi- ronment, these two components are combined into the risk of material misstatement (RMM), which is the risk a material misstatement exists in the financial statements before auditors apply their own procedures. Each of these components is now discussed in detail.

Obtain (or Retain)

Engagement

Engagement Planning

Risk Assessment

Substantive Procedures Reporting

STAGES OF AN AUDIT

Inherent Risk Inherent risk is the probability that, in the absence of internal controls, material errors or frauds could enter the accounting system used to develop financial statements. You can think of inherent risk as the susceptibility of the account to misstatement. Inherent

EXHIBIT 4.1 Inherent, Control, and Detection Risk

Events, Transactions

Financial Statements

Internal Controls

Accounting Information

System Audit Procedures

AUDIT RISK The likelihood that an

error or fraud will occur and not be caught by either internal controls or auditor’s procedures

DETECTION RISK The likelihood that an

error or fraud will not be caught by the auditor’s

procedures

CONTROL RISK The likelihood that an

error or fraud will not be prevented or detected by the client’s internal

controls

INHERENT RISK The likelihood that an

error or fraud will enter the accounting

information system

RISK OF MATERIAL MISSTATEMENT

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risk is a function of the nature of the client’s business and strategy to achieve competi- tive advantage, the major types of transactions, and the effectiveness and integrity of its managers and accountants. It is important to understand that for different accounts, various assertions are riskier than others. For cash, existence is riskier than completeness because it is more likely that a client would try to include more cash than it really had on its balance sheet rather than less; and for accounts payable, completeness is riskier than existence because it is more likely that a client would try to understate what it really owed rather than overstate the amount. As a result, auditors focus their attention on relevant assertions. Finally, it is important for students to remember that auditors do not create or control inherent risk. They can only try to assess its magnitude in an appropriate manner. This will be discussed in more detail later in the chapter.

Control Risk Control risk is the probability that the client’s internal control activities will fail to prevent or detect material misstatements provided that such misstatements enter or would have entered the accounting system in the first place. So, for misstatements that could occur, what is the audit client doing about such occurrences? Does it have the proper systems, processes, and controls in place to either prevent or detect misstatements? Recall from our discussion of auditing standards in Chapter 2 that one of the major purposes of an internal control system is to ensure appropriate processing and recording of transactions for the production of reliable financial statements. Similar to inherent risk, auditors do not create or manage control risk. They can only evaluate an entity’s internal control system and assess its magnitude in an appropriate manner.

External auditors’ task of control risk assessment begins with learning about an entity’s internal controls that are designed to prevent and detect material misstatements related to each relevant assertion for each significant account and disclosure. The auditors then perform tests of controls if appropriate to determine whether they are operating effectively. This process is discussed in detail in Chapter 5.

Detection Risk Detection risk is the probability that the auditor’s own procedures will fail to detect material misstatements provided that any have entered the accounting system in the first place and have not been prevented or detected and corrected by the client’s internal controls. In contrast to inherent risk and control risk, auditors are responsible for performing the evidence-gathering procedures that manage and establish detection risk. These audit procedures represent the auditors’ opportunity to detect material misstatements that may exist in the financial statements. In other words, unlike inherent risk and control risk, auditors can and do influence the level of detection risk.

In Chapter 3, you learned about substantive procedures, the procedures used to detect material misstatements that may exist in the significant account balances and disclosures presented in the financial statements and footnotes. The two categories of substantive procedures are (1) tests of details of transactions and balances, which provide specific evidence directly supporting assertions; and (2) substantive analytical procedures, which study plausible relationships among financial and nonfinancial data. Auditors are able to reduce detection risk by completing more and stronger substantive tests. Generally speak- ing, in response to a higher assessed risk of material misstatement for a relevant assertion being audited, auditors must reduce detection risk to an appropriate level by planning appropriate substantive procedures. This relationship is now further illustrated with a discussion of the audit risk model.

Audit Risk Model The three components of audit risk can be expressed in a conceptual model that is designed to help auditors understand how the assessment of each component affects the overall audit risk being faced on the engagement. It is important to stress that the

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following discussion is conceptual in nature. It is also important to point out that the audit risk model assumes that each of the elements is independent. Thus, the risks can be expressed in a model form as follows:

Audit risk (AR) = Inherent risk (IR) × Control risk (CR) × Detection risk (DR) Assume that auditors want to perform an audit of a particular assertion or disclosure

well enough to hold the AR to a relatively low level (e.g., 0.05, which means that, on average, 5 percent of audit opinions would be wrong). For example, suppose that an audit team thought valuation of a particular inventory balance was subject to great inherent risk (say, IR = 0.90) and that the client’s internal control was not very effective (say, CR = 0.50). Thus, RMM would be 0.45 (0.90 × 0.50). If auditors wanted to keep audit risk at a low level (say, AR = 0.05), according to the model, this example would produce the following results:

AR = IR X CR X DR 0.05 = 0.90 X 0.50 X DR

Solving for DR: DR = 0.111 (rounded to 0.11)

Set Desired Level of

Audit Risk Assess

Inherent Risk

Assess Control Risk

Solve for Detection Risk

1 2 3 4

[0.05] [0.90] [0.50] [0.11]

You should notice that the assessment of inherent risk (IR) and control risk (CR) led to a determination of detection risk (DR). As a result, detection risk depends on and is planned for based on the assessment of the other risk factors. DR is calculated and derived from the others by solving the risk model equation. It is not an independent judg- ment. Hence,

DR = AR/(IR × CR) DR = 0.11 = 0.05/(0.90 × 0.50)

While detection risk is defined as the risk that the auditors’ procedures fail to detect material misstatements, it is important that you understand that the application of DR is different. The 11 percent represents the amount of risk the auditors can allow and still maintain overall audit risk at 0.05. Conceptually then, auditors must design procedures so that DR will not exceed 0.11 (approximately). Exhibit 4.2 provides a visual display of the steps in the audit risk process.

LOW or very low

set assess

Risk of Material Misstatement (RMM)

assess calculate

AR= IR× CR× DR HIGH if material misstatement is likely to enter the accounting information system

HIGH if material misstatement is not likely to be detected by client’s internal controls

What is the acceptable level of detection risk? HIGH means we can a�ord less e�ective testing, and LOW means we need more e�ective testing.

EXHIBIT 4.2 Audit Risk Model

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Based on the allowable or planned level of detection risk (which is always based on the assessment of IR and CR), auditors modify the nature, the timing, and the extent of further audit procedures. The nature of an audit procedure refers to the type of proce- dure (e.g., observation, recalculation, inquiry) and the purpose of the procedure (e.g., test of controls, substantive procedure). When determining the nature of the audit pro- cedure, the auditor is considering what to do. When doing so, the auditor considers the overall effectiveness of different types of audit procedures in detecting misstatements. While inquiry of management about whether accounts receivable listed on the balance sheet really exist is an audit procedure, it would not be an effective one. A much more effective procedure would be to confirm accounts receivable directly with the client’s customers. Timing refers to when the audit procedures will be completed. To do so, the auditor typically considers whether to complete the procedures at an interim date or at the balance sheet date. While confirmation of accounts receivable may be performed at an interim date, auditors are expressing an opinion on year-end balances. The closer the procedures are performed to year-end (the balance sheet date), the more effective they are because there is less chance of a material misstatement occurring between the interim confirmation date and year-end. Finally, extent refers to the number of tests performed. Clearly, the larger the number of accounts receivable confirmations that are mailed to customers, the greater the chance of finding errors and fraud, and therefore, the lower the detection risk.

Note that there is an inverse relationship between RMM (i.e., inherent risk and con- trol risk) and detection risk. In other words, the greater the risk of material misstate- ment, the lower the detection risk that auditors could allow in order to maintain the level of audit risk with which they feel comfortable. This makes sense. If the relevant assertion is risky or the related controls are poor, auditors would want to reduce detec- tion risk by modifying the nature, timing, and extent of further procedures to increase their effectiveness. On the other hand, if the account is not risky and controls are strong, the auditor could employ less effective (and presumably less costly) substantive audit procedures.

The practical problem here is knowing whether the audit has been planned and per- formed well enough to limit the detection risk to as low as 0.11. Remember that the audit risk model is only a conceptual tool. Auditors cannot calculate the exact level of DR (or, for that matter, IR or CR), so the model represents more of a way to think about audit risks than a way to calculate them. However, the AICPA Audit Sampling Guide does use this model to calculate risks and the related sample sizes:

The Impact of Detection Risk Allowed on the Nature, Timing, and Extent of Further Audit Procedures

  Lower Detection Risk Allowed Higher Detection Risk Allowed

Nature More effective tests Less effective tests Timing Testing performed at year-end Testing can be performed at interim Extent More tests Fewer tests

The conceptual model does allow for some additional key insights, including these:

1. Auditors cannot estimate inherent risk to be zero and omit other evidence-gathering procedures.

2. Auditors cannot place complete reliance on internal controls (that is, CR = 0) to the exclusion of other audit procedures.

3. Auditors would not seem to exhibit due professional care if the level of audit risk was too high.

4. Although permissible, audit teams rarely choose to rely exclusively on evidence pro- duced by substantive procedures. Even if they think that control risk is high, auditors often perform some tests of controls to make sure the controls are in place.

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Up to this point, the components of the audit risk model have been expressed quanti- tatively (as numbers). In practice, largely all firms use qualitative measures of audit risk such as “low,” “moderate,” and “high.” In fact, it is not likely that you will ever “solve” for AR on your audit engagement. Yet whether expressed quantitatively or qualitatively, audit theory places both inherent risk and control risk on a probability continuum. Consider the following illustration for control risk (Exhibit 4.3) where qualitative control risk categories are expressed in terms of representative control risk probabilities.

Control Risk Categories (Qualitative) Representative Control Risk Probabilities (Quantitative)

Low control risk 0.10–0.45 Moderate control risk 0.40–0.70 Control risk slightly below the maximum 0.60–0.95 Maximum control risk 1.00

EXHIBIT 4.3 Qualitative and Quantitative Control Risk

REVIEW CHECKPOINTS 4.1 Define audit risk. 4.2 What are the components of the risk of material misstatement (RMM)? What are the components of

the audit risk model? 4.3 How is the audit risk model used to plan the audit? 4.4 What is meant by the terms nature, timing, and extent of further audit procedures?

EXHIBIT 4.4 Matrix Approach to Detection Risk (DR) Determination HighModerate

Control Risk (CR)

DR—High

DR—Moderate to High

DR—Moderate to High

DR—Moderate

DR—Moderate

DR—Moderate

DR—Low to Moderate

DR—Low to Moderate

DR—Low

Low

Low

Moderate

High

Inherent Risk (IR)

When risk is measured qualitatively, how do firms solve an equation to determine the appropriate level of detection risk? The simple answer is they do not. Rather, firms typi- cally use a matrix approach similar to the one shown in Exhibit 4.4. Auditors find the appropriate detection risk by reading the cell at the intersection of the assessed levels of inherent risk and control risk.

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124 Part Two The Financial Statement Audit

FRAUD RISK In the next section we will discuss the process auditors use to assess inherent risk. Prior to assessing inherent risk, it is important to understand fraud risk and the role it plays in the assessment of risk of material misstatement. You probably noticed that in our previous discussion of the audit risk model, there is no specific mention of fraud risk. While fraud risk is not a specific part of the audit risk model, fraud risk can never be ignored and does have an impact on the risk of material misstatement (that is, inherent risk and control risk) assessments. Auditors are required to consider fraud risk on each audit engagement for each relevant assertion related to each significant account and disclosure identified for an audit client. In effect, fraud risk is a special case of risk of material misstatement related to those situations where management intended to mislead the marketplace by issuing fraudulent financial statements.

When applying the audit risk model and assessing the risk of material misstate- ment, the auditor must always remember that a misstatement in the financial statements may be caused by an error or a fraud. What makes fraud different from errors is intent. Specifically, did a manager at the client intend to commit a fraud? Or, was the misstate- ment due to an error made by an employee? Because of the damage to the capital markets caused by fraudsters who have intentionally misstated their financial statements, and the difficulty of discovering misstatements that management is actively trying to hide, auditors must give separate and careful attention to fraud risk on every audit engagement. The  following Auditing Insight identifies a number of infamous CEO fraudsters.

LO 4-2 Explain auditors’ responsibility for fraud risk assessment and define and explain the differences among several types of fraud and errors that might occur in an organization.

When CEOs Go Bad* AUDITING INSIGHT

Perpetrator (age at trial) Company Verdict Punishment

Bernie Ebbers (63) WorldCom Found guilty on fraud and conspiracy charges related to an $11 billion accounting scandal.

Sentenced to 25 years in federal prison.

Walter Forbes (64) Cendant Found guilty of conspiracy to commit securities fraud and two counts of making false statements.

Sentenced to more than 12 years in prison; ordered to pay $3.3 billion in restitution.

Dennis Kozlowski (59) Tyco International Found guilty of stealing $600 million from the company.

Served a total of 6.5 years in a New York state prison.

Sanjay Kumar (44) Computer Associates 28 International Inc. (CA)

Pleaded guilty to obstruction of justice and securities fraud charges related to CA’s $3.3 billion accounting scandal.

Fined $8 million, sentenced to 12 years in prison, and ordered to pay $798.6 mil- lion in restitution.

Ken Lay (64) Enron Found guilty of securities fraud and related charges.

Suffered a massive coronary and passed away while awaiting sentencing.

Bernie Madoff (71) Madoff Investment Securities

Pleaded guilty to securities fraud, money laundering, filing false statements with the SEC, wire fraud, mail fraud, and sev- eral other charges.

Sentenced to 150 years in prison.

Angelo R. Mozilo (72) Countrywide Financial Settled with the SEC over securities fraud and insider trading charges.

Agreed to pay $67.5 million in fines and accepted a lifetime ban from serving as an officer or director of any public company.

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Perpetrator (age at trial) Company Verdict Punishment

Nathan Hardwick IV (53) LandCastle Title Found guilty on 21 counts of wire fraud, one count of conspiracy to commit wire fraud, and one count of making false statements to a federally insured finan- cial institution.

Sentenced to serve 15 years in prison.

Richard Scrushy (52) HealthSouth Was acquitted of 36 criminal conspiracy charges related to the fraud but was later found guilty of other bribery, con- spiracy, and mail fraud charges.

Settled civil charges with the SEC for $81 million; also in 2009, judge ruled that Scrushy was responsible for Health- South’s fraud and ordered him to pay $2.87 billion. Served almost 5 years in federal prison.

Jeffrey Skilling (52) Enron Found guilty of securities fraud and related charges.

Originally sentenced to 24 years in prison; after many challenges to the punishment, in 2013 the sentence was reduced to 14 years. Released in August 2018 after serving 11 years.

Calisto Tanzi (70) Parmalat Found guilty of securities laws violations related to his company’s 2003 collapse amid a giant financial fraud.

Currently serving a 17-year prison sentence.

Elizabeth Holmes (34) Theranos Settled fraud charges with the SEC. As of January 2020, awaiting criminal trial for wire fraud and conspiracy to commit wire fraud.

Settled charges with the SEC for $500,000 and $18.9 million shares of stock. Could face up to 20 years in prison for criminal charges.

Billie McFarland (26) Fyre Media (Fyre Festival) Plead guilty to wire charges related to Fyre Festival and to various fraud charges from a separate ticket-selling scheme.

Sentenced to 6 years in prison and ordered to pay $26 million.

Sources: “Ebbers Is Sentenced to 25 Years for $11 Billion WorldCom Fraud,” The Wall Street Journal, July 14, 2005, p. A1;  “Scrushy Is Convicted in Bribery Case,” The Wall Street Journal, June 30, 2006, p. A3;  “Ex-CEO of Cendant Is Found Guilty in Third Trial,” The Wall Street Journal, November 1, 2006, p. C3; “Skilling Gets 24 Years in Prison,” The Wall Street Journal, October 24, 2006, p. C1; “Parmalat Founder Gets Prison Term,” The Wall Street Journal, December 19, 2008, p. B2; Laurence Viele Davidson, “HealthSouth’s Scrushy Liable in $2.88 Billion Fraud (Update 3),” Bloomberg, June 18, 2009; www.bloomberg.com/apps/news?pid=ne wsarchive&sid=a89tFKR4OevM (referenced August 10, 2011); Adam Liptak “Justices Limit Law Used for Corruption Cases,” The New York Times, June 25, 2010, p1; Gretchen Morgenson, “Angelo Mozilo of Countrywide Settles Fraud Case for $67.5 Million,” The New York Times, October 16, 2010, p.1; A. Smith, “Ex-Enron CEO Skilling Has 10 Years Lopped off Sentence,” CNN.com, June 21, 2013, http://money.cnn.com/2013/06/21/news/companies/skilling-enron-resentencing/ index.html;.Taylor Dunn, Victoria Thompson, Rebecca Jarvis, and Ashley Louszko, “Ex-Theranos CEO Elizabeth Holmes says ’I don’t know’ 600-plus times in never-before-broadcast deposition tapes,” Abcnews.go.com, January 23, 2019, https://abcnews.go.com/Business/theranos-ceo-elizabeth-holmes-600-times- broadcast-deposition/story?id=60576630; Rebecca Jarvis and Taylor Dunn, “Theranos founder Elizabeth Holmes settles with SEC in alleged ‘elaborate, years- long fraud’,” Abcnews.go.com, https://abcnews.go.com/Business/theranos-founder-elizabeth-holmes-settles-sec-alleged-elaborate/story?id=53760680; Lindsey Bever and Amy Wang, “The Fyre Festival was a total disaster. Its founder is going to prison for wire fraud.” The Washington Post, October 11, 2018, https://www. washingtonpost.com/arts-entertainment/2018/10/11/fyre-festival-was-total-disaster-its-founder-is-going-prison-wire-fraud/?utm_term=.7c40218e03c6; Doha Madani, “Fyre Festival organizer Billy McFarland sentenced to 6 years on fraud charges,” NBC News, October 11, 2018, https://www.nbcnews.com/news/us-news/ fyre-festival-organizer-billy-mcfarland-sentenced-6-years-fraud-charges-n919086; Ben Lane, “Former LandCastle Title CEO Nat Hardwick found guilty of embez- zling $26 million,” Housingwire.com, February 13, 2019, https://www.housingwire.com/articles/48174-former-landcastle-title-ceo-nat-hardwick-sentenced-to- 15-years-for-embezzling-26-million; Chris Morris, “Former Enron CEO Jeff Skilling Released From Prison,” Fortune, August 31, 2018, http://fortune.com/2018/08/31/ enron-ceo-jeff-skilling-released-prison/

Given the damage that can occur to the capital markets as a result of fraud, auditors are required by professional standards to hold a brainstorming session to consider the risk of fraud in every audit engagement. The required brainstorming session will be discussed later in the chapter in the context of gathering information for risk assessment. It is important for students to recognize that the nature, timing, and extent of audit work should change as a result of the auditor’s ultimate fraud risk assessment. In general, the lower the risk of material misstatement due to fraud, the less persuasive the audit evidence needs to be. It therefore follows that when fraud risk factors are identified, the

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126 Part Two The Financial Statement Audit

auditor generally must obtain more persuasive audit evidence. Most importantly, once fraud risk factors are identified, the auditor should clearly identify the fraud risks and then design and perform procedures that respond directly to fraud risks. The next several paragraphs provide some basic definitions and examples of fraud and fraud risk factors to help further your understanding

Fraud Fraud is the act of knowingly making material misrepresentations of fact with the intent of inducing someone to believe the falsehood and act on it and, thus, suffer a loss or damage. Through both fraud and aggressive financial reporting, some companies have caused financial statements to be misstated, usually by (1) overstating revenues and assets, (2) understating expenses and liabilities, and (3) giving disclosures that are misstated or that omit important information.3 Fraud that affects financial (or other) information and causes financial statements to be materially misstated often arises from the perceived need to get through a difficult period. The difficult period may be characterized by cash shortage, increased competition, cost overruns, and similar events that cause financial difficulty. Managers usually view these conditions as temporary, believing that getting a new loan, selling stock, or otherwise buying time to recover can overcome them. In  the meantime, falsified financial statements are used to benefit the company. Generally, fraudulent financial statements show financial performance and ratios that are more favorable than current industry experience or than the company’s own history. Exhibit 4.5 illustrates three categories of factors that might indicate increased risk of fraudulent financial reporting.

A very common reason cited for falsifying financial statements is so a company can meet its earnings projections either provided by management or set by financial analysts.

3An academic study (see M. Nelson, J. Elliott, and R. Tarpley, “How Are Earnings Managed? Examples from Auditors,” Accounting Horizons, November 2002) examined more than 500 attempts to manage earnings that were detected by auditors. The majority (more than 50 percent) of the attempts involved improper expense reductions, approximately 20 percent involved improper revenue increases, and the remainder involved business combinations and other accounting artifices.

EXHIBIT 4.5 Fraud Risk Factors

Management’s Characteristics and Influence Industry Conditions

Operating Characteristics and Financial Stability

• Management has a motivation (bonus compensation, stock options, etc.) to engage in fraudulent reporting.

• Management decisions are dominated by an individual or a small group.

• Management fails to display an appropriate attitude about internal control and financial reporting.

• Managers’ attitudes are very aggressive toward financial reporting.

• Managers place too much emphasis on earnings projections.

• Management participates excessively in the selection of accounting principles or the determination of estimates.

• The company has a high turnover of senior management.

• The company has a known history of violations.

• Managers and employees tend to be evasive when responding to auditors’ inquiries.

• Managers engage in frequent disputes with auditors.

• Company profits lag those of its industry. • New requirements are passed that could

impair stability or profitability. • The company’s market is saturated due to

fierce competition. • The company’s industry is declining. • The company’s industry is changing rapidly.

• A weak internal control environment prevails.

• The company is not able to generate sufficient cash flows to ensure that it is a going concern.

• There is pressure to obtain capital. • The company operates in a tax haven

jurisdiction. • The company has many difficult accounting

measurement and presentation issues. • The company has significant transactions

or balances that contain estimates that are difficult to audit.

• The company has significant and unusual related-party transactions.

• Company accounting personnel are lax or inexperienced in their duties.

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Simply stated, when a company fails to meet earnings projections, its stock price usually falls and the managers of the company face great scrutiny. As a result, managers work very hard to meet expectations set by analysts. In fact, sometimes a company’s perfor- mance will exactly meet the earnings targets announced by management months earlier. To avoid the negative outcomes that typically accompany a failure to meet expectations, managers sometimes commit fraud. The accompanying Auditing Insight illustrates an example that occurred at Bankrate.

While reviewing the preliminary financial results for the second quar- ter of 2012, the chief financial officer, VP of finance, and director of accounting at Bankrate Inc. concluded that their quarterly perfor- mance was going to fall dramatically short of analyst expectations. In  order to avoid possible repercussions from Wall Street, the man- agers directed two different divisions to record additional revenue totaling $800,000, without supporting documentation or analysis. Eventually, the company’s auditors, Grant Thornton, discovered and flagged the unsupported revenue. In July 2015, Bankrate restated

its financial statements for the second quarter of 2012. In addition, in September 2015, Bankrate was fined $15 million to settle the accounting fraud charges.

Sources: Accounting and Auditing Enforcement Release No. 3683, September 8, 2015 (available at: https://www.sec.gov/litigation/admin/2015/33-9901. pdf); Michael Cohn, “Bankrate to Pay $15 Million to Settle Accounting Fraud Charges,” Accounting Today, September 8, 2015 (available at: www. accountingtoday.com/news/audit-accounting/bdo-settle-sec-charges- false- misleading-audit-opinions-75733-1.html).

Meeting Analyst Expectations at Bankrate AUDITING INSIGHT

While not as common, there are times when management may find it beneficial to commit fraud by understating assets and revenues and overstating expenses and liabili- ties. This is likely to occur during times when profits are high and management wants to put reserves in a “cookie jar”4 that can be used to increase profits in future years and “smooth earnings” at the discretion of the management team. Understating profits also can be desirable if the company is under scrutiny by governmental bodies, taxing authori- ties, labor unions, or competitors. Therefore, auditors must be aware of the potential for fraudulent activity in both directions, depending on the relevant facts and circumstances.

When assessing the risk of fraud, auditors need to know about the red flags, those telltale signs and indications that have accompanied many frauds that have occurred in the past. Because of the double-entry bookkeeping system, fraudulent accounting entries always affect at least two accounts and two places in financial statements. Because many frauds involve improper recognition of assets, there is a theory of the “dangling debit,” which is an asset amount that can be investigated and found to be false or questionable. Frauds may involve the omission of liabilities, but the matter of finding and investigating the dangling credit is normally very difficult. It “dangles” off the books. In other words, the “dangling credit” is a credit that was never recorded to a liability account, resulting in an omission of a liability that should have been recorded. (Consider the implications for the completeness assertion in this scenario.) Misstated disclosures also present difficulty, mainly because they involve words and messages instead of numbers. Omissions may be difficult to notice, and misleading inferences may be very subtle. Exhibit 4.5 presents some of the other risk factors that have characterized situations in which frauds have occurred. Among the fraud risk factors identified, when a company has difficult accounting issues or has balances that contain difficult estimates to audit, these issues can be very challenging for auditors.

Types of Fraud Remember, financial statements may be materially misstated as a result of errors or fraud. While accounting errors are usually unintentional, fraud consists of knowingly making material misrepresentations of fact with the intent of inducing someone to believe the

4Cookie jar reserves are overaccruals created by a company (credit accrual, debit expense). In times when the company struggles, it reverses the overaccrual (debit accrual, credit expense) to pump up profits. Once the “cookie jar” reserve has been established, auditors are in a fix because it may be difficult to object to the company correcting the overaccrual.

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128 Part Two The Financial Statement Audit

falsehood and act on it and, thus, suffer a loss or damage. This definition encompasses all means by which people can lie, cheat, steal, and dupe other people. There are, in essence, two different types of fraud: Fraudulent financial reporting and misappropriation of assets.

Fraudulent financial reporting is defined in AU-C 240.A2 as “intentional misstatements, including omissions of amounts or disclosures in financial statements to deceive financial statement users. It can be caused by the efforts of management to manage earnings in order to deceive financial statement users by influencing their perceptions about the entity’s performance and profitability.”* Given this definition, fraudulent financial reporting is often referred to as management fraud. Management fraud is deliberate fraud committed by management that injures investors and creditors through materially misstated information.

Misappropriation of assets is defined in AU-C 240.A7 as involving “the theft of an entity’s assets and is often perpetrated by employees in relatively small or immaterial amounts.”* Therefore, misappropriation of assets is often referred to as employee fraud. Employee fraud is the use of fraudulent means to misappropriate funds or other property from an employer. It usually involves falsifications of some kind: using false documents, lying, exceeding authority, or violating an employer’s policies. It consists of three phases: (1) the fraudulent act, (2) the conversion of the funds or property to the fraudster’s use, and (3) the cover-up. Employee fraud can be classified as either embezzlement or larceny. This type of fraud is discussed in detail in Chapter 6. Other definitions related to misap- propriation of assets are

∙ Embezzlement is a type of fraud involving employees or nonemployees wrongfully misappropriating funds or property entrusted to their care, custody, and control, often accompanied by false accounting entries and other forms of deception and cover-up.

∙ Larceny is simple theft; for example, an employee misappropriates an employer’s funds or property that has not been entrusted to the custody of the employee.

∙ Defalcation is another name for employee fraud, embezzlement, and larceny.

Misstatements due to fraudulent financial reporting or misappropriation of assets are distinctly different than errors. Errors are unintentional misstatements or omissions of amounts or disclosures in financial statements. Errors are not considered fraud because they occur unintentionally.

Exhibit 4.6 shows some acts and devices that are often involved in financial frauds. Notice that these actions may be perpetrated by the organization or may be perpetrated upon the organization. Collectively, these are known as white-collar crimes—the misdeeds of people who wear ties to work and steal with a pencil or a computer terminal. White- collar crime produces ink stains instead of bloodstains.

American Institute of Certified Public Accountants. “Consideration of Fraud in a Financial Statement Audit.” Accessed June 24, 2019. https://www.aicpa.org/research/standards/auditattest/downloadabledocuments/au-c-00240.pdf. American Institute of Certified Public Accountants. “Consideration of Fraud in a Financial Statement Audit.” Accessed June 24, 2019. https://www.aicpa.org/research/standards/auditattest/downloadabledocuments/au-c-00240.pdf.

When CFOs are caught fudging the numbers, it’s more likely they were pressured by upper management than looking for some immedi- ate financial benefit. At least that’s the way The Conference Board sees it after analyzing more than 20 years of accounting and auditing enforcement actions by the Securities and Exchange Commission. The study found that CFOs have an inherently higher risk of litigation in

accounting manipulation cases, yet they often do not get the personal financial benefits of cooking the books. However, when CEOs apply enough pressure, CFOs may acquiesce and set aside their role as watchdog of financial reporting quality.

Source: T. Whitehouse, Compliance Week, May 20, 2011.

Wayward CFOs Often Coerced by CEOs, Study Says

AUDITING INSIGHT

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Auditing standards require that auditors specifically assess the risk of material misstate- ment due to fraud for each engagement. Fraud risk factors relate to both misstatements arising from fraudulent financial reporting and misstatements arising from misappro- priations of assets (usually as a result of employee theft and the related attempt to con- ceal this theft through erroneous journal entries). Furthermore, auditors should consider these risk factors when determining what audit procedures to perform. With regard to the audit risk model, fraud risk is always considered a key factor when an auditor assesses inherent risk. A complete discussion of inherent risk assessment follows in the next section.

One last note regarding our responsibility for fraud: audit teams are concerned with fraud only as it affects the financial statements. That is, audit teams are not responsible to detect all fraud but are responsible to detect cases where fraudulent activity results in materially misstated financial statements. For example, if a warehouse employee is misappropriating inventory but that embezzlement does not result in materially misstated financial statements, auditors do not necessarily have a responsibility to detect this type of fraud. However, if management is materially misstating revenues in order to meet earnings expectations, auditors are responsible for detecting this misstatement. That is not to say that auditors would ignore immaterial fraud (indeed, any instance of fraud would cause auditors to re-evaluate their assessment of management’s integrity), but only that auditors’ primary responsibility is to design procedures to provide reasonable assur- ance that material frauds that might misstate the financial statements are detected.

EXHIBIT 4.6 Overview of Types of Frauds

Owners Managers

Vendors Suppliers

Consultants

Stockholders Creditors

Fraudulent Financial Statements Securities Fraud

Theft of Trade Secrets Employee Bribery

Short Shipment Double Billing False Invoices Employee Bribery

Expense Account Padding Embezzlement Theft of Cash and Property Kickbacks False Benefits Claims Padded Payroll

False Loss Claims

Tax Evasion Contract Cost Padding False Benefit Claims

Shoplifting False Refunds False Credit Cards Hot Checks

False Advertising Short Shipments Defective Products Price Fixing

Insider Trading Related-Party Transactions

Competitors

Employees Insurers

Government

Customers

COMPANY

REVIEW CHECKPOINTS 4.5 What is the primary difference between a material misstatement due to fraud and one due to error? 4.6 What is the auditor’s responsibility regarding fraud risk? 4.7 What are the defining characteristics of (a) white-collar crime, (b) employee fraud, (c) embezzle-

ment, (d) larceny, (e) defalcation, (f) management fraud, and (g) errors? 4.8 Identify three different categories of fraud risk factors. Next, for each category, what are some of

the conditions that can help contribute to a higher likelihood of financial statement fraud?

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130 Part Two The Financial Statement Audit

INHERENT RISK ASSESSMENT—“WHAT COULD GO WRONG?” The professional standards make clear that risk assessment underlies the entire audit pro- cess. As a result, it is absolutely essential that auditors take great care to appropriately assess the risks of material misstatement, either due to error or fraud that exists on an audit engagement. When performing risk assessment procedures to accomplish this objective, the first step taken by auditors is often to assess inherent risk for each relevant assertion related to each of the significant accounts and disclosures identified on an audit engagement.

Recall that inherent risk is the probability that, in the absence of internal controls, material errors or frauds could enter the accounting system used to develop financial statements. Inherent risks can arise from a variety of different sources, and an auditor’s basis for assessing a client’s inherent risk is often found in his or her familiarity with the types of misstatements that could occur for each assertion in any account balance or class of transactions. Clearly, hundreds of innocent errors and not-so-innocent fraud schemes are possible. Instead of trying to learn about the hundreds of possible errors and frauds, it is better to begin with an introduction to the seven general categories of errors and fraud. In a sense, these seven categories answer the audit question: “What Could go wrong?” in the financial statements. Exhibit 4.7 shows the seven categories with some examples.

In effect, at both the overall financial statement level and at the management financial statement assertion level, inherent risk refers to the exposure or susceptibility of an asser- tion within an entity’s financial statements to a material misstatement without regard to the system of internal controls. A detailed understanding of an audit client’s business model, including its products and services, is an essential part of an auditor’s inherent risk assessment process at both the financial statement and the financial statement assertion

LO 4-3 Explain an auditor’s responsibility to assess inherent risk, including a description of the type of risk assessment procedures that should be performed when assessing inherent risk on an audit engagement.

EXHIBIT 4.7 General Categories of Misstatements

What Could Go Wrong? Error Examples Fraud Examples Assertion Violated

1.  Invalid transactions are recorded.

A computer malfunction causes a sales transaction to be recorded twice.

Fictitious sales are recorded and charged to nonexistent customers.

Occurrence

2.  Valid transactions or disclosures are omitted from the financial statements.

Shipments to customers are never recorded because of problems in the company’s information processing system.

Shipments are made to an employee’s friend and intentionally never recorded.

Completeness

3.  Transaction or disclosure amounts are inaccurate.

An employee calculates depreciation incorrectly.

A company “short ships” a shipment to a customer and bills the customer for the full amount ordered.

Accuracy

4.  Transactions are classified in the wrong accounts.

Sales to a subsidiary company are recorded as sales to external parties instead of intercompany sales, or the amount is charged to the wrong customer account receivable record.

A loan to the company’s CEO (not permitted under Sarbanes–Oxley) is classified as an account receivable to conceal the transaction.

Classification

5.  Transaction accounting and posting are incorrect.

Sales are posted in total to the accounts receivable control account, but some are not posted to individual customer account records.

Repairs and maintenance expenses are recorded as additions to property, plant and equipment accounts to keep expenses off the income statement.

Accuracy

6.  Transactions are recorded in the wrong period.

The company fails to record a shipment that was sent by a supplier FOB shipping point in December, but the shipment was not received (or recorded) until January.

Shipments made in January (of the next fiscal year) are backdated and recorded as sales in December.

Cutoff

7.  Disclosures are incomplete or misleading.

The company did not include the effective tax rate reconciliation in the footnotes.

Management fails to disclose litigation against the company.

Presentation and Disclosure

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levels. Inherent risk assessment helps to guide the auditor in allocating more and stron- ger resources to test specific accounts and disclosures that present a higher likelihood of material misstatement and therefore present a higher level of inherent risk. In effect, inherent risk assessment provides the basis for executing an appropriate response to the risks identified. Remember that the assessment of inherent risk can be based on a variety of types of information. The risk assessment process is summarized in Exhibit 4.8.

At a preliminary level, the best indicator of the risk of a material misstatement in the year under audit is a material misstatement that was discovered during the previous audit. Also, changes in transaction types, technology, personnel, or accounting principles may increase the risk of material misstatement. The nature of the client’s business can pro- duce complicated transactions and calculations that are subject to information processing and accounting treatment error. For example, real estate, franchising, and oil and gas transactions are frequently complicated and subject to accounting error. Some types of inventories are more difficult than others to count, value, and keep accurately in perpetual records. The following factors have been suggested as being related to the susceptibility of accounts to misstatement or fraud:

∙ Dollar size of the account. The higher the account balance, the greater the chance of having errors or fraud in the account.

∙ Liquidity. The greater the account’s liquidity (ability to be easily converted to cash), the more susceptible the account is to fraud. For example, cash is more susceptible to theft than, say, a building.

∙ Volume of transactions. The higher the volume of transactions, the higher the chance of error or fraud occurring in the transactions.

EXHIBIT 4.8 The Risk Assessment Process Document

Understand Company and Its

Environment

Industry and

External Factors

Nature of the

Company

Objectives and

Strategies

Required understanding needed to plan audit - will help identify high

risk areas

Accounting Principles

and Disclosures

Measurement and Analysis of

Financial Performance

Understand Internal Control

over Financial Reporting

Information from Client Acceptance and Retention Evaluation, Audit Planning, Past Audits, and Other Engagements

• More E�ective

Substantive Procedures

• Procedures Closer to Year-End

• Specialists • Experienced

Personnel

Brainstorming

Perform Analytical Procedures

Inquire of Audit Committee,

Management, and Others

Information and audit procedures

used to assess risk

Assess Risk Factors

Respond Communicate

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132 Part Two The Financial Statement Audit

∙ Complexity of the transactions. Very complex transactions (e.g., those involving deriv- ative securities or hedging transactions) tend to have a higher percentage of errors than simple transactions.

∙ Subjective estimates. Subjective measurements (e.g., estimating the allowance for doubtful accounts) tend to have more errors and fraud than objective measurements (e.g., counting petty cash). Simply stated, the more subjective the measurement, the easier it is to manipulate.

Understanding the Client’s Business and Its Environment Gaining a detailed understanding and knowledge of the client’s business and its environ- ment within the context of its industry is essential in an audit. Auditing standards require auditors to obtain a thorough understanding of the business to plan and perform the audit work. More specifically, a thorough understanding of the business will help identify areas of increased risk of material misstatement. Obtaining an understanding of the client’s business includes understanding

∙ Relevant industry, regulatory, and other external factors. ∙ The nature of the company and related parties. ∙ The effect of client computerized processing. ∙ The company’s selection and application of accounting principles, including related

disclosures. ∙ The company’s objectives and strategies and those related business risks that might

reasonably be expected to result in risks of material misstatement. ∙ The company’s measurement and analysis of its financial performance.

Industry, Regulatory, and Other External Factors Auditors must obtain an understanding of relevant industry, regulatory, and other external factors that encompasses the client’s competitive environment. This includes a detailed understanding of the regulatory environment, including the applicable financial reporting framework (e.g., U.S. GAAP or IFRS). Auditors must also understand the broad eco- nomic environment in which the client operates, including such things as the effects of national economic policies (e.g., price regulations and import/export restrictions), the geographic location and its economy (e.g., northeastern states versus sunbelt states), and developments in taxation and regulatory areas (e.g., industry regulation, approval processes for products in the drug and chemical industries).

Industry characteristics are also important. There is a great deal of difference in the production and marketing activities of banks, insurance companies, mutual funds, supermarkets, hotels, oil and gas industries, agriculture organizations, manufacturers, and so forth. Industry expertise also involves knowledge of the competition and an understand- ing of the client’s market. Few auditors are experts in all of these areas. Public accounting firms must have experts in all industries they examine and rely on them to supervise audits in their industry of expertise. This is why considering the expertise needed on an engage- ment is crucial to effective audit planning and engagement team assignment in those indus- tries. Indeed, some public accounting firms have reputations for having many audit clients in a particular industry while others have a larger presence in other industries. Further, most large public accounting firms organize their auditors by industry, allowing individuals to become familiar with issues in the industry to which they are assigned.

In addition, auditors should be aware of the effects that economic distress and slow recovery can have on their clients. In the past, PCAOB inspectors have identified instances in which auditors failed to comply with auditing standards in connection with an economic crisis, such as fair value measurements, impairment of goodwill, indefinite- lived intangible assets, and other long-lived assets, allowance for loan losses, off-balance sheet structures, revenue recognition, inventory, and income taxes.5

5Report on Observations of PCAOB Inspectors Related to Audit Risk Areas Affected by the Economic Crisis, September 29, 2010.

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The Nature of the Company Obtaining an understanding of the nature of the company includes understanding

∙ The company’s organizational structure and management personnel. Is the client cen- tralized or decentralized? Who makes the decisions? Are senior managers familiar with accounting and reporting requirements? Do they value the importance of good controls? Are any officers, employees, or shareholders involved in related-party transactions?

∙ The sources of funding of the company’s operations and investment activities. Is the company funded by debt or equity? Are there restrictions placed by lenders that man- agement must meet (e.g., debt covenants)? Does it have the financing in place to meet future cash requirements? Are any lenders or shareholders involved in related-party transactions?

∙ The company’s significant investments. Is the company invested in other compa- nies for strategic purposes? Do investments provide a significant source of income? What is the company’s investment policy? Do overseas investments present a risk of nationalization? Are any subsidiaries involved in related-party transactions? Is the company planning to acquire another company? As the following Auditing Insight reveals, there are additional risks for auditors if their client is either about to be acquired by or planning to acquire another company.

∙ The company’s operating characteristics, including its size and complexity. Does the company operate internationally? Do subsidiaries operate in diverse industries?

∙ The sources of the company’s earnings, including the relative profitability of key products and services, and key supplier and customer relationships. Are there any threats to loss of revenue from losing suppliers or customers? Could key products be overtaken by competitors’ products? Could advances in technology make the client’s products obsolete? Are any customers or suppliers related parties?

When Hewlett-Packard (HP) admitted that it overpaid when it acquired Autonomy for $11.1 billion in October 2011, the manage- ment team did not accept responsibility for the blunder. Rather, an investigation completed by HP concluded that there were serious “accounting improprieties” and “outright misrepresentations” found on Autonomy’s financial statements. According to HP CEO Meg Whit- man, “There appears to have been a willful sustained effort” to inflate Autonomy’s revenue and profitability. “This was designed to be hidden.” As a result, HP wrote down $8.8 billion of Autonomy’s value just one year after the acquisition. To help recoup some of their losses, HP filed a lawsuit in 2015 against former Autonomy CEO Mike Lynch and CFO Sushovan Hussain for $5 billion that, as of 2019, was still making its way through the UK courts. In the mean- time, in April 2018 the US Department of Justice convicted Sushovan Hussain of falsifying financial statements and exaggerating the com- pany’s value. Criminal charges have also been filed in the US against Mike Lynch.

For its part, Deloitte UK defends its audit work completed at the company. In fact, a spokesman for Deloitte UK “categorically

denies that it had any knowledge of any accounting improprieties or any misrepresentations in Autonomy’s financial statements, or that it was complicit in any accounting improprieties or misrepresenta- tions.”* The Financial Reporting Council (FRC), the auditing regula- tor in the UK, disagrees. In 2018 the FRC filed a formal complaint against Deloitte, accusing them of “failing to adequately challenge Autonomy’s accounting and disclosure of its purchases and sales of computer hardware.” According to the FRC, the conduct of the auditors fell “significantly short of the standards reasonably to be expected.”

Source: “HP Says It Was Duped, Takes $8.8 Billion Charge,” The Wall Street Journal, November 21, 2012, p. A1; Stu Woo, “US Charges Autonomy Founder With Fraud Over Hewlett Packard Deal,” The Wall Street Journal, November 30, 2018, https://www.wsj.com/articles/u-s-charges-autonomy-founder- with-fraud-over-hewlett-packard-deal-1543582883; “Deloitte and Former Autonomy Chiefs Face Action,” BBC News, May 31, 2018, https://www.bbc. com/news/business-44315824; Gareth Corfield, “HPE wants British ex-CFO to testify in UK Autonomy lawsuit before Uncle Sam sentences him,” The Register, February 18, 2019, https://www.theregister.co.uk/2019/02/18/ sushovan_hussain_testimony_hpe_autonomy_lawsuit/.

Worthen, Ben. November 20, 2012. “H-P Says It Was Duped, Takes $8.8 Billion Charge.” The Wall Street Journal. https://www.wsj. com/articles/SB10001424127887324352004578130712448913412.

How Hewlett-Packard Overpaid for AutonomyAUDITING INSIGHT

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134 Part Two The Financial Statement Audit

Related Parties Related parties include those individuals or organizations that can influence or be influ- enced by decisions of the company, possibly through family ties or investment relation- ships. According to the professional standards, an auditor’s primary objective in regard to related parties is to obtain the evidence needed to determine whether “related parties and relationships and transactions with related parties have been properly identified, accounted for, and disclosed in the financial statements.”6 Because one of the basic assumptions of historical cost accounting is that transactions are valued at prices agreed on by two independent parties (i.e., “arm’s-length transactions”), valuation of related-party transac- tions is particularly troublesome. For example, auditors must remember that the economic substance of a particular transaction (and its effect on the financial condition of the entity) could be significantly different from its legal form (e.g., capitalized leases versus operat- ing leases).

Auditors strive to identify related-party relationships and transactions during the planning stage to be able to obtain evidence that the financial accounting and disclosure for them are proper. Some methods include reviewing the board of directors’ meeting minutes, making inquiries of key executives, and reviewing stock ownership records (5 percent ownership in the company is usually used as a good cutoff). Auditors also should question the persuasiveness of the evidence obtained from related parties because the source of the evidence may be biased. Hence, auditors should obtain evidence of the purpose, nature, and extent of related-party transactions and their effect on financial statements, and the evidence should extend beyond inquiry of management.

6Public Company Accounting Oversight Board. “Auditing Standard No. 18: Related Parties.” Accessed June 24, 2019. https:// pcaobus.org/Standards/Archived/PreReorgStandards/Pages/Auditing_Standard_18.aspx.

Client Computerized Processing Clients can exhibit great differences in the way that their computerized processing activi- ties are organized. The degree of centralization inherent in the organizational structure can vary. A highly centralized organizational structure generally has all significant computerized processing controlled and supervised at a central location. The control environment, the computer hardware, and the computerized systems can be uniform throughout the company. Auditors can obtain most of the necessary computerized

For the most part, yes. A recent academic study examines the rela- tionship between related-party transactions and subsequent financial statement restatements, which would signal the previous existence of a material misstatement. Looking at 3,588 observations, the authors find that companies that engage in related-party transactions have a higher likelihood of future restatements, as compared to those that did not have such transactions. In particular, related-party transactions that relate to tone at the top, such as a loan or consulting arrangement with a director, officer, or major shareholder are more greatly associ- ated with restatements then related-party transactions that deal more with normal course of business events.

Interestingly, auditors may not recognize these transactions as the red flags they appear to be. When looking at audit fees, companies

that report related-party transactions have lower audit fees than com- panies that do not. This is counterintuitive, as you would expect the increased risk of material misstatement associated with related-party transactions would require more audit work and therefore higher fees. Companies with related-party transactions also are less likely to hire auditors that are industry specialists. The less frequent hiring of industry specialists and lower audit fees could signal that companies with related-party transactions are, for whatever reason, looking for a lower quality audit.

Sources: M. Kohlbeck and B. Mayhew, “Are Related Party Transactions Red Flags?” Contemporary Accounting Research 35, no. 2 (2017), pp. 900–928.

Are Related Party Transactions Really that Troublesome?

AUDITING INSIGHT

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processing information by visiting the central location. At the other extreme, a highly decentralized organizational structure generally allows various departments, divisions, subsidiaries, or geographical locations to develop, control, and supervise computerized processing in an autonomous fashion. In this situation, the computer hardware and the computer systems are usually not uniform throughout the company. Thus, auditors might need to visit many locations to obtain the necessary audit information.

Selection and Application of Accounting Principles, Including Related Disclosures Auditors should evaluate whether the company’s selection and application of accounting principles are appropriate for its business and consistent with the applicable financial reporting framework and accounting principles used in the relevant industry. Auditors should pay attention to significant changes in the company’s accounting principles, financial reporting policies, or disclosures and the reasons for such changes; significant accounting principles in controversial or emerging areas; and the methods the company uses to account for significant and unusual transactions.

Accounting estimates are a concern because numerous fraud cases have involved the deliberate manipulation of estimates to increase net income. Accounting estimates are approximations of financial statement numbers and are often included in financial state- ments. Examples include valuation of investment securities, net realizable value of accounts receivable, depreciation expense, insurance loss reserves, percentage-of- completion contract revenues, impairment of goodwill, pension expense, warranty liabilities, fair value of financial instruments, and many more. Management is responsible for making account- ing estimates. Auditors are responsible for determining that all appropriate estimates have been made, that they are reasonable, and that they are presented in conformity with GAAP and adequately disclosed. The following Auditing Insight provides a brief description of “what went wrong” at Toshiba related to an important accounting estimate.

In early September 2015, the Japanese conglomerate Toshiba announced a $1.9 billion earnings write down that involved the past seven fiscal years. The accounting irregularities were primarily related to “percentage of completion” estimates that were used to account for both revenue and costs for various infrastructure projects that included railway system, hydroelectric, and nuclear projects. The  accounting rules specify that the estimates are supposed to represent reasonable estimates of the extent of contract progress. However, due to the subjectivity involved in the estimates, there is always an opportunity

for management bias to occur during the estimation process and for a fraud to occur. As a result, auditors must always be aware of this pos- sibility whenever they are auditing an accounting estimate.

Sources: Eric Pfanner and Megumi Fugukawa, “Toshiba Slashes Earnings for Past Seven Years,” The Wall Street Journal, September 7, 2015 (avail- able at http://www.wsj.com/articles/toshiba-slashes-earnings-for-past- 7-years-1441589473); David Katz, “Accounting Rife with Estimates Haunted Toshiba,” CFO.com, September 9, 2015 (available at http://ww2.cfo.com/ financial-reporting-2/2015/09/accounting-rife-estimates-haunted-toshiba/).

Percentage of Completion Estimates at ToshibaAUDITING INSIGHT

With respect to auditing accounting estimates, auditors are supposed to monitor the differences between management’s estimates and the closest reasonable estimates sup- ported by the audit evidence and evaluate the differences taken altogether for indications of a systematic bias. For example, management may estimate an allowance for doubt- ful accounts to be $50,000, and the auditors may estimate that the allowance could be $40,000 to $55,000. In this case, management’s estimate is within the auditors’ range of reasonableness. However, the auditors should note that the management estimate leans toward the conservative side (more than the auditors’ $40,000 lower estimate but not much less than the auditors’ higher $55,000 estimate). If other estimates exhibit the same conservatism and the effect is material, the auditors will need to evaluate the overall rea- sonableness of the effect of all estimates taken together.

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136 Part Two The Financial Statement Audit

Company Objectives, Strategies, and Related Business Risks An auditor needs to gain a detailed understanding of the audit client’s strategy to achieve a competitive advantage within its industry. The purpose of obtaining an understand- ing of the company’s objectives and strategies is to identify business risks that could reasonably be expected to result in material misstatement of the financial statements. The best starting point is with management, whose job it is to be knowledgeable about the company’s business risks. Any risks that could adversely affect a company’s ability to achieve its objectives and execute its strategies are called business risks. Although not all business risks are relevant to auditors, the following are examples of potential business risks that might result in material misstatement of the financial statements:

∙ Industry developments for which the company does not have the personnel or expertise to deal with the changes.

∙ New products and services that might not be successful. ∙ Expansion of the business when the demand for the company’s products or services

has not been accurately estimated. ∙ The effects of implementing a strategy that will lead to new accounting requirements. ∙ Financing requirements that the company may be unable to meet, resulting in a loss of

financing.

If you think about the financial statements as a window into the operations and results of a business, you can imagine peering through them to see activities of thousands of employees, suppliers, and customers working to achieve their goals. You should also be able to see the effects of the industry environment, including economic and politi- cal events, weather occurrences, technological advances, and social and demographic patterns. Given this view of financial statements, it’s easier to understand why auditors need to take the time to carefully acquire knowledge about a client’s business, industry, and strategy to achieve competitive advantage. This foundation of company- and indus- try-specific knowledge allows the auditor to better understand the client’s business risk, which is a precursor to assessing inherent risk and audit risk.

Indeed, the professional standards recognize that most business risks are eventually reflected in the financial statements. So auditors devote a significant amount of time to gain an understanding of their clients’ business risks. Firms believe they must learn more about their clients’ business strategies and processes to understand whether the financial statements are fairly presented.

Gaining an understanding of strategies and processes involves gathering evidence in areas not historically addressed by auditors. Auditors might ask production person- nel about labor problems or marketing personnel about product quality or competition. The process has been criticized by some as being more consulting than auditing, but it is essential in order to assess the risk of material misstatements. It addresses factors that audit team members could miss by getting lost in the details of an approach that simply started with the financial statements. Business risk assessment also makes auditors much more knowledgeable about their client’s business and its environment. We should note that, even when taking a top-down approach that starts with an understanding of the risks faced by the client in executing its strategy within the industry, the audit team ultimately still has to focus its procedures on the significant accounts and relevant management assertions.

Company Performance Measures The purpose of obtaining an understanding of the company’s performance measures is to determine what information management and others deem to be key indicators of company performance that may affect the risk of material misstatement. A key step for auditors to consider is to try to understand those measures to which management or financial statement users might be sensitive. For example, measures used to determine

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management compensation or analysts’ ratings might place pressure on management to manipulate financial results. Also, auditors might gain a better understanding of their clients by reviewing measures management uses to monitor operations, such as budget variances or trend analysis. Finally, those measures might be indicators of qualitative fac- tors that should be considered when determining materiality, as discussed in Chapter 3.

REVIEW CHECKPOINTS 4.9 Why is it important for an auditor to carefully assess inherent risk on each audit engagement? 4.10 What is meant by the nature of the company, and why is it important to inherent risk assessment? 4.11 Why should auditors understand their clients’ performance measures when assessing inherent

risk? 4.12 What is the major concern for auditors related to evidence obtained from related parties?

GATHERING INFORMATION AND PRELIMINARY ANALYTICAL PROCEDURES

Auditors have a responsibility to keep up with developments within their clients’ busi- nesses, industries, and the overall economy. Remember from our discussion in Chapter 1 that the auditing environment is rapidly being transformed into an environment character- ized by the availability of “Big Data.” Only a few of the many different sources of infor- mation available are described briefly in this section. The AICPA industry accounting and auditing guides are often a very good place to start. These guides explain the typical transactions and accounts used by various types of businesses and not-for-profit organi- zations. Many databases and information sources are available on the Internet, such as the Library of Congress E-resources Online Catalog (http://eresources.loc.gov/).

Auditors should make sure to read public information about the company, such as company-issued press releases, company-prepared presentation materials for analysts or investor groups, and analyst reports, as well as to observe or read transcripts of earnings calls and, to the extent publicly available, of other meetings with investors or rating agen- cies. Auditors also need to obtain an understanding of compensation arrangements with senior management, including incentive compensation arrangements, changes or adjust- ments to those arrangements, and special bonuses, by reviewing the documents and dis- cussing the arrangements with management. Board of directors compensation committee minutes often contain useful information about the intent of such arrangements.

General Business Sources Most industries have specialized trade magazines and journals. You may not choose to read Grocer’s Spotlight for pleasure, but magazines of this special type are very valu- able for learning and maintaining an industry expertise. In addition, specific informa- tion about public companies can be found in registration statements and 10-K reports filed with the SEC. General business magazines and newspapers often contribute insights about an industry, an entity, and individual corporate officers. Many are available, including such leaders as Bloomberg Businessweek, Forbes, Fortune, Harvard Business Review, Barron’s, and The Wall Street Journal. Auditors typically read several of these regularly. Additionally, many companies present “company story” information on their websites. A visit to company websites can provide a wealth of information about products, markets, and strategies. For public companies, auditors should also monitor the client’s daily stock price for any unusual trading activity that might indicate new information that affects the company’s business risk.

LO 4-4 Understand the different sources of information and the audit procedures used by auditors when assessing risks, including analytical procedures, brainstorming, and inquiries.

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138 Part Two The Financial Statement Audit

Company Sources Other early information-gathering activities include (1) reviewing the corporate char- ter and bylaws or partnership agreement; (2) reviewing contracts, agreements, and legal proceedings; and (3) reading the minutes of the meetings of directors and committees of the board of directors. The minutes provide a history of the company, critical events and significant transactions, and future company intentions. A company’s failure to provide minutes is a significant scope limitation that could result in the public accounting firm’s disclaiming an opinion on the company’s financial statements.

Information from Client Acceptance or Continuance Evaluation, Audit Planning, Past Audits, and Other Engagements A great deal of information about the client is gathered in the pre-engagement planning process discussed in Chapter 3. Auditors evaluate the competence and integrity of man- agement and the riskiness of the business before taking or continuing a client. As noted, the best indicator of the risk of a material misstatement is the presence of misstatements in previous audits that required adjusting entries. For example, for nonpublic clients, pub- lic accounting firms often develop client income tax provisions once the audit is com- plete; thus, the income tax adjusting entry would show up as an adjustment every year. Finally, auditors who have industry expertise often have more than one client in that industry, so they can transfer general knowledge of risks encountered in other clients while maintaining confidentiality standards required by the profession.

Boards of directors are responsible for monitoring their companies’ busi- nesses. The minutes of their meetings and the meetings of their com- mittees (e.g., executive committee, finance committee, compensation committee, and audit committee) frequently contain information of vital interest to the independent auditors. Some information examples follow:

• Amount of dividends declared. • Elections of officers and authorization of officers’ salaries. • Authorization of stock options and other incentive compensation

arrangements. • Acceptance of contracts, agreements, and lawsuit settlements. • Approval of major purchases of property and investments. • Discussions of possible mergers and divestitures.

• Authorization of financing by stock issuance, long-term debt issuance, and leases.

• Approval to pledge assets as security for debts. • Discussion of negotiations on bank loans and payment waivers. • Approval of accounting policies and accounting for significant and

unusual transactions. • Authorizations of individuals to sign bank checks.

Auditors take notes or make copies of important parts of these minutes and compare them to information in the accounts and disclosures (e.g., compare the amount of dividends declared to the amount paid, compare officers’ authorized salaries to amounts paid, compare agreements to pledge assets to proper disclosure in the notes to financial statements).

What’s in the Minutes of Meetings?

Preliminary Analytical Procedures Auditors are required to complete preliminary analytical procedures on each engage- ment. When completing analytical procedures, auditors are required to develop an expec- tation about what an account balance should be and then compare that expectation to the recorded balance. When doing so, auditors typically use the prior-year balances as the starting point for their expectation for each account balance. At this stage, analytical procedures are reasonableness tests; auditors compare their expectation for each of the account balances with those recorded by management. According to auditing standards, analytical procedures must be applied in the preliminary stages of each audit. During this critical point of the engagement, auditors use analytical procedures to identify poten- tial problem areas so that subsequent audit work can be designed to reduce the risk of missing something important. Analytical procedures during the preliminary stages also

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provide an organized approach—a standard starting place—for becoming familiar with the client’s business and identifying areas of risk. Auditors need to remember that pre- liminary analytical procedures are based on unaudited data, so they should consider the effectiveness of controls over their reliability when deciding how much weight to place on the results.

Auditors should perform five steps when completing analytical procedures: 1. Develop an expectation. A variety of sources can provide evidence for auditors’

expectations of the balance in a particular account: ∙ Balances for one or more comparable periods (e.g., vertical and horizontal analyses). ∙ Anticipated results found in the company’s budgets and forecasts. ∙ Leveraging predictable patterns among account balances based on the company’s

experience. ∙ Relevant information from third-party sources for the industry in which the com-

pany operates. ∙ Relevant nonfinancial information (e.g., physical production statistics, sales orders).

2. Define a significant difference. Basically, the question is, “What percentage (or dollar) difference from your expectation can still be considered reasonable?” It is important that this decision be made before making the comparison to prevent auditors from rationalizing differences and failing to follow up.

3. Compare expectation with the recorded amount. Many auditors start with comparative financial statements and calculate year-to-year changes in balance-sheet and income- statement accounts (horizontal analysis). They next calculate common-size statements (vertical analysis) in which financial statement amounts are expressed as percentages of a base, such as sales for the income-statement accounts or total assets for the balance-sheet accounts. These initial calculations (see Exhibit 4.9) provide a basis for describing the financial activities for the current year under audit. Although vertical and horizontal analyses are fairly basic, other analytical procedures—including math- ematical time series and regression calculations, comparisons of multiyear data, and trend analyses—can be more complex.

4. Investigate significant differences. Auditors typically look for relationships that do not make sense as indicators of problems in the accounts, and they use such indicators to plan additional audit work. In the planning stage, analytical procedures are used to identify potential problem areas so that subsequent audit work can be designed to reduce the risk of missing something important. The application demonstrated here can be described as attention directing: pointing out accounts that could contain errors and frauds. The insights derived from preliminary analytical procedures do not provide direct evidence about the numbers in the financial statements. Although the insights derived from preliminary analytical procedures provide only limited evidence about the numbers in the financial statements, they do help auditors identify risks as an aid in preparing the audit plan.

5. Document each of the preceding steps. For companies that have not undergone any significant changes in operations, current-year recorded amounts should be fairly similar to those of the prior year (step 1). Because changes are not expected, auditors can identify any changes that are more than 10 percent and $100,000 as deserving additional attention (step 2). Note that the threshold is both 10 percent and $100,000 instead of just one trigger or the other. A change in an account balance from $100 to $200 is a 100 percent change, but the change is clearly immaterial. Similarly, an increase in sales from $9.9 million to $10 million meets the $100,000 threshold but does not appear unreasonable in percentage terms. In step 3, auditors compare expec- tations with the recorded balances. Exhibit 4.9 contains financial balances for the prior year (consider them audited) and the current year (consider them unaudited at this stage). Common-size statements (vertical analysis) are shown in parallel columns, and the dollar amount and percentage change (horizontal analysis) are shown in the last two columns.

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140 Part Two The Financial Statement Audit

EXHIBIT 4.9 Dunder-Mifflin Inc.—Preliminary Analytical Procedures Data

  Prior Year Current Year Change

  Balance Common Size Balance Common Size Amount Percent Change

Income            

Sales (net) $ 9,000,000 100.00% $ 9,900,000 100.00% $ 900,000 10.00% Cost of goods sold 6,750,000 75.00 7,200,000 72.73 450,000 6.67 Gross margin 2,250,000 25.00 2,700,000 27.27 450,000 20.00 General expense 1,590,000 17.67 1,734,000 17.52 144,000 9.06 Depreciation 300,000 3.33 300,000 3.03 0 0.00 Operating income 360,000 4.00 666,000 6.46 306,000 85.00 Interest expense 60,000 0.67 40,000 0.40 (20,000) –33.33 Income taxes (40%) 120,000 1.33 256,000 2.59 136,000 113.33 Net income $ 180,000 2.00% $ 370,000 3.74% $ 190,000 105.56% Assets

Cash $ 600,000 14.78% $ 200,000 4.12% ($400,000) –66.67% Accounts receivable 500,000 12.32 900,000 18.56 400,000 80.00 Allowance for doubtful accounts (40,000) –0.99 (50,000) –1.03 (10,000) 25.00 Inventory 1,500,000 36.95 1,600,000 32.99 100,000 6.67  Total current assets 2,560,000 63.05 2,650,000 54.63 90,000 3.52 Equipment 3,000,000 73.89 4,000,000 82.47 1,000,000 33.33 Accumulated depreciation (1,500,000) –36.95 (1,800,000) –37.11 (300,000) 20.00 Total assets $ 4,060,000 100.00% $ 4,850,000 100.00% $ 790,000 19.46% Liabilities and Equity

Accounts payable $ 500,000 12.32% $ 400,000 8.25% ($100,000) –20.00% Bank loans, 11% 0 0.00 750,000 15.46 750,000 Accrued interest 60,000 1.48 40,000 0.82 (20,000) –33.33  Total current liabilities 560,000 13.79 1,190,000 24.53 630,000 112.50 Long-term debt, 10% 600,000 14.78 400,000 8.25 (200,000) –33.33  Total liabilities 1,160,000 28.57 1,590,000 32.78 430,000 37.07 Capital stock 2,000,000 49.26 2,000,000 41.24 0 0.00 Retained earnings 900,000 22.17 1,260,000 25.98 360,000 40.00 Total liabilities and equity $ 4,060,000 100.00% $ 4,850,000 100.00% $ 790,000 19.46%

The investigation of significant differences (step 4) is probably the most critical step in the analytical procedures process. After generating basic financial data and relationships, the next step is to determine whether the financial changes and relationships actually describe what is going on within the company. According to the current-year unaudited financial statements in Exhibit 4.9, the company increased net income by increasing sales 10 percent, reducing cost of goods sold as a proportion of sales, and controlling other expenses. At least some of the sales growth appears to have been prompted by easier access to credit (accounts receivable increased by 80 percent) and more service (more equipment in use). The company also appears to have used most of its cash and borrowed more to purchase equipment, make payments on long-term debt, and pay dividends. Inventory and cost of goods sold, on the other hand, remained fairly consistent compared to the previous year, with both accounts increasing by only 6.7 percent.

The next step is to ask, “What could be wrong?” and “What errors and frauds, as well as legitimate explanations, could account for these financial results?” As an example of how analytical procedures are used, we limit our attention to the Accounts Receivable and Inventory accounts. At this point, some other ratios can help support the analysis. Exhibit 4.10 contains several familiar ratios. (Appendix 4A at the end of this chapter contains these ratios and their formulas.)

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∙ Question: Are the accounts receivable collectible? (Alternative: Is the allowance for doubtful accounts large enough?) Easier credit can lead to more bad debts. The company has a much larger amount of receivables, the days’ sales in receivables has increased significantly, the receivables turnover has decreased, and the allowance for doubtful accounts is smaller in proportion to the receivables. If the prior-year allow- ance for bad debts at 8 percent of receivables was appropriate and conditions have not become worse, it could be that the allowance should be closer to $72,000 than $50,000. The auditors should work carefully on the evidence related to accounts receivable valuation.

∙ Question: Could the inventory be overstated? (Alternative: Could the cost of the goods sold be understated?) Overstatement of the ending inventory would cause the cost of goods sold to be understated. The percentage of cost of goods sold to sales shows a decrease. If 75 percent of the prior year represents a more accurate cost of goods sold amount, then the income before taxes could be overstated by $225,000 (75 percent of $9.9 million minus $7.2 million unaudited cost of goods sold). The days’ sales in inventory and the inventory turnover remained the same, but you could expect them to change in light of the larger volume of sales. Careful work on the physical count and valuation of inventory appears to be needed.

Other questions can be asked and other relationships derived when industry statistics are available. Industry statistics can be obtained from such services as Yahoo! Finance, Google Finance, Dun & Bradstreet, and Standard & Poor’s. These statistics include industry averages for important financial benchmarks such as gross profit margin, return on sales, current ratio, debt/net worth, and various others. A comparison with client data can reveal out-of-line statistics, indicating a relatively strong feature of the company, a weak financial position, or possibly an error or misstatement in the client’s financial statements. However, care must be taken with industry statistics. A particular company could or could not be well represented by industry averages.

Comparing reported financial results with internal budgets and forecasts also can be useful. If the budget or forecast represents management’s estimate of probable future outcomes, planning questions can arise for items that fall short of or exceed the budget. If a company that expected to sell 10,000 units of a product sold only 5,000 units, the

  Prior Year Current Year Percent Change

Balance-Sheet Ratios

Current ratio 4.57 2.23 —51.29% Days’ sales in receivables 18.40 30.91 67.98 Doubtful accounts ratio 0.0800 0.0556 —30.56 Days’ sales in inventory 80.00 80.00 0.00 Debt/equity ratio 0.40 0.49 21.93

Operations Ratios

Receivables turnover 19.57 11.65 —40.47 Inventory turnover 4.50 4.50 0.00 Cost of goods sold/Sales 75.00% 72.73% —3.03 Gross margin percentage 25.00% 27.27% 9.09 Return on beginning equity 6.62% 12.76% 92.80

Financial Distress Ratios (Altman)

Working capital/Total assets 0.49 0.30 —38.89 Retained earnings/Total assets 0.22 0.26 17.20 EBIT/Total assets 0.09 0.14 54.87 Market value of equity/Total debt 2.59 1.89 —27.04 Net sales/Total assets 2.22 2.04 —7.92 Discriminant Z-score 4.96 4.35 —12.32

EXHIBIT 4.10 Dunder-Mifflin Inc.— Selected Financial Ratios

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auditors would want to plan a careful analysis of the inventory of unsold units for obso- lescence (valuation). If 15,000 were sold, an auditor would want to audit for sales validity (occurrence). Budget comparisons can be tricky, however. Some companies use budgets and forecasts as goals rather than as expressions of probable outcomes. Also, meeting the budget with little or no shortfall or excess can result from managers’ manipulating the numbers to “meet the budget.” Auditors must be careful to know something about an entity’s business conditions from sources other than the internal records when analyzing comparisons with budgets and forecasts to determine inherent risk.

Cash flow analysis enables the auditors to see the crucial information of cash flow from operating, investing, and financing activities. A cash flow deficit from operations can signal financial difficulty. Companies fail when they run out of cash (no surprise) and are unable to pay their debts when they become due. Professional auditing standards state that audi- tors are responsible for letting financial statement users know whether they have substantial doubts as to whether the client will be able to survive into subsequent periods (i.e., whether the company can remain a going concern), and cash flow analysis is a good starting place.

• Auditors noticed large quantities of rolled steel in the company’s inventory. Several 60,000-pound rolls were entered in the inventory list. The false entries were detected because the auditor knew the company’s forklift trucks had a 20,000-pound lifting capacity.

• Auditors could have compared the total quantity of vegetable oils the company claimed to have inventoried in its tanks to the stor- age capacity reported in national export statistics. The company’s “quantity on hand” amounted to 90 percent of the national supply and greatly exceeded its own tank capacity.

• A comparison of the current year’s balance in accrued wages pay- able to the prior year’s balance revealed a dramatic decrease in the current year. Based on the analytical procedure, it was learned that the company failed to accrue for a significant percentage of its wages payable at the end of the current year.

• Auditors developed a complex regression model to estimate the electric utility company’s total revenue. They used empirical rela- tions of fuel consumption, meteorological reports of weather condi- tions, and population census data in the area. The regression model estimated revenue within close range of the reported revenue.

• Auditors for a small regional airline calculated an estimate of air- line revenue by multiplying the number of company planes times an estimate of the number of flights made by each plane in a year times the number of seats on each plane times an estimate of the average ticket price. The revenue reported by the airline was sig- nificantly higher than the auditors’ estimate, meaning that either more than one person was sitting in the same seat at the same time or that the auditors needed to more closely examine recorded revenue transactions. Additional investigation discovered that the airline was in fact fraudulently overstating its revenues.

Some Examples of Analytical Procedures AUDITING INSIGHT

As previously stated, professional standards require auditors to perform analytical pro- cedures during the planning stages of the audit “with the objective of identifying unusual or unexpected relationships” involving significant financial accounts “that might indicate a material misstatement, including material misstatement due to fraud.” When doing so, the auditor should consider all types of relevant data to help improve their understand- ing of risk on the audit. Importantly, professional standards allow the use of “data that is preliminary or data that is aggregated at a high level” when completing analytical proce- dures at the planning stages. As a result, the increased use of big data and analytical tools has the potential to improve the effectiveness of this type of risk assessment procedure.7

Indeed, auditors now have the opportunity to use new types of analyses that utilize third-party data to supplement their “traditional” analytical procedures. The additional data can help auditors refine their expectations and improve the results of preliminary analytical procedures, which form initial beliefs about the nature, timing, and extent of audit evidence to be gathered from an audit client. While this type of access to increased volumes of data on the client has the potential to improve audit effectiveness, it also can have an initial negative impact on audit efficiency if audit professionals are unable to efficiently execute such additional procedures. 7See PCAOB Auditing Standard No. 2110, Identifying and Assessing Risks of Material Misstatement, paragraphs 46–48.

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While the availability of even more third-party data offers considerable promise for auditors when completing preliminary analytical procedures, audit professionals in today’s environment also need to learn how to make the best use of internal client data when completing such procedures. For example, when completing preliminary analyti- cal procedures, the availability of largely all of the client’s internal data can allow for a more robust trend analysis (i.e., year over year) on a multitude of financial and nonfinan- cial data. Auditors are encouraged to consider the facts and circumstances of each audit engagement and utilize computer-assisted audited techniques to facilitate the most useful trend analyses for the financial statement audit. The following box provides guidance on how IDEA can be used to improve the efficiency of analytical procedures.

The IDEA software package can be helpful when summarizing inter- nal client data for purposes of analytical procedures used during the planning process. For example, in the IDEA Analysis Workbook, it is stated that “IDEA can help with the preparation of figures for an ana- lytical review. In particular, IDEA can generate analyses that would not otherwise be available. The Stratification task (from the Analysis tab on the IDEA Ribbon) generates a profile of the population in value bands, groups of codes, or dates. This is particularly useful when auditing assets such as accounts receivable, inventories, or loans

or for a breakdown of transactions. Additionally, the information can be summarized by particular codes or subcodes. Figures can also be compared against previous years to determine trends. A chart can be produced if required.”

At the end of this chapter, problems 4.66, 4.67 and 4.68 can be completed to illustrate the use of IDEA during preliminary analytical procedures. To be most useful, each of these analyses would have to be completed for multiple years so comparisons could be made and meaningful expectations could be developed.

Analytical ProceduresUSING IDEA IN THE AUDIT

Before moving forward, here are a few more thoughts about analytical procedures. Pro- fessional standards mandate that analytical procedures are performed at the beginning of an audit—the preliminary stage application of analytical procedures discussed in this chapter and at the end of an audit when the partners in charge review the overall quality of the work and look for apparent problems. Analytical procedures can also be used as a substantive testing procedure to gather evidence about the relevant assertion being tested. When using substantive analytical procedures, the auditor must take great care to develop an indepen- dent expectation that is based on reliable information. When this has been developed, the expectation is compared to the recorded amount, and any significant differences must be investigated and corroborated with documentary evidence. The procedure to provide evi- dence about an assertion must be conducted with exacting precision and a high degree of rigor. Regardless of when analytical procedures are performed, auditors conclude their analytical procedures test work by documenting the team’s findings (step 5).

Interviews with 36 practicing auditors found that the corporate scandals that occurred in the late 1990s/early 2000s and the ensuing Sarbanes– Oxley Act, along with the advent of improved technology, have led to the following changes in how firms perform analytical procedures:

• Increased use of analytical procedures. • Development of more precise, quantitative expectations. • Gathering broader industry and company information, including

nonfinancial information.

• Reliance on analytical procedures more to decrease substantive tests of detail.

• Less experienced staff to conduct (but not to design) a larger por- tion of analytical procedures.

• Increased consideration of underlying controls. Source: G. Trompeter and A. Wright, “The World Has Changed—Have Ana- lytical Procedure Practices?” Contemporary Accounting Research 27, no. 2 (2010), pp. 669–700.

Analytical Procedures in Practice AUDITING INSIGHT

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Audit Team Brainstorming Discussions On every audit engagement, the risk assessment process includes required audit team brainstorming sessions in which critical audit areas are discussed. These sessions update audit team members on important aspects of the audit and heighten team members’ awareness of the potential for fraud and errors in the engagement. Items typically discussed include previous experiences with the client, how a fraud might be perpetrated and concealed by the client, and procedures that might detect fraud. When studying a business operation, auditors’ ability to think like a criminal and devise ways to steal can help in creating procedures to determine whether fraud has happened. Often, imaginative extended procedures can be employed to unearth evidence of fraudulent activity.

A secondary objective of the discussions is to set a proper tone for the engagement. These sessions address not only fraud risk, but also other client business and audit-related risk assess- ments. While these brainstorming sessions typically begin during the planning stage of engage- ments, they should be held on a continual basis through the conclusion of the engagement.

Many firms have fraud specialists that assist audit teams throughout the risk assess- ment process. If an auditor’s specialists are assigned to the audit, his/her involvement during brainstorming sessions is particularly important because, as a result of his/her experience, he/she is particularly adept at identifying critical audit areas and how these areas influence the risk of misstatement due to fraud.

• An engagement partner or an auditor’s forensic specialist is the best choice to lead the brainstorming session, but the use of group decision software (which protects individuals’ identities) allows each engagement team member to participate freely with- out fear of intimidation or repercussion. Managers and partners should be active participants.

• Audit team members should be reminded of the purpose of the brainstorming session and stress the importance of professional skepticism.

• A good strategy is to discuss material misstatements found in pre- vious audits and/or frauds found on similar engagements.

• When checklists are used, fully discuss each item on the list and don’t limit discussions solely to items on the checklist. In other words, consider what might have been left off the checklist.

• The idea-generation phase should be separated from the idea- evaluation phase. Considering each threat as it is brought up

may cause individuals to feel slighted and may inhibit further idea generation. Engagement team members should be encouraged to discuss why they feel an identified risk is important.

• An information technology audit specialist should attend. • The session should be held during preplanning or early in the plan-

ning stage. • It should include discussion of how management might perpetrate

fraud and audit responses to fraud risk. • Time should be set aside at the end of the session to indicate how

the audit plan should be modified as a result of the discussions.

Sources: M. Landis, S. Jerris, and M. Braswell, “Better Brainstorming,” Journal of Accountancy, October 2008, pp. 70–73; J. F. Brazel, T. D. Carpenter, and J. G. Jenkins, “Auditors’ Use of Brainstorming in the Consideration of Fraud: Reports from the Field,” The Accounting Review 85, no. 4 (2010), pp. 1273–1301.

Some Best Practices in Brainstorming AUDITING INSIGHT

Inquiry of Audit Committee, Management, and Others within the Company Interviewing the entity’s management, internal auditors, directors, the audit committee, and other employees is a required audit process that can bring auditors up to date on changes in the business and the industry. Such inquiries of client personnel have the multiple purposes of building personal working relationships, observing the competence and integrity of client personnel, obtaining a general understanding of the client or company, and probing for problem areas that could harbor financial misstatements. Issues to discuss include selection of accounting principles; susceptibility to errors and fraud, including known or suspected fraud; and how management controls and monitors fraud risks. Other company employees to question might include operations or marketing managers or those involved in significant and unusual transactions.

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Another source of information is company discussion boards or apps where anony- mous whistleblowers can post information that management may not wish to disclose to auditors.

Blind is an app launched originally in the US in 2015 that allows employees to anonymously post about compensation, workplace harassment, company policies, and more. Employees use company email addresses to create an account with Blind, after which the employee is verified and added to a specific company board that is only visible by employees of that firm. Despite using a work email address to sign up, Blind claims on their website to have a “patented infrastructure” to guarantee the anonymity of posts. Blind has recently begun accepting public domain names such as Gmail and Yahoo, although accounts created with public domains will have limited access to only topics channels, which include HR Issues, office life, etc. Blind is not the first app of it’s kind, it follows apps such as Secret

and Whisper, although it is unique in that it is more focused on sharing “workplace” secrets.

Recently, Blind has received a lot of press for exposing sexual harassment issues and inappropriate accessing of customer data within organizations. As auditors, what kind of information could Blind tell us about management integrity at the client? Could account- ing fraud be the next big trending topic on Blind? Auditors may want to consider thinking out of the box, and looking inside the apps, as another source of information about their clients.

Source: Sara O’Brien, “App lets workers talk about their companies anonymously,” CNN Business, February 12, 2018, https://money.cnn. com/2018/02/12/technology/blind-app/index.html

What do Apps Like “Blind” Mean for Auditors?AUDITING INSIGHT

OVERALL ASSESSMENT AND DOCUMENTATION OF INHERENT RISK ASSESSMENT

The overall goal of the risk assessment process that has been described in this chapter is to identify and then properly assess the risks of material misstatement that exist at an audit client. Once the risk assessment process is complete, auditors have a basis to plan and then implement an appropriate testing response for each of the assessed risks. This process must be completed in a very detailed manner for each relevant assertion related to each significant financial statement account and disclosure. In a sense, auditors need to think about how all of the risks identified at the company and the financial statement level could affect risks of material misstatement at the relevant assertion level. If you recall from our discussion of the audit risk model, the overall risk of material misstatement includes both inherent risk and control risk. We will discuss the assessment of control risk and the effect of tests of control in Chapter 5. For now, we will focus on the assessment of inherent risk, which needs to be evaluated without regard to the system of internal controls.

The assessment of inherent risk needs to occur for each significant financial statement account and disclosure. An account or disclosure is significant if there is a chance that it could contain a material misstatement. When making this determination, the auditor should evaluate both the quantitative and the qualitative risk factors associated with the financial statement account or disclosure. When doing so, clearly the overall materiality level is a critically important factor. However, it is possible that an account or disclo- sure could be significant even though its balance is below materiality. For example, an account balance may be understated or a disclosure could be omitted, among a host of other factors. Once each of the significant accounts and disclosures have been identified, the auditor then needs to identify the relevant financial statement assertions.

Relevant Assertions According to the professional standards (AS 2201.28), a financial statement assertion is relevant if it has a “reasonable possibility of containing a misstatement that would cause the financial statements to be materially misstated.”* Therefore, based on all of the

LO 4-5 Explain how auditors complete and document the overall assessment of inherent risk.

Public Company Accounting Oversight Board. “AS 2201: An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements.” Accessed June 24, 2019. https://pcaobus.org/Standards/Auditing/Pages/AS2201.aspx.

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146 Part Two The Financial Statement Audit

risk assessment procedures performed, auditors must identify those assertions that have a meaningful bearing on whether the account is fairly stated. For example, the valuation assertion would only be relevant to the cash account if the audit client had cash accounts that were denominated in a foreign currency. However, due to the nature of cash, it is likely that the existence assertion would always be relevant.

Once each relevant assertion is identified for each significant account and disclosure, the auditor must then identify the likely sources of misstatements that could cause the financial statements to be materially misstated. It is important that this step is completed at a detailed and almost granular level. To do so, the professional standards suggest that an auditor should consider “what could go wrong” when thinking about each of the relevant financial statement assertions. The comprehensive identification of “what could go wrong” for each relevant financial statement assertion is the foundation for the risk assessment pro- cess and ultimately the audit plan. Exhibit 4.11 provides a summary of this process.

Once the likely sources of misstatements that could cause the financial statements to be materially misstated have been identified, the auditors’ next task is to assess the types of risk present, the likelihood that material misstatement has occurred, the magnitude of the risk, and the pervasiveness of the potential for misstatement. This lays the groundwork for the identification of internal controls that the client should have in place to mitigate the various risks of material misstatement, which will be explored in detail in Chapter 5.

Document Risk Assessment Auditors must carefully document the risk assessment process in the workpapers to pro- vide a record of the procedures performed. Items that must be documented include the following:

∙ Discussions with engagement personnel. ∙ Procedures to identify and assess risk. ∙ Significant decisions during discussion. ∙ Specific risks identified and audit team responses. ∙ Explanation of why improper revenue recognition is not a risk, if so deemed. ∙ Results of audit procedures, particularly procedures regarding management override. ∙ Other conditions causing auditors to believe that additional procedures are required. ∙ Communications to management and those charged with governance, such as the audit

committee.

Fraud and Other Significant Risks In addition to the risk assessment based on factors previously identified, auditing standards require several other fraud risk assessments to be made. First, auditors must presume that improper revenue recognition is a fraud risk. Another risk is that, despite the existence of controls, management might override the controls through force of authority. Because sev- eral major frauds were committed through year-end adjusting entries (such as WorldCom’s capitalization of telephone line expenses), auditors must examine journal entries and other

EXHIBIT 4.11 What Could Go Wrong?

Significant Accounts Relevant Assertions What Could Go Wrong?

Existence The cash balance may not exist in the company’s bank accounts.

 Cash Valuation The cash balance that is held in foreign countries may not have been translated properly.

  Presentation and disclosure There may be restrictions on the cash balance that were not properly disclosed.

Accounts Receivable  

Existence Accounts receivable balances are inflated and don’t really exist.

Completeness Not all accounts receivable have been recorded.

Valuation Receivables are not included in financial statements at the appropriate amount, and valuation adjustments are not recorded properly.

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adjustments (especially those made close to year-end). If any significant and unusual account- ing entries are identified, auditors must evaluate the business rationale behind the significant transactions. Team members gather information necessary to identify key fraud risk factors (red flags) indicating an increased potential for fraud to occur.

In addition, while completing risk assessment procedures, auditors may determine that an identified risk represents a significant risk. Significant risks are those risks that require special audit consideration because of the nature of the risk or the likelihood and potential magnitude of misstatement related to the risk. By definition, fraud risks are significant risks. Auditors should specifically examine controls and design tests to address significant risks. Auditors should evaluate quantitative and qualitative risk fac- tors based on the likelihood and potential magnitude of misstatements. They should consider whether the risk is related to recent significant economic, accounting, or other developments; the complexity of transactions; whether the risk involves related parties; the degree of complexity or judgment required and uncertainty involved; and whether the risk involves significant transactions that are unusual or outside the company’s normal course of business.

Auditors must next respond to the results of the risk assessments. Using the audit risk model, the auditor adjusts detection risk for significant accounts and relevant disclosures. Additional considerations must be made for risks identified as significant risks. For example, if the potential for fraud is high, auditors should include more experienced team members. Other responses include examining more transactions, performing extended procedures, including targeting tests toward higher risk areas, performing more tests of transactions at year-end rather than at interim points, and gathering higher quality evidence. Finally, the auditors should use less predictable audit procedures such as “ surprise” inventory observations in which management is not told at which company warehouse locations auditors will show up to watch the client counting inventory or extended procedures such as using larger sample sizes.

Finally, when collecting evidence to support the financial statements throughout the audit, auditors must remain vigilant against the potential for fraud. Discrepancies in the accounting records, conflicting evidence, and missing documentation are all symptom- atic of financial statement fraud. When such instances are identified, auditors must follow up with management to identify the source of the problems. Management’s response is a key source of evidence; vague, implausible, or inconsistent responses to inquiries can be a key indicator of the pervasiveness of the fraud. Similarly, problematic or unusual reac- tions such as refusal to cooperate, hostility, or management delays in responding to the auditors are often present in financial statement frauds. The evaluation for potential fraud continues throughout the audit. Audit team members must be on the lookout for unusual findings or events and, upon discovery, not simply write them off as isolated occurrences.

Communication of Fraud Risks Auditors must always exercise significant care because accusations of fraud are taken very seriously by audit clients. For this reason, if preliminary findings indicate fraud pos- sibilities, auditors should enlist the cooperation of management and assist fraud examina- tion professionals when bringing an investigation to a conclusion.

Standards for external auditors contain materiality thresholds related to auditors reporting their knowledge of frauds. Auditors may consider some minor frauds clearly inconsequential, especially when they involve misappropriations of assets by employees at low organizational levels. Auditors should report these to management at least one level above the people involved. The idea is that small matters can be kept in the manage- ment family. Having said this, fraud has often been compared to an iceberg: most of it can be hidden from sight. For this reason, auditors should be extremely cautious in deciding whether a fraud is “clearly inconsequential.”

On the other hand, frauds involving senior managers or employees with significant internal control roles are never inconsequential and should be reported (along with any frauds that cause material misstatement in the financial statements) directly to those charged with governance, usually the entity’s audit committee of its board of directors.

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All companies with securities traded on the exchanges (e.g., New York, American, and NASDAQ) are required to have audit committees. Audit committees are composed of independent, outside members of the board of directors (those not involved in the company’s day-to-day operations) who can provide a buffer between the audit firm and management. Auditing standards set forth requirements intended to ensure that audit committees are informed about the scope and results of the independent audit.8 External auditors are required to make oral or written communications about other topics, including the discovery of fraud.

Auditors are normally required to keep client information confidential. However, under AICPA auditing standards, limited disclosures to outside agencies of frauds and clients’ noncompliance are permitted. If the audit firm resigns or is fired, the firm can cite these matters in the letter attached to SEC Form 8-K, which requires explanation of an organization’s change of auditors. The predecessor auditor may tell the succes- sor auditor about the client when the successor makes the inquiries required by auditing standards. Auditors must respond when answering a subpoena issued by a court or other agency with authority. When performing work under generally accepted government auditing standards (mandated by the Government Accountability Office), auditors are required to report frauds and noncompliance to the client agency under the audit contract.

8Audit standards have broadened communications to include groups that serve in a similar role for private companies and refers to such groups as “those charged with governance.” Audit committees serve in this role for public companies.

REVIEW CHECKPOINTS 4.13 What are some types of knowledge and understanding about a client’s business and industry that

an auditor is expected to obtain? What are some of the methods and sources of information for understanding a client’s business and industry?

4.14 What is the purpose of performing preliminary analytical procedures in audit planning? 4.15 What are the five steps involved with the use of preliminary analytical procedures? 4.16 What are some of the ratios that can be used in preliminary analytical procedures? 4.17 When are analytical procedures required, and when are they optional?

AUDITORS’ RESPONSIBILITIES FOR NONCOMPLIANCE WITH LAWS AND REGULATIONS

In addition to errors and fraud, a client’s noncompliance with laws and regulations can cause financial statements to be materially misstated, and external auditors are advised to be aware of circumstances that could indicate noncompliance (Exhibit 4.12). Auditors are not required to be legal experts, but they must understand the legal and regulatory framework under which their client operates and how the entity is compliant with that framework. Auditing standards deal with two types of noncompliance: (1) direct-effect noncompliance, which produces direct and material effects on financial state- ment amounts (e.g., violations of pension laws or government contract regulations for revenue and expense recognition) that require the same assurance as errors and frauds (i.e., auditors must plan their work to provide reasonable assurance there are no material misstatements), and (2) indirect-effect noncompliance, which refers to violations of laws and regulations that are not directly connected to financial statements (e.g., occupational health and safety, food and drug administration regulations, environmental protection, and equal employment opportunity).

For direct-effect noncompliance, an auditor should consider the laws and regulations that are typically known by auditors to have a direct and potentially material effect on the financial statements. A classic example would be the corporate income tax code. Under

LO 4-6 Explain auditors’ responsibilities with respect to a client’s failure to comply with laws or regulations.

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tax law, the auditor knows that corporate taxes will impact both the accrued tax payable account and the income tax expense account in the financial statements. Another exam- ple might involve regulations that dictate the amount of revenue to be recorded by a client for a government contract. As you consider these examples and their direct effect on the financial statements, it is not surprising that (AS 2405.05) an “auditors responsibility to detect and report misstatements resulting from illegal acts having a direct and material effect on the determination of financial statement amounts is the same as that for mis- statements caused by error or fraud.”*

The responsibility for detecting indirect-effect noncompliance is not the same as the responsibility to detect a material misstatement resulting from fraud, as an auditor cannot possibly be expected to know all the relevant laws and regulations that affect their clients. As a result, the professional standards (AS 2405.06) recognize that for indirect-effect non- compliance “an auditor ordinarily does not have sufficient basis for recognizing possible violations of such laws and regulations.”* For example, consider an audit client who has violated environmental regulations. Ultimately, such a violation may result in a contingent liability being recorded in the financial statements. However, the auditor may not become aware of the violation until an investigation occurs or the resultant fine is reported to the auditor by the client. Thus, auditor responsibility for detecting indirect-effect noncompli- ance is limited as follows. If the auditor becomes aware of the possibility that an illegal act occurred that might have a material effect on the financial statements, the auditor should perform procedures that are directly focused on whether such an illegal act occurred. Oth- erwise, because the auditor cannot be considered an expert in all laws and regulations, an auditor is not required to provide assurance about indirect-effect noncompliance.

Of course, auditors must always respond to any type of noncompliance or suspected noncompliance that is identified during the audit. To do so, they must gain an understand- ing of the nature and circumstances of the noncompliance and then evaluate the possible effect on financial statements. The noncompliance should be discussed with manage- ment at a level above the person responsible for the noncompliance. If noncompliance is “clearly inconsequential,” that may be the extent of the follow-up. Noncompliance or suspected noncompliance having financial statement effects of more than this threshold should be reported to those charged with governance such as the audit committee, and the financial statements should contain adequate disclosures about the organization’s non- compliance. Discussion with the client’s legal counsel may also be necessary. External auditors always have the option to withdraw from an engagement if management and directors do not take satisfactory action under the circumstances.

Public Company Accounting Oversight Board. “AS 2405: Illegal Acts by Clients.” Accessed June 24, 2019. https://pcaobus.org/ Standards/Auditing/Pages/AS2405.aspx. Public Company Accounting Oversight Board. “AS 2405: Illegal Acts by Clients.” Accessed June 24, 2019. https://pcaobus.org/ Standards/Auditing/Pages/AS2405.aspx.

The following can be indicators of a company’s noncompliance: • Investigations, fines, or penalties • Payments for unspecified services or loans to consultants, related parties, employees, or government

employees • Excessive sales commissions or agent’s fees • Purchases significantly above or below market • Unusual payments in cash, cashiers’ checks to bearer, or transfers to numbered accounts • Unusual transactions with companies in tax havens • Payments to countries other than origination • Inadequate audit trail • Unauthorized or improperly recorded transactions • Media comment • Noncompliance cited in reports of examinations • Failure to file tax returns or pay government duties or fees

EXHIBIT 4.12 Indicators of Noncompliance

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The Private Securities Litigation Reform Act of 1995 imposed another reporting obli- gation. Under this law, when auditors believe an illegal act that is more than “clearly inconsequential” has or may have occurred, the auditors must inform the organization’s board of directors. When the auditors believe the illegal act has a material effect on the financial statements, the board of directors has one business day to inform the U.S. Secu- rities and Exchange Commission (SEC). If the board decides not to inform the SEC, the auditors must (1) within one business day give the SEC the same report they gave the board of directors or (2) resign from the engagement and, within one business day, give the SEC the report. If the auditors do not fulfill this legal obligation, the SEC can impose a civil penalty (e.g., monetary fine) on them.

In April 2018, Panasonic agreed to pay the Department of Justice $137 million and another $143 million to the SEC for a total penalty of $280 million related to violations of the Foreign Corrupt Practices Act (FCPA). Panasonic Avionics Corp. (PAC), the in-flight entertainment unit of Panasonic, hired a “consultant” who was in reality a foreign official that worked at an airline in the middle east, paying the official over $875,000 over 6 years for little or no work to show for it. The official, however, did have some influence over the choice of the in- flight entertainment provider at the airline. As a result, PAC earned more than $92 million in profits from portions of a contract with the airline. In another “in-flight” mishap, PAC paid a consultant who was employed with an unnamed US airline for “inside” or other “sensitive” information about one of their competitors.

The turbulence didn’t stop there for PAC. On record, PAC appro- priately terminated sales agents in their Asia region for not meeting

company compliance requirements. However, PAC continued to use the employees secretly by re-hiring them as subagents of another company. This allowed PAC to hide more than $7 million in payments to at least 13 subagents. The mischaracterization of payments made to consultants and sales agents caused the parent company of Panasonic to falsify their accounting records, in violation of the FCPA.

Source: The United States Department of Justice: Office of Public Affairs, “Panasonic Avionic Corporation Agrees to Pay $137 Million to Resolve Foreign Corrupt Practices Act Charges,” April 30, 2018, https://www.justice.gov/opa/ pr/panasonic-avionics-corporation-agrees-pay-137-million-resolve-foreign- corrupt-practices-act. Aaron Smith, “Panasonic agrees to pay US government $280 million for anti-bribery violations,” CNN Business, April 30, 2018, https:// money.cnn.com/2018/04/30/news/companies/panasonic-us-government- penalty/index.html

That’s Some Costly In-flight Entertainment AUDITING INSIGHT

REVIEW CHECKPOINT 4.18 How do the professional audit standards differ for (a) errors, (b) frauds, (c) direct-effect

noncompliance, and (d) indirect-effect noncompliance?

AUDIT STRATEGY MEMORANDUM The audit plan discussed in Chapter 3, which summarizes all of the important planning information and serves to document that auditors have followed generally accepted audit- ing standards, includes a description of the audit strategy memorandum. After assessing the overall financial statement risks, determining which accounts are significant, and which assertions are relevant to those accounts, the auditor should establish an overall audit strategy that sets the scope, timing, and direction for auditing each relevant assertion. The strategy is a result of the audit risk model. If auditors believe they can rely on company controls to mitigate risks, they test the controls as described in Chapter 5. Depending on the results of such tests, the auditors determine the nature, timing, and extent of substan- tive procedures. If the auditors identified fraud risk or other significant risks or noncom- pliance with laws and regulations, they specifically address them in the strategy, including the possibility of adding fraud specialists to the team or by expanding testing.

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by auditing standards, (2) the factors that are significant in directing the activities of the engagement team, and (3) the results of preliminary engagement activities and the auditor’s evaluation risk assessment. Also, various laws or regulations may require other matters to be communicated. The strategy should outline the nature, timing, and extent of resources necessary to perform the engagement. Planned tests of controls, substan- tive procedures, and other planned audit procedures required to be performed so that the engagement complies with auditing standards should be documented with specific direc- tions about the effect on the audit.

The audit strategy memorandum becomes the basis for preparing the audit plan that lists the audit procedures to be completed for each relevant assertion related to each sig- nificant account and disclosure identified on the audit engagement. Since the audit pro- cedures to be performed by the auditors are designed to gather sufficient appropriate evidence on which to base their audit opinion on the financial statements, the professional auditing standards require a written audit plan that documents the audit strategy on each engagement. An example of an audit strategy memorandum is presented in Appendix 4B.

REVIEW CHECKPOINT 4.19 What is the purpose of an audit strategy memorandum? What information should it contain?

According to AS 1101.03, “To form an appropriate basis for expressing an opinion on the financial statements, the auditor must plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement due to error or fraud. Reasonable assurance is obtained by reducing audit risk to an appro- priately low level through applying due professional care, including obtaining sufficient appropriate audit evidence.”* In order to accomplish this objective, the auditor must take the time to carefully assess audit risk on each audit engagement.

Audit risk is the risk assumed by the auditors that they could express an incorrect opinion on financial statements that are materially misstated as a result of errors or fraud. The audit risk model breaks down audit risk into three components: inherent risk, control risk, and detection risk. Inherent risk involves the susceptibility of accounts to misstate- ment (assuming that no controls are present). Control risk addresses the effectiveness (or lack thereof) of the controls in preventing or detecting misstatements. Inherent and control risk are often combined and referred to as the risk of material misstatement. Detection risk involves the effectiveness of the auditors’ procedures in detecting fraud or misstatement. Solving for detection risk in the audit risk model yields guidance for the preparation of the audit plan and the nature, timing, and extent of further audit procedures to be performed.

Risk assessment starts with knowledge of the types of errors and frauds that can be perpetrated. It involves understanding the company, its industry, and its environment. Auditors assess risk by obtaining public and internal information, holding team brain- storming discussions, performing analytical procedures, and inquiring of management, directors, and key employees. The culmination of the auditor’s risk assessment process is the identification of the risk of material misstatement for each relevant assertion for each significant account and disclosure on each audit engagement. During the engagement, auditors respond to identified risks by increasing the effectiveness of their procedures and employing specialists and experienced personnel when necessary. Audit strategies are the auditors’ summaries of their assessments and how they will respond to identified risks, particularly significant risks, which include the risk of fraud. Audit strategies are documented in the audit plan.

Public Company Accounting Oversight Board. “Auditing Standard No. 14: Evaluating Audit Results.” Accessed June 24, 2019. https://pcaobus.org/Standards/Archived/PreReorgStandards/Pages/Auditing_Standard_14.aspx.

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accounting estimates: The approximations of financial statement numbers often included in financial statements, 135 analytical procedures: Procedures that allow auditors to evaluate financial information by studying relationships among both financial and nonfinancial data. When used near the end of the audit, analytical procedures allow auditors to assess the conclusions reached during the audit and evaluate the overall financial statement presentation, 138 audit committee: A subcommittee of the board of directors that is generally composed of three to six “outside” members of the organization’s board of directors, 148 audit risk: The risk that the auditor will express an inappropriate audit opinion when the financial statements are materially misstated (e.g., giving an unmodified opinion on financial statements that are misleading because of material misstatements the auditors failed to discover), 118 audit strategy memorandum: The scope, timing, and direction for auditing each relevant assertion based on the results of the audit risk model, 150 business risks: Those factors, events, and conditions that could prevent the organization from achieving its business objectives, 136 control risk: The likelihood that the client’s internal control policies and procedures fail to prevent or detect a material misstatement, 120 defalcation: Another name for employee fraud and embezzlement, 128 detection risk: The likelihood that the auditors’ substantive procedures will fail to detect a material misstatement that exists within an account balance or class of transactions, 120 direct-effect noncompliance: The violations of laws or government regulations by the entity or its management or employees that produce direct and material effects on dollar amounts in financial statements, 148 embezzlement: A type of fraud involving employees or nonemployees wrongfully taking money or property entrusted to their care, custody, and control, often accompanied by false accounting entries and other forms of lying and cover-up, 128 employee fraud: The use of fraudulent means to take money or other property from an employer. It consists of three phases: (1) the fraudulent act, (2) the conversion of the money or property to the fraudster’s use, and (3) the cover-up, 128 errors: The unintentional misstatements or omissions of amounts or disclosures in financial statements, 128 extended procedures: The audit procedures used in response to heightened fraud awareness as the result of the identification of significant risks, 147 fraud: The misrepresentation of facts that the individual knows to be false with the intention to deceive, 126 fraudulent financial reporting: Intentional misstatements, including omissions of amounts or disclosures in financial statements intended to deceive financial statement users, 128 horizontal analysis: The comparative analysis of year-to-year changes in balance-sheet and income-statement accounts, 139 indirect-effect noncompliance: The violation of laws and regulations that does not directly affect specific financial statement accounts or disclosures (e.g., violations relating to insider securities trading, occupational health and safety, food and drug administration regulations, environmental protection, and equal employment opportunity), 148 inherent risk: The probability that in the absence of internal controls, material errors or frauds could enter the accounting system used to develop financial statements, 119 larceny: The simple theft of an employer’s property that is not entrusted to an employee’s care, custody, or control, 128 management fraud: The deliberate fraud committed by management that injures investors and creditors through materially misleading information, 128 misappropriation of assets: Asset theft from an entity. It is often perpetrated by employees in small amounts and is sometimes referred to as employee fraud, 128 related parties: Those individuals or organizations that are closely tied to the audit client, possibly through family ties or investment relationships, 134 relevant assertion: A financial statement assertion that has a reasonable possibility of containing a misstatement or misstatements that would cause the financial statements to be materially misstated, 119 risk of material misstatement (RMM): The combined inherent and control risk; in other words, the likelihood that material misstatements may have entered the accounting system and not been detected and corrected by the client’s internal control, 119

Key Terms

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significant account or disclosure: An account or disclosure that has a reasonable possibility of containing a material misstatement individually or when aggregated with others regardless of the effect of controls, 119 significant risk: A risk of material misstatement that requires special audit consideration. Fraud risk is always considered significant risk, 147 vertical analysis: The common-size analysis of financial statement amounts created by expressing amounts as proportions of a common base such as sales for the income-statement accounts or total assets for the balance-sheet accounts, 139 white-collar crime: Fraud perpetrated by people who work in offices and steal with a pencil or a computer terminal. The contrast is with violent street crime, 128

4.20 Auditing standards do not require auditors of financial statements to a. Understand the nature of errors and frauds. b. Assess the risk of occurrence of errors and frauds. c. Design audits to provide reasonable assurance of detecting errors and frauds. d. Report all errors and frauds found to police authorities.

4.21 If sales were overstated by recording a false credit sale at the end of the year, where could you find the false “dangling debit”? a. Inventory. b. Cost of goods sold. c. Bad debt expense. d. Accounts receivable.

4.22 One of the typical characteristics of management fraud is a. Falsification of documents in order to misappropriate funds from an employer. b. Victimization of investors through the use of materially misleading financial statements. c. Illegal acts committed by management to evade laws and regulations. d. Conversion of stolen inventory to cash deposited in a falsified bank account.

4.23 Which of the following circumstances would most likely cause an audit team to perform extended procedures? a. Supporting documents are produced when requested. b. The client made several large adjustments at or near year-end. c. The company has recently hired a new chief financial officer after the previous one

retired. d. The company maintains several different petty cash funds.

4.24 The likelihood that material misstatements may have entered the accounting system and not been detected and corrected by the client’s internal control is referred to as a. Inherent risk. b. Control risk. c. Detection risk. d. Risk of material misstatement.

4.25 The risk of material misstatement is composed of which audit risk components? a. Inherent risk and control risk. b. Control risk and detection risk. c. Inherent risk and detection risk. d. Inherent risk, control risk, and detection risk.

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4.26 The risk that the auditors’ own testing procedures will lead to the decision that material mis- statements do not exist in the financial statements when in fact such misstatements do exist is a. Audit risk b. Inherent risk c. Control risk d. Detection risk

4.27 The auditors assessed risk of material misstatement at 0.50 and said they wanted to achieve a 0.05 risk of failing to express a correct opinion on financial statements that were materially misstated. What detection risk do the auditors plan to use for planning the remainder of the audit work? a. 0.20 b. 0.10 c. 0.75 d. 0.00

4.28 If tests of controls induce the audit team to change the assessed level of control risk for fixed assets from 0.4 to 1.0 and audit risk (0.05) and inherent risk remain constant, the acceptable level of detection risk is most likely to a. Change from 0.1 to 0.04. b. Change from 0.2 to 0.3. c. Change from 0.25 to 0.1. d. Be unchanged.

4.29 Which of the following is a specific audit procedure that would be completed in response to a particular fraud risk in an account balance or class of transactions? a. Exercising more professional skepticism. b. Carefully avoiding conducting interviews with people in areas that are most susceptible

to fraud. c. Performing procedures such as inventory observation and cash counts on a surprise or

unannounced basis. d. Studying management’s selection and application of accounting principles more carefully.

4.30 Analytical procedures are generally used to produce evidence from a. Confirmations mailed directly to the auditors by client customers. b. Physical observation of inventories. c. Relationships among current financial balances and prior balances, forecasts, and

nonfinancial data. d. Detailed examination of external, external-internal, and internal documents.

4.31 Which of the following relationships between types of analytical procedures and sources of information are most logical?

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Type of Analytical Procedure Source of Information

a. Comparison of current account balances with prior periods Physical production statistics b. Comparison of current account balances with expected balances Company’s budgets and forecasts c.  Evaluation of current account balances with relation to

predictable historical patterns Published industry ratios

d.  Evaluation of current account balances in relation to nonfinancial information

Company’s own comparative financial statements

4.32 Analytical procedures can be used in which of the following ways? a. As a means of overall review near the end of the audit. b. As “attention-directing” methods when planning an audit at the beginning. c. As substantive audit procedures to obtain evidence during an audit. d. All of the above.

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4.33 Analytical procedures used when planning an audit should concentrate on a. Weaknesses in the company’s internal control activities. b. Predictability of account balances based on individual significant transactions. c. Management assertions in financial statements. d. Accounts and relationships that can represent specific potential problems and risks in the

financial statements. 4.34 When a company that sells its products with a positive gross profit increases its sales by

15 percent and its cost of goods sold by 7 percent, the cost of goods sold ratio will a. Increase. b. Decrease. c. Remain unchanged. d. Not be able to be determined with the information provided.

4.35 Auditors are not responsible for accounting estimates with respect to a. Making the estimates. b. Determining the reasonableness of estimates. c. Determining that estimates are presented in conformity with GAAP. d. Determining that estimates are adequately disclosed in the financial statements.

4.36 An audit strategy memorandum contains a. Specifications of auditing standards relevant to the financial statements being audited. b. Specifications of procedures the auditors believe appropriate for the financial statements

under audit. c. Documentation of the assertions under audit, the evidence obtained, and the conclusions

reached. d. Reconciliation of the account balances in the financial statements with the account bal-

ances in the client’s general ledger. 4.37 It is acceptable under generally accepted auditing standards for an audit team to

a. Assess risk of material misstatement at high and achieve an acceptably low audit risk by performing extensive substantive tests.

b. Assess control risk at zero and perform a minimum of detection work. c. Assess inherent risk at zero and perform a minimum of detection work. d. Decide that audit risk can be 40 percent.

4.38 Under the Private Securities Litigation Reform Act (the Act), independent auditors are required to first a. Report in writing all instances of noncompliance with the act to the client’s board of directors. b. Report to the SEC all instances of noncompliance with the act they believe have a mate-

rial effect on financial statements if the board of directors does not first report to the SEC. c. Report clearly inconsequential noncompliance with the act to the audit committee of the

client’s board of directors. d. Resign from the audit engagement and report the instances of noncompliance with the

act to the SEC. 4.39 When evaluating whether accounting estimates made by management are reasonable,

auditors would be most interested in which of the following? a. Key factors that are consistent with prior periods. b. Assumptions that are similar to industry guidelines. c. Measurements that are objective and not susceptible to bias. d. Evidence of a conservative systematic bias.

4.40 An audit committee is a. Composed of internal auditors. b. Composed of members of the audit team. c. Composed of members of a company’s board of directors who are not involved in the

day-to-day operations of the company. d. A committee composed of persons not associating in any way with the client or the board

of directors.

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4.41 When auditors become aware of noncompliance with a law or regulation committed by client personnel, the primary reason that the auditors should obtain a better understanding of the nature of the act is to a. Recommend remedial actions to the audit committee. b. Evaluate the effect of the noncompliance on the financial statements. c. Determine whether to contact law enforcement officials. d. Determine whether other similar acts could have occurred.

4.42 Which of the following statements best describes auditors’ responsibility for detecting a client’s noncompliance with a law or regulation? a. The responsibility for detecting noncompliance exactly parallels the responsibility for

errors and fraud. b. Auditors must design tests to detect all material noncompliance that indirectly affects the

financial statements. c. Auditors must design tests to obtain reasonable assurance that all noncompliance with

direct material financial statement effects is detected. d. Auditors must design tests to detect all noncompliance that directly affects the financial

statements.

4.43 Auditors perform analytical procedures in the planning stage of an audit for the purpose of a. Deciding the matters to cover in an engagement letter. b. Identifying unusual conditions that deserve more auditing effort. c. Determining which of the financial statement assertions are the most important for the

client’s financial statements. d. Determining the nature, timing, and extent of further audit procedures for auditing the

inventory.

4.44 A primary objective of analytical procedures used in the final review stage of an audit is to a. Identify account balances that represent specific risks relevant to the audit. b. Gather evidence from tests of details to corroborate financial statement assertions. c. Detect fraud that may cause the financial statements to be misstated. d. Assist the auditor in evaluating the overall financial statement presentation.

(AICPA adapted)

4.45 An auditor’s analytical procedures indicate a lower than expected return on an equity method investment. This situation most likely could have been caused by a. An error in recording amortization of the excess of the investor’s cost over the invest-

ment’s underlying book value. b. The investee’s decision to reduce cash dividends declared per share of its common stock. c. An error in recording the unrealized gain from an increase in the fair value of available-

for sale securities in the income account for trading securities. d. A substantial fluctuation in the price of the investee’s common stock on a national stock

exchange. (AICPA adapted)

4.46 Which of the following risk types increase when an auditor performs substantive analytical audit procedures for financial statement accounts at an interim date? a. Inherent b. Control c. Detection d. Sampling

(AICPA adapted)

4.47 Which of the following matters relating to an entity’s operations would an auditor most likely consider as an inherent risk factor in planning an audit? a. The entity’s fiscal year ends on June 30. b. The entity enters into significant derivative transactions as hedges.

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c. The entity’s financial statements are generated at an outside service center. d. The entity’s financial data is available only in computer-readable form.

(AICPA adapted)

4.48 What is the primary objective of the fraud brainstorming session? a. Determine audit risk and materiality. b. Identify whether analytical procedures should be applied to the revenue accounts. c. Assess the potential for material misstatement due to fraud. d. Determine whether the planned procedures in the audit plan will satisfy the general audit

objectives. (AICPA adapted)

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4.49 Analytical Procedures and Interest Expense. Weyman Z. Wannamaker is the chief finan- cial officer of Cogburn Company. He prides himself on being able to manage the company’s cash resources to minimize the interest expense. Consequently, on the second business day of each month, Weyman pays down or draws cash on Cogburn’s revolving line of credit at First National Bank in accordance with his cash requirements forecast.

You are the auditor. You find the information on this line of credit in the following table. You inquired at First National Bank and learned that Cogburn Company’s loan agreement specifies payment on the first day of each month for the interest due on the previous month’s outstanding balance at the rate of “prime plus 1.5 percent.” The bank gave you a report that showed the prime rate of interest was 8.5 percent for the first six months of the year and 8.0 percent for the last six months.

Cogburn Company Notes Payable Balances

Date Balance

Jan 1 $150,000 Feb 1 200,000 Apr 1 225,000 May 1 285,000 Jun 1 375,000 Aug 1 430,000 Sep 1 290,000 Oct 1 210,000 Nov 1 172,000 Dec 1 95,000

Required: a. Prepare an audit estimate of the amount of interest expense you expect to find as the bal-

ance of the interest expense account related to these notes payable. b. Which of the types of analytical procedures did you use to determine this estimate? c. Suppose that you find that the interest expense account shows expense of $23,650 related

to these notes. What could account for this difference? d. Suppose that you find that the interest expense account shows expense of $24,400 related

to these notes. What could account for this difference? e. Suppose that you find that the interest expense account shows expense of $25,200 related

to these notes. What could account for this difference?

4.50 Appropriateness of Evidence and Related Parties. Johnson & Company, CPAs, audited Guaranteed Savings & Loan Company. M. Johnson had the assignment of evaluating the collectability of real estate loans. Johnson was working on two particular loans:

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(1) a $4 million loan secured by Smith Street Apartments and (2) a $5.5 million construction loan on Baker Street Apartments now being built. The appraisals performed by Guaranteed Appraisal Partners Inc. showed values in excess of the loan amounts. On inquiry, Bumpus, the S&L vice president for loan acquisition, stated, “I know the Smith Street loan is good because I myself own 40 percent of the partnership that owns the property and is obligated on the loan.”

Johnson then wrote in the audit documentation: (1) the Smith Street loan appears collect- ible as Bumpus personally attested to knowledge of the collectability as a major owner in the partnership obligated on the loan; (2) the Baker Street loan is assumed to be collectible because it is new and construction is still in progress; and (3) the appraised values all exceed the loan amounts.

Required: a. Do you perceive any problems with related-party involvement in the evidence used by

Johnson? Explain. b. Do you perceive any problems with Johnson’s reasoning or the appropriateness of

evidence used in that reasoning?

4.51 Risk of Misstatement in Various Accounts. An auditor must identify the relevant assertions about each significant financial statement account and disclosure and then gather evidence to conclude whether a material misstatement exists for each assertion. The nature of each financial statement account and disclosure contributes to the likelihood that a material misstatement exists. a. In general, which accounts are most susceptible to overstatement? To understatement? b. Why do you think a company could permit asset accounts to be understated? c. Why do you think a company could permit liability accounts to be overstated? d. Which direction of misstatement is most likely: income overstatement or income

understatement?

4.52 Analysis of Accounting Estimates. Oak Industries, a manufacturer of radio and cable TV equipment and an operator of subscription TV systems, had a multitude of problems. Subscription services in a market area, for which $12 million of cost had been deferred, were being terminated, and the customers were not paying on time ($4 million receivables in doubt). The chances are 50-50 that the business will survive another two years.

An electronic part turned out to have defects that needed correction. Warranty expenses are estimated to range from $2 million to $6 million. The inventory of this part ($10 million) is obsolete, but $1 million can be recovered in salvage, or the parts in inventory can be rebuilt at a cost of $2 million. (The selling price of the inventory on hand would then be $8 million, with 20 percent of the selling price required to market and ship the products, and the normal profit is expected to be 5 percent of the selling price.) If the inventory were scrapped, the company would manufacture a replacement inventory at a cost of $6 million, excluding marketing and shipping costs and normal profit.

The company has defaulted on completion of a military contract, and the government is claiming a $2 million refund. Company attorneys think the dispute might be settled for as little as $1 million.

The auditors had previously determined that an overstatement of income before taxes of $7 million would be material to the financial statements. These items were the only ones left for audit decisions about possible adjustment. Management has presented the following analysis for the determination of loss recognition:

Write off deferred subscription costs $ 3,000,000 Provide allowance for bad debts 4,000,000 Provide for expected warranty expense 2,000,000 Lower-of-cost-or-market inventory write-down 2,000,000 Loss on government contract refund ????????

Required: Prepare your own analysis of the amount of adjustment to the financial statements. Assume that none of these estimates have been recorded yet, and give the adjusting entry you would

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recommend. Give any supplementary explanations you believe necessary to support your recommendation.

4.53 Horizontal and Vertical Analysis. Horizontal analysis refers to changes of financial state- ment numbers and ratios across two or more years. Vertical analysis refers to financial statement amounts expressed each year as proportions of a base such as sales for the income- statement accounts and total assets for the balance-sheet accounts. Exhibit 4.53.1 contains Retail Company’s prior-year (audited) and current-year (unaudited) financial statements, along with amounts and percentages of change from year to year (horizontal analysis) and common-size percentages (vertical analysis). Exhibit 4.53.2 contains selected financial ratios based on these financial statements. Analysis of these data can enable auditors to discern relationships that raise questions about misleading financial statements.

Required: Study the data in Exhibits 4.53.1 and 4.53.2. Write a memorandum identifying and explain- ing potential problem areas where misstatements in the current-year financial statements could exist. Additional information about Retail Company is as follows:

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EXHIBIT 4.53.1 Retail Company

  Prior Year (Audited) Current Year (Unaudited) Change

  Balance Common Size Balance Common Size Amount Percent

Assets:              Cash $ 600,000 14.78% $ 484,000 9.69% $ (116,000) –19.33%  Accounts receivable 500,000 12.32 400,000 8.01 (100,000) –20.00  Allowance doubt. accts. (40,000) –0.99 (30,000) –0.60 10,000 –25.00  Inventory 1,500,000 36.95 1,940,000 38.85 440,000 29.33   Total current assets 2,560,000 63.05 2,794,000 55.95 234,000 9.14  Fixed assets 3,000,000 73.89 4,000,000 80.10 1,000,000 33.33  Accum. depreciation (1,500,000) –36.95 (1,800,000) –36.04 (300,000) 20.00 Total assets $ 4,060,000 100.00% $ 4,994,000 100.00% $ 934,000 23.00% Liabilities and equity:  Accounts payable $ 450,000 11.08% $ 600,000 12.01% $ 150,000 33.33%  Bank loans, 11% 0 0.00 750,000 15.02 750,000 NA  Accrued interest 50,000 1.23 40,000 0.80 (10,000) –20.00  Accruals and other 60,000 1.48 10,000 0.20 (50,000) –83.33   Total current liab. 560,000 13.79 1,400,000 28.03 840,000 150.00  Long-term debt, 10% 500,000 12.32 400,000 8.01 (100,000) –20.00   Total liabilities 1,060,000 26.11 1,800,000 36.04 740,000 69.81  Capital stock 2,000,000 49.26 2,000,000 40.05 0 0  Retained earnings 1,000,000 24.63 1,194,000 23.91 194,000 19.40 Total liabilities and equity $ 4,060,000 100.00% $ 4,994,000 100.00% 934,000 23.00% Statement of operations:  Sales (net) $ 9,000,000 100.00% $ 8,100,000 100.00% $ (900,000) –10.00%  Cost of goods sold 6,296,000 69.96 5,265,000 65.00 (1,031,000) –16.38  Gross margin 2,704,000 30.04 2,835,000 35.00 131,000 4.84  General expense 2,044,000 22.7 2,005,000 24.75 (39,000) –1.91  Depreciation 300,000 3.33 300,000 3.70 0 0  Operating income 360,000 4.00 530,000 6.54 170,000 47.22  Interest expense 50,000 0.56 40,000 0.49 (10,000) –20.00  Income taxes (40%) 124,000 1.38 196,000 2.42 72,000 58.06 Net income $ 186,000 2.07% $ 294,000 3.63% $ 108,000 58.06%

“NA” means not applicable.

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∙ The new bank loan, obtained on July 1 of the current year, requires maintenance of a 2:1 current ratio.

∙ Principal of $100,000 plus interest on the 10 percent long-term note obtained several years ago in the original amount of $800,000 is due each January 1.

∙ The company has never paid dividends on its common stock and has no plans for a dividend.

4.54 Analysis and Judgment. As part of your regular year-end audit of a public client, you must estimate the probability of success of its proposed new product line. The client has experienced financial difficulty during the last few years and, in your judgment, a suc- cessful introduction of the new product line is necessary for the client to remain a going concern.

Five elements are necessary for the successful introduction of the product: (1) success- ful labor negotiations before the strike deadline between the construction firms contracted to build the necessary addition to the present plant and the building trades unions, (2) suc- cessful defense of patent rights, (3) product approval by the Food and Drug Administration (FDA), (4) successful negotiation of a long-term raw material contract with a foreign sup- plier, and (5) successful conclusion of distribution contract talks with a large national retail distributor.

In view of the circumstances, you contact experts who have provided your public account- ing firm with reliable estimates in the past. The labor relations expert estimates that there is an 80 percent chance of successfully concluding labor negotiations. Legal counsel advises that there is a 90 percent chance of successfully defending patent rights. The expert on FDA product approvals estimates a 95 percent chance of new product approval. The experts in the remaining two areas estimate the probability of successfully resolving (1) the raw materials contract and (2) the distribution contract talks to be 90 percent in each case. Assume that these estimates are reliable.

Required: What is your assessment of the probability of successful product introduction? (Hint: You can assume that each of the five elements is independent of the others.)

4.55 Analytical Procedures. Kelly Griffin, an audit manager, had begun preliminary analytical procedures of selected statistics related to the Majestic Hotel. Her objective was to obtain an understanding of the hotel’s business in order to draft a preliminary audit plan. She wanted to see whether she could detect any troublesome areas or questionable accounts that could require special audit attention. Unfortunately, Griffin caught the flu and was hospitalized. From her sickbed, she sent you the schedule she had prepared (Exhibit 4.55.1) and has asked you to write a memorandum identifying areas of potential misstatements or other matters that the preliminary audit plan should cover.

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  Prior Year (audited)

Current Year (unaudited)

Percent Change

Balance-sheet ratios:        Current ratio 4.57 2.0 −56.34%  Days’ sales in receivables 18.40 16.44 −10.63    Doubtful accounts ratio 0.0800 0.0750 −6.25    Days’ sales in inventory 85.77 132.65 54.66    Debt/equity ratio 0.35 0.56 40.89   Operations ratios:        Receivables turnover 19.57 21.89 11.89    Inventory turnover 4.20 2.71 −35.34    Cost of goods sold/sales 69.96% 65.00% −7.08    Gross margin % 30.04% 35.00% 16.49    Return on equity   6.61%   9.80% 48.26  

EXHIBIT 4.53.2 Retail Company

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  Majestic (percent)

Industry (percent)

Sales:      Rooms 60.4% 63.9%  Food and beverage 35.7 32.2  Other 3.9 3.9 Costs:      Rooms department 15.2 17.3  Food and beverage 34.0 27.2  Administrative and general 8.0 8.9  Management fee 3.3 1.1  Advertising 2.7 3.2  Real estate taxes 3.5 3.2  Utilities, repairs, maintenance 15.9 13.7 Profit per sales dollar 17.4 25.4 Rooms dept. ratios to room sales dollars:      Salaries and wages 18.9 15.7  Laundry 1.1 3.7  Other 5.3 7.6 Profit per rooms sales dollar 74.8 73.0 Food/beverage (F/B) ratios to F/B sales dollars:      Cost of food sold 42.1 37.0  Food gross profit 57.9 63.0  Cost of beverages sold 43.6 29.5  Beverages gross profit 56.4 70.5  Combined gross profit 57.7 64.6  Salaries and wages 39.6 32.8  Music and entertainment — 2.7  Other 13.4 13.8 Profit per F/B sales dollar 4.7 15.3 Average annual percent of rooms occupied 62.6 68.1 Average room rate per day $160 $120 Number of rooms available per day 200 148

EXHIBIT 4.55.1 Analytical Procedure Documentation

Required: Write a memorandum describing Majestic’s operating characteristics compared to the indus- try average insofar as you can tell from the statistics. Do these analytical procedures identify any areas that could represent potential misstatements in the audit?

4.56 Preliminary Analytical Procedures. Dunder-Mifflin Inc. wanted to expand its manu- facturing and sales facilities. The company applied for a loan from First Bank, presenting the prior-year audited financial statements and the forecast for the current year shown in Exhibit 4.56.1. (Dunder-Mifflin Inc.’s fiscal year-end is December 31.) The bank was impressed with the business prospects and granted a $1,750,000 loan at 8 percent interest to finance working capital and the new facilities that were placed in service July 1 of the current year. Because Dunder-Mifflin Inc. planned to issue stock for permanent financing, the bank made the loan due on December 31 of the following year. Interest is payable each calendar quarter on October 1 of the current year and January 1, April 1, July 1, October 1 of the following year.

The auditors’ interviews with Dunder-Mifflin Inc. management near the end of the cur- rent year produced the following information: The facilities did not cost as much as previ- ously anticipated. However, sales were slow and the company granted more liberal return privilege terms than in the prior year. Officers wanted to generate significant income to impress First Bank and to preserve the company dividend ($120,000 paid in the prior year).

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  Prior Year (audited) Forecast

Current Year (unaudited)

Revenue and Expense:      

Sales (net) $ 9,000,000 $ 9,900,000 $ 9,720,000 Cost of goods sold 6,296,000 6,926,000 7,000,000 Gross margin 2,704,000 2,974,000 2,720,000 General expense 2,044,000 2,000,000 2,003,000 Depreciation 300,000 334,000 334,000 Operating income 360,000 640,000 383,000 Interest expense 60,000 110,000 75,000 Income taxes (40%) 120,000 212,000 123,200 Net income 180,000 318,000 184,800 Assets: Cash 600,000 880,000 690,800 Accounts receivable 500,000 600,000 900,000 Allowance for doubtful accounts (40,000) (48,000) (90,000) Inventory 1,500,000 1,500,000 1,350,000  Total current assets 2,560,000 2,932,000 2,850,800 Fixed assets 3,000,000 4,700,000 4,500,000 Accumulated depreciation (1,500,000) (1,834,000) (1,834,000) Total assets $ 4,060,000 $ 5,798,000 $ 5,516,800 Liabilities and Equity: Accounts payable $ 450,000 $ 450,000 $ 330,000 Bank loans, 8% 0 1,750,000 1,750,000 Accrued interest 60,000 40,000 40,000 Accruals and other 50,000 60,000 32,000  Total current liabilities $ 560,000 $ 2,300,000 $ 2,152,000 Long-term debt, 10% 600,000 400,000 400,000  Total liabilities $ 1,160,000 $ 2,700,000 $ 2,552,000 Capital stock 2,000,000 2,000,000 2,000,000 Retained earnings 900,000 1,098,000 964,800 Total liabilities and equity $ 4,060,000 $ 5,798,000 $ 5,516,800

EXHIBIT 4.56.1 Dunder-Mifflin Inc.

The production managers had targeted inventory levels for a 4.0 turnover ratio and were largely successful even though prices of materials and supplies had risen about 2 percent relative to sales dollar volume. The new facilities were depreciated using a 25-year life from the date of opening.

Dunder-Mifflin Inc. has now produced the current-year financial statements (Exhibit 4.56.1, Current Year column) for the auditors’ work on the current audit.

Required: Perform preliminary analytical procedures on the current-year unaudited financial state- ments for the purpose of identifying accounts that could contain errors or frauds. Use your knowledge of Dunder-Mifflin Inc. and the forecast in Exhibit 4.56.1. Calculate comparative and common-size financial statements as well as relevant ratios. (Assume that the market value of the equity for the company is $3 million.) Once your calculations are complete, identify the accounts that could be misstated.

4.57 Audit Risk Model. Audit risks for particular accounts and disclosures can be conceptual- ized in the model: Audit risk (AR) = Inherent risk (IR) × Control risk (CR) × Detection risk (DR). Use this model as a framework for considering the following situations and deciding whether the auditor’s conclusion is appropriate. a. Paul, CPA, has participated in the audit of Tordik Cheese Company for five years, first

as an assistant accountant and the last two years as the senior accountant. Paul has never seen an accounting adjustment recommended and believes the inherent risk must be zero.

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b. Hill, CPA, has just (November 30) completed an exhaustive study and evaluation of the internal controls of Edward Foods Inc. (fiscal year ending December 31). Hill believes the control risk must be zero because no material errors could possibly slip through the many error-checking procedures and review layers that Edward used.

c. Fields, CPA, is lazy and does not like audit jobs in Philadelphia. On the audit of Philly Manufacturing Company, Fields decided to use substantive procedures to audit the year- end balances very thoroughly to the extent that the risk of failing to detect material errors and irregularities should be 0.02 or less. Fields gave no thought to inherent risk and con- ducted only a very limited review of Philly’s internal control system.

d. Shad, CPA, is nearing the end of a “dirty” audit of Allnight Protection Company. All of Allnight’s accounting personnel resigned during the year and were replaced by inexperi- enced people. The comptroller resigned last month in disgust. The journals and ledgers were a mess because the one computer specialist was hospitalized for three months dur- ing the year. “Thankfully,” Shad thought, “I’ve been able to do this audit in less time than last year when everything was operating smoothly.”

(AICPA adapted)

4.58 Auditing an Accounting Estimate. Suppose management estimated the market valuation of some obsolete inventory at $99,000; this inventory was recorded at $120,000, which resulted in recognizing a loss of $21,000. The auditors obtained the following information: The  inventory in question could be sold for an amount between $78,000 and $92,000. The costs of advertising and shipping could range from $5,000 to $7,000.

Required: a. Would you propose an audit adjustment to the management estimate? Prepare the appro-

priate accounting entry. b. If management’s estimate of inventory market (lower than cost) had been $80,000, would

you propose an audit adjustment? Prepare the appropriate accounting entry.

4.59 Risk Assessment. This question consists of a number of items pertaining to an auditor’s risk analysis for a company. Your task is to tell how each item affects overall audit risk—that is, the probability of issuing an unmodified audit report on materially misleading financial statements.

Bond, CPA, is considering audit risk at the financial statement level in planning the audit of Toxic Waste Disposal (TWD) Company’s financial statements for the year ended December 31, 2020. TWD is a privately owned company that contracts with municipal governments to remove environmental wastes. Audit risk at the overall financial statement level is influenced by the risk of material misstatements, which may be indicated by a combination of factors related to management, the industry, and the company.

Required: Based only on the following information, indicate whether each of the following factors (items 1 through 15) would most likely increase overall audit risk, decrease overall audit risk, or have no effect on overall audit risk. Discuss your reasoning.

Company Profile 1. This was the first year TWD operated at a profit since 2017 because the municipalities

received increased federal and state funding for environmental purposes. 2. TWD’s board of directors is controlled by Mead, the majority stockholder, who also acts

as the chief executive officer. 3. The internal auditor reports to the controller, and the controller reports to Mead. 4. The accounting department has experienced a high rate of turnover of key personnel. 5. TWD’s bank has a loan officer who meets regularly with TWD’s CEO and controller to

monitor TWD’s financial performance. 6. TWD’s employees are paid biweekly. 7. Bond has audited TWD for five years.

Recent Developments 8. During 2020, TWD changed the method of preparing its financial statements from the

cash basis to the accrual basis under generally accepted accounting principles.

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164 Part Two The Financial Statement Audit

9. During 2020, TWD sold one-half of its controlling interest in United Equipment Leas- ing (UEL) Co. TWD retained significant interest in UEL.

10. During 2020, the state dropped litigation filed against TWD in 2016 alleging that the company discharged pollutants into state waterways. Loss contingency disclosures that TWD included in prior-years’ financial statements are being removed for the 2019 financial statements.

11. During December 2020, TWD signed a contract to lease disposal equipment from an entity owned by Mead’s parents. This related-party transaction is not disclosed in TWD’s notes to its 2020 financial statements.

12. During December 2020, TWD completed a barter transaction with a municipality. TWD removed waste from a municipally owned site and acquired title to another con- taminated site at below-market price. TWD intends to service this new site in 2021.

13. During December 2020, TWD increased its casualty insurance coverage on several pieces of sophisticated machinery from historical cost to replacement cost.

14. Inquiries about the substantial increase in revenue that TWD recorded in the fourth quarter of 2020 disclosed a new policy. TWD guaranteed several municipalities that it would refund the federal and state funding paid to it if any municipality fails federal or state site cleanup inspection in 2021.

15. An initial public offering of TWD’s stock is planned for late 2021.

4.60 Auditing Standards Review. Management fraud (fraudulent financial reporting) is not the expected norm, but it happens from time to time. In the United States, several cases have been widely publicized. They happen when motives and opportunities overwhelm manage- rial integrity. a. What distinguishes management fraud from a defalcation? b. What are an auditor’s responsibilities under auditing standards to detect management

fraud? c. What are some characteristics of management fraud that an audit team should consider to

fulfill the responsibilities under auditing standards? d. What factors might an audit team notice that should heighten the concern about the exis-

tence of management fraud? e. Under what circumstances might an audit team have a duty to disclose management’s

frauds to parties other than the company’s management and its board of directors? (AICPA adapted)

4.61 Analytical Procedures: Ratio Relationships. The following situations represent errors and frauds that could occur in financial statements.

Required: State how the ratio in question would compare (higher, equal, or lower) to what the ratio should have been had the error or fraud not occurred. a. The company recorded fictitious sales with credits to sales revenue accounts and debits to

accounts receivable. Inventory was reduced, and cost of goods sold was increased for the profitable “sales.” Is the current ratio higher than, equal to, or lower than what it should have been?

b. The company recorded cash disbursements by paying trade accounts payable but held the checks past the year-end date, meaning that the “disbursements” should not have been shown as credits to cash and debits to accounts payable. Is the current ratio higher than, equal to, or lower than what it should have been? Consider cases in which the current ratio before the improper “disbursement” recording was (1) higher than 1:1, (2) equal to 1:1, and (3) lower than 1:1.

c. The company uses a periodic inventory system for determining the balance-sheet amount of inventory at year-end. Very near the year-end, merchandise was received, placed in the stockroom, and counted, but the purchase transaction was neither recorded nor paid until the next month. What was the effect of this on inventory, cost of goods sold, gross profit, and net income? How were these ratios affected compared to what they would have been without the error: current ratio [remember three possible cases from part (b)], gross mar- gin ratio, cost of goods sold ratio, inventory turnover, and receivables turnover?

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d. The company is loath to write off customer accounts receivable even though the financial vice president makes entirely adequate provision for uncollectible amounts in the allow- ance for bad debts. The gross receivables and the allowance both contain amounts that should have been written off long ago. How are these ratios affected compared to what they would have been if the old receivables had been properly written off: current ratio, days’ sales in receivables, doubtful account ratio, receivables turnover, return on begin- ning equity, and working capital/total assets?

e. Since last year, the company has reorganized its lines of business and placed more emphasis on its traditional products while selling off some marginal businesses merged by the previous management. Total assets are 10 percent less than they were last year, but working capital has increased. Retained earnings remained the same because the dispos- als created no gains, and the net income after taxes is still near zero, which is the same as last year. Earnings before interest and taxes (EBIT) remained the same, a small positive EBIT. The total market value of the company’s equity has not increased, but that is better than the declines of the past several years. Proceeds from the disposals have been used to retire long-term debt. Net sales have decreased 5 percent because the sales’ decrease resulting from the disposals has not been overcome by increased sales of the traditional products. Is the discriminant Z-score of the current year higher or lower than the one of the prior year? (See Appendix 4A for the Z-score formula.)

4.62 Audit Strategy Memorandum. The auditor should establish an overall audit strategy that sets the scope, timing, and direction of the audit and guides the development of the audit plan. In establishing the overall audit strategy, the auditor should develop and document an audit plan that includes a description of (a) the planned nature, timing, and extent of the risk assessment procedures, (b) the planned nature, timing, and extent of tests of controls and substantive procedures, and (c) other planned audit procedures that must be performed so that the engagement complies with auditing standards.

Required: Select a public company and determine a significant risk that could affect its financial state- ments. (Hint: Go to the EDGAR database at www.sec.gov and select the company’s form 10-K. The 10-K will have a list of risk factors the company faces.) Describe the risk and how it could affect the financial statements, including what assertions might be misstated. Prepare an audit strategy memorandum for the risk describing what controls the company might use to mitigate the risk, how you could test the controls, and what substantive proce- dures you might use to determine whether there is a misstatement. Because this is early in your auditing class, do not worry about specific procedures; just be creative and think about a general strategy an auditor might use.

4.63 Errors and Frauds. Give an example of an error or fraud that would misstate financial statements to affect the accounts as follows, taking each case independently. (Note: “Over- state” means the account has a higher value than would be appropriate under GAAP and “understate” means it has a lower value.) a. Overstate one asset; understate another asset. b. Overstate an asset; overstate stockholders’ equity. c. Overstate an asset; overstate revenue. d. Overstate an asset; understate an expense. e. Overstate a liability; overstate an expense. f. Understate an asset; overstate an expense. g. Understate a liability; understate an expense.

4.64 Compliance with Laws and Regulations. Audit standards distinguish auditors’ responsi- bility for planning procedures for detecting noncompliance with laws and regulations having a direct effect on financial statements versus planning procedures for detecting noncompli- ance with laws and regulations that do not have a direct effect on financial statements.

Required: a. What are the requirements for auditors to plan procedures to detect direct-effect compli-

ance versus indirect-effect compliance?

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166 Part Two The Financial Statement Audit

b. For each of the following instances of noncompliance, explain why they are either direct-effect (D) or indirect-effect (I) noncompliance: 1. A manufacturer inflates expenses on its corporate tax return. 2. A retailer pays men more than women for performing the same job. 3. A coal mining company fails to place proper ventilation in its mines. 4. A military contractor inflates the overhead applied to a combat vehicle. 5. An insurance company fails to maintain required reserves for losses. 6. An exporter pays a bribe to a foreign government official so that government will buy

its products. 7. A company backdates its executive stock options to lower the exercise price. 8. A company fails to fund its pension plan in accordance with ERISA.

4.65 Identifying Significant Accounts – Auditors gather information from a variety of sources, including 10-K reports, to help assess risk and identify significant accounts and relevant assertions.

Required: You are performing risk assessment procedures for Apple Inc. One source of information you will use to help assess risk and identify significant accounts is Apple’s most recent 10-K filing. Go to the sec.gov website and search for Apple Inc.’s most recent 10-K filing. Read through the Item 1, Business, and Item 1A, Risk Factors, sections. Based off this discussion, what accounts do you believe might be susceptible to misstatement and why?

4.66 Preparing and Analyzing an Aging Schedule — Using IDEA. For this exercise, your client, Bright IDEAs Inc., has provided you with a listing of sales invoices. To test whether the client appears to have a receivables collectability problem, the auditor must complete a series of related steps: 1. Import the client’s database of sales invoices. You may have already completed this step

in Chapter 3. 2. Perform an aging analysis by following the instructions in the IDEA Workbook.

Required Data and additional instructions available on McGraw-Hill Connect.

Required: Complete the preceding steps and answer the following questions: a. What percentage of customers have accounts that are aged greater than 90 days? b. What percentage of customer balances are aged greater than 90 days? c. What effects would the findings in parts (a) and (b) have on the auditor’s assessment of

the risk of material misstatement? What accounts and assertions are most likely influ- enced by these findings?

4.67 Summarizing Obsolete Inventory — Using IDEA. For this exercise, your client, Bright IDEAs Inc., has provided you with a listing of inventory as of year end. To analyze the amount of obsolete inventory, as reported by the client, the auditor must complete a series of related steps: 1. Import the client’s database of inventory on hand. You may have already completed this

step in Chapter 3. 2. Summarize items identified as obsolete by the client by following the instructions in the

IDEA Workbook.

Required Data and additional instructions available on McGraw-Hill Connect. Complete the preceding steps and answer the following questions:

a. What percentage of the dollar amount of the client’s inventory has been identified as obsolete?

b. What effects would the findings in part (a) have on the auditor’s assessment of the risk of material misstatement? What accounts and assertions are most likely influenced by these findings?

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4.68 Analyzing Profit Margins — Using IDEA. For this exercise, your client, Bright IDEAs Inc., has provided you with a listing of inventory as of year end, which includes current sell- ing prices. To test whether profit margins appear adequate to justify the inventory valuation provision, the auditor must complete a series of related steps: 1. Import the client’s database of inventory on hand. You may have already completed this

step in Chapter 3 or Ex 4.67. 2. Create an analysis of selling price changes by following the instructions in the IDEA

Workbook. 3. Create an analysis of profit margins by following the instructions in the IDEA Workbook.

Required Data and additional instructions available on McGraw-Hill Connect.

Required: Complete the preceding steps and answer the following questions: a. What percentage of inventory items have price movements in excess of 50%? How many

of these items experienced price increases? How many experienced price decreases? Which direction of change would be most concerning to the auditor?

b. What percentage of items have negative profit margins? c. What effects would the findings in part (a) and (b) have on the auditor’s assessment of the

risk of material misstatement? What accounts and assertions are most likely influenced by these findings?

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Preliminary Analytical Procedures You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Watershed and have been assigned to the engagement team of a new audit client, Apollo Shoes Inc. You have been asked to perform preliminary analytical procedures in an effort to help identify significant accounts and relevant assertions and assess risk of material misstatement. Detailed instructions for performing the preliminary analytical procedures, as well as working papers, can be found in Connect.

Apollo Shoes

Audit Risk Model You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Watershed and have been assigned to the engagement team of a new audit client, Apollo Shoes Inc. You have been asked to evaluate a set of facts to determine the relationship of each with inherent or control risk, in an effort to determine the impact on detection risk. Detailed instructions for performing the audit risk case, as well as working papers, can be found in Connect.

Apollo Shoes

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Selected Financial Ratios

Appendix 4A

Balance-Sheet Ratios Formula*

Current ratio Current assets _______________ Current liabilities

Days’ sales in receivables Ending net receivables

___________________ Credit sales / 360

Doubtful account ratio Allowance for doubtful accounts ___________________________ Ending gross receivables

Days’ sales in inventory

Ending inventory ___________________

Cost of goods sold / 360

Debt-to-equity ratio Current and long-term debt

_______________________ Stockholder equity

Operations Ratios  

Receivables turnover Credit sales ___________________ Ending net receivables

Inventory turnover Cost of goods sold

________________ Ending inventory

Cost of goods sold ratio Cost of goods sold

________________ Net sales

Gross margin ratio Net sales − Cost of goods sold

________________________ Net sales

Return on stockholder equity Net income _____________________________________ Stockholder equity (beginning balance)

Financial Distress Ratios (Altman)

The discriminant Z-score is an index of a company’s financial health. The higher the score, the healthier the company. The lower the score, the closer financial failure approaches. The score that predicts financial failure is a matter of dispute. Research suggests that companies with scores above 3.0 never go bankrupt. Generally, companies with scores below 1.0 experience financial difficulty of some kind. The score can be a negative number.

(X1) Working capital/Total assets Current assets − Current liabilities ___________________________ Total assets

(X2) Retained earnings/Total assets Retained earnings (ending)

___________________________ Total assets

(X3) Earnings before interest and taxes/Total assets Net income + Interest expense + Income tax expense

__________________________________________ Total assets

(X4) Market value of equity/Total debt Market value of common and preferred stock

_____________________________________ Current liabilities and long-term debt

(X5) Net sales/Total assets Net sales __________ Total assets

Discriminant Z-score (Altman) 1.2 * X1 + 1.4 * X2 + 3.3 * X3 + 0.6 * X4 + 1.0 * X5 *These ratios are shown to be calculating using year-end rather than year-average, numbers for balances such as accounts receivable and inventory. Other accounting and finance reference books could contain formulas using year-average numbers. As long as no dramatic changes have occurred during the year, the year-end numbers can have much audit relevance because they reflect the most current balance data. For comparative purposes, the ratios should be calculated on the same basis for all years being compared.

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Sample Audit Memorandum

OVERVIEW Integrated Care Health Insurance Inc. (Integrated) offers a variety of valuable products and services ranging from medical, dental, and behavioral health coverage to life insur- ance and disability plans as well as management services for Medicaid plans. Purchas- ing health coverage ensures future security with respect to high and unexpected costs of health care for individuals, families, and businesses. Benefits offered by Integrated include not only coverage for medical expenses but access to a wide network of doctors, hospitals, and specialists.

PRODUCT PRICING Integrated uses a special process to calculate premiums charged for services offered. The method involves pooling customers with similar characteristics into a single risk group based on age, gender, medical history, lifestyle, and other factors such as benefits desired, administration costs, and tax obligations. After Integrated pools customers into their respective risk groups, Integrated has the responsibility to balance projected future costs with premiums charged. The most important factor in determining financial success for Integrated is its ability to predict trends and future medical costs. Therefore, faulty forecasts can lead to huge risks and downfalls for Integrated if expectations fall short of actual results. Competing in an industry where new technology and medical break- throughs are discovered almost daily means that sustaining profitability is an increasing concern.

GOVERNMENT INFLUENCES Along with a great deal of risk being inherent in its business, Integrated operations are impacted by the U.S. economy and unemployment rate. Additionally, the health care reform legislation passed in 2010 has caused significant changes to many facets of the industry’s operation. Given that the new legislation requires coverage for those who are currently uninsured, the insurance companies acquired millions of new customers virtu- ally overnight. Health care reform is a constant source of debate in the government, there- fore it is uncertain how future legislation will impact the industry.

CUSTOMERS, SUPPLIERS, AND COMPETITORS Integrated’s customers include employer groups, self-employed individuals, part-time and hourly workers, governmental organizations, labor groups, and immigrants. Although there are a considerable number of companies competing, experts have noted a trend that competition is virtually disappearing due to the domination of markets by only a few providers. In a study published by the American Medical Association, 24 of 43 states have one or two insurers comprising a market share of a staggering 70 percent.9 These statistics may suggest that there is essentially no competition in the market. However, 1,300 companies are competing in the health insurance industry, and Integrated faces significant competition in highly concentrated markets. In addition to the competition and

INTEGRATED CARE HEALTH INSURANCE INC AUDIT MEMORANDUM (ABRIDGED)

9D. W. Emmons, J. R. Guardado, C. K. Kane, “Competition in Health Insurance: A Comprehensive Study of U.S. Markets, 2010 Update,” American Medical Association.

Appendix 4B

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170 Part Two The Financial Statement Audit

governmental influences already present, Integrated is also facing competition from hos- pitals that play a pertinent role in determining the amounts billed for services provided.

RISK ASSESSMENT The following analysis provides an overview of the identified risks and expected controls for Integrated for one accounting cycle.

REVENUE AND COLLECTION CYCLE Risks Due to the contract nature of the insurance industry, revenue recognition is not a high-risk area when compared to other industries. Integrated has set contracts with commercial organizations, individuals, and the government. Therefore, large fluctuations through- out the year do not typically occur. However, one area of significant risk involves the Medicare risk adjustment. The Centers for Medicare & Medicaid Services (CMS) deter- mines Medicare and Medicaid premium payments employing a risk-based formula using coding provided by the insurance companies based on data from the diagnosis. Members with Medicare and Medicaid benefits associated with the health insurance entity are given a risk category based on their health conditions. However, because these contracts are preset for a year, patients’ risk categories might fluctuate, causing an increase in needed payment from the CMS. Integrated must ensure that revenue is recognized properly by recording a risk adjustment for the difference between what CMS paid and what should have been paid based on the appropriate risk categories. CMS also performs audits known as Risk Adjusted Data Validation (RADV) audits to ensure CMS remits premium payments to insurance organizations appropriately.

Another area of significant risk around revenue recognition involves the Medicare Part D risk-sharing provision. With Medicare Part D, insurance entities contract with CMS for set premiums on an annual basis. The ultimate payment of total premiums, however, depends on certain thresholds that might require additional payment by CMS or reim- bursement to CMS. A reconciliation (true-up) is performed after year-end to account for these differences. However, because this true-up process might occur six to nine months after year-end, Integrated must account for this process by recording receivables or pay- ables that estimate these differences. Significant estimates are used to develop these adjustments and require the company to plan the audit procedures to provide reasonable assurance that these estimates do not include material misstatements.

Controls The difficulty in predicting revenue adjustment amounts from these two programs con- cerns Integrated management’s assertions of completeness, accuracy, valuation of finan- cial statement accounts, and proper disclosure of required revenue recognition elements. To meet disclosure assertions, Integrated established a disclosure committee to deter- mine what revenue-related disclosures should be made regarding Medicare and Medic- aid. This committee meets prior to the release of each quarter’s financial statements or as often as management requires. Valuation and accuracy assertions are met by requiring that qualified personnel utilize acceptable models commonly used in industry practice when estimating the amounts for the varying revenues. Appropriate supervisors review all estimates for accuracy and verify that estimates conform to the company’s operational objectives.

AUDIT APPROACH Due to the high-risk nature of the unique business and audit risks detailed here, an audit plan for Integrated must include both test of controls and substantive procedures to pro- vide for the appropriate level of detection risk. As mentioned, significant estimates are

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included in the financial statements for almost every accounting cycle within the health insurance industry. The amount of management judgment needed to determine these esti- mates requires the use of extensive substantive testing to provide reasonable assurance that material misstatements do not exist within the financial statements. The following detailed audit plan provides guidance on the types of control testing and substantive test- ing that would provide reasonable assurance that material misstatements do not exist in relation to the risks outlined within this report.

AUDIT STRATEGY MEMORANDUM Integrated Care Health Insurance Inc.

Overview This audit strategy is intended to provide our responses to the risks identified for Integrated and generally detail the associated tests of controls and substantive procedures that will be required during the audit.

Risks Revenue recognition related to participation in Medicare and Medicaid programs (Revenue and Collection Cycle)

Assertions Tests of Controls Substantive Procedures

Valuation or allocation Test information technology and manual controls relative to calculation of revenues from Medicare and Medicaid contracts.

Reperform revenue calculations for a sampling of Medicare- and Medicaid- issued contracts.

Confirm that management estimates for risk-sharing and risk- adjustment provisions (reviews include determining whether qualified personnel perform the estimates, making estimates conform to industry practices, and verifying that estimates are accurate).

Reperform estimates for risk-sharing and risk-adjustment provisions.

Confirm that assumptions and methodologies for estimates of risk-sharing and risk-adjustment provisions are documented and approved by management.

Produce independent estimates for risk- sharing and risk-adjustment provisions.

Obtain an understanding of assumptions and methodology of estimates for risk-sharing and risk-adjustment provisions.

 

Presentation and disclosure Confirm that a disclosure committee has been established. Review disclosure committee meeting minutes

Confirm that comparisons of actual and budgeted Medicare and Medicaid revenues are conducted by management and significant variances are monitored.

Review board of directors meeting minutes, agreements, budgets, and plans for Medicare and Medicaid revenues that should be included in financial statements.

  Test whether disclosures and classifications conform to accounting principles.

Source: Mark Fedewa, Emily O’Bryan, Amela Pajazetovic, and Susan Schmidt, “An Analysis of Business and Audit Risk for a Health Insurance Provider,” unpublished working paper, University of Kentucky. February 28, 2011.

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C H A P T E R 5

Risk Assessment: Internal Control Evaluation

As stated on January 29, 2019, by SEC Chief Accountant Wesley Bricker when commenting on the issuance of separate “cease and desist” orders against four public companies for failure to maintain proper internal controls (https://www. sec.gov/news/press-release/2019-6).

Adequate internal controls are the first line of defense in detecting

and preventing material errors or fraud in financial reporting . . .

when internal control deficiencies are left unaddressed, financial

reporting quality can suffer.

Professional Standards References

Topic AU-C/ISA Section

AS Section

Overall Objectives of the Independent Auditor 200 1001, 1005, 1010, 1015

Audit Documentation 230 1215

Consideration of Fraud in a Financial Statement Audit 240 2401

Communications with Audit Committees 260 1301

Communicating Internal Control-Related Matters Identified in an Audit 265 1305

Consideration of Internal Control in an Integrated Audit 265 2201

Reporting on Whether a Previously Reported Material Weakness Continues to Exist 265 6115

Audit Planning 300 2101

Identifying and Assessing the Risks of Material Misstatement 315 AS 12

Materiality 320 2110

Auditors’ Responses to Risks of Material Misstatement 330 2301

Audit Considerations Relating to an Entity Using a Service Organization 402 2601

Audit Evidence 500 1105

Audit Evidence—Specific Considerations for Selected Items 501 2503, 2505, 2510

Consideration of the Internal Audit Function in a Financial Statement Audit 610 2605

Compliance Auditing Considerations in Audits of Recipients of Governmental Financial Assistance 935 6110

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LEARNING OBJECTIVES An important objective of the internal control system is to help ensure that the financial statement information being presented by an organization is credible and can be relied upon. Therefore, it is essential that an auditor take the time to understand whether an entity’s internal control system has been designed and is operating effectively. In fact, the fundamental principles of auditing state that, to fulfill auditors’ responsibility “[t]o obtain reasonable assurance . . . the auditor identifies and assesses risks of material misstatement, whether due to fraud or error, based on an understanding of the entity and its environment, including the entity’s internal control” [emphasis added]. The responsibility is even greater for most public companies because the law and professional standards require that the auditor express an opinion on management’s assessment of the effectiveness of the company’s internal control system. As a result, the evaluation of an entity’s internal control system is a critical phase of most every public company audit engagement.

Beyond its importance in the production of reliable financial statement information, the establishment of an internal control system is an important management function to help ensure the effectiveness and efficiency of operations and the entity’s compliance with laws and regulations. As a result, understanding the elements of internal control and how to evaluate their effectiveness is an important skill that every accountant should have. Even if you do not go into auditing, you probably will

have responsibility for maintaining internal controls at some point in your accounting career.

This chapter presents a general introduction to the theory and definitions you will find useful for internal control evaluation and control risk assessment. The chapter uses the payroll cycle to provide specific examples of internal control activities and related audit procedures.

Your objectives are to be able to:

LO 5-1 Define and describe what is meant by internal control.

LO 5-2 Distinguish between the responsibilities of management and auditors regarding an entity’s internal control.

LO 5-3 Define and describe the five basic components of internal control and specify some of their characteristics.

LO 5-4 Explain the process the audit team uses to assess control risk; understand its impact on the risk of material misstatement; and, ultimately, know how it affects the nature, timing, and extent of further audit procedures to be performed on the audit.

LO 5-5 Describe additional responsibilities for management and auditors of issuers required by Sarbanes–Oxley and PCAOB Auditing Standard No. 2201.

LO 5-6 Explain the communication of internal control deficiencies to those charged with governance, such as the audit committee and other key management personnel.

INTRODUCTION On January 29, 2019, the SEC issued “cease and desist” orders against four public com- panies: Lifeway Foods Inc., Digital Turbine Inc., CytoDyn Inc., and Grupo Simec S.A.B de C.V. According to the SEC’s orders, each company had acknowledged that their internal control systems had material weaknesses. However, after providing each of these companies with as many as 10 years to address their problems, the SEC finally had enough and decided to take action.

It seems clear that the substantial penalties levied by the SEC sends a message to all public companies that if a material weakness exists in your internal control system, the management team had better take remedial action to fix any problems that exist. Because, if not, the SEC will take action. As stated in their “cease and desist” orders, “disclosure of material weaknesses is not enough without meaningful remediation. We are committed to holding corporations accountable for failing to timely remediate material weaknesses.” (https://www.sec.gov/news/press-release/2019-6)

Why the emphasis on internal controls by the SEC? To start, maintaining a system of internal controls for the accounting system is required under the law by the Securities and Exchange Act of 1934 for public companies (i.e., issuers). In addition, Section 404 of the

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174 Part Two The Financial Statement Audit

Sarbanes-Oxley Act of 2002 requires the management team of issuers to assess the effec- tiveness of its own system of internal control and then have an independent CPA firm assess the effectiveness of its internal control system during its annual audit.

By holding both management and the auditor responsible for evaluating the effective- ness of the internal control system, the act appears to have imposed the necessary over- sight to improve the accuracy and reliability of the financial statements reported by the entity. Indeed, the act places an emphasis on the internal control system as an important mechanism to prevent or detect material misstatements in the financial statements due to fraud. Simply stated, the intense scrutiny on both the design and operating effective- ness of internal control systems over financial reporting improves the reliability of the financial statements which clearly benefits the capital markets, as shown in the following auditing insight. This chapter focuses on the importance of the internal control system in the financial statement auditing process.

Elon Musk, the billionaire co-founder of Tesla Inc., will pay a $20 million fine to the SEC for a tweet made on August 7, 2018, which indicated that he had secured financing to take the company public, causing an increase of over six percent in the company’s stock price.

The SEC’s complaint against Tesla relates to the lack of con- trols or procedures in place as to whether Musk’s tweets contained

information required in SEC disclosures. The SEC also contends that Tesla did not have sufficient processes in place to determine whether the tweets were accurate or complete.

Source: https://www.sec.gov/news/press-release/2018-226.

Was The Tweet Worth $20 Million?AUDITING INSIGHT

INTERNAL CONTROL DEFINED For purposes of the financial statement auditing process, as you will soon learn in this chapter, if the system of internal control is properly designed and is also operating effec- tively, it should be producing reliable financial statements. As the figure below clearly illustrates, the most important goal of the system should be to produce reliable financial statements, and as long as the system is operating effectively, auditors should be able to rely on the internal control system to reduce substantive testing procedures. Of course, audit professionals need to follow a required process in order to reach this conclusion, which we cover in this chapter.

The Committee of Sponsoring Organizations (COSO)1 is responsible for defining what is meant by internal control effectiveness. COSO comprises leaders in the auditing profession from the Financial Executives Institute, the American Accounting Associa- tion, the Institute of Internal Auditors, the Institute of Management Accountants, and the American Institute of Certified Public Accountants. It publishes an integrated frame- work which is used by management teams and auditors as the benchmark to assess inter- nal control effectiveness. The resulting report, known as the COSO framework, was last updated in 2013 and defined internal control as follows:

Internal control is a process, effected by an entity’s board of directors, management and other personnel, designed to provide reasonable assurance regarding the achievement of objectives in the following three categories:

∙ Reliability of financial reporting. ∙ Effectiveness and efficiency of operations. ∙ Compliance with applicable laws and regulations.

LO 5-1 Define and describe what is meant by internal control.

1COSO, “Internal Control—Integrated Framework Executive Summary,” May 2013, New York: AICPA

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Stated differently, internal control is a set of policies and procedures designed to achieve management objectives in three different categories. In the financial reporting category, the management objectives are related to producing reliable financial reports and safe- guarding assets. In the operations category, some examples of management objectives are maintaining a good business reputation, ensuring a positive return on investment, increasing market share, promoting new product innovation, and using assets effectively and efficiently. In the compliance category, the broad management objective is to comply with laws and regulations that affect the entity. It is important to point out that external auditors are primarily concerned with a client’s internal control system as it relates to the financial reporting category.

The updated framework acknowledges the widespread use of the COSO framework and provides enhancements that were specifically designed to make it easier to be used as a benchmark for evaluating internal control effectiveness by auditors across the world. In fact, the Auditing Standards Board has even integrated important aspects of the COSO framework into the professional standards (i.e., AU-C 315).2 We believe that the frame- work can be very helpful as students learn about the underlying concepts and principles of an effective internal control system. As a result of its importance, throughout this chapter we will highlight how the COSO framework has impacted the auditor’s role in evaluating a client’s system of internal control during the audit.

2AU-C 315–Communications Between Predecessor and Successor Auditors.

REVIEW CHECKPOINTS 5.1 What is the Committee of Sponsoring Organizations (COSO)? Briefly describe the purpose of the

COSO framework of internal control effectiveness. 5.2 What are the three goals of an internal control system according to the COSO report? Which of the

three is most important to auditors?

The Sarbanes–Oxley Act of 2002 defines internal control in a manner that is consistent with the COSO definition. However, the Sarbanes– Oxley definition focuses on the role of the internal control system over financial reporting and notes that control policies and procedures should allow

1. Records to be maintained in reasonable detail to accurately reflect transactions.

2. Transactions to be recorded to permit financial statements to be prepared in accordance with GAAP.

3. Transactions to be executed in accordance with authorization from the entity’s management.

4. Unauthorized acquisition, use, or disposition of the entity’s assets to be prevented or detected on a timely basis.

Source: U.S. Congress, Sarbanes–Oxley Act of 2002, Pub. L. No. 107-204, 116 Stat. 745 (2002).

Sarbanes–Oxley Definition of Internal ControlAUDITING INSIGHT

MANAGEMENT VERSUS AUDITORS’ RESPONSIBILITY FOR INTERNAL CONTROL

Management’s Internal Control Responsibilities Section 302 of the Sarbanes–Oxley Act stipulates criminal penalties for both CEOs and CFOs if they issue materially misleading financial statements. A clear intention of this section of the act is to make sure that the upper management team takes full responsibility

LO 5-2 Distinguish between the responsibilities of management and auditors regarding an entity’s internal control.

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176 Part Two The Financial Statement Audit

for establishing and maintaining a system of internal control. Simply stated, the threat of criminal penalties is usually enough to make sure that management takes their responsibility for internal control effectiveness seriously.

To accomplish this objective, management is responsible for assessing the full range of risks it would like to control, including financial reporting risks. Such a risk assessment process generally leads to the establishment of important objectives for the internal control system. For example, management must make sure that transactions are properly authorized, and that the accounting records and other system-generated reports are complete and accurate. In addition, management must ensure the security of their assets, including their data. It is also important that an appropriate control environment is established that allows for the implementation of appropriate internal control activi- ties, appropriate information and communication channels, and proper monitoring of the operation of all internal control activities.

Management is also responsible for maintaining documentation that is sufficient to provide evidence that the system of internal control has been designed and is operat- ing effectively. For example, such documentation needs to provide evidence about how important internal control decisions were considered and ultimately how the final decisions were reached for key professional judgments. Finally, the documentation must be robust enough to allow auditors to gain an understanding of the internal control system and ultimately conduct an audit of the effectiveness of the internal control system.

In addition to requiring that the CEO and CFO certify the entity’s financial statements and disclosures under Section 302, Sarbanes–Oxley requires management to assess and report on the entity’s internal control over financial reporting in Section 404. Specifically, the entity’s annual report must include the following:

∙ A statement that management is responsible for establishing and maintaining adequate internal control over financial reporting.

∙ A statement identifying the framework (e.g., the COSO framework) that management uses as a benchmark for evaluating the effectiveness of the entity’s internal control.

∙ A statement providing management’s assessment of the effectiveness of the entity’s internal control.

Under Section 302, management must also disclose any material weaknesses in internal control. If any material weaknesses exist, management cannot conclude that the entity’s internal control over financial reporting is effective. See Exhibit 5.1 for excerpts from a Costco Wholesale Corporation management report on internal control over financial reporting, which identified a material weakness in its system of internal control. This report was issued on October 26, 2018.

Auditors’ Internal Control Responsibilities Auditors have at least three reasons for conducting an evaluation of an entity’s internal control system. First, Sarbanes–Oxley requires an audit of effectiveness of internal con- trol over financial reporting for issuers. The internal control audit is conducted along with the financial statement audit as part of an overall integrated audit that is completed at issu- ers. In essence, the audit firm employs one integrated process that culminates in the issu- ance of two opinions: one on the entity’s financial statements and one on management’s assessment of the effectiveness of the entity’s internal control over financial reporting.

The second reason for evaluating an entity’s internal control is to assess preliminary risk of material misstatement (RMM) for each relevant assertion. The assessment of RMM at the assertion level is completed for all financial statement audits in order to give the audit team a basis for planning the audit and determining the nature, timing, and extent of further audit procedures to be conducted for the financial statement audit. RMM is composed of inherent risk and control risk. The assessment of inherent risk, the susceptibility of an account to misstatement, was the focus of Chapter 4; this chap- ter focuses on control risk assessment. Recall that control risk is the probability that an

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Our management is responsible for establishing and maintaining adequate internal control over financial reporting . . . Our internal control over financial reporting is designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with U.S. GAAP and includes those policies and procedures that: (1) pertain to the maintenance of records that in reasonable detail accurately and fairly reflect our transactions and the dispositions of our assets; (2) provide reasonable assurance that our transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles and that our receipts and expenditures are being made only in accordance with appropriate authorizations; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of our assets that could have a material effect on our financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Projections of any evaluation of effectiveness for future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate. Under the supervision of and with the participation of our management, we assessed the effectiveness of our internal control over financial reporting as of September 2, 2018, using the criteria set forth by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) in Internal Control—Integrated Framework (2013). A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of our annual or interim financial statements will not be prevented or detected on a timely basis.

We identified a material weakness in internal control related to ineffective information technology general controls (ITGCs) in the areas of user access and program change-management over certain information technology (IT) systems that support the Company’s financial reporting processes. Our business process controls (automated and manual) that are dependent on the affected ITGCs were also deemed ineffective because they could have been adversely impacted. We believe that these control deficiencies were a result of: IT control processes lacking sufficient documentation such that the successful operation of ITGCs was overly dependent upon knowledge and actions of certain individuals with IT expertise, which led to failures resulting from changes in IT personnel; insufficient training of IT personnel on the importance of ITGCs; and risk-assessment processes inadequate to identify and assess changes in IT environments that could impact internal control over financial reporting. The material weakness did not result in any identified misstatements to the financial statements, and there were no changes to previously released financial results. Based on this material weakness, the Company’s management concluded that at September 2, 2018, the Company’s internal control over financial reporting was not effective.

The Company’s independent registered public accounting firm, KPMG LLP has issued an adverse audit report on the effectiveness of the Company’s internal control over financial reporting as of September 2, 2018, which appears in Item 8 of this Form 10-K. Following identification of the material weakness and prior to filing this Annual Report on Form 10-K, we completed substantive procedures for the year ended September 2, 2018. Based on these procedures, management believes that our consolidated financial statements included in this Form 10-K have been prepared in accordance with U.S. GAAP. Our CEO and CFO have certified that, based on their knowledge, the financial statements, and other financial information included in this Form 10-K, fairly present in all material respects the financial condition, results of operations and cash flows of the Company as of, and for, the periods presented in this Form 10-K. KPMG LLP has issued an unqualified opinion on our financial statements, which is included in Item 8 of Form 10-K.

Management has been implementing and continues to implement measures designed to ensure that control deficiencies contributing to the material weakness are remediated, such that these controls are designed, implemented, and operating effectively. The remediation actions include: (i) creating and filling an IT Compliance Oversight function; (ii) developing a training program addressing ITGCs and policies, including educating control owners concerning the principles and requirements of each control, with a focus on those related to user access and change management over IT systems impacting financial reporting; (iii) developing and maintaining documentation underlying ITGCs to promote knowledge transfer upon personnel and function changes; (iv) developing enhanced risk assessment procedures and controls related to changes in IT systems; (v) implementing an IT management review and testing plan to monitor ITGCs with a specific focus on systems supporting our financial reporting processes; and (vi) enhanced quarterly reporting on the remediation measures to the Audit Committee of the Board of Directors. We believe that these actions will remediate the material weakness. The weakness will not be considered remediated, however, until the applicable controls operate for a sufficient period of time and management has concluded, through testing, that these controls are operating effectively. We expect that the remediation of this material weakness will be completed prior to the end of fiscal 2019. http://investor.costco.com/static-files/c812aa61-1f39-4ee8-b1bd-314b3d8b0b20

EXHIBIT 5.1 Excerpts from Costco Wholesale Corporation’s Management Report on Internal Control over Financial Reporting

entity’s controls will fail to prevent or detect material misstatements due to errors or frauds that would otherwise have entered the system. The audit team assesses control risk to complete the preliminary determination of RMM for each relevant assertion identified in the audit plan; the higher the assessment of control risk, the higher the assessment of RMM. Most audit teams express their control risk assessment decision with descriptive terminology (e.g., high, moderate, low), which recognizes the imprecise nature of evalu- ating risk.

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178 Part Two The Financial Statement Audit

An audit team’s assessment of control risk as high implies that the controls are not effective at preventing or detecting material misstatements and could not be relied upon by the audit team. In this situation, the audit team would likely use substantive tests of details designed to obtain evidence (nature) at or near the entity’s fiscal year-end (timing) with large sample sizes (extent).

On the other hand, an audit team’s assessment of control risk as low implies that the controls are effective at preventing or detecting material misstatements and could possi- bly be relied upon by the audit team. In this situation, the audit team might be able to use less time-consuming substantive analytical procedures to obtain evidence (nature) at an interim date before the entity’s fiscal year-end (timing) with much smaller sample sizes (extent).

Of course, an audit team might assess control risk as moderate (between low and high) and adjust the substantive procedures accordingly in order to obtain enough evidence to mitigate the risk of material misstatement to a low level for the relevant assertion being tested. Ultimately, the final decision about nature, timing, and extent of testing is a matter of professional judgment for the audit team. Exhibit 5.2 illustrates the trade-off between testing and relying on internal controls and how it impacts the nature, timing, and extent of further audit procedures to be performed.

Third, for each fraud risk identified during the planning stage, the audit team should evaluate whether the client has implemented control activities that are specifically designed to address the risk of fraud that has been identified. These might include control activities that are designed to address fraud risks for specific financial statement accounts or, more generally, control activities that are designed to promote a culture of honest and ethical behavior. For example, the audit team evaluates the controls related to the use of period-end journal entries on each audit engagement due to their frequent use in the past to commit frauds at companies such as WorldCom, Waste Management, and Dell Inc.

  Less Reliance on Internal Control(higher control risk; lower detection risk)

More Reliance on Internal Control(lower control risk; higher detection risk)

Nature More effective tests (for example, use of substantive tests of detail)

Less effective tests (for example, use of substantive analytical procedures)

Timing Testing performed at year-end Testing can be performed at interim Extent Higher sample size Lower sample size

EXHIBIT 5.2 Relationship between Internal Control Reliance and Audit Procedures

REVIEW CHECKPOINTS 5.3 What are management’s and auditors’ respective responsibilities regarding internal control? 5.4 Define control risk and explain the role of control risk assessment in audit planning. 5.5 What are the primary reasons for conducting an evaluation of an audit client’s internal control? 5.6 How does control risk affect the nature, timing, and extent of further audit procedures?

COMPONENTS OF INTERNAL CONTROL According to the COSO3 framework, an internal control system that is designed and operat- ing effectively will have met three overarching goals within an organization (Exhibit 5.3). First, the system will allow for effective and efficient operations. Second, it will allow for reliable financial reporting. And, third, the system will allow the organization to comply with laws and regulations.

LO 5-3 Define and describe the five basic components of internal control and specify some of their characteristics.

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To achieve the specific objectives for each of these three goals, the COSO frame- work defines five interrelated components of a properly designed internal control system: (1) control environment, (2) risk assessment, (3) control activities, (4) monitoring, and (5) information and communication. It is important to point out that the five components should not operate independently of each other. Instead, they should be considered as working in an integrated manner to support the internal control system’s overall effectiveness.

To help facilitate the evaluation of internal control effectiveness, the COSO frame- work identifies 17 principles of an effective internal control system. These principles are designed to provide clarity in determining what is meant by internal control effectiveness for each component (i.e., is it present and functioning) and are used by auditors to help evaluate whether the internal control system is indeed operating effectively. The principles are now also used to help illustrate each of the five components.

Control Environment The control environment sets the tone of the organization. It is the foundation for all other components of internal control. It provides discipline and structure to all participants and stakeholders. Control environment factors include the integrity, ethical values, and com- petence of the entity’s people. According to the COSO framework, a well-functioning internal control environment is characterized by philosophies such as the following:

∙ Integrity and ethical values. Sound integrity and ethical values, particularly of top management, are developed and understood and set the standard of conduct for finan- cial reporting.

∙ Board of directors. The board of directors understands and exercises oversight respon- sibility related to financial reporting and related internal control.

∙ Management’s philosophy and operating style. Management’s philosophy and operat- ing style support achieving effective internal control over financial reporting.

∙ Organizational structure. The company’s organizational structure supports effective internal control over financial reporting by establishing clear and unambiguous report- ing lines.

∙ Financial reporting competencies. The company retains individuals who are compe- tent in financial reporting and related oversight roles.

EXHIBIT 5.3 Internal Control— Integrated Framework (COSO)

Definition

Compliance with laws and regulations

Control environment Risk assessment Control activities

Reliable financial reporting

Reliable financial annual and interim reports (e.g., GAAP)

Control environment Risk assessment Control activities Monitoring Information and communication

Monitoring Information and communication

E�ectiveness and e�ciency of operations

Risk assessment Control activities Monitoring Information and communication

Various company- specific objectives

Control environment

Goals

Specific Objectives

Components

Internal control is a management process

designed to achieve

Compliance with laws and regulations that apply to the company

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180 Part Two The Financial Statement Audit

∙ Authority and responsibility. Management and employees are assigned appropriate levels of authority and responsibility to facilitate effective internal control over finan- cial reporting.

∙ Human resources. Human resource policies and practices are designed and imple- mented to facilitate effective internal control over financial reporting.

Most importantly, the effectiveness of the control environment is influenced heavily by a company’s management team and is strongly and unquestionably related to the “tone at the top” set by management. The key is for management to be deliberate in trying to impact the attitudes toward internal controls throughout the organization by setting the proper example for the organization to follow. It has been said that the control environ- ment has a “pervasive” effect on the reliability of financial reporting because it affects all other components of an organization’s internal control system.

In February 2019, Hertz Global Holdings Inc. agreed to pay the SEC $16 million to settle accounting fraud charges. Feeling the pressure to meet internal budgets, business plans and earnings estimates, execu- tives at Hertz overstated pre-tax income by $235 million from 2012 to 2014. The managers used improper accounting methodologies that were inconsistent with GAAP in order to meet expectations.

However, Hertz isn’t taking this lying down. The company has sued its former CEO, CFO, General Counsel, and others in an effort to clawback $70 million in incentive compensation that was tied to

the fraudulent financials. According to Hertz’s board, the former CEO “created a pressure-cooker work environment in which he leaned on subordinates to make “inappropriate accounting decisions” so the firm could hit its financial targets” sometimes “berating subordinates who did not come up with “non-traditional” accounting approaches to fill the gaps between Hertz’s actual and expected performance.”

Sources: https://www.sec.gov/enforce/33-10601-s; https://www.bloomberg.com/news/articles/2019-04-01/ hertz-seeks-70-million-in-clawbacks-tied-to-accounting-scandalack,

Tone at the Top - How Hertz Got It WrongAUDITING INSIGHT

Because the control environment sets the overall foundation for internal control, profes- sional auditing standards require an auditor to obtain an understanding of the control environ- ment on all engagements. As part of this understanding, auditors also have to take the time to consider the functioning of the client’s board of directors and, in particular, the impact of its audit committee on the client’s control environment. The audit committee is a subcommit- tee of the board of directors that is generally composed of three to six independent members (those not involved in the entity’s day-to-day management) of the organization’s board of directors. Each member must be financially literate, and one member must be a financial expert. The purpose of including independent members is to provide a buffer between the audit team and the operating management team of the company. The buffer allows the audit team (and the corporate internal audit department) to report any controversial findings to members of the board of directors without fear of reprisal.

For example, should the internal auditors find wrongdoing in the CEO’s office, it would do no good to report the matter to the CEO. Similarly, if management does not have control over appointing auditors, management is prevented from threatening to dis- miss the auditors if they do not agree with an inappropriate accounting practice. Some of the more important duties of the audit committee are

∙ Appointment, compensation, and oversight of the public accounting firm conducting the entity’s audit.

∙ Resolution of disagreements between management and the audit team. ∙ Oversight of the entity’s internal audit function. ∙ Approval of nonaudit services provided by the public accounting firm performing the

audit engagement. ∙ Oversight of the anonymous fraud hotline that is designed to provide employees a con-

fidential and effective manner in which to report possible financial reporting issues. ∙ Authority to engage legal counsel in the event of management fraud.

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Small and midsize entities may implement the control environment factors differently than larger entities. For example, smaller entities might not have a written code of con- duct but instead develop a culture that emphasizes the importance of integrity and ethical behavior through oral communication and by management example. Similarly, a smaller entity may not have an independent or outside member on its board of directors. Regard- less of the size of the entity, the COSO framework establishes five principles which, if applied properly, will result in an effective control environment component. The five principles of the control environment component are listed in Exhibit 5.4.

Risk Assessment In recent years, entities of all sizes have increasingly recognized the need for a formalized process to identify, properly assess, and ultimately manage the full range of business risks that they face: factors, events, and conditions that can prevent organizations from achiev- ing their business objectives. One way managers address these concerns is to employ an enterprise risk management (ERM) framework such as the one developed by COSO to facilitate the assessment and mitigation of business risks that the entity faces. COSO defines ERM as “a process, effected by an entity’s board of directors, management and other personnel, applied in strategy setting and across the enterprise, designed to identify potential events that may affect the entity, and manage risks to be within its risk appetite, to provide reasonable assurance regarding the achievement of entity objectives.”3 In other words, management, boards, and employees have to be constantly thinking about what could go wrong with the business and how they can prevent it.

Although not all entities will employ a robust ERM framework, at a minimum, an effective internal control system will include some type of process where management takes the steps necessary to identify risks, estimate their significance and likelihood, and consider how to manage the risks. By setting management objectives, management can identify critical success factors and institute policies and procedures to ensure that they are met. (Note: The risk assessment element of the COSO framework is management’s responsibility and is not related to an auditor’s assessment of inherent risk, control risk, and the overall risk of material misstatement at the assertion level.) Although an audit client’s risk assessment process should relate to all its objectives, the professional stan- dards require the auditor to specifically gain an understanding of the process as it relates to financial reporting risks, including fraud risk. When gaining such an understanding, the auditor should determine whether management is actually assessing the likelihood of fraud risks and how it is managing such risks.

In completing their work, the audit team members seek to understand whether man- agement is specifying financial reporting objectives with sufficient clarity and criteria to

3COSO, “Enterprise Risk Management—Integrated Framework Executive Summary,” September 2004, New York: AICPA, p. 2.: COSO. “Enterprise Risk Management—Integrating with Strategy and Performance,” June 2017, New York: AICPA.

  Principles of Control Environment as per the COSO Framework

1. The organization demonstrates a commitment to integrity and ethical values.

2. The board of directors demonstrates independence from management and exercises oversight of the development and performance of internal control.

3. Management establishes, with board oversight, structures, reporting lines, and appropriate authorities and responsibilities in the pursuit of objectives.

4. The organization demonstrates a commitment to attract, develop, and retain competent individuals in alignment with objectives.

5. The organization holds individuals accountable for their internal control responsibilities in the pursuit of objectives.

EXHIBIT 5.4 Five Principles of the Control Environment

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enable the identification of risks of material misstatement in financial reporting, in par- ticular due to fraud. Once identified, the audit team also would like to see that manage- ment has a basis for determining how to manage the identified risks. For smaller entities, the risk assessment process is likely to be less formal and less structured. Although all entities should have established financial reporting management objectives, they may be recognized implicitly rather than explicitly in smaller entities. Regardless of the size of the entity, the COSO framework establishes four principles that, if applied properly, will result in an effective risk assessment component when evaluating the system of internal control. The four principles of the risk assessment component are listed in Exhibit 5.5.

EXHIBIT 5.5 Four Principles of the Risk Assessment

  Principles of Risk Assessment as per COSO Framework

1. The organization specifies objectives with sufficient clarity to enable the identification and assessment of risks relating to objectives.

2. The organization identifies risks to the achievement of its objectives across the entity and analyzes the risks as a basis for determining how the risks should be managed.

3. The organization considers the potential for fraud in assessing risks to the achievement of objectives.

4. The organization identifies and assesses changes that could significantly impact the system of internal control.

REVIEW CHECKPOINTS 5.7 What are the five components of management’s internal control? 5.8 What is the control environment? 5.9 What is an audit committee? What are its duties? 5.10 What is the purpose of risk assessment for an entity?

Control Activities In a well-functioning internal control system, once the risks to management’s objectives have been identified, internal control activities are established to eliminate, mitigate, or compensate for the risks. Control activities are specific actions that a client’s management and employees take to help ensure that management’s directives are carried out. The pro- fessional standards require the audit team members to document their understanding of the internal control system on each audit, which includes their understanding of whether management has implemented control activities that are sufficient to address the risks of material misstatement for each relevant assertion related to each significant account or disclosure.

To answer this important question, the audit team members usually begin the process by considering what they learned about the internal control system as they were gaining an understanding of the other components of the COSO framework—in particular, the control environment and risk assessment components described earlier. The next step in the process requires the audit team members to document their understanding of the extent to which each of the client’s control activities has been designed to sufficiently address a relevant financial statement assertion. To do so, an auditor first considers “what could go wrong” for each of the identified relevant assertions. That is, an auditor must consider how a material misstatement could occur for each relevant assertion. Once each “what could go wrong” is identified, an auditor must then determine if management has implemented a control activity that is designed to mitigate the risk of material misstate- ment identified for that assertion. This step will be covered in more depth later in the chapter. However, for now, see Exhibit 5.6 for several examples of this process that might occur for several relevant assertions related to the revenue account.

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Importantly, when documenting their understanding of the internal control system, the audit team should keep in mind the following questions related to control activities:

∙ Information technology. Has the audit client taken full advantage of their existing tech- nological platform (e.g., SAP) by using entirely automated control activities whenever it is efficient and effective?

∙ Level of integration with their risk assessment process. Has the audit client’s manage- ment team taken the actions necessary to sufficiently address the identified risks of material misstatement for each relevant assertion?

∙ Selection and development of control activities. Has the audit client’s management team designed and implemented control activities with full consideration of their cost and their potential effectiveness in mitigating the risks of material misstatement identified?

∙ Policies and procedures. Have the policies related to reliable financial reporting been documented and communicated throughout the company by the audit client’s manage- ment team?

In addition, regardless of the size of the entity, the COSO framework establishes three principles that, if applied properly, will result in an effective evaluation of the control activities component. The three principles of the control activities component are listed in Exhibit 5.7.

There are a number of different types of controls in today’s financial statement audit environment. Ultimately, financial reporting control activities are imposed on the account- ing system for the purpose of preventing, detecting, and correcting errors and frauds that could enter and flow through to the financial statements. Clearly, preventive controls, procedures that prevent misstatements before they occur (those that ensure hiring compe- tent people, limiting access, requiring approval, separating duties, etc.), are preferable to detective controls, procedures that detect misstatements after they occur. In some sense, all control activities can be thought of as preventive controls because the possibility of being caught by a detective control might prevent someone from committing an error or a fraud. Control activities also include management review controls, information process- ing controls, physical security controls, and controls that allow for proper separation of duties. Each of these additional categories is now discussed in turn.

Relevant Assertion What Could Go Wrong? Control Activity

Occurrence Sales revenue is recorded when the goods had not been shipped to the customers.

All sales invoices are matched to shipping documents before recording them in the general ledger.

Valuation Goods will be shipped to a new customer who is unable to pay for the goods.

The credit department performs a detailed credit check for all new customers.

Completeness Goods will be shipped to a customer, and the revenue is not recorded.

All shipping documents are matched to sales invoices that have been recorded in the general ledger.

EXHIBIT 5.6 Relevant Assertions, What Could Go Wrong and Control Activities for the Revenue Account

EXHIBIT 5.7 Three Principles of the Control Activities

  Principles of Control Activities as per COSO Framework

1. The organization selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels.

2. The organization selects and develops general control activities over technology to support the achievement of objectives.

3. The organization deploys control activities through policies that establish what is expected and procedures that put policies into action.

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Management Review Controls An audit client’s management team has primary responsibility for ensuring that the organization’s objectives are being met. As a result, management review controls are an important way for a management team to actively participate in the supervision of opera- tions. For example, management’s study of budget variances with follow-up action is an example of a management review control. In general, a management team that performs more frequent reviews has more opportunities to detect errors in the records than man- agement that does not perform frequent reviews. The frequency, of course, is governed by the costs and benefits. In addition, subsequent action to investigate or correct differences is critically important to demonstrate that the control is truly operating in an effective manner. Without a doubt, periodic management reviews and subsequent follow-up action to correct identified errors tends to lower the risk that material misstatements exist in the financial statement accounts.

Information Processing Control Activities Information processing control activities are essential to the effectiveness of an internal control system. Generally speaking, all organizations employ computerized information processing on a routine basis. When entities use computerized information processing, the professional standards make clear that information technology (IT) poses specific risks to an entity’s internal control system. And, although the focus of this chapter is on providing a broad understanding of internal control, you should be aware that the use of computerized information processing requires entities to implement specific control activities to enable it to support the relevant financial statement assertions.

For staff auditors in today’s financial statement audit environment, the most important information processing control activities are the ones that are designed to ensure the com- pleteness and accuracy of system generated reports. Recall from Chapter 1 that a system generated report is a report generated by the audit client’s information system that is used to execute its internal control procedures or produce its financial statements. If such a report is used by the audit client’s management for either of these purposes, the client must have control activities in place to ensure that each report is complete and accurate. See Exhibit 5.8 for several examples of system generated reports and the related control activity where the report is needed for its proper execution.

The full range of auditing considerations that are relevant to an audit client’s comput- erized information processing environment are discussed in detail in Module H. How- ever, before moving on, it is important to realize that even “spreadsheet goofs” can pose risks to an entity’s internal control system, as shown in the following Auditing Insight. In addition, although almost all organizations employ computerized information process- ing, manual controls over certain information processing activities remain important in many systems. For example, important manual control activities over the purchasing and cash disbursement cycle include using purchase orders to ensure proper authorization (the occurrence assertion), matching vendor invoices with receiving reports and purchase orders to ensure that the quantity billed agrees with the quantity ordered and received

EXHIBIT 5.8 System Generated Reports and Internal Control Activities

System Generated Reports Internal Control Activities

Accounts Receivable Aging Report The accounts receivable aging report is generated on a monthly basis by the information system. The report is reviewed by the Chief Financial Officer to evaluate the adequacy of the allowance for doubtful accounts.

Three-Way Match Exception Report The three-way match exception report is generated on a weekly basis by the information system. The report is reviewed by the accounts payable clerk and all exceptions are followed up on and resolved by the clerk.

New Hires Report The new hires report is generated on a quarterly basis by the information system. The report is reviewed by the payroll clerk to ensure that all new employees are reflected in payroll expense.

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at previously agreed-upon prices (the accuracy assertion), and using and accounting for prenumbered documents (checks, purchase orders, and receiving reports) to ensure that all transactions have been recorded (the completeness assertion). (Note: Failure to account for the numeric sequence of documents eliminates the benefit of prenumbering.) The specific control activities for each cycle are discussed in more detail in Chapters 6 through 10.

TransAlta Corp. confessed that a “clerical error” was a costly one— $24 million, to be exact—for the power producer. The Calgary-based company said a spreadsheet goof by an employee caused the com- pany to pay higher than intended rates to ship power in New York. CEO Steve Snyder explained via a conference call that a “cut-and- paste” foul-up within an Excel spreadsheet on a bid to New York’s power grid operator led TransAlta to secure 15 times the capacity of power lines at 10 times the price. The costly human error couldn’t be reversed by the grid operator, and although TransAlta has since tried to recoup the mammoth losses, it was left with a $24 million lesson.

In October 2003, about two weeks after releasing its third- quarter earnings figures, Fannie Mae had to restate its unrealized gains account by $1.2 billion for errors in “mark-to-market” calcula- tions. This was apparently the result of “honest mistakes made in a spreadsheet used in the implementation of the new accounting standard.”

Sources: “Cut-and-Paste Oops Costly for TransAlta,” Canadian Press, June 4, 2003; “Fannie Mae Corrects Mistakes in Results,” The New York Times, October 30, 2003, p. C1.

Spreadsheet GoofsAUDITING INSIGHT

Physical Security Controls Physical access to assets, data and important records, documents, and blank forms should be limited to only authorized personnel. Assets such as inventory and securities should not be available to persons who have no need to handle them. Likewise, access to records should be denied to people who do not have a record-keeping responsibility for them. Some blank forms are very important for accounting and certain control activities, and their availability should also be restricted.

In addition, given the importance of the computerized information processing system, physical security of computer equipment and restricting access to the organization’s data and computer application files are important to achieving effective internal control. Access controls help prevent the improper use or manipulation of data files, unauthorized use of computer programs, and improper use of the computer equipment. Overall, in today’s environment, it is essential that organizations have a robust set of cyber security control activities in place and operating effectively. As illustrated in the following Auditing Insight, sometimes a weakness in cyber security control activities can lead to the loss of assets.

In late 2018, the SEC reported that nine public companies, from a variety of industries including technology, real estate, financial and consumer goods, energy, and more, recently lost nearly $100 million to cyber criminals. The companies were defrauded by two different schemes, emails from fake executives and emails from fake vendors.

According to the report, the spoofed emails from fake executives “were not sophisticated frauds in general design or the use of technol- ogy. In fact, from a technological perspective they only required creat- ing an email address to mimic the executive’s address.” The emails

actually included spelling mistakes! However, the fake vendor emails were more sophisticated and were generally not discovered as fraud until the real vendor contacted the company for payment for its past due invoices. In each case, company personnel wired money to the fraudulent accounts costing each of the nine companies anywhere from $1 million to $45 million dollars that will not be recovered.

Sources: https://www.sec.gov/news/press-release/2018-236: https://www. sec.gov/litigation/investreport/34-84429.pdf.

Did They Really Lose $100 million?AUDITING INSIGHT

Also, locked doors, security passes, passwords, and check-in logs can be used to limit access to the computer system hardware. One way to detect inappropriate computer usage is by specifying a planned schedule for running large-scale computerized applications.

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A schedule can help detect unauthorized access because most software can produce usage reports that can be compared to the planned schedule. Applications that are being run at unauthorized times can then be investigated for inappropriate use of computer resources.

Separation of Duties A very important characteristic of an effective internal control system is that an appro- priate separation of duties (or functional responsibilities) plan is in place. Four types of functional responsibilities should be performed by different departments (see Exhibit 5.9), or at least by different persons on the entity’s accounting staff:

1. Authorization to execute transactions. This duty belongs to people who have the authority and the responsibility for initiating or approving transactions. Authorization may be general, referring to a class of transactions (e.g., all purchases up to $100,000), or it may be specific (e.g., sale of a major asset).

2. Recording transactions. This duty refers to the accounting and record-keeping func- tion, which in most organizations is delegated to a computerized information system. People who control computerized processing are the record keepers.

3. Custody of assets involved in the transactions. This duty refers to the actual physical possession or effective physical control of property.

4. Periodic reconciliation of existing assets to recorded amounts. This duty refers to making comparisons at regular intervals and taking appropriate action with respect to any differences.

Incompatible responsibilities are combinations of responsibilities that place a person alone in a position to create and conceal misstatements due to errors or frauds in her or his normal job. Duties should be divided so that no one person can control more than one of these responsibilities. If different departments or persons are forced to deal with these different facets of transactions, frauds are more difficult to commit because they would then require collusion of two or more persons, and most people hesitate to seek the help of others in order to conduct wrongful acts. A second benefit of separating duties is that by acting in a coordinated manner (handling different aspects of the same transaction), innocent errors are more likely to be found and corrected. The old saying “Two heads are better than one” is often proven to be true.

In most computerized information processing environments, employees who have access to an application (such as payroll) might be in a position to perform incompat- ible functions. As a result, to achieve proper separation of duties, it is essential for an organization to have a well-thought-out plan that limits employees’ access to the com- puterized information processing system (e.g., SAP, Oracle) to only those applications that are necessary for such employees to complete their jobs. In effect, companies must design internal control activities that will effectively limit opportunities for any one indi- vidual to both perpetrate and conceal misstatements or losses due to errors or fraud. In most situations, these often include password access controls that are designed to align the computer access rights to transactions, data, key documents, and assets with only those employees who require such access to complete their clearly defined role within the internal control system. In a sense, proper separation of duties is accomplished through appropriate system access controls.

EXHIBIT 5.9 Separation of Duties

Authorization

Reconciliation

RecordingCustody

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Level of Automation When gaining an understanding of an internal control system, it is important for the audi- tor to consider the level of automation used to execute each control activity. In general, control activities are categorized by auditors as purely manual controls, manual controls that rely on a system generated report, and entirely automated controls.

Manual controls are control activities that operate in a completely manual manner with full dependence on a person. An example of this control would be a three-way match control in the purchases cycle where the accounts payable clerk was responsible for phys- ically matching the details of a purchase order, receiving report, and a vendor invoice before authorizing the amount for payment. Since the control is operated manually with- out the use of the computer information system, there is no reliance on the computer information system for it to operate effectively.

Like purely manual controls, manual controls that rely on a system generated report depend on a person. However, the difference is that the person operating the control must rely on a report that is generated by the computer information system. An example would be a control, executed by the controller, that was designed to evaluate the accounts receiv- able aging report to determine the reasonableness of the allowance for doubtful accounts. Importantly, the proper execution of the control is dependent on the completeness and accuracy of the accounts receivable aging report.

Entirely automated control activities operate completely within the computer infor- mation system. An example of this would be an automated credit approval control that is used by a bank to ensure that it does not extend credit beyond each customer’s credit limit. The proper execution of the control is entirely automated. Thus, when a customer attempts to use the credit card, the amount of the sale is added to that customer’s existing balance and the amount is compared to the credit limit for that customer. If you have ever been denied when attempting to pay for dinner or purchase clothes, you certainly know about this automatized control.

REVIEW CHECKPOINTS 5.11 What is a control activity? 5.12 What is the difference between preventive controls and detective controls? Give an example of each. 5.13 What kinds of functional responsibilities should be performed by different departments or persons

in a control system with good separation of duties?

Information and Communication When evaluating the information and communication component of internal control, the “auditor should obtain an understanding of the information system [emphasis added] includ- ing the related business processes, relevant to financial reporting. As part of that process, the auditor must seek to understand the nature of the underlying accounting records, sup- porting information and the accounts that are used to fully execute a transaction.” The audi- tor should also understand “how the information system captures events and conditions, other than transactions, that are significant to the financial statements.”4 Clearly, the size of the entity will have an impact on this component. However, regardless of the entity’s size. the COSO framework establishes three principles that, if applied properly, will result in an effective evaluation of the information and communication component. The three prin- ciples of the information and communication component are listed in Exhibit 5.10.

The professional standards recognize that to make effective decisions, managers must have access to timely, reliable, and relevant information. As a result, an entity’s infor- mation system should be devised to identify data from reliable external sources such as 4PCAOB Auditing Standard 2110, “Identifying and Assessing Risks of Material Misstatement.”

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suppliers, customers, economic databases, and so on, as well as internal sources. Having superior information systems can be a part of an entity’s strategy and competitive advan- tage (e.g., Amazon.com). Management evaluates the quality of information by determin- ing whether the content is appropriate and the information is timely, current, accurate, and accessible. Note that these sometimes are contradictory. For example, waiting to ensure that information is accurate can cause it not to be timely.

Communication includes report production and distribution. The account balances are summarized in internal management reports and external financial statements. The inter- nal reports are management’s feedback for monitoring operations. The external reports are the financial information for outside investors, creditors, and others. Communication also involves expectations, responsibilities of individuals and groups, and other important matters. Specific duties must be made clear, and people need to know how their activities relate to the work of others. People also need to know what behavior is expected. In addi- tion, personnel need a means of communicating significant information upstream in an organization. Outsiders also should know that fraudulent and unethical behavior by entity personnel is unacceptable and should be reported to management.

The information system produces a trail of activities (often referred to as an audit trail) from data identification to reports. You can visualize that the audit trail begins with the source documents (purchase orders, sales orders, etc.) and proceeds through to the financial reports. Auditors often follow this trail frontward and backward, identifying and testing relevant control activities along the way (Exhibit 5.11). They follow it backward from the financial reports to the source documents to determine whether everything in the financial reports is supported by appropriate source documents (the occurrence asser- tion). They follow it forward from source documents to reports to determine whether everything that happened (i.e., transactions) was recorded in the accounts and reported in the financial statements (the completeness assertion).

Information systems in small or midsize organizations are likely to be less formal than in larger organizations, but their role is just as significant. Smaller entities with active management involvement may not need extensive descriptions of accounting procedures, sophisticated accounting records, or written policies. Communication may be less formal and easier to achieve in a small or midsize company than in a larger enterprise because the smaller organization has fewer levels, and management has more visibility and availability.

One final and very important consideration made by the audit team when gaining an understanding of this component relates to the use of information produced by the company

EXHIBIT 5.11 Occurrence and Completeness of a Sales Transaction

Sales Order SalesAuthorization Shipping

Documents

Occurrence Direction

Completeness Direction

Sales Invoice FinancialStatements

  Principles of Information and Communication as per COSO Framework

1. The organization obtains or generates and uses relevant quality information to support the functioning of internal control.

2. The organization internally communicates information, including objectives and responsibilities for internal control, necessary to support the functioning of internal control.

3. The organization communicates with external parties regarding matters affecting the functioning of internal control.

EXHIBIT 5.10 Three Principles of Information and Communication

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Monitoring The COSO framework recognizes that in order to allow for continuous improvements and consider changes in the entity’s operating environment, management needs to monitor its internal control systems. According to COSO, a well-functioning monitoring system is characterized by philosophies such as the following:

∙ Ongoing and separate evaluations. Ongoing evaluations of controls that are separate from other types of evaluations (e.g., operational) enable management to determine whether the other components of internal control continue to function over time.

∙ Reporting deficiencies. Internal control deficiencies are identified and communicated in a timely manner to those parties responsible for taking corrective action and to management and the board as appropriate.

It is important to note that monitoring does not include regular management and supervisory control activities and other actions that employees take in performing their everyday duties. Effective monitoring involves ongoing evaluation of the controls. Some common monitoring controls include

∙ Periodic evaluation of controls by the internal audit department. ∙ Analysis of and appropriate follow-up of operating reports or metrics that might iden-

tify anomalies indicative of a control failure. ∙ Supervisory review of controls, such as reconciliation reviews as a normal part of

processing. ∙ Self-assessments by boards and management regarding the tone they set in the organi-

zation and the effectiveness of their oversight functions. ∙ Audit committee inquiries of internal and external auditors. ∙ Quality assurance reviews of the internal audit department.5

5Guidance on Monitoring Internal Control Systems, COSO, January 2009.

In a recent public report about its inspections program, the PCAOB specifically discussed a recurring finding related to information that is produced by the entity being audited. Specifically, the PCAOB noted that its “inspections staff has continued to observe instances in which auditors selected controls for testing but did not sufficiently test the controls over completeness and accuracy of system-generated data or reports used in the operation of those controls.” For example, “man- agement used reports that were generated by the issuer’s information system to perform its review control; however, the engagement team did not test controls over the accuracy and completeness of these reports. In addition, the engagement team did not test the reports to verify the completeness and accuracy of the individual variance

calculations to determine whether the investigation of other variances was necessary.” Because an entity’s use of IT affects the fundamental manner in which information is produced, it is essential that an auditor is comfortable with the completeness and accuracy of all information used by management to execute control activities that are deemed important to the auditor.

Source: PCAOB Staff Inspection Brief - Preview of Observations from 2016 Inspections of Auditors of Issuers. Volume 2017/4. November 2017; PCAOB Observations from 2010 Inspections of Domestic Annually Inspected Firms Regarding Deficiencies in Audits of Internal Control over Financial Reporting. PCAOB Release No. 2012-006. December 10, 2012 (both available at www. pcaobus.org).

PCAOB Identifies Deficiencies Related to System-Generated Data

AUDITING INSIGHT

during the audit (like System Generated Reports discussed previously). The professional standards are clear that an auditor cannot ever rely on information produced by the com- pany’s information system without investigation. Instead, the audit team is required to per- form audit procedures that are designed either to test the controls that have been designed to ensure that the information is complete and accurate or to test the completeness and accu- racy of the information using substantive testing procedures. The following Auditing Insight demonstrates the focus of the PCAOB on the importance of this issue.

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As you can see, some of the control activities explained earlier in this chapter also serve as monitoring activities. For example, analyzing customer complaints for follow-up is a control activity, but analyzing them to determine whether the complaints result from a weakness in other controls (e.g., a failure to compare shipping documents to customer orders) is a monitoring activity.

Although the preceding procedures provide management daily monitoring opportuni- ties, the oversight provided to the entity by the board of directors (and, more specifically, the audit committee) provides the highest level of monitoring. In addition, management’s close involvement in operations often will identify significant variances from expecta- tions and inaccuracies in financial data. Finally, ongoing monitoring activities of small and midsize entities are more likely to be informal and are typically performed as a part of the overall management of the entity’s operations. However, regardless of the entity’s size, the COSO framework establishes two principles that, if applied properly, will result in an effective evaluation of the monitoring component. The two principles of the moni- toring component are listed in Exhibit 5.12.

Limitations of Internal Control Internal control provides reasonable assurance, not absolute assurance, that management’s objectives will be achieved. Because people operate the controls, breakdowns can occur. Internal control can help prevent and detect many errors, but it cannot guarantee that they will never happen. In that spirit, several limitations to internal control systems prevent management from obtaining complete assurance that controls are absolutely effective:

∙ Human error due to mistakes in judgment, fatigue, and carelessness can still occur. ∙ Although controls are implemented to prevent and detect errors, deliberate circumven-

tion by people in the system can still occur. ∙ Because most internal controls are directed at lower-level employees, management

override can occur. For example, it is often possible for management to override con- trols by force of authority (i.e., if the CEO says to do something, most employees will).

∙ Although separation of duties can be extremely effective in an internal control system, collusion among people who are supposed to act independently can lead to a failure in the achievement of relevant internal control objectives.

In addition, one other limitation deserves special consideration. That is, an internal control system is always subject to cost–benefit considerations. Internal control could be made perfect, or nearly so, but at great expense. For example, at the lowest level of con- trol, a company’s inventory could be left completely unlocked and unguarded (i.e., with no controls at all); next, a fence could be used; locks could be installed; lighting could be used all night; television monitors could be put in place; or at the highest level of control, armed guards could be hired. Each of these successive safeguards costs additional money (as does extensive supervision of clerical personnel in an office). At some point, the cost of protecting the inventory from theft (or the cost of supervisors catching every clerical error) exceeds the benefit of the internal control activity. In the professional auditing standards, the concept of reasonable assurance recognizes that the costs of controls should not exceed the benefits that are expected from the controls. Hence, an entity can decide that certain controls are too costly considering the risk of loss that can occur. Finally, it is important for students to remember that internal control is a process, a means for

EXHIBIT 5.12 Two Principles of Monitoring Activities

  Principles of Monitoring Activities as per COSO Framework

1. The organization selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning.

2. The organization evaluates and communicates internal control deficiencies in a timely manner to those parties responsible for taking corrective action, including senior management and the board of directors, as appropriate.

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REVIEW CHECKPOINTS 5.14 What is meant by the information and communications component of an effective internal control

system? How can an auditor evaluate whether a client’s internal control system is functioning properly for this component?

5.15 Give some examples of everyday work an entity’s management can use to enact the monitoring component of internal control. When are such activities control activities, and when are they monitoring activities?

5.16 What is the concept of reasonable assurance? What are the key limitations of an internal control system?

INTERNAL CONTROL EVALUATION To this point, we have defined internal control, identified management’s and the audit team’s responsibility for internal control, and described the five components of internal control defined by COSO. These components are considered to be criteria for evaluating an entity’s internal control over financial reporting and the bases for an auditor’s assess- ment of control risk for each relevant assertion about each significant financial statement account or disclosure. In assessing control risk, audit teams typically use a three-phase procedure illustrated in Exhibit 5.13. It is important to note that these phases must be com- pleted for each relevant financial statement assertion level if the auditor plans to rely on a control activity to modify the nature, timing, and extent of substantive audit procedures.

Phase 1: Understand and Document the Client’s Internal Control The process of obtaining an understanding of internal controls should occur early in the audit engagement. On every audit engagement, the audit team should evaluate the design of internal control and determine whether controls have been implemented over all rel- evant assertions related to each significant account and financial statement disclosure. The  procedures used to gain an understanding of internal controls provide the audit team an overall acquaintance with the control environment and management’s risk assessment, the flow of transactions through the accounting system, and the design of some client control activities. Gaining an understanding of internal controls should be performed in a “top-down” risk-based manner that first identifies significant accounts and disclosures and their relevant assertions. This was discussed in Chapter 4. Recall that an account’s significance is based on its inherent risk (i.e., the likelihood of containing a material mis- statement before the consideration of internal control). Thus, audit teams focus on likely sources of significant misstatements. This determination is not based on quantitative mea- sures alone, but it is unlikely that a large, material account balance would ever be omitted from consideration. Relevant assertions are those that represent the possibility of a material misstatement. Thus, an assertion that does not represent a meaningful risk of misstatement (e.g., completeness of cash) is not relevant and should not be considered by the audit team.

LO 5-4 Explain the process the audit team uses to assess control risk; understand its impact on the risk of material misstatement; and, ultimately, know how it affects the nature, timing, and extent of further audit procedures to be performed on the audit.

Understand and Document the Client’s Internal Control

Assess the Control Risk (Preliminary)

Identify Controls to Test and Perform Tests of Control

management to achieve its objectives, not an end in itself. It is also dynamic, operating every day within an entity’s operating structure, which can and does evolve as the entity and its operating environment change over time.

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192 Part Two The Financial Statement Audit

EXHIBIT 5.13 Phases of Internal Control Evaluation Obtain an understanding

of internal control

Control environment Risk assessment Control activities Information and Communication Monitoring

Narrative memo Flowchart Questionnaire

Assess control risk (preliminary assessment)

Perform tests of controls of the specified controls

Specify the controls to be tested and the degree of compliance required

Perform the planned (or revised) substantive procedures

Document the basis for assessing control risk less than 100%

Can control risk

be low or less than maximum?

Is reduction of the control risk

assessment cost e�ective?

Document the understanding

Ph as

e 3:

T es

tin g

Ph as

e 1:

U nd

er st

an di

ng Ph

as e

2: A

ss es

sm en

t

Design a preliminary program of substantive procedures for auditing the relevant assertions about significant financial statement accounts and disclosures

Yes

Yes

No

No

No

Yes Is the

actual degree of compliance comparable

to the required degree?

Assess high or maximum (100%) control risk and design the audit program for more e�ective substantive procedures

Identifying Entity-Level Controls For all the relevant assertions for each significant account and disclosure, audit teams begin by examining entity-level controls, controls that are pervasive to the internal control system and the reliability of the financial statements taken as a whole. See Exhibit 5.14 for the PCAOB’s list of entity-level controls from the professional standards and the audit team’s methods of obtaining an understanding of such controls. Notice that the PCAOB explicitly includes parts or all of the COSO framework elements. This is deliberate. If the audit team decides that an entity-level control sufficiently reduces a specific risk of material misstatement for a relevant assertion, it may not need to delve further into transaction-level controls (discussed next) related to that risk. For example, if a chief financial officer who is very familiar with the company’s payroll process performs reviews

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Types of Entity-Level Controls Assessment

• Controls related to the control environment • Controls related to management override • Centralized processing and controls

including shared service environments • Controls to monitor results of operations • Controls to monitor other controls.

The primary evidence to test these controls is gathered through observation and inquiry and some document examination. Ultimately, the auditor needs to determine whether management’s integrity, values, and operating style promote effective control consciousness throughout the entity.

• Management’s risk assessment The audit team next needs to gain an understanding of how the client assesses and responds to risk. If the client already uses enterprise risk management, inquiring and obtaining documentation of such processes is usually enough.

• Period-end financial reporting process The auditor should assess the processes that are used to produce its annual and quarterly financial statements, including the extent to which IT is involved in the period-end process. The auditor must document who is actually participating from the management team and where the process actually takes place. Finally, the auditor needs to understand and document the types of adjusting entries that have occurred and the extent of process oversight by the management team, the board, and the audit committee.

• Policies that address significant business control and risk management practices

An entity’s internal auditors and systems staff often review and evaluate this documentation. Independent auditors may review and study their work instead of doing the same tasks over again. Other sources of information include (1) previous experience with the entity as found in the prior-year audit, (2) responses to inquiries directed to client personnel, and (3) examination of documents and records.

EXHIBIT 5.14 Entity-Level Controls and Their Assessment

of weekly payroll reports and investigates discrepancies thoroughly, this may provide a control that is sufficient to meet the internal control objectives for payroll reporting (i.e., address or mitigate the risk of material misstatement for each of the relevant assertions for payroll expense).

In addition to entity-level controls, the audit team also identifies transaction-level controls, controls that pertain to specific classes of transactions, account balances, and disclosures. The most effective method used to gain an understanding of (1) the flow of transactions; (2) the points at which a material misstatement could occur; and (3) the controls that management has implemented to mitigate each risk of material misstatement identified is to perform a walkthrough of a single transaction through the entire accounting system. During the walkthrough, the auditor is able to learn by observing the activities that occur and the documents that are used within an internal control process. The auditor must come to understand internal control in order to evaluate design effectiveness.

Design effectiveness determines whether the controls over financial reporting, if operating effectively, would be expected to prevent or detect errors or fraud that could result in a material misstatement in the financial statements. A walkthrough consists of a combination of inquiry of personnel, observation of an entity’s operations, and docu- ment examination while tracing a single transaction through the entire audit trail from the beginning or the initiation of the transaction to its final inclusion in the financial statements. Each client employee involved is asked to demonstrate the procedures that he or she follows in processing the transaction. The walkthrough is an important step in awareness because, often, the information that is contained in manuals and understood by supervisors may not be the same as the procedures actually being performed. People can change procedures to make them more efficient, they can forget to perform procedures, they may go on vacation, they may intentionally not perform procedures, or the proce- dures may not be understood by a new person taking over that position.

At this point, the audit team has learned the design of controls (or how those controls are intended to function). However, this does not inform the audit team as to the operat- ing effectiveness of controls unless there is some automation that provides for the con- sistent application of the operation of the control. Additionally, reperformance of critical controls along the transaction trail can take place at this time to provide evidence of

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194 Part Two The Financial Statement Audit

operating effectiveness. Operating effectiveness refers to whether the control is operat- ing as designed and whether the person performing the control possesses the necessary authority and qualifications to perform the control effectively. Evidence of this nature will be obtained in a subsequent phase of the audit team’s study of internal control.

Document the Internal Control Understanding Once the audit team has completed the walkthrough and learned about the design and implementation of the entity’s internal control system, it is required to document that understanding. The understanding can be summarized and documented effectively in the form of narratives, flowcharts, and even questionnaires. Each of these is now discussed.

The most common way for documenting the audit team’s understanding of internal con- trol is to write a narrative description of each significant process within the internal control system. Such a narrative simply describes all environmental elements, the process flow of transactions through the accounting system, and all control activities. The narrative description can be quite useful for all audits. However, for a large entity, this description may make it difficult to identify the points in the process where a material misstatement might occur, also known as process risk points.

Another method for documenting the auditors’ understanding of an entity’s internal control system is to construct an accounting process flowchart. In today’s financial state- ment audit environment, many companies have their own flowcharts that the audit team may use as a starting point instead of constructing their own from scratch. The advan- tages of flowcharts can be summarized by an old adage: “A picture is worth a thousand words.” Flowcharts tend to help the audit team better assess the points in the process where a material misstatement can occur which helps to reveal key points in the process where a control activity is needed. This of course can be quite beneficial in helping audit teams identify missing control activities in the process.

Construction of a flowchart can be quite time-consuming because an auditor must take the time to learn about the operating personnel involved in the system and gather samples of relevant documents. Thus, the information for the flowchart, like the narrative descrip- tion, involves much effort and observation. When the flowchart is complete, however, the result is an easily evaluated, informative description of the system that shows the various duties performed by individuals and provides graphic evidence of any conflicting responsibilities (i.e., lack of separation of duties). Further, once a flowchart is complete, subsequent audits can easily access the flowchart and update it for changes that have been made in the process since the prior year. In recent years, flowcharting has become even more popular as a way to document an auditor’s understanding of the internal con- trol system, primarily because of its effectiveness in evaluating internal control design. In  addition, advances in technological tools have also made the construction of a flow- chart much more efficient.

For any flowcharting application, the chart must be understandable to an audit super- visor. Flowcharts are created with audit-specific flowcharting software but also can be created rather easily in Excel or PowerPoint. The flowchart should communicate all rel- evant information and evidence about separation of responsibilities, authorization, and accounting and control activities in an understandable, visual form. The starting point in the system, if possible, should be placed at the upper-left-hand corner. The flow of procedures and documents should be from left to right and from top to bottom as much as possible. The shapes of the symbols are commonly understood and fairly obvious. For example, rectangles are processes, circles are connectors, quadrilaterals are manual processes, and so on. Narrative explanations should be written on the face of the chart as annotations or in a readily available reference key.

Refer to Exhibit 5.15 for a partial flowchart representation of the beginning stages of a payroll processing system. The connectors shown by the circled numbers indicate con- tinuation on the flowchart. Ultimately, the flowchart ends showing entries in accounting journals and ledgers. In Exhibit 5.15, you can see some characteristics of both flowchart construction and this specific accounting system. By reading down the columns for each

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department, you can see that transaction-initiation authority (both hiring and time card preparation) and custody of checks are separated.

A third way to document the auditor’s understanding of an internal control system is to conduct a formal interview with knowledgeable managers using an internal control questionnaire illustrated in Exhibit 5.16. Such a questionnaire is typically organized under headings that identify questions related to relevant themes like the control environment and relevant management assertions. Not all questionnaires are organized like this, so audit teams need to know the general objectives in order to know whether the question- naire is complete. Likewise, if you are assigned to prepare an internal control question- naire, you will need to be careful to include questions about each relevant assertion.

Internal control questionnaires are designed to help the audit team obtain evidence about the control environment and the accounting and control activities that are con- sidered appropriate for normal circumstances. All organizations have unique features, and answers to the questions should not be taken as final and definitive evidence about how well controls actually function. Evidence obtained through the interview process is categorized as inquiry-level information that is not sufficient to demonstrate the operat- ing effectiveness of a control activity. The person being interviewed could always give answers that reflect what the system should be rather than what it really is. The person can be unaware of informal ways in which duties have been changed or can be innocently ignorant of the system details. Nevertheless, interviews and questionnaires can be useful for detecting internal control weaknesses.

One key advantage of using internal control questionnaires is that audit teams are less likely to forget to cover some important point. Questions are worded such that a “no” answer points out a weakness or control deficiency, thus making analysis easier. However, audit teams should be aware that entity personnel often fully understand that “yes” answers are “good” and “no” answers are “bad,” so they tend to tell audit teams yes all the time. Good auditors often change a question when they ask it, just to ensure that the interviewee is listening and not giving only yes answers. Also, internal control

EXHIBIT 5.15 Payroll System Flowchart

Employment Authorization

Employment Authorization

Operating Department

Human Resources Payroll

Information Technology

Review Review

Payroll Program

1

2

1 3

Initiates Hiring

Approved by

Supervisor

Time Record

Labor Distribution

Payroll Register

Tax and Payroll Reports

Update Master

File

Approves Hiring To

Employee

2

3

Paycheck or

Direct Deposit Payroll Master

File

Labor Distribution

Payroll Register

Tax and Payroll Reports

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196 Part Two The Financial Statement Audit

  Yes/No Comments

Control Environment    

1. Are all employees paid by check or direct deposit?    

2. Is a special payroll bank account used?    

3. Are payroll checks signed by persons who do not prepare checks or keep cash funds or accounting records?

   

4. If a check-signing machine is used, are the signature plates controlled?    

5. Is the payroll bank account reconciled by someone who does not prepare, sign, or deliver paychecks?    

6. Are payroll department personnel rotated in their duties? Required to take vacations? Bonded?    

7. Is there a timekeeping department (function) independent of the payroll department?    

8. Are authorizations for deductions signed by the employees on file?    

Occurrence    

9. Are time cards or piecework reports prepared by the employee approved by her or his supervisor?    

10. Is a time clock or other electromechanical or computerized system used?    

11. Is the payroll register sheet signed by the employee preparing it and approved prior to payment?    

12. Are names of terminated employees reported in writing to the payroll department?    

13. Is the payroll periodically compared to personnel files?    

14. Are checks distributed by someone other than the employee’s immediate supervisor?    

15. Are unclaimed wages deposited in a special bank account or otherwise controlled by a responsible officer?

   

16. Do internal auditors conduct occasional surprise distributions of paychecks?    

Completeness    

17. Are names of newly hired employees reported in writing to the payroll department?    

18. Are blank payroll checks prenumbered and the numerical sequence checked for missing documents?    

Accuracy    

19. Are all wage rates determined by contract or approved by a personnel officer?    

20. Are timekeeping and cost accounting records (such as hours, dollars) reconciled with payroll department calculations of hours and wages?

   

21. Are payrolls audited periodically by internal auditors?    

22. Are individual payroll records reconciled with quarterly tax reports?    

Classification    

23. Do payroll accounting personnel have instructions for classifying payroll debit entries?    

Cutoff    

24. Are monthly, quarterly, and annual wage accruals reviewed by an accounting officer?    

EXHIBIT 5.16 Internal Control Questionnaire—Payroll Processing

questionnaires tend to be inflexible. If a key question is not included on the list because the question is unique to a client, the auditor might not even know to ask the question. Thus, for new clients, other methods of gaining an understanding that are tailored to the client are preferable. In practice, audit teams typically use a combination of methods to document their understanding of the client’s internal control.

Key Decision: Deciding Whether to Continue to Test Controls For an integrated audit at an issuer, the auditor must test controls for all relevant assertions for each significant account and disclosure. This will be discussed in detail later in this chapter. However, for audits of non-issuers, after the audit team members have documented their understand- ing of the entity’s internal control, an important decision needs to be made: Should the

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audit team perform tests of the operating effectiveness of those controls? Audit teams may choose not to do so for one of two reasons. First, the audit team may conclude that the internal control system is too ineffective in preventing or detecting misstatements to rely upon and justify reductions of subsequent substantive audit procedures for the rel- evant assertions. This conclusion is equivalent to assessing control risk at the highest level and planning more extensive substantive testing procedures. Consider for a moment the Costco management report presented earlier that identified a material weakness in the internal control system. In such a situation, since the audit team would not likely be able to rely upon the internal control system, they would have no choice but to conduct significant substantive testing to make sure that the audit is conducted in an effective manner.

For the audits of non-issuers, a second reason that audit teams might not test controls would be the team’s decision that it would take more time to test the operating effective- ness of the control activities than it would take to perform the substantive tests necessary for a relevant assertion (even if the controls turn out to be working well). In this situation, the cost of obtaining a low control risk assessment can be high. In this case, the conclu- sion is also equivalent to assessing control risk at 100 percent, but this time it is because the audit team has not conducted the tests of operating effectiveness of control activities, not because the team has concluded that controls are ineffective.

For either reason, however, the result is the same: More extensive and effective substantive procedures are required to be completed in order to reduce the risk of mate- rial misstatement for a relevant assertion to an acceptably low level. For example, sup- pose the extensive testing of controls over the accuracy of payroll expenses is estimated to take 40 hours. Also suppose that, if controls were excellent, the substantive tests of payroll accuracy (e.g., confirmation sent to employees) could be reduced by 30 hours. The additional work to test controls is not economical. The decision to stop work on control risk assessment in this case is a matter of audit efficiency—it doesn’t make sense to spend 40 hours testing controls to reduce substantive tests by 30 hours. Of course, the auditors’ rationale for their final decision must be carefully documented. Before moving on, remember that this decision is appropriate only for non-issuers; audit teams must extensively test internal control over financial reporting for issuers.

REVIEW CHECKPOINTS 5.17 What is meant by a “top-down” approach to evaluation of internal controls? 5.18 Must the overall understanding of internal control always be followed by assessment and testing

phases? Explain. 5.19 Where can an auditor find a client’s documentation of the accounting system? 5.20 What are the advantages and disadvantages of documenting internal control by using (1) an

internal control questionnaire, (2) a narrative memorandum, and (3) a flowchart?

Phase 2: Assess the Control Risk (Preliminary)

Understand and Document the Client’s Internal Control

Assess the Control Risk (Preliminary)

Identify Controls to Test and Perform Tests of Control

After completing phase 1—understanding and documenting internal control—the audit team should be able to make a preliminary assessment of control risk. At this prelimi- nary stage, the audit team members also may use their internal control findings from the

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198 Part Two The Financial Statement Audit

Significant Account

Relevant Assertions What Could Go Wrong? Internal Control Activity

Cash

Existence The cash balance may not exist in the company’s bank accounts.

The CFO performs a detailed review of the bank reconciliation on a monthly basis.

Valuation The cash balance that is held in foreign countries may not have been translated properly.

The treasurer reviews the cash translation adjustment calculation monthly and independently checks that the appropriate spot rate has been used for each foreign currency.

Presentation and disclosure

There may be restrictions on the cash balance that were not properly disclosed.

The corporate secretary reviews the cash footnote disclosure on a quarterly basis to ensure that all legal restrictions on the cash balance have been properly disclosed.

Accounts Receivable

Existence Accounts receivable balances are inflated and don’t really exist.

Check sales order and shipping document to make sure sales were earned and a customer owes a balance.

Completeness Not all accounts receivable have been recorded.

Check invoices with shipping document to A/R ledger.

Valuation Receivables are not included in financial statements at the appropriate amount, and valuation adjustments are not recorded properly.

Management evaluates the collectability of delinquent receivables on a timely basis.

EXHIBIT 5.17 What Could Go Wrong and Control Activities

previous year’s audit. At this stage of the process, auditors seek to identify internal con- trol activities that are explicitly designed to support reliable financial statement reporting for the relevant financial statement assertion identified about each significant account and disclosure. It is important to remember that a well-designed internal control system will clearly link key internal control activities to the relevant financial statement asser- tions being supported. Exhibit 5.17 provides an illustration of this step by extending the exhibit that was developed in Chapter 4 (Exhibit 4.12) with a fourth column.

At this stage of the process, auditors are trying to identify the controls that may be relied upon as part of the overall audit process. To do so, auditors need to identify the controls that they believe will mitigate the risks of material misstatement that have been identified for each of the relevant assertions. As part of this process, auditors will often categorize controls as either preventive or detective, automated or manual, and will also note how often the control is performed (e.g., daily, weekly, monthly, etc.). The categori- zation process helps an auditor to better understand each control which facilitates internal control testing. Indeed, it is important to remember that any control that may be relied upon would have to be tested before the audit team could rely on them to reduce substan- tive testing. However, it is important to point out that audit teams should not perform tests of controls for those controls that will not be relied upon because there is no need to prove that they are operating effectively. Doing so would be inefficient. Instead, the audit team would have to perform additional substantive procedures to compensate for the lack of internal controls that could be relied upon to obtain sufficient appropriate evidence that would allow the auditor to reach a conclusion for the related relevant assertions.

Tests of controls must be performed to obtain evidence about whether control activi- ties that are candidates to be relied upon actually operate as described. The test of con- trols audit plan consists of procedures designed to produce evidence of how effectively the controls operate in practice. If they are determined to be operating effectively after testing, control risk can be assessed below the maximum. If they do not operate with the

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required level of effectiveness, the final conclusion is to assess a high or maximum con- trol risk, revise the audit plan to consider the control weakness, and then proceed with additional substantive audit procedures.

The distinction between the understanding and documenting phase and the prelimi- nary control risk assessment phase is useful for understanding the audit team’s study and evaluation of internal control. However, the audit team typically performs these phases together, not as separate and distinct audit tasks. For non-issuers, the audit team can halt the control evaluation process for efficiency or effectiveness reasons. However, if the audit team wants to justify a low risk assessment to reduce the substantive audit proce- dures, the evaluation must be continued in phase 3, the testing phase.

To summarize, then, at this stage, the audit team members have established an assess- ment of the level of control risk based on its understanding of internal control and iden- tified control strengths and weaknesses. If this assessment is at a level less than the maximum level (i.e., the audit team members want to rely on internal controls to modify the nature, timing, and extent of further audit procedures), the auditors must next perform tests of controls. This final phase is discussed in the next section.

Phase 3: Identify Controls to Test and Perform Tests of Controls When audit teams reach the third phase of an evaluation of internal control, they already have identified specific control activities for relevant assertions on which risk could be assessed below the maximum (100 percent). This is often referred to as controls on which the audit team intends to rely. To support the reduced control risk assessment and the reduction of related substantive procedures for each relevant assertion, audit teams must test the control activities to determine whether they are operating effectively throughout the period. The required level of effectiveness is a matter of professional judgment. Audit  teams know that compliance cannot realistically be expected to be perfect. The  auditors could decide, for example, that evidence such as 98 percent of recorded payroll being supported by validated time cards is sufficient to assess a “low” control risk for the occurrence assertion. Most public accounting firms have internal guidelines to determine the acceptable rate of compliance for an internal control activity to be con- sidered effective. Generally, if a control is judged to be more important and would result in a more significant reduction in substantive testing, the level of compliance must be higher. Factors to consider in determining appropriate levels of compliance are discussed in more detail in Module E.

Understand and Document the Client’s Internal Control

Assess the Control Risk (Preliminary)

Identify Controls to Test and Perform Tests of Control

The professional standards make clear that when designing tests of controls, the auditor needs to consider the means of selecting items for testing. For tests of internal controls, there are two approaches that are commonly used: (1) testing all items in a population and (2) testing a sample from a population. The decision of which approach to use depends on the nature of the control that is being tested, along with the availability of data. For example, a control activity that is entirely automated might best be tested by an automated audit procedure that can be efficiently and effectively applied to the entire population of occurrences of that control activity. However, for a manual control activity, the auditor is likely to take a sample from the population of occurrences of that control activity. In addition, it should be noted that some manual controls (such as locking a door to safeguard assets) may have little documentation and may require other means of

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testing (e.g., observation and inquiry). In today’s auditing environment, the increased use of computers by both the client and the auditor has dramatically increased the number of tests of control that can be effectively applied to the entire population of control occur- rences in an efficient manner (such as exception testing).

Exception Testing One way to subject all items in a population of occurrences for a particular control activ- ity is to use exception testing. Exception testing is designed to identify a violation of a particular control activity through the use of an automated test procedure designed to test all items in a population. For example, consider an entirely automated control activity that is designed to compare a customer’s credit limit to the sum of (1) a potential sales transaction and (2) that customer’s outstanding credit balance before approval of that sales transaction. If the control activity operated effectively throughout the year, a cus- tomer’s outstanding credit balance would not exceed its credit limit.

Given the nature of the control activity, one way to test the operating effectiveness would be through the use of exception testing. That is, an auditor could obtain evidence about the control’s operating effectiveness by using a procedure that compares each cus- tomer’s credit limit to that customer’s outstanding credit balance at the end of each day for the year under audit. Such a testing strategy would not have been possible (at least economically) in previous years. However, due to advances in information technology, such testing is now possible. As a direct result, entry-level audit professionals are now expected to consider the full extent of client data available for testing purposes, before they move forward with audit tests.

IDEA can be helpful to audit professionals when completing excep- tion tests and conducting audit sampling. This addendum sum- marizes several useful assignments that are available to students in the IDEA Data Analysis Workbook: IDEA Version Ten (the IDEA Workbook). The assignments allow students to experience a hands- on application of the IDEA software to exception testing. Ultimately, exception tests provide evidence about the operating effectiveness

of internal control activities by testing all items in a population. Module F provides a detailed illustration of how auditors use the sampling features of IDEA to select a representative sample from a complete population of control occurrences for a control activity to be tested.

At the end of this chapter, problems 5.72 and 5.73 can be com- pleted to illustrate the use of IDEA during internal control testing.

Internal Control TestingUSING IDEA IN THE AUDIT

Audit Sampling Of course, there are many control activities that do not lend themselves to automated audit testing. In such situations, auditors are likely to take a sample from the population of occurrences for the control activity being tested. Most importantly, in such situations, the population being sampled must include all occurrences of the relevant control activity for the entire period of reliance, and the sample must be representative of that population to be considered appropriate audit evidence.

Tests of controls, when performed, should be applied to samples of transactions and control activities executed throughout the period under audit. The reason for this require- ment is that the conclusions about controls will be generalized to the whole period under audit. If the auditor obtains audit evidence about the operating effectiveness of controls during an interim period, additional audit evidence should be obtained for the remain- ing period. There are certain situations when audit teams can rely on tests from previous periods if they have evidence that the procedure has not changed and the auditor does not believe there is a significant risk of material misstatement. However, in an annual audit, the auditor may not rely on audit evidence about the operating effectiveness of controls

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obtained in prior audits for controls that have changed since they were last tested or for controls that mitigate a significant risk. Audit sampling is discussed in detail in Module E.

Perform Tests of Controls Once the items have been selected for testing, the four methods of testing controls are inquiry, observation, document examination, and reperformance. Generally, audit teams use inquiry about the existence of control activities and then corroborate the oral evidence by observing that the client-described control activities are actually being performed. Observation occurs when auditors have eyewitness observation of employees at their jobs performing control activities. Observation is typically used when certain control activities, such as separation of employees’ duties, leave no documentary evidence for subsequent examination. Observation also can produce evidence of access controls such as the use of password-secured access to the computerized information system, locked doors, and security guards. The limitation of observation is that this test of control is performed as of one point in time (usually near year-end), and what is observed at that point in time may not be representative of prior time periods.

Some tests of controls depend on documentary evidence such as a payroll entry supported by a time card. In these cases, document examination for evidence of signatures, initials, checklists, reconciliations, and the like provides better evidence than procedures that leave no documentary tracks. Document examination might be enough; the audit team may look to see whether the documents were marked with an initial, signature, or stamp to indicate they had been checked. For example, audit teams could examine canceled checks for authorized signatures, inspect voucher packets for the initials of the employee who matched vendor invoices with supporting purchase orders and receiving reports, or examine bank reconciliations to make sure that they have been performed on a timely basis.

Generally, the most effective test of controls is reperformance. Reperformance can involve any client internal control activity, such as the detailed review of the monthly bank reconciliation by the entity’s CFO. For this control, the auditor would follow up on each reconciling item reviewed by the CFO and then reperform each of the mathemati- cal calculations. The key difference between document examination and reperformance is that with the former, audit teams inspect documents for evidence that employees have performed the control activity; reperformance provides direct evidence that the control activity was (or was not) done correctly. Exhibit 5.18 puts control testing within the perspective of the payroll function with examples of specific assertions being supported. Appendix 5A illustrates a sample audit plan for these tests.

Overall, the audit team’s choice of which test of controls to use depends on the nature and importance of the control activity being tested. Not surprisingly, certain types of tests produce more evidence about the operating effectiveness of a control activity than others. The following hierarchy lists the type of control tests from the least persuasive (inquiry) to the most persuasive type of evidence:

∙ Inquiry of client personnel. ∙ Observation of the control activity being performed. ∙ Inspection of relevant documentation. ∙ Reperformance of the control activity.

Importantly, if the control activity has high risk, the audit team needs more persuasive evidence about its operating effectiveness than it would for a lower risk control in order to determine if it is operating effectively. Since gathering more persuasive evidence is typi- cally associated with a higher cost than gathering less persuasive evidence, if the audit team wants to achieve a lower control risk assessment, it will be more costly. This is why it may be more efficient for the auditor to choose not to rely on controls and instead rely on substantive testing procedures to gain assurance for certain significant accounts.

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Relevant Assertion Control to Mitigate the Risk of Material Misstatement Tests of Controls

Occurrence. Payroll and related events that have been recorded have occurred and pertain to the entity.

1. Payroll accounting is separated from personnel and supervision.

2. Labor usage reports are compared to job time tickets or lists of amount of time clocked.

3. Payroll supervisor approved labor usage.

1. Observe separation of duties. 2a. Vouch labor costs to labor reports. 2b. Vouch labor reports to time tickets

authorized by management. 3. Examine documentary evidence of

supervisor approval.

Completeness. All payroll events that occurred should have been recorded.

1. All documents are prenumbered and numerical sequence reviewed.

2. Labor costs were reviewed by supervisors and compared to budgets.

3. The personnel department notified the payroll department of new hires to include in payroll.

1. Inspect numerical sequence of selected job cost tickets and paychecks.

2. Examine documentary evidence of supervisor review of labor costs.

3. Trace a sample of employees in the personnel file to payroll time logs and the payroll register.

Accuracy. Payroll amounts and related data have been recorded accurately.

1. Payroll entries are reviewed by a person independent of preparation.

2. Budgeted payroll expenses by department are compared to actual expenses.

1. Examine evidence of review and ensure that a party independent of preparation conducted the review.

2. Examine documentary evidence of budget comparison.

Classification. Payroll-related events are recorded in the proper accounts.

1. Job cost sheets are posted weekly and summary journal entries of work-in- process and of work completed prepared monthly.

2. Payroll supervisor is required to approve distribution of payroll expense accounts and to compare payroll costs to budget.

1. Observe that payroll account distribution and job cost sheets agree.

2. Examine supervisor signature on payroll reports. Note evidence of comparison to budget.

Cutoff. Payroll-related events have been recorded in the correct accounting period.

1. Payroll reports are prepared weekly and transmitted to cost accounting.

1. Observe that the date of payroll reports agrees with dates in weekly journal entries.

EXHIBIT 5.18 Relevant Assertions about Payroll Cycle Transactions

Of course, the level of automation of the control activity will also have a big impact on the nature of the control testing performed. That is, for manual controls that rely on a system generated report, the audit team would have to separately test whether the report is being generated by the system in a complete and accurate manner. In addition, for auto- mated control activities that operate entirely within the entity’s computer information system, the audit team would have to perform tests on the system to make sure that the control is operating effectively. The auditing considerations that are relevant to testing the completeness and accuracy of system generated reports and testing the operating effec- tiveness of purely automated controls are discussed in detail in Module H.

Direction of the Tests of Controls The tests of controls in Exhibit 5.18 are designed to test the payroll accounting cycle in two directions. One is the completeness direction, whereby the audit team is interested in ensuring that all valid hours are included in the entity’s payroll; as a result, time logs (which represent valid hours worked) are traced to payroll department files and the payroll register (which represents hours included in the payroll). Exhibit 5.19 shows that the sample for this direction is taken from the popula- tion of time logs (including listings of electronic clock-ins).

The purpose of the occurrence test of payroll is to ensure that all labor hours included in the payroll (represented by the payroll register) were actually worked (represented by time logs). As a result, entries would be selected from the payroll register and vouched back to the time logs by the auditor. Because payroll provides access to cash, this cycle is

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highly susceptible to fraudulent activity on the part of an organization’s employees. If a fictitious employee were created and added to the payroll, his or her pay could be depos- ited into another person’s account. This is relatively difficult to detect in the era of direct deposit of paychecks.

Reassess the Control Risk The audit team should evaluate the evidence obtained from an understanding of the cli- ent’s internal control and from the related tests of control activities. If control risk (and the related RMM) is assessed very low, the substantive procedures on the relevant asser- tions for significant account balances can be limited in cost-saving ways. For example, a surprise payroll distribution as a substantive test might be considered unnecessary or the audit team might decide it is appropriate to place considerable reliance on control activi- ties in the payroll system. On the other hand, if tests of control activities reveal weak- nesses (e.g., improper separation of duties, inaccurate cost reports, inaccurate tax returns, or lax personnel policies), the RMM would be assessed at higher levels and substantive procedures would need to be increased to lower the risk of failing to detect material mis- statements in the financial statements.

Final assessment of control risk (and consequently, the RMM) is complicated. In the detailed sampling module (Module F), you will find explanations of sampling methods for performing tests of controls of the type illustrated in Exhibit 5.18. Further discussion of assessing the RMM (including control risk) is saved for those modules. However, rec- ognize that the final evaluation of an entity’s internal control is the assessment of the con- trol risk related to each relevant assertion. These assessments are the auditors’ expression of the effectiveness of control activities for preventing, detecting, and correcting specific errors and frauds in management’s relevant financial statement assertions.

An assessment of control risk should be coordinated with the final audit plan, which includes the list of substantive procedures to detect material misstatements in account balances and financial statement disclosures for each relevant assertion. Note that the reassessment of control risk can go only one direction: upward. If the controls are not functioning as described, they cannot be relied upon. On the other hand, even if weak controls are functioning, they are still weak and do not reduce the risk of material mis- statement. There is one exception: You find that you were in error during the understand- ing of controls phase; there are additional controls about which you were unaware. In that case, lowering control risk could be justified.

Thus far, our discussion of tests of control activities and substantive procedures has assumed that these are easily distinguishable. Be advised, however, that general audit procedures can at times be used as dual-purpose tests. That is, a single audit test can

EXHIBIT 5.19 Dual-Direction Test of Payroll Controls

Summary Listing [Payroll Journal]

Vouching/Tracing (Payroll Cycle)

Source Documents [Time Logs]

Q: Did all recorded labor hours actually occur?

Q: Were all labor hours recorded?

Vouching (Occurrence)

Tracing (Completeness)

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produce both control testing and substantive testing evidence and, thus, serve both pur- poses. For example, a selection of recorded payroll entries could be used to (1) vouch payroll to time cards and (2) calculate the correct dollar amount of payroll. The first procedure provides relevant information about an important control activity. The second provides dollar value information that can help offer substantive evidence to support the account balance in the financial statements.

REVIEW CHECKPOINTS 5.21 What are tests of control activities? 5.22 What is the difference between document examination and reperformance when conducting tests

of controls? 5.23 What purposes are served by a dual-purpose test?

RESPONSIBILITIES IN THE AUDITS OF ISSUERS REQUIRED BY PCAOB AUDITING STANDARD NO. 2201

PCAOB Auditing Standard No. 2201 (AS 2201) details the work that the external audit team of an issuer must perform to comply with section 404 of Sarbanes–Oxley. The audit team must plan and perform the audit to obtain reasonable assurance about whether the entity maintained effective control over financial reporting. The SEC understands reason- able assurance not to be absolute but a “high level of assurance” is expected. The focus in the professional standard is to determine whether a material weakness exists at the end of the year being reported on. If a material weakness exists, the entity’s internal control over financial reporting cannot be considered effective. For the audit team, this duty entails an increased amount of testing for the internal control system.

According to GAAS, when auditing non-issuers, the audit team must obtain an under- standing of internal controls to determine the nature, timing, and extent of further audit procedures to be performed. If the team members plan to rely on controls to reduce sub- stantive procedures, they must test the controls for operating effectiveness. However, if they do not plan to rely on controls, tests of operating effectiveness are not required. Under Sarbanes–Oxley, an audit of the internal control system over financial reporting is required. The audit of internal controls must be integrated with the financial statement audit and cannot be performed as a separate engagement. Thus, the procedures related to internal control in an integrated audit performed under AS 2201 are far more extensive than those in a GAAS audit for a nonissuer.

Requirements Much of the initial work, including documenting and testing controls, is done by employ- ees of the client, management, the internal audit staff, and even outside consultants hired by management. AS 2201 encourages the audit team to use the work of internal auditors and others, but the audit team members must evaluate the internal auditors’ competence and objectivity and must perform some tests of their work. For more risky areas, audit teams should perform more of the work and the assessment of likely sources of misstate- ment themselves or supervise any others who assist them in the evaluation.

Another important difference between AS 2201 internal control audits and GAAS financial statement audits is that the audit of internal control is as of the end of the fiscal year, whereas, for audits of the financial statements, the audit team must understand and evaluate internal control for the entire period to determine its effect on the nature, timing, and extent of further audit procedures.

LO 5-5 Describe additional responsibilities for management and auditors of issuers required by Sarbanes–Oxley and PCAOB Auditing Standard No. 2201.

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  Internal Control Audit Financial Statement Audit

Scope Test each relevant control activity each year Test relevant control activities if relying on them

Reporting Opinion on the effectiveness of internal control No opinion on internal control

Timing Evaluate effectiveness of internal control as of the fiscal year-end

Evaluate effectiveness of internal control throughout the fiscal year

AS 2201 emphasizes the use of a six-step audit process that is designed to evaluate the effectiveness of the internal control system over financial reporting:

1. Planning the engagement. The audit team must evaluate controls for all relevant assertions and for all significant accounts or disclosures. Thus, significant accounts, locations, and assertions must be identified. A difficult decision in auditing controls of global organizations is determining which locations are significant and must be visited. Each location is evaluated based on size, risks, and whether risks are mitigated by entitywide controls. The key to determining whether an account, location, or asser- tion is significant is whether there is more than a remote possibility that a material misstatement could be associated with it. Just as control risk is used to determine the nature, timing, and extent of further audit procedures, inherent risk is used to determine the nature, timing, and extent of tests of controls.

2. Using a top-down approach. As mentioned earlier, the top-down approach focuses on the threats to the integrity of the external financial reporting process. The audit team’s first step in gaining an understanding of the client’s internal control system should focus on entity-level controls (ELCs) because they can have a pervasive impact on control activities at the process, transaction, or application level. The team next moves down to the significant accounts and disclosures and their relevant assertions. By relevant, we mean that the assertion has a reasonable possibility of containing a material misstatement. The audit team is required to understand the internal control process over financial reporting. This aspect of the standard emphasizes performing a walkthrough of the internal control process by the audit team members. The top-down approach recommended in AS 2201 is illustrated in Exhibit 5.20.

3. Testing controls. After identifying significant controls over financial reporting in the previous step, the audit team decides which controls to test. The evaluation and testing for each assertion must be performed on an annual basis. After an understanding of internal controls is gained through inquiry, document examination, and observation, the controls are evaluated for the possibility that they would not prevent or detect a misstatement. The tests of operating effectiveness are similar to a test of controls discussed previously. A sample of transactions is examined using inquiry, observation, document examination, and reperformance. The more risk associated with a control,

EXHIBIT 5.20 Top-Down Process

Begin at Financial Statement Level

Understand Overall Risks

Focus on Entity- Level Controls

Work to Significant Accounts,

Disclosures, and Relevant Assertions

Attend to Possibility of Material

Misstatement

Select Controls for Testing

Top-Down Process

Verify Understanding of

Process Risks

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the more persuasive evidence is required for testing. Tests of controls are not per- formed if the internal control system design is not considered effective. Only the con- trol activities for each relevant assertion that the auditor is relying on to mitigate the risk of material misstatement need to be tested.

4. Evaluating identified deficiencies. An internal control deficiency—whether resulting from a design or an operating deficiency—exists when either the design or the opera- tion of the control under consideration does not allow the entity’s management or employees to detect or prevent misstatements in a timely fashion. A design deficiency is a problem relating to either a necessary control that is missing or an existing control that is so poorly designed that it fails to satisfy the control’s objective. An operat- ing deficiency, on the other hand, occurs when a properly designed control is either ignored or inappropriately applied (possibly because employees are poorly trained). More serious internal control deficiencies can be categorized into one of two groups— material weaknesses or significant deficiencies—depending on their severity.

∙ A material weakness in internal control is defined as a deficiency, or combination of deficiencies, that results in a reasonable possibility that a material misstatement would not be prevented or detected on a timely basis. The following circumstances should be regarded as strong indicators that a material weakness exists:

∙ Restatement of previously issued financial statements to reflect the correction of a material misstatement.

∙ Evidence of material misstatements (identified by the audit team) that were not prevented or detected by the client’s internal controls.

∙ Ineffective oversight of the financial reporting process by the entity’s audit committee. ∙ Indication of fraud (either material or immaterial) by senior management.

∙ A significant deficiency is a deficiency or a combination of deficiencies in internal con- trol that is less severe than a material weakness yet important enough to merit attention by those charged with governance. The primary difference between a significant deficiency and a material weakness

involves the magnitude of the potential misstatement that could occur and would not be detected on a timely basis. As the potential misstatement reaches overall materiality, an auditor may conclude that a material weakness exists. The final conclusion is always a matter of professional judgment. 5. Wrapping up. Audit teams are required to issue an opinion on the effectiveness of internal

controls. They do so by evaluating evidence obtained from all sources, including the team’s testing of controls, any misstatements detected during the financial statement audit, and any identified control deficiencies and material weaknesses. Audit teams then form an opinion on the effectiveness of internal control over financial reporting. Audit teams can issue one of three types of opinions on internal controls:

∙ Unqualified. No material weaknesses exist. ∙ Disclaimer of opinion. The audit team cannot perform all of the procedures

considered necessary and is unable to determine whether material weaknesses exist. ∙ Adverse opinion. One or more material weaknesses exist.

Note that because the opinion on internal controls is as of the end of the fiscal year, the entity may be able to correct or remediate deficiencies or weaknesses after they have been detected. However, the audit team must have sufficient time to test the design effectiveness and operating effectiveness of the remediated control before providing an unqualified opinion.6

In addition to expressing an opinion on the effectiveness of the entity’s internal con- trol over financial reporting, the audit team also should evaluate the completeness and

6Clients may request auditors to report separately on the elimination of material weaknesses. Guidance on preparing such a report is provided by PCAOB’s AS 4.

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presentation of management’s annual report on internal control over financial reporting. Among other factors, the audit team also must obtain written representations from man- agement that explicitly acknowledges

∙ It is responsible for effective internal control over financial reporting. ∙ It has evaluated the effectiveness of the internal control over financial reporting. ∙ It has disclosed all internal control deficiencies and frauds to the audit team.

6. Reporting on internal control. The next step in the process is reporting on internal con- trol over financial reporting. For the auditors’ report on internal control, two options are available. One option is to have two separate reports: one on the fairness of the entity’s financial statements (presented earlier in Chapter 2) and a separate report on internal control over financial reporting. Each report would be separately titled, dated (although using the same date), and signed. The auditors’ separate report on internal control is discussed in detail in the following section. The second option is to prepare a combined report that expresses one opinion on the financial statements and a second on the effectiveness of internal control over financial reporting. An example of a com- bined auditors’ report on internal control over financial reporting and financial statements is shown in Chapter 12.

Since the passage of Sarbanes-Oxley, much debate has taken place about the costs and benefits on Section 404b, the provision that requires auditors to opine on the internal control effectiveness of their clients.

Well, a recent academic study focuses on this aspect of the law by attempting to measure the benefits and the costs associated with exempting small issuers from this section of the law.

In their study, the authors report a benefit of exemption as “an aggregate $388 million in audit fee savings from 2007–2014.” The costs

“stem from internal control misreporting: an aggregate $719 million of lower operating performance due to non-remediation and a $935 million delay in aggregate market value decline due to the failure to disclose ineffective internal controls.”

Source: Benefits and costs of Sarbanes-Oxley Section 404(b) exemption: Evidence from small firms’ internal control disclosures. Journal of Accounting and Economics 63, 2017, W. Ge. S. Koester, and S. McVay, pp. 358–384.

The Cost and Benefits of Section 404AUDITING INSIGHT

REVIEW CHECKPOINTS 5.24 What is management’s responsibility for reporting on internal control over financial reporting? 5.25 What steps do audit teams follow in examining internal control over financial reporting? 5.26 What are (a) an internal control deficiency, (b) a significant deficiency, and (c) a material

weakness? 5.27 What options are available to the auditor for presenting reports on the entity’s financial state-

ments and internal control over financial reporting?

INTERNAL CONTROL COMMUNICATIONS Whether auditing a non-issuer under GAAS or an issuer in an audit conducted under PCAOB standards, the audit team must communicate significant deficiencies and mate- rial weaknesses in internal control that come to their attention during the performance of the audit. Auditors’ communications of significant deficiencies and material weaknesses are intended to help management carry out its responsibilities for internal control moni- toring and change. However, external auditors’ observations and recommendations are usually limited to external financial reporting matters.

LO 5-6 Explain the communication of internal control deficiencies to those charged with governance, such as the audit committee and other key management personnel.

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For issuers, the auditors’ report must be in writing and presented to those in charge of governance (usually the audit committee) before their report on internal control over financial reporting is issued to the public. The report is to be addressed to management, the board of directors, or the audit committee. See Exhibit 5.21 for an illustration of such a report. In addition, all deficiencies noted must be communicated in writing to management.

If the audit team members do not identify any significant deficiencies, they should not issue a report stating that “no significant deficiencies were noted during the audit.” Doing so might be misleading because an integrated audit is not designed to detect all signifi- cant deficiencies. A manager receiving such a report could conclude (incorrectly) that the audit team is stating positively that the entity has no internal control problems.

Audit teams often issue another type of report to management called a management letter. This letter may contain commentary and suggestions on a variety of matters in addition to internal control matters. Examples include issues identified during the audit related to operational and administrative efficiency, business strategy, and profit-making possibilities. Auditing standards do not require management letters, but they represent a type of value-added management advice rendered as part of an audit.

Michael Scarn, LLP, CPAs Scranton, PA

March 7, 2021

Board of Directors Dunder-Mifflin Inc. Scantron, ME

In planning and performing our audit of the financial statements of Dunder-Mifflin Inc. for the year ended December 31, 2020, we considered its internal control in order to determine our audit procedures for the purpose of expressing our opinion on the financial statements as well as the effectiveness of the company’s internal control over financial reporting. Our consideration of internal control would not necessarily disclose all deficiencies in internal control that might be significant deficiencies. However, we noted a certain matter involving the internal control and its operation that we consider to be a significant deficiency under standards established by the Public Company Accounting Oversight Board. A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough to merit attention by those charged with governance.

The matter noted is that shipping personnel have both transaction-initiation and alteration authority as well as custody of inventory assets. If invoice/shipping copy documents are altered to show a shipment of smaller quantities than actually shipped, customers or accomplices can receive your products without charge. The sales revenue and accounts receivable could be understated, and the inventory could be overstated. This deficiency caused us to spend more time auditing your inventory quantities.

A material weakness in internal control is defined as a deficiency, or combination of deficiencies, that results in a reasonable possibility that a material misstatement would not be prevented or detected on a timely basis. We do not believe that the significant deficiency described above is a material weakness.

This report is intended solely for the information and use of the board of directors and its audit committee, and is not intended to be, and should not be, used by anyone other than these specified parties.

Respectfully yours, Michael Scarn, LLP, CPAs

EXHIBIT 5.21 Internal Control Letter

REVIEW CHECKPOINT 5.28 What reports (other than auditors’ report) on internal control do audit teams give to an entity’s

management, board of directors, or audit committee?

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The purposes of the audit team’s evaluation of internal control are to assess the control risk (as part of the overall assessment of the RMM) in order to make the substantive audit plan and to report control deficiencies to management and the board of directors. The PCAOB’s AS 2201 defines additional responsibilities for management and public accounting firms’ reports on internal control stipulated by the Sarbanes–Oxley Act.

Internal control consists of five components: control environment, risk assessment, information and communication system, control activities, and monitoring of the control system. The auditor is required to gain an understanding of each of these components and to document this understanding in the audit files. The control environment and man- agement’s risk assessment are explained in terms of understanding the client’s business. Elements of the accounting system are explained in conjunction with control activities designed to prevent, detect, and correct misstatements that occur in transactions. Docu- mentation of an entity’s internal control system is accomplished through the use of ques- tionnaires, flowcharts, and narratives.

Internal control is assessed in a top-down manner by which audit teams first identify accounts that may contain significant risks of material misstatement. Audit teams then identify which relevant assertions may be misstated. After determining “what could go wrong,” audit teams examine entity-level controls that might mitigate the risk of material misstatement. Finally, audit teams identify transaction level controls that would mitigate any residual risks. If the audit team relies on controls, it must test the controls to ensure they are operating effectively. Where controls are not in place to reduce the risk, or if test- ing the controls would not be cost effective, substantive tests are designed to identify any material misstatements.

It is important to distinguish the “client’s control activities” from the “audit team’s tests of controls.” Control activities are part of the internal control designed and operated by the entity. The audit team’s procedures are the audit team’s own evidence-gathering work performed to obtain evidence about the client’s control activities.

Sarbanes–Oxley requires that management of issuers report on their assessments of the effectiveness of their financial reporting controls and that audit teams provide opin- ions on the controls over financial reporting. This may involve more extensive procedures than those required by GAAS.

Summary

adverse opinion on internal control over financial reporting: The opinion issued when the auditors conclude that the financial statements do not present the financial condition, results of operations, and cash flows in accordance with GAAP, 207. audit committee: A subcommittee of the board of directors that is generally composed of three to six “outside” members of the organization’s board of directors, 180. auditors’ report on internal control over financial reporting: A report required by the Sarbanes–Oxley Act that provides an opinion on the effectiveness of the entity’s internal control over financial reporting, 207. business risks: Those factors, events, and conditions that could prevent the organization from achieving its business objectives, 181. control activities: The specific actions taken by a client’s management and employees to help ensure that management directives are carried out, 182. control risk: The likelihood that the client’s internal control policies and procedures fail to prevent or detect a material misstatement, 176. design effectiveness: A condition expressing whether controls would be expected to prevent or detect errors or fraud that could result in a material misstatement in the financial statements, 193. detective controls: The activities that detect misstatements after they occur, 183. disclaimer of opinion on internal control over financial reporting: A report issued when auditors do not express an opinion on the fairness of the entity’s financial statements. Disclaimers of opinion are issued for pervasive going-concern uncertainties, pervasive scope limitations, situations in which auditors’ are associated with (but did not audit) financial statements, and situations in which the auditors are not independent, 207.

Key Terms

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dual-purpose test: An audit procedure used as both a test of controls and a substantive test, 203. enterprise risk management (ERM): A process effected by an entity’s board of directors, management, and other personnel applied in strategy setting and across the enterprise that is designed to identify potential events that may affect the entity and to manage risks to be within its risk appetite to provide reasonable assurance regarding the achievement of entity objectives, 181 entity-level controls: The controls that are pervasive to the financial statements taken as a whole, 192. flowchart: The audit documentation that provides a visual display of the accounting system and control activities in an entity’s internal control system, 194. information system: An entity’s system, usually built on some type of technological platform that has been designed to produce the information necessary for the entity to operate and control its business operations, 187. integrated audit: The term used to describe an audit process that is designed to provide an opinion on both the financial statements and the internal control system of an entity, 176. internal control: A process, effected by an entity’s board of directors, management, and other personnel, designed to provide reasonable assurance regarding the achievement of objectives in the reliability of financial reporting, the effectiveness and efficiency of operations, and compliance with applicable laws and regulations, 195. internal control deficiency: A condition that exists when the design or operation of a control does not allow the entity’s management or employees to detect or prevent misstatements in a timely fashion, 206. internal control questionnaire: The audit documentation that uses a checklist of internal control–related questions to gain and document an understanding of the client’s internal control, 195. issuer: An issuer is an entity that registers and sells securities (e.g., common stock) to the investing public, 173. management’s annual report on internal control over financial reporting: A report required by the Sarbanes–Oxley Act that states that management is responsible for establishing and maintaining adequate internal control over financial reporting, identifies the framework management uses to evaluate the effectiveness of the entity’s internal control, and provides management’s assessment of the effectiveness of the entity’s internal control, 207. material weakness: A deficiency or combination of deficiencies that results in a reasonable possibility that a material misstatement would not be prevented or detected on a timely basis, 206. non-issuer: A nonissuer is an entity that does not offer securities to the investing public, 197. narrative description: The audit documentation that describes the environmental elements, the accounting system, and the control activities in an entity’s internal control, 194. operating effectiveness: Description of a condition expressing whether a control is operating as designed and whether the person performing the control possesses the necessary authority and qualifications to perform the control effectively, 194. preventive controls: The activities that prevent misstatements before they occur, 183. reasonable assurance: The concept that recognizes that the costs of control activities should not exceed the benefits that are expected from the control activities, 190. significant deficiency: A deficiency or a combination of deficiencies in internal control that is less severe than a material weakness yet important enough to merit attention by those charged with governance, 206. system generated report: Any report that is generated by the audit client’s information system that is used to execute its internal control procedures or produce its financial statements. It is important to test that each system generated report is complete and accurate if it is being used for either of these purposes, 184. substantive procedures: The detailed audit and analytical procedures designed to detect material misstatements in account balances and footnote disclosures, 203. transaction-level controls: The controls that relate to specific classes of transactions, account balances, and disclosures, 193. unqualified opinion on internal control over financial reporting: The report issued when no material weaknesses in internal control over financial reporting are identified and no scope limitations on the audit of internal control exist, 177. walkthrough: The tracing of one or more transactions through the audit trail from initiation of the transaction to its inclusion in the financial statements, 193.

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5.29 The most important foundational component of an entity’s internal control system is a. Effectiveness and efficiency of operations. b. The control environment. c. Reliability of financial reporting. d. Compliance with applicable laws and regulations.

5.30 The primary purpose for obtaining an understanding of internal control during the audit of a non-issuer is to a. Provide a basis for making constructive suggestions in a management letter. b. Determine the nature, timing, and extent of further audit tests to be performed. c. Provide the rationale for the inherent risk assessment at the financial statement assertion

level. d. Provide information for a communication of internal control–related matters to management.

5.31 Effectiveness of audit procedures would be reduced by a. Selecting larger sample sizes for audit. b. Performing audit procedures at the fiscal year-end date as opposed to the interim period. c. Deciding to obtain external evidence instead of internal evidence. d. Performing procedures during the interim period as opposed to at the fiscal year-end date.

5.32 According to the PCAOB, during the audit of internal controls for an issuer, the ultimate objective of testing the design effectiveness of internal controls is to a. Determine whether the company’s controls are processing company data effectively. b. Determine that the company’s controls will satisfy the company’s control objectives and

can effectively prevent or detect errors or fraud that could result in material misstate- ments, if they operate as prescribed.

c. Determine that the company’s employees are processing the controls according to the policy and procedures manuals at the company.

d. None of the above.

5.33 To test the operating effectiveness of a control, an audit team might use a combination of each of the following tests except for a. Inquiry of client personnel. b. Observation of company operations. c. Confirmation of balances. d. Inspection of documentation.

5.34 Which of the following is a preventive control? a. Reconciliation of a bank account. b. Recalculation of a sample of payroll entries by internal auditors. c. Separation of duties between the payroll and personnel departments. d. Detailed fluctuation analysis completed by the CFO for revenue.

5.35 In most audits of large entities, control risk assessment contributes to audit efficiency, which means that a. The cost of substantive procedures will exceed the cost of control evaluation work. b. Auditors will be able to reduce the cost of substantive procedures by an amount more

than the control evaluation costs. c. The cost of control evaluation work will exceed the cost of substantive procedures. d. Auditors will be able to reduce the cost of substantive procedures by an amount less than

the cost of tests of controls.

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Multiple-Choice Questions for Practice and Review

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5.36 Which of the following is a device designed to help the audit team obtain evidence about the accounting and control activities of an audit client? a. A narrative memorandum describing the control system. b. An internal control questionnaire. c. A flowchart of the documents and procedures used by the company. d. All of the above.

5.37 Tests of controls in a GAAS audit are required for a. Obtaining evidence about the financial statement assertions. b. Accomplishing control over the occurrence of recorded transactions. c. Applying analytical procedures to financial statement balances. d. Obtaining evidence about the operating effectiveness of client control activities.

5.38 A transaction-level internal control activity is best described as a. An action taken by auditors to obtain evidence. b. An action taken by client personnel for the purpose of preventing, detecting, and correcting

errors and frauds in transactions to eliminate or mitigate risks identified by the company. c. A method for recording, summarizing, and reporting financial information. d. The functioning of the board of directors in support of its audit committee.

5.39 When planning the audit of internal controls for an issuer, the audit team should a. Identify significant accounts, locations, and relevant assertions. b. Conduct a walkthrough of the internal control process. c. Make inquiries of employees regarding the existence of control activities. d. Reperform control activities performed by client employees to determine their effectiveness.

5.40 A material weakness is a situation in which a. It is probable that an immaterial financial statement misstatement would not be detected

on a timely basis. b. There is a remote likelihood that a material misstatement would be detected on a timely

basis. c. It is reasonably possible that a material misstatement would not be detected on a timely

basis. d. It is reasonably possible that an immaterial misstatement would not be detected on a

timely basis.

5.41 When completing the audit of internal controls for an issuer, the severity of an internal con- trol deficiency depends on a. Whether there is a reasonable possibility that the company’s controls will fail to prevent

or detect a misstatement of an account balance or disclosure. b. Whether a misstatement has actually occurred as a result of the deficiency. c. The magnitude of the potential misstatement resulting from the deficiency or the

deficiencies. d. Both a and c are correct. e. All of the above are correct.

5.42 Which of the following does not accurately summarize auditors’ requirements regarding internal control?

  Issuer Non-issuer

a. Understanding Yes Yes

b. Documenting Yes Yes

c.  Evaluating control risk Yes Yes

d. Test controls Yes Yes

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5.43 When completing the audit of internal controls for an issuer, the PCAOB requires the audit team to audit internal controls over a. Operations. b. Compliance with regulations. c. Financial reporting. d. All of the above.

5.44 When completing the audit of internal controls for an issuer, AS 2201 requires auditors to report on

Management’s Report on Internal Control

An Audit of Internal Control

a. No No

b. Yes No

c. No Yes

d. Yes Yes

5.45 When completing the audit of internal controls for an issuer, AS 2201 requires auditors to test a. Operating effectiveness only. b. Design effectiveness only. c. Both operating and design effectiveness. d. Neither operating nor design effectiveness

5.46 Which of the following would probably not be considered an indication of a material weakness? a. Evidence of a material misstatement. b. Ineffective oversight by the audit committee. c. Immaterial fraud committed by senior management. d. Overproduction by the manufacturing plant.

5.47 Which report would not be appropriate for a public accounting firm to provide on financial reporting controls? a. Unqualified—no material weaknesses found. b. Disclaimer of opinion—unable to perform all necessary procedures. c. Disclaimer of opinion—significant deficiencies exist. d. Adverse—material weaknesses exist.

5.48 The purpose of separating the duties of hiring personnel and distributing payroll checks is to separate the a. Authorization of transactions from the custody of related assets. b. Operational responsibility from the record-keeping responsibility. c. Human resources function from the controllership function. d. Administrative controls from the internal accounting controls.

(AICPA adapted)

5.49 If the auditors encounter a significant scope limitation in evaluating an issuer’s internal con- trol over financial reporting, which of the following types of opinions on the effectiveness of the company’s internal control over financial reporting would be appropriate? a. Unqualified opinion or adverse opinion. b. Qualified opinion or adverse opinion. c. Unqualified opinion or disclaimer of opinion. d. Disclaimer of opinion.

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5.50 If the auditor plans to assess control risk at less than the maximum and rely on controls, and the nature, timing, and extent of further audit procedures are based on that lower assessment, the auditor must a. Obtain evidence that the controls selected for testing are designed effectively and oper-

ated effectively during the entire period of reliance. b. Assess control risk at less than the maximum for all relevant assertions. c. Perform only substantive procedures. d. Provide additional examples of responses to assessed fraud risks relating to fraudulent

financial reporting.

5.51 When testing a control activity’s operating effectiveness, procedures the auditor performs to test operating effectiveness would likely include a. Inquiry of appropriate personnel. b. Reading over the company’s code of conduct. c. Reperformance of the control activity. d. Both a and c are correct.

5.52 Matters that could affect the necessary extent of testing for a control activity as it related to the degree of auditor reliance on a control activity would not include the following: a. The frequency of the performance of the control by the company during the period being

audited. b. The length of time that the auditor is planning to rely on the operating efficiency of the

control activity. c. The expected rate of deviation for a control activity. d. The relevance and reliability of the audit evidence to be obtained to test the operating

effectiveness of a control activity.

5.53 The auditor should assess control risk for each relevant assertion by evaluating the evidence obtained from all sources, including a. The auditor’s testing of controls for the audit of internal control on a public company. b. Misstatements detected during the financial statement audit. c. Any control deficiencies identified during the audit. d. All of the above.

5.54 Once the auditor detects a control deficiency, which of the following steps must he or she take first? a. Perform tests of other controls related to the same assertion as the control deemed

ineffective. b. Evaluate the severity of the deficiency on the auditor’s control risk assessment for that

assertion. c. Modify the planned substantive procedures as a result of the deficiency. d. Test the deficient control, assuming a maximum level of risk.

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5.55 Internal Control Audit Standards. Auditors are required to obtain a sufficient under- standing of each component of a client’s internal control. This understanding is used to assess control risk and plan the audit of the client’s financial statements.

Required: a. For what purposes should an auditor’s understanding of the internal control components

be used in planning an audit? b. What is required for an audit team to assess control risk below the maximum level?

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Exercises and Problems

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c. What should an audit team consider when seeking to reduce the planned assessed level of control risk below the maximum?

d. What are the documentation requirements concerning a client’s internal control compo- nents and the assessed level of control risk?

(AICPA adapted)

5.56 Separation of Duties. Your small business client, Phillip’s Computer Repair Shop, is experiencing financial difficulties and has to lay off one of its four employees in the account- ing area. Phillip has asked you to determine what duties should be assigned to the three remaining employees—Abigail, Bryan, and Chris—to maintain the best separation of duties.

Required: Assign the following 10 duties to each of the three employees. a. Reconcile bank statement. b. Open mail and list checks. c. Prepare checks for Phillip’s signature. d. Prepare payroll checks. e. Maintain personnel records. f. Prepare deposit and take to bank. g. Maintain petty cash. h. Maintain accounts receivable records. i. Maintain general ledger. j. Reconcile accounts receivable records to general ledger account.

5.57 Types of Audit Tests. Indicate whether each of the following audit procedures is a test of controls, a substantive test, or a dual-purpose test. Next, indicate the financial statement assertion most closely related to each audit procedure.

Required: a. Vouch recorded sales invoices to supporting shipping documents. b. Inspect recorded sales invoices for credit approval. c. Vouch recorded sales invoices prices to the approved price list. d. Send confirmations to all customers regarding accounts receivable. e. Recalculate the arithmetic accuracy of the recorded sales invoices. f. Compare the shipment date of recorded sales invoices with the invoice record date. g. Trace recorded sales invoices to posting in the general ledger control account and in the

correct customer’s account. h. Select a sample of shipping documents from the shipping department file and trace ship-

ments to recorded sales invoices. i. Scan recorded sales invoices and shipping documents for missing numbers in sequence. j. Vouch sales invoices and shipping documents. k. Evaluate the adequacy of the allowance for doubtful accounts. l. Obtain financial statements or credit reports on large past due accounts and inquire of the

credit manager about collections. m. Calculate an estimate of the allowance for doubtful accounts using prior relations of

write-offs and sales.

5.58 Impact of Sarbanes–Oxley Act. Your long-time client, Central Office Supply, has been rapidly expanding, and the board of directors is considering taking the company public. CEO Terry Puckett has heard that costs of operating a public company have increased sig- nificantly as a result of the Sarbanes–Oxley Act. Puckett is particularly concerned with reports that audit fees have doubled because of internal control provisions of the act and PCAOB Auditing Standard No. 2201. Puckett has asked you to explain the possible effects on the audit of complying with the requirements of Sarbanes–Oxley.

Required: Draft a letter to Puckett outlining the changes in the company’s responsibilities for internal con- trol and changes in the audit due to Sarbanes–Oxley and PCAOB Auditing Standard No. 2201.

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5.59 Internal Control Questionnaire Items: Assertions, Tests of Controls, and Possible Errors or Frauds. Following is a selection of items from the payroll processing internal control questionnaire in Exhibit 5.15. 1. Are names of terminated employees reported in writing to the payroll department? 2. Are authorizations for deductions signed by the employee on file? 3. Is there a timekeeping department (function) independent of the payroll department? 4. Are timekeeping and cost accounting records (such as hours, dollars) reconciled with

payroll department calculations of hours and wages?

Required: For each of the four preceding questions a. Identify the assertion to which the question applies. b. Specify one test of controls an auditor could use to determine whether the control was

operating effectively. c. Provide an example of an error or fraud that could occur if the control were absent or

ineffective. d. Identify a substantive auditing procedure that could detect errors or frauds that could

result from the absence or ineffectiveness of the control items.

5.60 Obtaining a “Sufficient” Understanding of Internal Control. The 12 partners of a regional public accounting firm met in special session to discuss audit engagement effi- ciency. Jones spoke up, saying, “We all certainly appreciate the firmwide policies set up by Martin and Smith, especially in connection with the audits of the large clients that have come our way recently. Their experience with a large public accounting firm has helped build our practice. But I think the standard policy of conducting tests of internal control on all audits is raising our costs too much. We can’t charge our smaller clients fees for all of the time the staff spends on this work. I would like to propose that we give engagement partners discretion to decide whether to do a lot of work on assessing control risk. I may be old-fashioned, but I think I can finish a competent audit without it.” Discussion on the subject continued but ended when Martin said, with some emotion, “But we can’t disregard generally accepted auditing standards like Jones proposes!”

Required: What do you think of Jones’s proposal and Martin’s view of the issue? Discuss.

5.61 Fraud Opportunities. Simon Blank Construction Company has two divisions. The president (Chris Simon) manages the roofing division. Simon delegated authority and responsibility for management of the modular manufacturing division to John Gault. The company has a competent accounting staff and a full-time internal auditor. Unlike Simon’s procedures, however, Gault and his secretary handle all bids for manufacturing jobs, pur- chase all materials without competitive bids, control the physical inventory of materials, contract for shipping by truck, supervise the construction activity, bill the customer when the job is finished, approve all bid changes, and collect the payment from the customer. With Simon’s tacit approval, Gault has asked the internal auditor not to interfere with his busy schedule.

Required: Discuss this situation in terms of internal control and identify frauds that could occur.

5.62 Internal Control Questionnaire Items: Errors That Could Occur from Control Weak- nesses. Refer to the internal control questionnaire on a payroll system (Exhibit 5.15). a. Assume that the answer to each question is no. Prepare a table matching the questions

to errors or frauds that could occur because of the absence of the control. Your column headings should be

Question Possible Error or Fraud Due to Weakness

b. Which controls are preventive controls and which are detective?

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5.63 Role of a Board of Directors in Internal Control. Assume that the local newspaper just ran the following headline and article: “Audit Results: Airport executives from Kentucky racked up $500K in lavish expenses, concert tickets, and even gentlemen’s club tabs”

LEXINGTON, Ky. (AP)—A small commercial airport in Kentucky—and the taxpayers who support it—picked up top executives’ tabs in recent years for Hannah Montana concert tickets, Nintendo Wii video game bundles and even a $4,400 gentlemen club check, according to a state auditor’s report.

The report released Wednesday outlines indulgences ranging from pricey electronics and exercise equipment to lavish meals and champagne. In three years, officials tallied more than $500,000 in questionable personal expenses. [Author’s note: General fund expenses were approximately $10,000,000 annually.]

Kentucky Auditor Crit Luallen said the former executive director at Lexington’s Blue Grass Airport created a culture of wasteful spending so vast, employees sometimes were paid twice for the same expense and used airport credit cards as if they were personal checkbooks.

“I don’t think we have ever seen an audit where so many different individuals involved in the management of a public agency abused the trust with such arrogance and lack of ethical standards,” she said.

Luallen says she has forwarded the case to the Kentucky attorney general, the U.S. attor- ney’s office, and the FBI.

Although the audit only covered the past three years, it does refer to one of the more glar- ing examples reported by the Herald-Leader: a $4,400 charge Michael Gobb and two other directors incurred at a Dallas strip club in 2004.

The charge, which appeared on the credit card statement of the airport’s director of plan- ning, was listed as going to Millennium Restaurant. The word “marketing” was handwritten next to the amount. The Associated Press obtained that receipt and others through an open records request.

The audit found that airport employees also used the coffers for tuxedos and other expen- sive clothing; more than 400 DVDs—many of them currently missing—for the internal airport library; $14,000 in holiday hams given out as gifts; and $7,400 for a NASCAR driving experi- ence excursion for staff described as “team building.”

More than 92 percent of the things Gobb charged to his airport card lacked proper docu- mentation, Luallen said.

While Luallen acknowledged that Gobb was responsible for the free-spending culture, she said the board and its public accounting firm should have supervised the airport more closely.*

Source: Excerpted from Ky. Airport Execs Racked Up Lavish Expenses, Jeffrey McMurray, Associated Press, February 26, 2009.

Required: a. Discuss the role of the board of directors in monitoring the behavior of a chief executive

officer. b. If the chief executive officer has subordinates incur expenses that he or she approves,

how can the board prevent abuse? c. Should external auditors be expected to detect abuses such as these? d. How should the use of credit cards be controlled?

5.64 Authorization of Credit Tests of Controls — Using IDEA For this exercise, your cli- ent, Bright IDEAs Inc., has provided you with data for two related files, a listing of sales invoices, and a listing of customers with credit limits. To test whether credit authorization controls are in place, the auditor must complete a series of related steps: 1. Import the client’s database of sales invoices (pp. 28–45 of the IDEA Workbook). 2. Summarize the Accounts Receivable balance by customer (pp. 67–79 of the IDEA

Workbook).

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218 Part Two The Financial Statement Audit

3. Import the client’s customer credit limit data into IDEA (pp. 70–79 of the IDEA Workbook).

4. Join the Accounts Receivable balances by customer with the credit limit data (pp. 80–87 of the IDEA Workbook).

5. Extract customers with exceeded credit limits (pp. 88–89).

Required Data Available on Connect ∙ ACC_REC2015.ACCDB ∙ CUSTOMER.TXT

Required: Complete the preceding steps and answer the following questions: a. How many customers were granted credit with no indication that they had any credit

limit assigned to them? b. How many customers exceeded their credit limit? c. What effects would the findings in parts (a) and (b) have on the auditor’s assessment of

the risk of material misstatement? What accounts and assertions are most likely influ- enced by these findings?

Source: C1202 IDEA Data Analysis Workbook: IDEA Version Ten. 2016. CaseWare IDEA, Inc. Toronto, CA.

5.65 Identifying Payments to Unauthorized Suppliers — Using IDEA For this exercise, your client, BrightIDEAs Inc., has provided you with data for two related files: an accounts payable history file and a supplier master file. To test the authorization of purchases to only legitimate suppliers, the auditor must complete a series of related steps: ∙ Import the client’s database of accounts payable (pp. 98–109 of the IDEA Workbook). ∙ Import the client’s authorized supplier list (pp. 110–113 of the IDEA Workbook). ∙ Merge the accounts payable and supplier databases (pp. 169–175 of the IDEA Workbook). ∙ Identify payments to unauthorized suppliers (pp. 175–176 of the IDEA Workbook). ∙ ACCPAY2015.TXT ∙ Supplier.xls

Required: Complete the preceding steps and answer the following questions:

∙ How many different unauthorized suppliers were paid during the year? ∙ What was the total dollar amount of the payments to unauthorized suppliers? ∙ What effects would the findings in parts (a) and (b) have on the auditor’s assessment of

the risk of material misstatement? What accounts and assertions are most likely influ- enced by these findings?

Source: C1202 IDEA Data Analysis Workbook: IDEA Version Ten. 2016. CaseWare IDEA, Inc. Toronto, CA.

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Internal Control Testing You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Water- shed and have been assigned to the engagement team of a new audit client, Apollo Shoes Inc. You have been asked to perform certain procedures related to the internal control system for Apollo Shoes. A detailed audit program for performing the procedures related to the internal control system, as well as working papers and supporting documentation, can be found on Connect.

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Audit Plan

Appendix 5A

DUNDER-MIFFLIN INC. Audit Plan for Tests of Controls in the Payroll Cycle

12/31/20

   

  Performed By Ref.

1. Observe the separation of duties between the personnel, timekeeping, and payroll departments.

   

2. Select a sample of payments from the payroll distribution for the year.    

a. Vouch labor costs to labor reports.    

b. Vouch labor reports to time tickets or computerized listing.    

c. Examine documentary evidence of supervisor review of labor costs.    

d. Examine documentary evidence of supervisor approval.    

3. Account for numerical sequence of selected job cost tickets and paychecks. Trace a sample of employees in the personnel file to payroll department files and the payroll register.

   

4. Examine documentary evidence of budget comparison.    

5. Reconcile the payroll account distribution report and the job cost sheets.    

6. Examine supervisor signature on payroll reports. Note evidence of comparison to budget.

   

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Employee Fraud and the Audit of Cash

C H A P T E R 6

Rather fail with honor than succeed by fraud. Sophocles, Greek playwright and scholar (496–406 BC)

Professional Standards References

Topic AU-C/ISA Section

AS Reference

Consideration of Fraud in a Financial Statement Audit 240 2401

Consideration of Laws and Regulations 250 2405

Audit Planning 300 2101

Consideration of Internal Control in an Integrated Audit 265 2201

Identifying and Assessing the Risks of Material Misstatement 315 2110

Auditors’ Responses to Risks of Material Misstatement 330 2301

Audit Considerations Relating to an Entity Using a Service Organization 402 2601

Audit Evidence 500 1105

External Confirmations 505 2310

Using the Work of an Audit Specialist 620 1210

LEARNING OBJECTIVES In Chapter 5, we emphasized the important role of the internal control system in helping to ensure that the financial statement information being presented by an organization is credible and can be relied upon. Beyond its critical nature in the production of reliable financial statement information, the establishment of an internal control system is also important to help protect an organization’s assets from being stolen. In this chapter, we focus on the auditor’s role in helping clients prevent and/or detect the misappropriation (or theft) of assets in their organization.

Recall that in Chapter 4 we focused on the auditor’s responsibilities related to fraudulent financial reporting, that is when an organization intentionally issues false or misleading financial statements to the investing marketplace. The professional standards make clear that auditors are also responsible for considering the possibility of misstatements that arise from the misappropriation of assets, otherwise known as employee theft. As a result, this chapter begins with a comprehensive discussion of this type of fraud.

Next, because cash is often the primary target of employee theft, the chapter logically transitions to a discussion of how the cash balance is audited.

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This discussion includes a description of the most common relevant financial statement assertions, along with a focus on the control and substantive testing procedures that are typically performed during the audit of cash balances. Importantly, our discussion of controls includes specific examples of additional internal control activities that can be put in place to help prevent or detect employee theft, also known as a misappropriation of assets fraud.

Your objectives are to be able to:

LO 6-1 Define and explain the differences among several kinds of employee frauds that might occur at an audit client.

LO 6-2 Identify and explain the three conditions (i.e., the fraud triangle) that often exist when a fraud occurs.

LO 6-3 Describe techniques that can be used to prevent employee fraud.

LO 6-4 Identify the relevant assertions and risks of material misstatement that are typically related to the cash balance.

LO 6-5 Identify important internal control activities present in a properly designed system to mitigate the risk of material misstatements for each relevant assertion related to cash and to help prevent or detect employee fraud.

LO 6-6 Give examples of substantive procedures used to test cash and relate them to the relevant assertions.

LO 6-7 Describe some extended procedures for detecting employee fraud schemes involving cash.

INTRODUCTION Fraud examinations can be very exciting for auditors. A fraud examination has the aura of detective work—finding things that people want to keep hidden. However, such examina- tions are not easy and are not activities to be pursued without special training, experience, and care. While Module D presents a more detailed discussion of fraud examinations, this chapter presents a general introduction to the theory and definitions related specifi- cally to misappropriation of assets-type fraud. In addition, you will learn how auditors evaluate the design and operating effectiveness of internal controls that are designed to mitigate the risk of this type of employee fraud. Importantly, because cash is often the primary target of fraudsters in these schemes, we illustrate internal controls as they relate to cash. Next, we present a discussion of the audit of the cash account on the balance sheet, with specific examples of internal control activities and related control tests and substantive audit procedures.

It is essential that auditors maintain their professional skepticism at all times through- out the engagement. In fact, professional standards require that when auditors brainstorm about the potential for all types of fraud in an engagement, the activity should “occur with an attitude that includes a questioning mind, and the key engagement team members should set aside any prior beliefs they might have that management is honest and has integrity.”1 Why is it so important that auditors maintain such a high degree of skepti- cism? Because a fraud is often committed by a person that an auditor least expects. Con- sider a Little League coach ripping off the league to buy expensive jewelry by using a routing number from a league payroll check.2 Or consider an executive assistant at a large public accounting firm who wrote more than $1 million in checks to herself that were drawn on a client’s bank account.3 You just never know from where the next fraud might originate!

LO 6-1 Define and explain the differences among several kinds of employee frauds that might occur at an audit client.

1PCAOB Auditing Standard No. 2110, “Identifying and Assessing Risks of Material Misstatement.” 2“Little League Coach Accused of Fraud,” St. Petersburg Times, p. 3B, July 4, 2009. 3“Aide Gets 2 Years in Fraud Case,” San Francisco Chronicle, p. D2, October 28, 2010.

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Not surprisingly, whenever a fraud risk exists, the professional standards require that auditors gain an understanding of the internal controls that are in place to mitigate the assessed fraud risk. At a minimum, auditors are required to document that under- standing in the workpapers. In fact, auditors are also likely to evaluate the design, implementation, and operating effectiveness of identified internal control activi- ties related to fraud risks that exist. Importantly, an entity’s internal control cannot thwart or detect all fraud schemes. Inherent limitations in internal control (such as collusion among employees) prevent complete assurance that every fraud scheme will be detected before a loss is incurred. For this reason, the entity’s auditors, accoun- tants, and security personnel must be acquainted with the basics of fraud awareness. Although the professional auditing standards concentrate on fraudulent financial reporting—the production of materially false and misleading financial statements— the standards also require auditors to pay particular attention to employee fraud per- petrated against a client for several reasons. First, it is possible that employee fraud can result in a material financial statement misstatement to the extent that a crime was covered up using the financial statements. Second, employee fraud can be indicative of control deficiencies which can influence the auditor’s assessment of control risk. Finally, audit clients always want to know if they are being robbed by their employees, regardless of the amount being stolen!

Employee Fraud Overview Fraud consists of knowingly making material misrepresentations of fact with the intent of inducing someone to believe the falsehood and act upon it and, thus, suf- fer a loss or damage. This definition encompasses all ways by which people can lie, cheat, steal, and deceive other people. Employee fraud (often referred to as misappro- priation of assets) is the use of fraudulent means to take money or other property from an employer. It usually involves falsifications of some kind—false documents, lying, exceeding authority, or violating an employer’s policies. Employee frauds generally consist of (1) the fraudulent act itself, (2) the conversion of assets to the fraudster’s use (very easy if cash is involved), and (3) the cover-up. Catching people in the fraudu- lent act is difficult to accomplish. The act of conversion is equally difficult to observe because it typically takes place in secret away from the entity’s offices (e.g., selling stolen inventory). By noticing signs and signals of fraud and then following the trail of missing, mutilated, or false documents that are part of the accounting records cover- up, alert auditors uncover many frauds. Being able to notice red flags, oddities, and unusual events takes some experience, but this chapter provides you with some ideas about where and when to look.

This is exactly the plan that was put into action by James Hammes after stealing $8.7 million from his employer, a Pepsi-Cola bottler based in Ohio. Amazingly, his plan almost worked as he eluded capture by hik- ing and then living on the Appalachian Trail using an assumed name.

Hammes committed the crime while working as a controller at the company from 1998 to 2009. Because he had access to both the cash and the accounting records, he was able to divert company cash into a personal bank account and then cover up his crime by manipulating the

accounting records. When the FBI started to ask him questions about the missing cash, Hammes decided to take a hike. Eventually, another hiker became aware of his story and tipped off the authorities. Hammes was sentenced to eight years in prison and must repay the money stolen.

Source: Michael Cohn, “Accountant Who Hid on Appalachian Trail Jailed for Embezzling Millions from Pepsi Bottler,” Accounting Today, June 23, 2016, available at: http://www.accountingtoday.com/news/audit-accounting/ accountant-appalachian-trail-jailed-embezzling-pepsi-78488-1.html.

Let’s Go for a Hike on the Appalachian Trail . . . for Life

AUDITING INSIGHT

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Employee Fraud Red Flags Employee fraud can involve all types of employees from high-level executives to hourly employees in the warehouse. For most people, committing a fraudulent act is stressful. Observation of changes in a person’s habits and lifestyle may reveal some red flags.4 Fraudsters often exhibit these behaviors:

∙ Experience sleeplessness. ∙ Drink too much. ∙ Take drugs. ∙ Become irritable easily. ∙ Can’t relax. ∙ Get defensive, argumentative. ∙ Can’t look people in the eye. ∙ Sweat excessively. ∙ Go to confession (e.g., priest, psychiatrist). ∙ Find excuses and scapegoats for mistakes. ∙ Work standing up. ∙ Work alone. ∙ Work late frequently. ∙ Don’t take vacations.

Personality red flags are difficult because (1) honest people often show them as well, (2) they often are hidden from view, and (3) auditors are not in a good position to notice these characteristics. Managers are in the best position to notice changes, especially when a person varies his or her lifestyle or spends more money than his or her salary seems to justify—for example, on homes, furniture, jewelry, clothes, boats, autos, vacations, and the like. Therefore, it is imperative that the auditor make specific inquiries of manage- ment regarding changes in an employee’s demeanor and lifestyle.

Characteristics of Fraudsters White-collar criminals are not like typical bank robbers who are often described as “young and dumb.” Bank robbers and other strong-arm criminals often make comical mistakes such as writing their holdup note on the back of a probation identification card, leaving the getaway car keys on the convenience store counter, using a zucchini as a holdup weapon, going through a fast-food restaurant’s drive-through window backward,

4Long lists of red flags can be found in G. J. Bologna and R. J. Lindquist, Fraud Auditing and Forensic Accounting (New York: John Wiley & Sons, 1995), pp. 49–56; W. S. Albrecht et al., in R. K. Elliott and J. J. Willingham, Management Fraud: Detection and Deterrence (New York: Petrocelli Books Inc., 1980), pp. 223–226; Statement on Auditing Standards No. 99 (New York: AICPA, 2002); Auditing for Fraud courses of the Association of Certified Fraud Examiners; and courses offered by other organizations such as the AICPA and The Institute of Internal Auditors.

Management fraud is an intentional deception that is orchestrated by management and is designed to injure investors and creditors by provid- ing materially misleading information.

Errors are unintentional misstatements or omissions of amounts or dis- closures in financial statements.

Direct-effect illegal acts are violations of laws or government regulations by the company, or its management or employees, that

produce direct and material effects on dollar amounts in financial statements.

Embezzlement is a type of fraud that typically involves an employee wrongfully stealing assets that were entrusted to his or her care, custody, or control. In many situations, embezzlement is accompanied by false accounting entries or lying to try to cover up the crime.

Other Definitions Related to Fraud and Illegal Acts

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and timing the holdup to get stuck in rush hour traffic. Then there’s the classic story about the robber who ran into his own mother at the bank. (She turned him in!)

Burglars and robbers average about $400–$500 for each hit. Employee frauds often range from $20,000 up to $500,000 or even in the millions if a computer is used. Yet employee frauds are not usually the intricate, well-disguised ploys you find in espionage novels. Who are these thieves wearing ties? What do they look like? Unfortunately, they look like most everybody else, including you and me. A typical white-collar criminal

∙ Has education beyond high school. ∙ Is likely to be married. ∙ Is a member of a church, mosque, or temple. ∙ Ranges in age from teens to over 60. ∙ Is socially conforming. ∙ Has an employment tenure from 1 to 20 years (although the scale of the fraud typically

increases with tenure as the employee becomes more trusted). ∙ Has no arrest record. ∙ Usually acts alone (70 percent or more of incidents).

In February 2013, investigators arrested Craig Haber, a partner in tax and advisory services in the New York City office of Grant Thornton for stealing payments made by clients to the firm. Allegedly, his crimes began in July 2004 and continued through July 2012. In total, he is alleged to have stolen approximately $4 million from Grant Thornton. Apparently, Haber provided instructions to his clients to send checks or wire transfers directly to him in New York instead of sending the

payments to Grant Thornton’s headquarters in Chicago. He then took the checks and deposited them in a bank account that was opened “in the name of a sham business that was very similar to Grant Thornton’s name.” Haber then would transfer the funds from this account to his personal account. Source: M. Cohn, “Former Grant Thornton Partner Arrested for Stealing $4 Million in Client Payments,” Accounting Today, February 7, 2013.

Are You Kidding Me?AUDITING INSIGHT

In July 2012, almost a year after MF Global filed for bankruptcy on October 31, 2011, investigators reported that they had located the more than $1.6 billion of customer funds that were miss- ing from the company. The report ended a difficult process that revealed a complete lack of internal control in handling clients’ funds. Scott O’Malia, a commissioner at the Commodity Futures

Trading Commission, commented that the books at MF Global “are a disaster” and it is difficult to “figure out what numbers are the real numbers.”

Sources: “Inside the Hunt for MF Global Cash,” The Wall Street Journal, November 10, 2011, p. c1; “$1.6 Billion in Missing MF Global Funds Traced,” http://money.cnn.com/2012/04/24/news/companies/mf-global/index.htm.

How Can $1.6 Billion of Cash Be Missing?AUDITING INSIGHT

White-collar criminals do not make themselves obvious, although they may leave telltale signs or red flags. Older individuals (usually over 50) who hold high executive positions, have long tenure, and are respected and trusted employees have often gained the trust and confidence of others and, therefore, are in a position to commit the largest frauds. After all, these are the people who have access to the largest amounts of money and have the power to give orders and override controls. When managers minimize the significance of a weak or missing control by rationalizing that the employee involved is a “long-time trusted employee,” most experienced auditors will actually escalate their level of fraud risk awareness. You should as well.

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THE FRAUD TRIANGLE The three conditions that are likely to be present when a fraud occurs (Exhibit 6.1) are com- monly referred to as the fraud triangle. The first condition (incentive/pressure) recognizes that an employee or manager of a company is likely to either have incentives in place (e.g., bonus compensation) or be under significant pressure to meet specific estimates, forecasts, or expectations about net income. The second condition (opportunity) recognizes that in order for a fraud to be perpetrated, there must either be a weakness in the system of inter- nal control or an ability to circumvent the system. Finally, the third condition (attitude/ rationalization) recognizes that for an employee or a manager of a company to perpetrate a fraud, the individual must possess an “attitude” that allows her or him to rationalize why he or she is knowingly committing a crime. Each of these conditions is now discussed.5

LO 6-2 Identify and explain the three conditions (i.e., the fraud triangle) that often exist when a fraud occurs.

5For further reference, see D. R. Cressey, “Management Fraud, Accounting Controls, and Criminological Theory,” pp. 117–147, and Albrecht et al., “Auditor Involvement in the Detection of Fraud,” pp. 207–261, both in R. K. Elliott and J. J. Willingham, Management Fraud: Detection and Deterrence (New York: Petrocelli Books Inc., 1980); J. K. Loebbecke, M. M. Eining, and J. J. Willingham, “Auditors’ Experience with Material Irregularities: Frequency, Nature, and Detectability,” Auditing: A Journal of Practice and Theory, Fall 1989, pp. 1–28.

REVIEW CHECKPOINTS 6.1 What are the defining characteristics of employee fraud? Embezzlement? 6.2 What does a fraud perpetrator look like? How does one act?

• A small business owner hired his best friend to work as his accountant. The friend was given full, unlimited access to all aspects of the business and was completely responsible for the accounting. Five years later, the owner finally terminated the friend’s employment because the business was not profitable. Upon taking over the accounting responsibilities, the owner’s wife found that cash receipts from customers were twice the amounts formerly recorded by the accountant “friend.” An investi- gation revealed that the friend had stolen $450,000 in cash sales receipts from the business while the owner had never made more than $16,000 a year. (The friend had even used the stolen money to make loans to the owner to keep the business going!)

• An electrical supply company employed only one bookkeeper. She wrote the checks and reconciled the bank account. In the cash disbursements journal, she coded some checks as inventory, but she wrote the checks to herself, using her own name. When

the checks were returned with the bank statement, she simply destroyed them. Confronting continuous guilt over doing some- thing she knew was wrong, she contacted a lawyer and turned herself in but not before she had stolen $416,000 over a five-year period. Because of the lack of separation of duties and her trusted status in the company, the fraud might have continued indefinitely (or at least until she bankrupted the company).

• Alex W. was a 47-year-old treasurer of a credit union. Over a seven- year period, he stole $160,000 from it. He was a good husband and father of six children, and he was a highly regarded credit union offi- cial. His crime came as a stunning surprise to his associates. Why did he do it? He owed significant amounts on his home, cars, col- lege for two children, two side investments, and five credit cards. His monthly payments significantly exceeded his take-home pay.

Source: Association of Certified Fraud Examiners (ACFE), “Auditing for Fraud.”

Trusted Employees?AUDITING INSIGHT

EXHIBIT 6.1 Fraud Conditions Source: W. Hillison, D. Sinason, and C. Pacini, “The Role of the Internal Auditor in Implementing SAS 82,” Corporate Controller, July/August 1998, p. 20.

Motivation Opportunity

Highest Risk

Rationalization

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Incentive/Pressure Incentive or pressure gives rise to a motive to commit fraud. A motive, in the fraud con- text, is essentially a reason for a person to take a fraudulent action that is believed to be unshareable with friends and confidants. Psychotic motivation is relatively rare, but it is characterized by the habitual criminal who steals simply for the sake of stealing. In general, egocentric motivations drive people to steal to achieve more personal prestige. Ideological motivations are held by people who think their cause is morally superior and they are justified in making someone else a victim. However, economic benefits are by far the most common motivations in business frauds.

Incentives for employees to commit fraud can come from many places. In the case of Wells Fargo employees, the source may have been as simple as a rhyme. Over a four year period, over 5,000 lower-wage employees fraudulently opened over a million fake bank accounts and credit cards to make their ‘cross-sell’ goals of eight new accounts to existing custom- ers. By opening these fake accounts, and sometimes transferring money into them from the customers’ other accounts, Wells Fargo earned huge

amounts of fraudulent fees and employees met their quotas. But why eight? According to the CEO in the 2010 Wells Fargo annual report, “I’m often asked why we set a cross-sell goal of eight. The answer is, it rhymed with ‘great.’ Perhaps our new cheer should be: ‘Let’s go again, for 10!’”

Source: “How Wells Fargo Encouraged Employees to Commit Fraud”, October 6, 2016, http://theconversation.com/how-wells-fargo-encouraged-employees- to-commit-fraud-66615

Driven by a Rhyme!AUDITING INSIGHT

Kirbyjon Caldwell, a Houston pastor known for advising Presidents George W. Bush and Barack Obama, and Gregory Smith, a former financial advisor previously banned by the Financial Industry Regula- tory Authority, defrauded 29 elderly investors of $3.4 million by selling them old Chinese bonds that had been in default for over 75 years. The men are facing charges from the SEC.

Caldwell used his portion of the funds to pay for his living expenses, including his mortgage payment. Smith chose to purchase luxury automobiles.

Despite facing SEC charges, Caldwell still plans to preach to his congregation on Sundays.

Source: C. English, “Famed Pastor Defrauded $3.4M from Elderly Investors: SEC” NY Post, March 30, 2018.

Do You Prefer a Mortgage Payment or a Luxury Vehicle?

AUDITING INSIGHT

The economic motive is simply a need or desire for money, and at times it can be intertwined with egocentric and ideological motivations. Ordinary, honest people can experience circumstances in which they have a new or unexpected need for money. If the need arises and the legitimate channels to raise the money are closed, fraud may become an option for some individuals. Consider the following needs:

∙ Making a house payment. ∙ Pay uninsured medical bills. ∙ Pay gambling debts. ∙ Pay for drugs and alcohol. ∙ Pay alimony and child support. ∙ Pay for high lifestyle (vacation homes, cars, boats). ∙ Finance business or stock speculation losses.

Opportunity An opportunity is an open door that enables a would-be fraudster to violate some type of trust. The violation may be a circumvention of existing internal control activities, or it

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may be simply taking advantage of an absence or lapse of a control activity in an entity. In general, the higher the position in an organization, the higher the degree of trust, the more likely that controls can be overridden, and, hence, the greater the opportunity for larger frauds. Here are some examples:

∙ Inventory is not counted on a regular basis, so inventory shortages and losses are not known.

∙ Proper separation of duties related to cash receipts or payments is compromised because of a termination or retirement.

∙ The vice president of finance has investment authority without review. ∙ Frequent emergency jobs leave a lot of excess material in a manufacturing plant just

lying around.

Two lunch ladies in New Canaan, CT, were charged with embezzling nearly $500,000 from two schools in the area. Over the course of at least five years, the sisters devised a plan to steal cash payments made by students because the controls over the cash receipts were weaker than at other area schools. Their free lunches were stopped when employees from nearby schools noticed the financial inconsistencies

between school lunch programs. Once a point of sale system was put in place to track individual sales and the amount of cash received, daily deposits increased to appropriate levels.

Source: Beverly Yaa Danquah, “Lunch lady sisters accused of stealing nearly $500,000” NBC News, August 14, 2018. https://www.nbcnews.com/news/ us-news/lunch-lady-sisters-accused-stealing-nearly-500-000-n900596

That’s a Lot of Lunches!AUDITING INSIGHT

The second in command and heir-apparent to the CEO of a company apparently couldn’t wait her turn. It was discovered that she was forg- ing the CEO’s signature on expense reimbursements. Initially, the company attributed this to a lapse in judgment and a desire to get reimbursed faster. However, an investigation quickly discovered that she had received nearly $1.4 million in fraudulent reimbursement.

Included in this were many personal expenses reclassified as business expenses, such as toys labeled as “meals while out of town.”

Source: T. Couch, “Skimming and Scamming: Detecting and Preventing Expense Reimbursement Fraud” Accounting Today, June 25, 2018. https:// www.accountingtoday.com/opinion/skimming-and-scamming-detecting-and- preventing-expense-reimbursement-fraud

Her Time Was ComingAUDITING INSIGHT

Attitude/Rationalization Practically everyone, even the most violent criminal, knows the difference between right and wrong. Unimpeachable integrity is the ability to act in accordance with the high- est moral and ethical values at all times. Thus, it is the lapses in integrity that permit a person’s incentives or pressures to motivate fraudulent action when the opportunity pres- ents itself. But people normally do not make deliberate decisions to “lack integrity today while I steal some money.” They find a way to describe (rationalize) the act in words that make it acceptable for their self-image. Here are some of these rationalizations:

∙ I need it more than other people. ∙ I am borrowing the money and will pay it back. ∙ Nobody will get hurt. ∙ The company is big enough to afford it. ∙ A successful image is the name of the game. ∙ Everybody is doing it. ∙ I am underpaid, so this is due compensation.

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FRAUD PREVENTION Building a good fraud prevention program is an extremely difficult task. Most day-to-day business activities require some trust in the processes for which controls will never be absolute. Further, in an electronic payment environment, lack of controls can quickly lead to costly fraud from both inside and outside the organization. For example, if we entrust an individual with authorization for cash expenditures, a stolen or shared password enables anyone who acquires access to the employee’s account to obtain physical custody of the asset. As a result, taking steps to “fraud proof” an organization is a tall order.

Accountants and auditors have often been exhorted to be the leaders in fraud preven- tion by employing their skills in designing “tight” control systems. This strategy is, at best, a short-run solution to a large and pervasive problem. Business activity is built on the trust that people at all levels will do their jobs properly. As a result, it is essential that management establish a strong control environment. A strong control environment and tone at the top can have a pervasive effect on the prevention of fraud at an entity because it can impact all components of an organization’s internal control system. For example, a CEO who always acts with ethics and integrity sends a strong message to all employees that management is serious about internal controls and fraud prevention.

Beyond a strong control environment, management must be sensitive to the needs of the business by instituting controls that will prevent or detect fraud without impeding business activity. Control systems limit trust and, in the extreme, can strangle business in bureaucracy. The challenge is to have useful controls and to avoid picky rules that are “fun to beat.” Managers and employees must have freedom to do business, which may mean giving them some freedom that can result in committing frauds. Effective long-run prevention measures are complex and difficult, involving the elimination of the causes of fraud by mitigating the effect of motive, opportunity, and lack of integrity.

Managing People and Pressures in the Workplace From time to time, people experience financial and other pressures. The pressures can- not be eliminated, but forums and facilities for sharing such pressures can and have been created by leading organizations. Some companies have “ethics officers” to serve this purpose. Their job is to be available to talk over various ethical dilemmas faced in the workplace and help employees identify legitimate responses. However, it is important to remember that the ethics officers are not normally psychological counselors.

Many companies have anonymous hotlines for reporting ethical problems. Indeed, companies that must comply with the Sarbanes–Oxley Act of 2002 are required to main- tain an anonymous employee hotline. Usually, the best kind of hotline arrangement is to have the responding party be a third-party agency outside the organization. In the United States, some external providers are in the business of being the recipients of hotline calls and coordinating their activities with the audit committee or the internal audit department of the various organizations to whom they provide this service.

LO 6-3 Describe techniques that can be used to prevent employee fraud.

REVIEW CHECKPOINTS 6.3 What are some pressures that can cause honest people to contemplate fraud? List some egocentric

and ideological pressures as well as economic ones. 6.4 What conditions provide opportunities for employee fraud? 6.5 Give some examples of rationalizations that people have used to excuse fraud. Can you imagine

using them? 6.6 Is capability required to commit a fraud? Is capability part of opportunity, or should it be considered

a separate element of fraud?

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Another method of long-term fraud prevention, however, lies in the treatment of peo- ple within an organization. Managers and supervisors at all levels can exhibit a genuine concern for the personal and professional needs of their subordinates and fellow man- agers, and subordinates can show the same concern for each other and their managers. Many companies facilitate this caring attitude with an organized employee assistance program (EAP). They offer a range of counseling referral services dealing with substance abuse, mental health issues, family problems, crisis help, legal matters, health education, retirement, career paths, job loss troubles, and family financial planning. These program types are not guaranteed to prevent fraud, but they can have a positive impact for an organization.

When external auditors are engaged in the audit of an entity’s financial statements, they must obtain an understanding of and evaluate the control environment. In so doing, the audit team should consider how management addresses these types of employee issues. Using devices such as those discussed here can enhance an entity’s control envi- ronment and represents the start of an effective internal control system.

Internal Control Activities and Employee Monitoring As discussed in Chapter 5, internal control activities may include job descriptions and performance specifications that help people know the specific tasks they are supposed to accomplish. An entity whose only control is “trustworthy employees” has no control.6 The possibility of being detected by a control activity can be an effective deterrent to a potential fraudster. Stated simply, control activities often take away the opportunity for a fraudster to commit a fraud.

As previously discussed, concealment of the crime is a distinguishing attribute of a fraud. Often, the audit team’s first indication of a fraud is the identification of a control violation. Cover-up attempts generally appear in the accounting records. The key for an auditor is to be aware of and notice exceptions and oddities such as the following:

∙ Transactions recorded at unusual times of the day, month, or year. ∙ An unusual (either large or small) number or dollar amount of transactions. ∙ Transactions for “round” dollar amounts (e.g., $50,000). ∙ Transactions associated with unusual branches or locations of a multilocation entity. ∙ Cash shortages and overages. ∙ Excessive voids and credit memos. ∙ General ledgers that do not balance. ∙ An increase in past due receivables. ∙ Inventory shortages. ∙ Unexplained adjustments to inventory or accounts receivable balances, especially

without adequate supporting documentation. ∙ Increased scrap or waste in a manufacturing plant. ∙ Alterations on official documents. ∙ Duplicate payments made to the same vendor. ∙ Employees who cannot be found. ∙ Use of copies instead of originals for supporting documentation. ∙ Missing documentation to support transactions. ∙ Unusual endorsements on checks. ∙ Unusual patterns in deposits in transit. ∙ Common names or addresses for refunds. ∙ Consistent customer complaints about account balances or missing shipments.

6W.S. Albrecht, “How CPAs Can Help Clients Prevent Employee Fraud,” Journal of Accountancy, December 1988, pp. 110–114.

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As noted previously in Chapter 5, an important feature of an effective internal control system is the separation of duties and responsibilities for (1) transaction authorization, (2) record keeping, (3) custody of or access to assets, and (4) reconciliation of actual assets to the accounting records. In general, a person acting alone or in a conspiracy who can perform two or more of these functions can commit a fraud by taking assets, convert- ing them, and then covering up the crime. Proper separation of duties and responsibilities can prevent such fraudulent actions. For example, as it relates to cash disbursements, effective internal control begins with different people and different departments handling the cash disbursement authorization; custody of blank documents (checks); record keep- ing for payments; and bank reconciliation. Auditing with fraud awareness often involves the combination of observing client control activities that were put in place and trying to “think like a crook” and imagine ways that theft could occur. When controls are missing, the ways and means for theft may be obvious. Otherwise, it might take significant plan- ning and collusion to figure out how to steal from an employer.

According to fraud experts Joseph Wells and John Gill of the Asso- ciation of Certified Fraud Examiners, when assessing fraud risk, answering a set of 15 questions is a good starting point for sizing up a company’s vulnerability to fraud and creating an action plan for less- ening the risks. Their key questions are

1. Is the company dominated by one or two key employees?

2. Do any key employees appear to have a close association with vendors?

3. Do any key employees have outside business interests that might conflict with their job duties?

4. Does the organization conduct pre-employment background checks to identify previous dishonest or unethical behavior?

5. Does the organization educate employees about the importance of ethics and antifraud programs?

6. Does the organization have antifraud policies and provide an anonymous way to report suspected violations of ethics?

7. Is job or assignment rotation mandatory for employees who han- dle cash receipts and accounting duties?

 8. Has the company established positive pay controls with its bank by supplying the bank with a daily list of checks issued and autho- rized for payment?

 9. Are refunds, voids, and discounts evaluated on a routine basis to identify patterns of activity among employees, departments, shifts, or merchandise?

10. Are purchasing and receiving functions separate from invoice pro- cessing, accounts payable, and general ledger functions?

11. Is the employee payroll list periodically reviewed for duplicate or missing Social Security numbers?

12. Are there policies and procedures that address the identification, classification, and handling of proprietary information?

13. Do employees who have access to proprietary information sign nondisclosure agreements?

14. Is there a company policy that addresses the receipt of gifts, dis- counts, and services offered by a supplier or customer?

15. Are the organization’s financial goals and objectives realistic?

Source: Joseph T. Wells and John D. Gill, “Assessing Fraud Risk,” Journal of Accountancy, October 2007, pp. 63–65.

When Assessing Fraud Risk, Answer These Questions

AUDITING INSIGHT

When collecting corroborating evidence to support the financial statements, the audit team must remain vigilant against the potential for fraud. Discrepancies in the accounting records, conflicting evidence, and missing documentation are all symptomatic of finan- cial statement fraud. When the audit team identifies such instances, members must follow up with management to identify the source of the problems. Management’s response is a key source of evidence; vague, implausible, or inconsistent responses to inquiries can be a key indicator of the pervasiveness of the fraud. Similarly, problematic or unusual relationships between the audit team and management are often present in financial state- ment frauds.

Module D presents a comprehensive discussion of fraud examinations and how they differ from financial statement audits. However, an example to illustrate the difference

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between the engagements relates to evidence. The collection of evidence in a fraud examination (which can lead to prosecution and court scrutiny) is fundamentally dif- ferent from the collection of evidence to support the auditor’s opinion. If the auditors do come across questionable documents or any other evidence that may indicate fraud, they should immediately work to preserve the chain of custody of evidence. The chain of custody is the crucial link of the evidence to the criminal suspect that bears directly on the relevance of evidence often referred to by attorneys and judges. If documents are lost, mutilated, coffee stained, or otherwise compromised (so a defense attorney can argue that they were altered to frame the suspect), they lose their effectiveness for the prosecution. When completing a fraud examination, auditors should learn to mark the evidence, writing an identification of the location, condition, date, time, and circumstances as soon as it appears to be a signal of fraud. This marking should be on a separate tag or page; the original document should be put in a protective (plastic) envelope for preservation and locked away for protection. Then audit work should proceed with copies of the documents instead of originals. A record should be made of the safekeeping and of all persons who use the original. Any eyewitness observations should be recorded in a timely manner in a memorandum or on tape (audio or video) with corroboration of colleagues, if possible.

Similarly, an auditor may be involved in collecting evidence that is found in computers or stored in a digital manner. This type of computer forensic work must be completed with great care, and the goal is to examine the evidence in a manner that would be appropriate in reaching the goal of “identifying, preserving, recovering, analyzing, and presenting facts and opinions about the information.” Generally, the evidence that is gathered from a computer forensic investigation is subject to the same rules of evidence as manual data in the eyes of law enforcement. This brief example underscores the importance of an auditor being properly trained to conduct a fraud examination.

Tone at the Top Establishing the right tone at the top is an essential step toward building a strong fraud prevention program. This tone is established by upper management, in large part, to dem- onstrate a commitment to integrity and high ethical standards in the completion of all activities throughout the organization. The upper management team is responsible for setting the tone at the top. To send the right message from the top, many organizations publish codes of conduct for employees. Some of these codes are simple, and some are very elaborate. Government agencies and defense contractors typically have the most elaborate rules for employee conduct. Sometimes these codes are effective; sometimes they are not. However, a code can be effective only if the control environment and tone at the top support it. When the chairman of the board and the president make themselves visible and living examples of the code of conduct, other people will then believe it is real. Subordinates tend to follow the boss’s lead.

One of the large public accounting firms was conducting an “ethical compliance” attestation engagement of a Fortune 500 company. An ethical compliance attestation engagement is designed to ensure, among other things, that client personnel are following the company’s code of ethical conduct. Believing that the control environment and tone at the top were the most important elements of the client’s ethi- cal compliance control system, the engagement team started in the

CEO’s office. They found that the CEO was using the company plane to fly his fashion designer wife and her friends back and forth to Paris on a regular basis. When confronted in a board of directors meeting with the evidence, the CEO chastised the engagement team: “You weren’t supposed to check on me; you were supposed to check on the employees.” The board of directors disagreed and then requested the CEO’s resignation.

You’re Not Supposed to Audit Me!AUDITING INSIGHT

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Hiring and firing policies are important. Background checks on prospective employ- ees are advisable and very good business practice. A new employee who has been a fraudster in some other organization’s accounting department has a higher probability of being a fraudster in a new organization. As a result, organizations have even been known to hire private investigators to make background checks. Fraudsters should be fired and, in most cases, prosecuted. Experience has shown that they have a low rate of repeat offenses if they are prosecuted, but they have a high rate if not. Prosecution has the added benefit of sending the message that management does not believe that fraudulent activity is acceptable.

Unfortunately, the accompanying Auditing Insight, while incredibly disappointing, is far more common than it should be. As a result, auditors must always be vigilant and remain skeptical about the possibility of discovering employee fraud at their audit clients. This is why we have just provided so much coverage of the topic to begin this chapter. We now turn our attention to the account that is most frequently targeted by employee thieves—cash.

REVIEW CHECKPOINT 6.7 What are some red flags that may indicate a cover-up or concealment of a fraud? 6.8 Is there anything odd about these two situations? (a) A check to Larson Electric Supply was

endorsed with “Larson Electric” above the signature of “Eloise Garfunkle.” (b) Numerous electronic payments were made and dated December 25, January 1, and July 4.

In April 2013, a Roman Catholic nun pleaded guilty to stealing $128,000 from two different parishes in New York over a five-year period. As it turns out, the nun had a gambling addiction and appar- ently felt that she had nowhere else to turn to pay the debts except by

committing a crime. She now faces up to six months in jail and must repay the stolen money. Source: “NY Gambling Nun Admits Taking $128K from Churches,” The Wall Street Journal, April 9, 2013.

Did She Really Steal from the Church?AUDITING INSIGHT

THE AUDIT OF CASH This section of the chapter is focused on the procedures that are completed as part of the financial statement audit for cash. However, our discussion of controls also includes examples of internal control activities that are specifically put in place to help prevent or detect employee fraud. In addition, because cash is relevant to each of an audit client’s accounting cycles, we also discuss cash when describing the audits of the different cycles in the following chapters. For example, the basic activities in the revenue and collection cycle (Chapter 7) are (1) receiving and processing cus- tomer orders, including credit granting; (2) delivering goods and services to custom- ers; (3)  billing customers and accounting for accounts receivable; (4) collecting and depositing cash received from customers; and (5) reconciling bank statements. The basic acquisition and expenditure activities (Chapter 8) are (1) purchasing goods and services and (2) paying the bills. Similarly, the production and conversion cycle (Chapter 9) and the investing and financing cycle (Chapter 10) also feature the collec- tion or expenditure of cash.

LO 6-4 Identify the relevant assertions and risks of material misstatement that are typically related to the cash balance.

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Management Reports and Data Files in an Audit of Cash There are a number of different management reports, documents, and data files that are typically used by auditors when completing work on the cash account. These include the cash receipts journal, the cash disbursements journal, bank reconciliations, canceled checks, and bank statements.

Cash Receipts Journal The cash receipts journal contains all of the detailed entries for all receipts of cash by the entity (debits to the cash account), including cash deposits. It contains the popula- tion of credit entries that should be reflected in the credits to accounts receivable for customer payments. It also contains the adjusting and correcting entries that can result from the bank account reconciliation. These entries are important because they may signal the types of accounting errors or manipulations that occur in the cash receipts accounting.

Cash Disbursements Journal The cash disbursements journal is the company’s detailed record of entries for checks written and electronic payments made during the period being audited (cash disburse- ments). Because all cash disbursements (other than those from a petty cash or payroll account) should be made via check or electronic transfer, the cash disbursements journal contains the cash credit entries that provide a population for testing cash disbursements. It also contains the adjusting and correcting entries that can result from the bank account reconciliation. These entries are important because they may signal the types of account- ing errors or manipulations that occur in the cash disbursements accounting. The cash disbursements journal is usually inspected for suspect items such as checks made out to “cash” or “bearer” or electronic payments made to unauthorized vendors. In addi- tion, company procedures should require that “voided” checks be retained and auditors should review these checks to ensure they were in fact actually voided and have not been recorded in bank statements.

Bank Reconciliations The company’s bank reconciliation is the primary document used to test the cash bal- ance in the financial statements. The amount of cash in the bank is almost always differ- ent from the amount in the general ledger (financial statements), and the reconciliation is designed to explain the difference between these two amounts. In addition, a bank account reconciliation that compares the book cash balance to the bank cash balance provides management with an opportunity to monitor the separation of duties for cash receipts and cash disbursements. The timely preparation of bank reconciliations is, there- fore, an important element of a company’s internal control activities over cash.

Canceled Checks Exhibit 6.2 describes the information found on the front of a typical check. Although companies do not receive the actual check back, a scanned image obtained of the check front is generally included with most bank statements and can be used to test for payees, amounts, or dates that do not match the cash disbursements journal. Further, check fronts obtained directly from a bank statement can be used to verify appropriate use of certain important internal controls, such as dual signatures for expenditures greater than a cer- tain amount.

Individuals engaging in fraudulent schemes involving cash often try to conceal their crimes by removing canceled checks they made payable to themselves or endorsed on the back with their own names. Missing canceled checks are a red flag. However, banks no longer return the canceled checks to their customers. Instead, copies of the front of the checks are included with the bank statement, often received electronically. This infor- mation is sufficient for reconciling an account, but it does not provide the information

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EXHIBIT 6.2 How to Read a Canceled Check

Naomi, an employee at a check-cashing business in Brooklyn, New York, received only the basics of detecting check fraud from her super- visors: Look for watermarks, compare encoded check numbers, and question customers to see whether they can keep their stories straight if a check looks suspicious.

Earlier in the month, the main office of Naomi’s business warned workers to look for a Roberta Kane who had been successfully passing false checks in other branches. When Roberta walked into Naomi’s branch, Naomi closely examined her ID and the $200 check. The check’s routing numbers were larger than they should be, the check felt softer than others, and there was no watermark. Naomi asked Roberta how she had received the check and Roberta said it was a paycheck from her employer. Naomi called the number of the com- pany that supposedly wrote the check. When the number appeared to

be out of service, Naomi told Roberta that she had presented a false check and that the police would have to get involved. Roberta franti- cally ran for the door, leaving behind her fake check and ID. Even with the most basic knowledge of detecting check fraud, this teller was able to deter a thief. As you can see, it is important for auditors to review the fundamentals of check fraud detection.

In an unrelated case, four people were under investigation for an easily discovered counterfeit check-cashing scheme. Despite using high-tech computer equipment to generate the counterfeit checks, the fraudsters mistakenly misspelled the payer (Broyhill Furniture) as “Boryhill Furniture.”

Sources: Suzanne Mahadeo, “Check Fraud: Separating Money from Worthless Paper,” Fraud Magazine, September/October 2005, pp. 21–23, 50; “News of the Weird,” Funny Times, May 2003.

Who Was That Check from Again?AUDITING INSIGHT

that may assist a company or auditor in detecting or investigating possible frauds. Other banks retain images of checks (generally only the front) on their Internet sites. Given the reduction in ability to detect fraud through canceled check documentation, auditors, controllers, and CFOs should strongly recommend that their client or company pay close attention to the information that is available, and an increased emphasis on internal con- trols over checks is warranted.

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EXHIBIT 6.3 Small Business Bank Statement

Bank Statements Most of the information shown on the bank statement in Exhibit 6.3 is self-explanatory. However, auditors should not overlook the usefulness of some of the information: The num- ber and dollar amount of deposits and checks can be compared to the detail data on the bank statement; the account holder’s federal business identification number is on the statement, and this can be used in other databases; and the statement itself can be studied for alterations.

REVIEW CHECKPOINTS 6.9 Since checks are not received back by clients, how can an auditor tell whether the amount on a

check was altered prior to payment by a bank? 6.10 Take a closer look at Exhibit 6.3. Is there anything wrong with the bank statement? What are some

ways to tell whether any of the amounts have been altered?

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Significant Accounts and Relevant Assertions According to the professional standards, an account or disclosure is significant if there is a reasonable chance that it could contain a material misstatement. The auditor identifies significant accounts and relevant assertions by applying the audit risk model.

Chapter 4 introduced the audit risk model. As noted there, this model allows auditors to reduce audit risk to desired levels. Audit risk is defined as the risk that auditors will issue an unmodified opinion on financial statements that contain a material misstatement. Audit risk is manifested when a material misstatement enters the financial reporting pro- cess (inherent risk) that the client’s internal controls do not prevent or detect (control risk) and that the auditors’ substantive procedures do not detect (detection risk). Recall the basic three-step approach for using the audit risk model to plan an engagement:

1. Set audit risk at desired levels (normally, low). 2. Assess risk of material misstatement, which incorporates inherent risk based on the

nature of the account balance or class of significant transactions and control risk based on gaining an understanding of internal control.

3. Determine detection risk at the significant account and assertion level based on the level of audit risk and risk of material misstatement.

The components of the audit risk model are assessed for each significant account and relevant assertion. This assessment recognizes that certain accounts and assertions assume an increased level of importance and are of more interest to auditors than oth- ers. For cash, existence is always a relevant assertion in the audit plan. Other assertions may also be relevant, depending on the facts and circumstances of the engagement. For example, if an audit client has worldwide operations, valuation may be relevant because certain cash balances may be denominated in foreign currencies, necessitating a transla- tion adjustment.

Once all of the significant accounts and disclosures have been identified, the auditor then needs to identify the relevant assertions. According to the professional standards, a financial statement assertion is relevant if it has a “reasonable possibility of containing a misstatement that would cause the financial statements to be materially misstated.” Exhibit 6.4 identifies the relevant assertions that are typical for cash. Although different companies may have other risks, in general the most significant risks relate to the exis- tence of cash and the presentation and disclosure of cash. As previously stated, depending on the nature of the audit client’s operations, valuation may also be a relevant assertion for cash. Although we will focus our discussion on these assertions, other assertions may be relevant depending on the facts and circumstances at the audit client.

Significant Account Relevant Assertions

Cash

Existence

Valuation

Presentation and disclosure

EXHIBIT 6.4 Significant Accounts and Relevant Assertions

Risk of Material Misstatement As part of the planning process, the auditor must determine the source of a misstatement that could cause the financial statements to be materially misstated. One way to assess the risk of material misstatement is to use the “what could go wrong?” (WCGW) approach when thinking of each financial statement assertion. WCGW is a part of each audit firm’s process and enables a thorough assessment of the risk of material misstatement.

When considering WCGW for cash, auditors consider three primary concerns: (1) Does the reported cash balance really exist? (2) Is the cash balance valued properly? (3) Is the reported cash balance presented properly and have the appropriate disclosures been made? Exhibit 6.5 summarizes the WCGW analysis for cash.

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Significant Account Relevant Assertions What Could Go Wrong?

Cash Existence The cash balance may not exist in the company’s bank accounts.

Valuation The cash balance that is held in foreign countries may not have been translated properly.

Presentation and disclosure There may be restrictions on the cash balance that were not properly disclosed.

EXHIBIT 6.5 What Could Go Wrong?

Evaluating the Design and Operating Effectiveness of Internal Controls When evaluating the design of internal controls related to cash, an auditor must always consider whether the controls have been designed to mitigate the risk of material mis- statement for each relevant assertion identified for the cash balance. In addition, because cash is so frequently a favorite target of employee thieves, controls over cash must be unusually strong and include special considerations related to employee fraud. As a con- sequence, when evaluating the design of internal controls related to cash, an auditor must also consider whether the controls have been designed to mitigate the risk of employee fraud. Clearly, there is overlap between these two goals (i.e., mitigating the risk of mate- rial misstatement and preventing employee fraud), meaning that certain control activities may help to achieve objectives at an audit client. However, to help improve your under- standing of both objectives, we now consider these topics separately.

Internal Control Evaluation for Mitigating the Risk of Material Misstatement Recall from the audit risk model that the auditor assesses inherent risk to determine where in the financial statements it is reasonably possible that a material misstatement could enter the process before the consideration of any internal controls. However, risk of material misstatement is the combination of both inherent risk and control risk.

Professional standards require auditors to first gain an understanding of the internal controls that have been designed to mitigate the risk of material misstatement for each relevant assertion identified by the auditor. In a well-designed system, the internal control activity should be explicitly designed to be aligned with this relevant assertion that was identified in a WCGW analysis.

In effect, the question an auditor should ask is, “Has the audit client designed and implemented a control that, if operating effectively, would mitigate the identified risk of material misstatement? Would it prevent or detect the material misstatement?” Impor- tantly, we have already discussed how auditors would gain an understanding of the inter- nal controls related to cash earlier in this chapter, including the control environment and tone at the top. This discussion remains relevant when auditing the cash balance.

However, when auditing the cash balance, for each WCGW identified, the auditor seeks to identify a control activity that has been placed in operation to mitigate the identified risk of material misstatement. For example, as shown in Exhibit 6.6, for the WCGW scenario related to the existence of cash (i.e., the cash does not exist in the com- pany’s bank account), the auditor must consider what management can do to prevent this misstatement from entering the financial statements or from going undetected. One control that the auditor would expect management to implement involves periodic rec- onciliation of the bank balance to the book balance. If an employee regularly completes the reconciliation and a supervisor reviews the reconciliation, the control should miti- gate the risk that a material misstatement can proceed through the accounting system undetected.

In order to rely on the design of the client’s internal controls and support a reduction in control risk, the auditor must determine if each identified control is operating as designed and whether the person operating the control has the authority and competence to do so. The auditor’s ultimate responsibility is to document enough support to conclude whether the control activity was operating effectively to mitigate the risk of material misstatement for the relevant assertion identified.

LO 6-5 Identify important internal control activities present in a properly designed system to mitigate the risk of material misstatements for each relevant assertion related to cash and to help prevent or detect employee fraud.

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Auditors can perform tests of controls to determine whether company personnel are properly performing controls that are said to be in place. In general, the procedures used in tests of controls are inquiry, observation, inspection, and reperformance. Understand that if a control is missing or ineffective, the risk of a material misstatement increases, but an error or fraud may or may not exist. Thus, if controls are not in place or personnel in the organization are not performing their control activities effectively, auditors need to design substantive procedures to try to detect whether control failures have produced material misstatements in the financial statements. Exhibit 6.6 includes a column that identifies the type of test of controls that may be performed in order to support a reduc- tion in control risk and ultimately a reduction in the amount of substantive testing.

Once the tests of control are completed, auditors must evaluate the body of evidence related to internal controls. The initial process of obtaining an understanding of the com- pany’s controls and the later process of obtaining evidence from actual tests of controls are two of the phases of control risk assessment. If the control risk is assessed to be very low, the substantive procedures on the account balances can be reduced, resulting in audit efficiency. On the other hand, if tests of controls reveal weaknesses, the substantive pro- cedures need to be designed to lower the risk of failing to detect material misstatement in the account balances.

Internal Control Evaluation for Preventing or Detecting Employee Fraud We now take a step back from the financial statement audit to consider how an organiza- tion can help to prevent or detect employee fraud with properly designed control activi- ties. Recall that because cash is highly liquid, not easily identifiable as company property, and portable, it tends to be a favorite target of employee thieves. Thus, controls over cash must be unusually strong and include special considerations related to employee fraud. In that spirit, it is essential that an audit client implement control activities for both cash receipts and disbursements that are designed to help “fraud-proof” the organization. Of course, many of the control activities that we are about to discuss are also designed to help mitigate material misstatements in the financial statements. However, for now, please focus on the following control activities as they are designed to prevent the misap- propriation (or theft) of cash in an organization.

Control Activities for Cash Receipts Cash can be received in several ways—over the counter, through the mail, and by electronic funds transfer. It can also be received

EXHIBIT 6.6 Tests of Internal Control

Significant Account

Relevant Assertions What Could Go Wrong? Internal Control Activity Tests of Internal Control

Cash

Existence The cash balance may not exist in the company’s bank accounts.

The CFO performs a detailed review of the bank reconciliation on a monthly basis.

For a sample of bank reconciliations, reperform the reconciliation. Trace several reconciling items to the appropriate supporting documentation.

Valuation The cash balance that is held in foreign countries may not have been translated properly.

The treasurer reviews the cash translation adjustment calculation monthly and independently checks that the appropriate spot rate has been used for each foreign currency.

Inspect the monthly cash translation adjustment calculation for evidence of the treasurer’s review.

Presentation and disclosure

There may be restrictions on the cash balance that were not properly disclosed.

The corporate secretary reviews the cash footnote disclosure on a quarterly basis to ensure that all legal restrictions on the cash balance have been properly disclosed.

For a sample of cash accounts, reperform the work completed by the corporate secretary to ensure that all cash restrictions have been properly disclosed.

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in a lockbox arrangement in which payments are remitted by customers to an external location (i.e., a lockbox). In a lockbox arrangement, a fiduciary (usually a bank) opens the box on a daily basis, lists the receipts, deposits the money, and sends the remit- tance advices (stubs showing the amount received from each customer) to the com- pany. Refer to Exhibit 6.7 for some cash receipts processing procedures in a manual accounting setting.

In many situations, an individual employee initially receives cash and checks and thus has custody of the physical cash for a short time. Because this initial custody cannot be avoided, it is always a good control to (1) have two people open the mail containing cus- tomer receipts, if possible, resulting in joint custody; (2) endorse the checks immediately after removing them from the envelope; (3) prepare a list of the cash receipts as early in the process as possible; and then (4) separate the actual cash from the record-keeping documents. The cash should be sent to the cashier or treasurer’s office where a bank deposit is prepared and the money is sent to the bank daily and intact. (No money should be withheld from the deposit.) The list of remittance advices go to the accountants (con- troller’s office), who record the cash receipts. (You have prepared a “remittance advice” each time you write the amount enclosed on part of your credit card bill, tear it off, and enclose it with your check.)

The accountants who record cash receipts and credits to customer accounts should never handle the cash. They should use the remittance list or remittance advice to make the entries to the cash and accounts receivable control accounts and to the customers’ accounts receivable subsidiary account records. A good internal control activity is to

EXHIBIT 6.7 Cash Receipts Processing

Cash Remittance List

Prepare cash remittance

list.

Prepare monthly

reconciliation.

Post to customer accounts.

Approve discounts. Prepare deposit.

Prepare cash receipts journal. Post to general

ledger.

C.R.L. C.R.L.

Treasurer’s O�ce Controller’s O�ce

2 1

21

START Cash received

Marketing Department (salesclerks) Cashier Cash Management Accounts Receivable General Ledger

Operations Department (mailroom)

1 2

3

Deposit Slip Deposit Slip

C.R.L. Money

1

Cash Remittance List

2

2 3

Deposit Slip

Monthly Bank Statement

C.R.L. 2

3

Approval of discounts noted on remittance list.

All cash receipts are deposited intact, daily.

Individual Customer Accounts Subsidiary

Accounts Receivable Control

Cash AccountsTo

bank

Date Date

Cash Receipts Journal

Cash Remittance List

1

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have the control account and subsidiary account entries made by different people, and later the accounts receivable entries and balances can be compared (reconciled) to deter- mine whether they agree in total. Most computerized accounting programs post the cus- tomers’ accounts automatically by keying in the customer identification number, and the computer program controls agreement.

At the end of the day, an independent employee should receive (1) a copy of the check listing, (2) a report of payments recorded in accounts receivable, and (3) a copy of the deposit slip from the bank. Commercial deposit slips have multiple copies. The bank runs these copies through the teller machine, which imprints the time, date, account, and amount on each copy. At least one copy is returned to the person mak- ing the deposit, who returns the copy to the company as evidence that the deposit was made. If the cash received during the day is maintained intact, the information on all three items should match.

Take a close look at Exhibit 6.7. Suppose that the cashier who prepares the remit- tance list had stolen and converted Customer A’s checks to personal use. It might work for a short time until Customer A complained that the entity had not credited the account for payments. The cashier, of course, knows this. So, the cashier later puts Customer B’s check in the bank deposit but shows Customer A on the remittance list; thus, the accountants give Customer A credit. So far, so good for preventing Customer A’s com- plaint. But now Customer B needs to be covered. To detect this type of lapping scheme, a detailed audit should include a comparison of the checks listed on a sample of deposit slips (Customer B) to the detail of customer remittances recorded to customer accounts (Customer A). Doing so is an attempt to find credits given to customers for whom no pay- ments were received on the day in question.

Holly Dalton used her business as a property manager in Colorado Springs, CO, to steal nearly $100,000 from landlords and tenants. Dal- ton stole damage deposits and used a lapping scheme to steal rents. She would embezzle rent checks for her own use and would apply rent payments from other customers to the receivables to hide her

crime. Dalton was sentenced to four years probation and restitution, but did not serve any jail time for her crimes.

Source: “Property Management in Colorado Springs Sentenced to Probation,” KKTV News, January 9, 2018. https://www.kktv.com/content/news/Property-management- owner-wanted-for-allegedly-stealing-almost-100000-415338153.html

Lapping Up the RentsAUDITING INSIGHT

Employees outside the normal cash operations (recording and custody) should pre- pare bank account reconciliations on a timely basis. Deposit slips should be compared to the details on cash remittance lists, and the total should be traced to the general ledger accounts receivable entries. (This reconciliation would reveal whether money was with- held from the deposit.) This care is required to establish that all the receipts recorded in the books were deposited and that credit was given to the right customer.

A common feature of cash management is to require that persons who handle cash be insured under a fidelity bond, which is an insurance policy that covers most kinds of cash embezzlement losses. Fidelity bonds do not prevent or detect embezzlement, but the fail- ure to carry the insurance exposes the company to complete loss if embezzlement occurs. Moreover, bonding companies often perform their own background checks of employees before bonding them. Auditors often recommend fidelity bonding to small companies that might not know about such coverage.

Tests of Controls over Cash Receipts The first step in testing the controls over both cash receipts and cash disbursements (discussed later) is to gain an understanding of the controls and document that understanding. Information about a company’s internal control activities can be gathered in different ways, which may include completing an

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internal control questionnaire. A selection of this type of questionnaires for both manual and entirely automated controls over cash receipts is found in Appendix 6A at the end of this chapter. You can study these questionnaires for details related to other desirable control activities as well.

Another more common way to obtain general information about controls can be achieved by conducting a walkthrough. In conducting walkthroughs, the auditors select examples of a transaction (in this case, customer remittance advices) and “walk them through” the information-processing system from their initial receipt all the way to their recording in the accounting records. Sample documents are collected, and employees in each department are questioned about their specific duties. The walkthrough, com- bined with inquiries, can contribute evidence about appropriate separation of duties, which might be a sufficient basis for a preliminary assessment of control risk. However, a walkthrough is too limited in scope to provide evidence of whether the client’s control activities were operating effectively during the period under audit. Rather, to justify a low control risk assessment and a reduction of substantive testing procedures, an audi- tor would have to conduct a test of operating effectiveness for the control activity under consideration.

An entity should establish input, processing, and output control activities to pre- vent, detect, and correct accounting errors. Auditors can perform tests of controls to determine whether the internal control activities related to the correct handling of cash receipts are operating effectively. If the internal control activities are not operating effectively (e.g., because personnel in the organization are not performing the cash con- trol activities very well), auditors may need to expand substantive audit procedures to ensure that the cash balance is not materially misstated and to identify possible fraudu- lent acts related to cash.

Exhibit 6.8 contains a selection of tests of controls for cash receipts transactions. Many of these procedures can be characterized as steps taken to verify the content and character of sample documents from one file with the content and character of documents in another file. These steps are designed to enable the audit team to obtain objective evi- dence about the effectiveness of control activities and about the reliability of accounting records. An audit plan for tests of controls over cash is found in Appendix 6B.

Control Activities for Cash Disbursements As described in the previous section, the first step in testing the controls for cash disbursements is to gain an understanding of the controls and document that understanding. Similar to cash receipts, for cash disburse- ments, effective internal control begins with making sure that appropriate separation of duties has been achieved in an organization. Proper separation involves different people

Internal Control Test of Control

• Cash receipts are deposited intact and daily. 1. Observe the opening of the mail and ensure that:

  a. Two employees are opening the mail, remittance advice is received, and checks are properly endorsed.

  b. A listing of all checks is being prepared and compared to the total of the deposit ticket for the total of checks.

  c. The total amount of the deposit listed in the bank statement was recorded in the proper period.

• Deposits are reconciled with totals posted to the accounts receivable

2. For a sample of daily postings to the accounts receivable subsidiary ledger, trace the amount to the amount of cash subsidiary ledger.

EXHIBIT 6.8 Tests of Controls for Cash Receipts

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and different departments handling custody of blank documents (checks), cash disburse- ment authorization, record keeping for payments, and bank reconciliation:

∙ Custody. Blank documents such as blank checks should be kept secure at all times. If unauthorized persons can obtain a blank check, they can be in another country before an embezzlement is detected.

∙ Authorization. Cash disbursements are typically authorized by an accounts payable department’s assembly of purchase orders, vendor invoices, and internal receiving reports to demonstrate a valid obligation to pay. This assembly of supporting docu- ments is called a voucher and will be discussed in more detail in Chapter 8. (Accounts payable obligations usually are recorded when the purchaser receives the goods or services ordered.) A person authorized by management signs the checks. A company may have a policy to require two signatures on checks over a certain amount (e.g., $50,000). Vouchers should be marked “PAID” or otherwise stamped to show that they have been processed completely so they cannot be paid a second time.

∙ Recording. When checks are prepared, entries are made to debit accounts payable and credit cash. Someone without access to the check-writing function should always per- form the recording function.

∙ Reconciliation. Monitoring of the internal control over cash can be provided by timely bank reconciliations made by individuals outside of the normal cash operations.

If combinations of two or more of these responsibilities are completed by one per- son or within the same office, there may be an opportunity for a fraudster to commit a crime. In addition, and almost more important in today’s environment, is the fact that the computerized information-processing system must also provide for proper separation of duties. In practice, this is often accomplished by assigning the proper functional “permis- sions” to the appropriate employees through their password access credentials. Simply stated, in a computerized environment, proper separation of duties is dependent on proper password access controls. This is discussed in more detail in Module H.

Tests of Controls over Cash Disbursements An entity should have detailed control activities in place and operating to prevent, detect, and correct accounting errors. Audi- tors can perform tests of controls to determine whether the internal control activities related to the correct handling of cash disbursements are operating effectively. If the internal control activities are not operating effectively (e.g., because personnel in the organization are not performing the cash control activities very well), auditors need to expand substantive audit procedures to ensure that the cash balance is not materially mis- stated and to identify possible fraudulent acts related to cash.

Exhibit 6.9 identifies common internal control activities that are designed to prevent or detect the misappropriation of cash and the typical test of control that would be used by auditors. As you will note, many of these procedures can be characterized as steps

Internal Control Test of Control

• Checks are not printed until voucher packets are prepared.

• An employee compares amounts on printed checks with voucher packets prior to submission for signature.

• Only authorized signers are permitted to sign checks.

1. For a sample of recorded cash disbursements from the cash disbursements journal, inspect supporting documentation for evidence of mathematical accuracy, correct classification, proper approval, authorized signature and then compare the date on the check with the date recorded in the disbursements journal.

• Checks are prenumbered and accounted for. 2. Scan checks for sequence. Look for gaps in sequence and duplicate numbers.

• Bank reconciliations are prepared on a timely basis. 3. Review bank reconciliations to ensure that they were prepared on a timely basis.

EXHIBIT 6.9 Tests of Controls over Cash Disbursements

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taken to make it difficult for a fraudster to steal cash. However, there are also controls designed to detect fraudulent activity if it occurs. The control tests are designed to enable the audit team to obtain objective evidence about the operating effectiveness of control activities. Many businesses rarely write paper checks. The controls required for electronic payments requires the same system of separation of duties. However, the majority of the access and authorization controls are accomplished through passwords and restrictions of access to data and accounting information systems.

REVIEW CHECKPOINTS 6.11 What is the basic sequence of activities in the cash collection process? 6.12 Why should a list of cash remittances be made and sent to the accounting department? Wouldn’t it

be easier to send the cash and checks to the accountants so they can enter the credits to custom- ers’ accounts accurately?

6.13 What is lapping? What procedures can auditors employ to detect lapping? 6.14 What feature of the acquisition and expenditure control would be expected to prevent an

employee from embezzling cash by creating fictitious vouchers?

Substantive Procedures As you have learned previously while studying audit risk, the primary reason for evalu- ating the internal control system at an audit client is to reach an overall assessment of risk of material misstatement for each relevant assertion. In fact, the assessment of risk of material misstatement is completed to help form the basis for determining the nature, timing, and extent of substantive testing. Risk of material misstatement at the assertion level is comprised of both inherent risk and control risk for each relevant assertion.

If inherent risk has already been assessed as high, this means that there is high sus- ceptibility for this account to be misstated. Recall that control risk is the “probability that an entity’s controls will fail to prevent or detect material misstatements due to errors or frauds.” Due to the nature of cash, the majority of audit clients have strong controls over cash, and tests of controls often support a reduction in control risk. This reduction in con- trol risk reduces the auditor’s assessment of the risk of material misstatement over cash. However, regardless of the final assessment of the risk of material misstatement, as with any significant account, the auditor will perform at least some substantive procedures over cash.

As stated previously, there are two types of substantive tests: analytical procedures and tests of detail and balances. As you may recall, a substantive analytical procedure is one where the auditor substantiates an account or disclosure by developing an indepen- dent estimate of the amount and then comparing the recorded balance to the estimate. Due to the lack of predictability of the cash balance, auditors rarely, if ever, use sub- stantive analytical procedures to test cash. Rather, auditors typically rely exclusively on tests of detail. For example, auditors will generally test the bank reconciliations in detail, including sending confirmations to all banks in order to substantiate the existence of cash. Exhibit 6.10 presents the substantive tests that are likely to be completed to address remaining risks of material misstatement related to cash.

Without question, the most important test of detail completed on cash is to test the details of the entity-prepared and reviewed bank reconciliation for each significant bank- ing relationship, including confirmation of the balance with the financial institution. For that reason, our discussion of substantive procedures will focus almost exclusively on testing the bank reconciliation in detail. In effect, the auditor needs to obtain the bank rec- onciliation for each significant account and audit the details contained on each of them. In a well-functioning control environment, auditors should never have to perform the

LO 6-6 Give examples of substantive procedures used to test cash and relate them to the relevant assertions.

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company’s internal control activity of preparing the bank reconciliation. Always remem- ber that the timely completion of the bank reconciliation is the responsibility of the client and is a critical element of internal control over cash.

Bank Reconciliation A client-prepared bank reconciliation is shown in Exhibit 6.11. When auditing the bank reconciliation, the auditor should begin by confirming the account balance listed as the “balance per bank” on the top of the bank reconciliation for each bank account from each bank that the client utilizes in the business. The auditor is required to send a con- firmation request, and each bank should respond directly to the public accounting firm’s office. This procedure is important because the auditor needs to make sure that the con- firmation request was actually completed by an independent professional at a third-party bank. In fact, a failure to adhere to professional standards in this area was cited by the SEC and PCAOB when announcing financial statement fraud charges against Satyam, an information technology company based in India. A description is found in the follow- ing Auditing Insight.

EXHIBIT 6.10 Substantive Tests

Significant Account

Relevant Assertions

Internal Control Activity

Tests of Internal Control

Possible Substantive Tests of Detail

Cash

Existence The CFO perfoms a detailed review of the bank reconciliation on a monthly basis.

For a sample of bank reconciliations, reperform the reconciliation. Trace several reconciling items to the appropriate supporting documentation.

Test the bank reconciliation details for each significant cash account being held. Confirm the bank balance with each financial institution.

Valuation The treasurer reviews the cash translation adjustment calculation monthly and independently checks that the appropriate spot rate has been used for each foreign currency.

Inspect the monthly cash translation adjustment calculation for evidence of the treasurer’s review.

For a sample of monthly cash translation adjustment calculations, trace each foreign currency spot rate to a third-party pricing service.

Presentation and disclosure

The corporate secretary reviews the cash footnote disclosure on a quarterly basis to ensure that all legal restrictions on the cash balance have been properly disclosed.

For a sample of cash accounts, reperfom the work completed by the corporate secretary to ensure that all cash restrictions have been properly disclosed.

For a sample of cash accounts, examine the legal agreements with each financial institution. Based on the examination, determine whether the audit client has properly disclosed any legal restrictions in their footnotes.

The Securities and Exchange Commission recently charged “India- based Satyam Computer Services Limited with fraudulently over- stating the company’s revenue, income and cash balances by more than $1 billion over five years.” The SEC’s complaint states that “former senior officials at Satyam—an information technology ser- vices company based in Hyderabad, India—used false invoices and forged bank statements to inflate the company’s cash balances and make it appear far more profitable to investors.” In addition, “Satyam

employees created bogus bank statements to reflect payment of the sham invoices. This resulted in more than $1 billion in fictitious cash and cash-related balances.” In addition, the SEC instituted adminis- trative proceedings against the auditors, Price Waterhouse India for “failure to properly execute third-party confirmation procedures” to test the existence of cash at Satyam. Source: “SEC Charges Satyam Computer Services with Financial Fraud,” www .sec.gov, Case 2011-81, April 5, 2011.

The Dangers of Bank ConfirmationsAUDITING INSIGHT

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EXHIBIT 6.11 Bank Reconciliation

The previous auditing insight demonstrates the difficulties auditors can have with authenticating the source of confirmations. The use of third-party electronic information intermediaries, such as Confirmation (formerly called Confirmation.com), has changed the process of cash confirmation greatly over the past decade, but it has not reduced the auditor’s responsibility to authenticate the source of the information.

It is rare for a bank to respond to a paper request for confirmation, and thus nearly all audit firms confirm bank balances through a third-party intermediary, often Confirmation. A standard confirmation request to a bank will also confirm outstanding loan balances, which will provide substantive evidence to test the existence and completeness assertions for liabilities. We will discuss substantive tests of loan balances in more detail in Chapter 10.

As discussed above with the Satyam case, the key issue with confirmations of any kind is the reliability of the response. The use of electronic confirmation through an interme- diary such as Confirmation provides many benefits to the auditor. It allows information

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to be transmitted in a safe and secure manner, and most importantly, it allows for valida- tion of the authenticity of the bank employee responding to the confirmation request, an issue which was previously a major concern for auditors. Before an auditor can rely on an electronic confirmation, the auditor must obtain an understanding of the intermediary’s internal control system. In most situations, the auditor relies upon a report provided by another auditor who audited the design and operating effectiveness of the intermediary under SSAE 16, and provided a Service Organization Controls (SOC) report, most com- monly a SOC1 report. SOC reports are discussed in more detail in Module A.

The confirmation process through an online intermediary generally requires the regis- tration of the auditor, the client, and the financial institution, although in some situations, the intermediary will make paper confirmation requests on behalf of an auditor. Clients must provide electronic authorization in order for the auditor to request confirmation. Upon authorization, the auditor will initiate a confirmation request. Unlike traditional paper confirmations which often take multiple weeks for completion, electronic confir- mation requests are often completed in a matter of days.

Exhibit 6.12 provides an example of a standard electronic bank confirmation per- formed through Confirmation. You will note in Exhibit 6.12 that the auditor can also con- firm outstanding loan balances listed on the balance sheet. As shown, the auditors would be gathering evidence to test the completeness assertion for liabilities because the auditor would trace the information provided by the bank to loan balances listed on the balance sheet. We will discuss substantive tests of the loan balance in more detail in Chapter 10.

A word of caution is in order. Although financial institutions may note exceptions to the information requested in a confirmation and may confirm items omitted from it, the AICPA warns auditors that sole reliance on a confirmation to satisfy the completeness assertion for cash and liabilities is inappropriate. Employees of financial institutions can- not be expected to search their information systems for balances and loans that may not be immediately evident as the client company’s assets and liabilities — in fact the elec- tronic response shown here specifically notes that.

A benefit of electronic confirmation is outlined in the following Auditing Insight.

During the 2012 audit of Peregrine Financial Group Inc. (PFG), audi- tors from the National Futures Association requested permission to use an electronic confirmation platform, Confirmation, to confirm the cash balances at PFG. For several months, the CEO of PFG, Russell Wasendorf Sr., had adamantly resisted the authorization necessary to use Confirmation to confirm the company’s bank balances. Ultimately, Wasendorf agreed to allow the use of the electronic platform, and within 24 hours, it was discovered that one bank account only had $6 million instead of the approximately $220 million that the company

had reported to its auditors. It was later revealed that Wasendorf had falsified bank statements and forged official letters as well as other correspondence from the bank, including letters of confirmation. Apparently, he had rented a post office box to intercept bank confir- mation requests and forged the documents to conceal missing money.

Sources: “Red Flags at Failed Broker,” The Wall Street Journal, July 12, 2012, p. C1; “Peregrine’s Struggle to Stay Airborne,” The Wall Street Journal, July 19, 2012, p. C1; “Trading Firm CEO: I Spent It,” The Wall Street Journal, July 18, 2012, p. A1; “Per- egrine CEO’s Dramatic Confession,” The Wall Street Journal, July 14, 2012, p. A1.

Confirmation: Cash is Missing!AUDITING INSIGHT

Once the “balance in the bank” has been confirmed and cross-referenced to the bal- ance in the bank reconciliation, the following additional procedures are typically used in auditing the bank reconciliation:

∙ Test the mathematical accuracy of the reconciliation, including the listing of outstand- ing checks and deposits in transit.

∙ Examine reconciling items to ensure they are appropriately classified (e.g., that they were legitimate outstanding checks that were written but not paid by the bank at the statement date).

∙ Reconcile the book balance to the trial balance, which has been traced to the general ledger.

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EXHIBIT 6.12 Bank Confirmation

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The auditors’ information source for validating the bank reconciliation items is typi- cally a cutoff bank statement, which is normally a complete bank statement for the month following the date of the financial statements. The cutoff bank statement is important because it (1) is received directly by the auditors (which qualifies as external evidence) and (2) documents important bank transactions occurring early in the subsequent period. These transactions subsequent to the date of the financial statements are important for testing the completeness of the client’s outstanding check list as well as the existence of any deposits in transit. The bank cutoff statement can also be used in a search for unre- corded liabilities discussed in more detail in Chapter 8.

Deposits in transit should be vouched from the bank reconciliation to the bank cutoff statement (existence) and should have been recorded by the bank in the first business days of the cutoff period. If recorded later, the inference is that the deposit may have been composed of receipts of the period after the date of the financial statements.

When auditing negative reconciling items (i.e., outstanding checks) listed on the bank reconciliation and because the audit team is most concerned about the existence of cash (i.e., overstatement) rather than the completeness of cash (i.e., understatement), the completeness of the outstanding checks listing is more critical than to support the existence of such checks. Comparably, when auditing positive reconciling items (i.e., deposits in transit) listed on the bank reconciliation, the existence of the deposits-in-transit on the reconciliation is more criti- cal than their completeness because the audit team is most concerned about the existence of cash (i.e., overstatement) rather than the completeness of cash (i.e., understatement). As a result, the audit team traces outstanding checks that cleared on the cutoff bank statement (and were either returned with that statement or identified in that statement) to the client’s list of outstanding checks for evidence that all checks that were written prior to the reconciliation date were included on the list of outstanding checks. Additionally, canceled checks should be traced to the cash disbursements listing (journal). For large outstanding checks not clearing in the cutoff period, other documentation supporting the disbursement may be used. These procedures are key and described by tick marks in Exhibit 6.11. As the next Auditing Insight suggests, it is important to pay close attention to possible errors in the bank reconciliation.

Through the use of discretionary estimates, HealthSouth, one of the largest health care providers in the United States, inflated its assets by $1.5 billion. In an even more bizarre twist, the company overstated its cash by more than $300 million, according to prosecutors. Because auditors use standardized forms to confirm cash balances with finan- cial institutions, how the auditors missed the cash overstatement is

a mystery. “I’m shocked that cash is manipulated and overstated, because the darn stuff is so easy to count,” stated one audit expert. Nevertheless, auditors must never take the cash balance for granted when conducting the audit.

Source: “Did HealthSouth Auditor Ernst Miss Key Clues to Fraud Risks?” The Wall Street Journal, April 10, 2003.

The Darn Stuff Is So Easy to CountAUDITING INSIGHT

REVIEW CHECKPOINT 6.15 What is a bank reconciliation? Who should prepare it and how do auditors use it?

“EXTENDED PROCEDURES” TO DETECT FRAUD The auditing literature often refers to “extended procedures,” which are “specific responses to fraud risk factors.” Although the professional standards list a few of these procedures, an exhaustive list would be very lengthy. Moreover, authorities fear that a definitive list might limit the range of such procedures, so extended procedures are gener- ally identified as whatever is necessary in the circumstances. This section describes some

LO 6-7 Describe some extended procedures for detecting employee fraud schemes involving cash.

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of the extended procedures and warns that (1) some auditors may consider them ordinary and (2) other auditors may consider them unnecessary in any circumstances. They are useful detective procedures in either event. Consider the following procedures.

Schedule of Interbank Transfers Due to the nature of the cash balance, auditors also will sometimes, although rarely because of decreased float times, prepare a schedule of interbank transfers to determine whether transfers of cash from one bank to another were recorded properly (correct amount and correct date). The audit team should also be alert to the possibility of a company’s practice of illegal “kiting.” Check kiting is the deliberate floating of funds between two or more bank accounts in order to make it appear that more cash is present than is really the case. When a check is deposited in one bank, the cash receipts journal immediately includes that deposit. At the same time, the check, drawn on a different bank account, does not appear in the cash disbursements journal for several days. By this method, an entity can use the time required for checks to clear to inflate the cash amount on the entity’s books. Advances in information technology and increased bank scrutiny have reduced the incidences of check kiting dramatically in recent years. However, auditors must still be aware of the possibility; and the schedule of interbank transfers is a technique designed to detect the practice.

These are some characteristic signs of check-kiting schemes:

∙ Frequent deposits and checks in rounded and the same amounts. ∙ Frequent deposits with checks written on the same (other) banks. ∙ Short time lags between deposits and withdrawals. ∙ Frequent ATM account balance inquiries. ∙ Many large deposits made on Friday to take advantage of the weekend. ∙ Large periodic balances in individual accounts with no apparent business explanation. ∙ Low average balance compared to high level of deposits. ∙ Many checks made payable to other banks. ∙ Banks’ willingness to pay against uncollected funds. ∙ “Cash” withdrawals with deposit checks drawn on another bank. ∙ Checks drawn on foreign banks with lax banking laws and regulations.

Today, banks have implemented the Check Clearing for the 21st Century Act, referred to as “Check 21.” In this system, checks are converted to digital images, allowing for a dramatic increase in speed in check clearing. The benefit is that the “float” on the check is virtually eliminated, and kiting becomes difficult to perform and conceal. However, in the Check 21 system, the paper check is usually destroyed, a hard copy of the check is never returned to the customer or its bank, and consequently, the nature of the audit trail is significantly different. In investigating possible fraud, the audit team is able to obtain only an electronic copy of the front of the check and the controls over the safeguarding of the imaging files will be of great importance.

Proof of Cash Auditors can use another method to discover unrecorded cash transactions. It is called a proof of cash. The proof of cash is a reconciliation in which the bank balance, the bank report of cash deposited, and the bank report of cash paid are all reconciled to the cor- responding records maintained in the entity’s general ledger, cash receipts journal, and cash disbursements journal.

The proof of cash attempts to reconcile the deposits and payments reported by the bank to the deposits and payments recorded in the cash receipts and cash disbursements journals, respectively, as well as the final general ledger totals. The proof of cash is a very effective procedure to verify cash transactions but is usually used only when controls over cash are weak, which is rarely the case. Thus, a proof of cash is not always performed in an audit of cash.

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Count and Recount Cash on the Same Day If a client maintains a significant amount of cash on hand, such as a financial institution or some retailers, a second cash count is unexpected. Auditors might catch an embezzling employee who incorrectly believes that “the auditors are gone, so now it’s safe!” Auditors should always make sure a client employee is present during the count and that the employee signs for the returned cash so the auditor cannot be blamed for any shortages. Another “trick of the trade” is to make sure that the auditor’s pockets are empty (leave wallets locked up safely elsewhere) when counting client cash on hand. This is especially important when counting cash at a financial services client such as a bank or credit union. All cash should be counted simultaneously to prevent embezzling employees from substituting cash from other places. If this is not possible (e.g., the employee claims that he or she does not have the safe combination), there is audit tape (similar to police tape) to seal the safe until it can be opened with the auditor present. If the seal is broken, your suspicions should be raised.

Identity theft and hacking have become a major headache for both businesses and consumers. But sometimes, identity theft can be low tech. Five sales associates for Saks Fifth Avenue used stolen customer personal information to purchase hundreds of thousands of dollars of high-end handbags and shoes from the retailer’s famous Manhattan location. A ringleader stole the information and recruited associates

and customers to assist with the scheme. The associates would use fake customers to make the purchases, then sell the items on the black market or return them to the store.

Source: A. Katersky. “5 Indicted in Alleged Saks Fifth Avenue ID Theft Shopping Spree”. ABC News, October 6, 2014. https://abcnews.go.com/US/ ring-allegedly-stole-identities-shopping-saks-avenue/story?id=25997098

Free Givenchy, Anyone?AUDITING INSIGHT

Noting a significant change in the mix of cash and checks on bank deposit slips over time, a government auditor became suspicious enough to set up a hidden camera. The camera caught a county tax clerk “skimming” cash from daily property tax deposits. The clerk would pocket most of the cash, leaving the checks to be deposited. The fraud perpetrator was able to conceal the theft by replacing the missing cash with checks written to the county for other, miscellaneous purposes for which established procedures were not closely followed.

In an unrelated fraud, Ocean World Seafood was charged with food stamp fraud. According to investigators, a store of Ocean World’s size would normally make approximately $3,000 a month in sales paid with food stamps. Over a 13-month period, Ocean World accepted more than $1 million in food stamps. Apparently, the store would provide cash for food stamps, paying approximately 50 cents for $1 of food stamps. Source: “Store Owner Charged in $1 Million Food Stamp Fraud,” Associated Press Wire, April 15, 2005.

Mixing It UpAUDITING INSIGHT

Retrieve Customers’ Checks If an employee has diverted customer payments for his or her own use, the canceled checks and deposits to a bank where the company has no account are not available because they are returned to the issuing customer. Ask the customer to give copies of the front of the check or provide access for examination.

Use Marked Coins and Currency Plant marked money in locations where cash collections should be gathered and turned over for deposit.

Analyze the Mix of Cash and Checks in Deposits This procedure is most effective for retail operations in which cashiers receive significant amounts of both cash and checks. Unless there is a marked change in consumer behavior, one should expect the mix of cash and checks to be relatively consistent over time. A decrease in the proportion of cash in the mix is often a sign that employees may be stealing cash.

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Measure Deposit Lag Time Compare the date of the deposit slip to the date recorded as a debit in the general ledger to the date the deposit was credited in the account by the bank. Someone who takes cash and then holds the deposit for the next cash receipt to make up the difference causes a delay between the date of recording and the bank’s date of deposit.

Document Examination When performing this procedure, auditors will look for erasures, alterations, and photo- copies where originals should be filed, telltale lines from a copier when a document has been pieced together, handwriting, and other oddities. Auditors should always insist on seeing original documents instead of photocopies. Importantly, while professional docu- ment examination is a technical activity that requires special training (e.g., training by the IRS, FBI), crude alterations may still be observed by the auditor when performing procedures, which should lead to a consultation with a professional document examiner when deemed necessary.

Inquiry Be careful not to discuss fraud possibilities with the managers who might be involved. It gives them a chance to cover up their fraud or even resign from the organization prior to detecting the fraud. Described as a nonaccusatory method of asking key questions of personnel during a regular audit, fraud audit questioning (FAQ) provides employees an opportunity to furnish information about possible misdeeds. Fraud possibilities are addressed in a direct manner, so the FAQ approach must have the support of manage- ment. Example questions are: “Do you think fraud is a problem for business in general?” “Do you think this company has any particular problem with fraud?” “In your depart- ment, who is beyond suspicion?” “Is there any information you would like to furnish regarding possible fraud within this organization?”7

Covert Surveillance When performing this procedure, auditors will observe activities while not being seen. For example, audit team members might watch employees as they punch in to a work shift, observing whether they use only one time card. Casino auditors actually get paid to gamble so they can observe cash-handling procedures. Traveling hotel auditors may check in unannounced, use the restaurant and entertainment facilities, and observe employees to determine if they are stealing cash receipts or tickets. (Trailing people on streets, under- cover surveillance, and maintaining a “stake-out” should be left to trained investigators.)

Horizontal and Vertical Analyses Horizontal and vertical ratio analysis procedures are very similar to preliminary ana- lytical procedures explained in earlier chapters. Horizontal analysis refers to changes of

7Joseph T. Wells, “From the Chairman: Fraud Audit Questioning,” The White Paper, National Association of Certified Fraud Exam- iners, May–June 1991, p. 2. This technique must be used with extreme care and practice.

The district grocery store manager could not understand why receipts and profitability had fallen and inventory was hard to manage at one of the largest stores in her area. She hired an investigator who covertly observed the checkout clerks and reported that no one had shown suspicious behavior at any of the nine checkout counters. “Nine? That

store only has eight,” she exclaimed! As it turns out, the local store manager had installed another checkout aisle not connected to the cash receipts and inventory maintenance central computer and was pocketing all the receipts from that register.

Source: Association of Certified Fraud Examiners (ACFE), “Auditing for Fraud.”

The Case of the Extra CheckoutAUDITING INSIGHT

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Five individuals were charged with tax and insurance fraud in the operation of a temporary employment agency in southeastern Mas- sachusetts. From January 1993 through June 2001, the agency paid a large portion of its payroll in cash in order to avoid employment taxes (e.g., Social Security and Medicare) and to reduce payments

for workers’ compensation insurance. Why would a company pay its employees in cash? Is there a legitimate reason to do this? Even if the employees wanted cash, would there be a better way to provide it? Source: “Five Charged in $30 Million ‘Under-the-Table’ Payroll Fraud, Reports U.S. Attorney,” PR Newswire, January 27, 2005.

Thank Goodness It’s Payday!AUDITING INSIGHT

REVIEW CHECKPOINTS 6.16 Why would an auditor prepare a proof of cash? 6.17 What is the difference between a normal procedure and an extended procedure? 6.18 What can an auditor find using net worth analysis? Expenditure analysis?

financial statement numbers and ratios across several years. Vertical analysis refers to financial statement amounts expressed each year as proportions of a base such as sales for the income statement accounts and total assets for the balance sheet accounts. Auditors look for relationships that do not appear logical as indicators of potential large misstate- ment and fraud.

Net Worth Analysis This analysis is used when fraud has been discovered or strongly suspected and the infor- mation to calculate a suspect’s net worth can be obtained (e.g., asset and liability records, bank accounts). The method involves calculating the suspect’s net worth (known assets minus known liabilities) at the beginning and end of a period (months or years) and then trying to account for the difference as (1) known income less living expenses and (2) unidentified difference. The unidentified difference may be the best available approxima- tion of the amount of a theft.

Expenditure Analysis This analysis is similar to net worth analysis except the data are the suspect’s spending for all purposes compared to known income. If spending exceeds legitimate and explainable income, the difference may be the amount of a theft.

Reasonableness Tests Often, auditors become so involved in ticking and tying numbers that they forget to ask themselves the simplest questions: Where is the cash going? For what purpose? Is this reasonable? The answers to these questions often motivate the auditor to ask more pen- etrating questions of management and to dig for more evidence.

Although auditing standards concentrate on management fraud—the production of mate- rially false and misleading financial statements (i.e., fraudulent financial reporting)— professional standards also require auditors to consider employee fraud perpetrated against an entity. Attention to employee fraud is important in the context that the cover- up may create financial statement misstatements (e.g., overstating inventory to disguise unauthorized removal of valuable products). The three conditions that are likely to be present when a fraud occurs (Exhibit 6.1) are commonly referred to as the “fraud trian- gle.” The first condition (incentive/pressure) recognizes that an employee or a manager

Summary

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of a company is likely to either have incentives in place (e.g., bonus compensation) or be under significant pressure to meet specific estimates, forecasts, or expectations about net income. The second condition (opportunity) recognizes that in order for a fraud to be perpetrated, there must be a weakness in the system of internal control to allow the fraud to occur. Finally, the third condition (attitude/rationalization) recognizes that for an employee or a manager of a company to perpetrate a fraud, the individual must possess an “attitude” that allows her or him to rationalize that she or he is knowingly committing a crime.

Audit team members need to know about the red flags, those telltale signs and indica- tions that have accompanied many frauds. When studying a business operation, members’ ability to “think like a crook” to devise ways to steal can help in planning procedures designed to determine whether fraud has happened. Often, imaginative “extended proce- dures” can be employed to unearth evidence of fraudulent activity. Audit team members must always exercise technical and personal care, however, because accusations of fraud are taken very seriously. For this reason, after preliminary findings indicate fraud pos- sibilities, the audit team should enlist the cooperation of management and assist fraud examination professionals when bringing an investigation to a conclusion.

Once the relevant assertions have been identified for cash (e.g., existence) and the tests of control activities are complete, the auditor must evaluate the evidence obtained from risk assessment activities and control tests to determine the risk of material misstatement for each relevant assertion. Cash is highly liquid, very portable, and not easily identifi- able. For these reasons, cash is often the primary target of fraudulent activities and must be carefully controlled and monitored. Accordingly, controls over cash receipts and dis- bursements must be strong. With respect to auditing the cash balance, the detailed proce- dures performed on the bank reconciliation provide evidence about the existence of cash.

Additional procedures can be performed to try to detect attempts at lapping accounts receivable collections. These procedures include comparing the details of customer pay- ments listed in bank deposits to the details of customer payment postings (remittance lists).

check kiting: The practice of building up balances in one or more bank accounts based on uncollected (floating) checks drawn against similar accounts in other banks, 249 cutoff bank statement: A client bank statement (usually sent directly to the auditor) that includes all paid checks and deposits made through a certain date, usually the end of the month following the financial statement date, 248 direct-effect illegal acts: The violations of laws or government regulations by a company or its management or employees that produce direct and material effects on dollar amounts in financial statements, 223 embezzlement: A type of fraud involving employees or nonemployees wrongfully taking money or property entrusted to their care, custody, and control, often accompanied by false accounting entries and other forms of lying and cover-up, 223 employee fraud (also called misappropriation of assets): The use of fraudulent means to take money or other property from an employer. It consists of three phases: (1) the fraudulent act, (2) the conversion of the money or property to the fraudster’s use, and (3) the cover-up, 222 errors: The unintentional misstatements or omissions of amounts or disclosures in financial statements, 223 fidelity bond: An insurance policy that covers most kinds of cash embezzlement losses, 240 fraud: The misrepresentation of facts that the individual knows to be false with the intention to deceive, 222 lapping: The theft of a payment and the application of subsequent payments to cover the theft, 240 lockbox: An arrangement in which a fiduciary (e.g., a bank) receives the payments, lists the receipts, deposits the money, and sends the remittance advices (stubs showing the amount received from each customer) to the company, 239

Key Terms

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management fraud: The deliberate fraud committed by management that injures investors and creditors through materially misleading information, 223 misappropriation of assets: See employee fraud, 222 motive: In the fraud context, essentially a reason for a person to take a fraudulent action that is believed to be unshareable with friends and confidants, 226 proof of cash: A reconciliation in which the bank balance, the bank report of cash deposited, and the bank report of cash paid are all reconciled to the company’s general ledger and cash receipts and disbursements journals, 249 schedule of interbank transfers: A document prepared for use in analyzing whether transfers of cash from one bank to another were recorded properly (correct amount and correct date), 249

All applicable Exercises and Problems are available with Connect.

Multiple-Choice Questions for Practice and Review

6.19 When auditing with “fraud awareness,” auditors should especially notice and follow up employee activities under which of these conditions? a. The company always estimates the inventory but never takes a complete physical count. b. The petty cash box is always locked in the desk of the custodian. c. Management has published a company code of ethics and sends frequent communication

newsletters about it. d. The board of directors reviews and approves all investment transactions.

6.20 The best way to enact a broad fraud prevention program is to a. Install airtight control systems of checks and supervision. b. Name an “ethics officer” who is responsible for receiving and acting on fraud tips. c. Place dedicated hotline telephones on walls around the workplace with direct communi-

cation to the company ethics officer. d. Practice management “of the people and for the people” to help them share personal and

professional problems.

6.21 A good fraud prevention program should address employees’ motivation to steal from the company. The best method for doing this is to a. Establish employee assistance programs. b. Require a fidelity bond on all employees. c. Require reconciliations of all accounts to be reviewed by a supervisor. d. Ensure that all accounts with high inherent risk of fraud are audited.

6.22 A code of ethics is an important element of a fraud prevention program. Which of the fol- lowing would diminish the effectiveness of a company’s code of conduct? a. The establishment of a chief ethics officer. b. The establishment of a hotline for reporting unethical behavior. c. The violation of the code of ethics by senior management. d. The posting of the code of ethics in the company workplace.

6.23 Which of the following is least indicative of fraudulent activity? a. Numerous cash refunds have been made to different people at the same post office box

address. b. Internal auditors cannot locate several credit memos to support reductions of customers’

balances. c. Bank reconciliation has no outstanding checks or deposits older than 15 days. d. Three people were absent the day the auditors handed out the paychecks and have not

picked them up four weeks later.

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6.24 When performing confirmation of cash balances with a bank, the auditor is primarily gath- ering evidence related to which financial statement assertion? a. Existence. b. Completeness. c. Valuation. d. Presentation and Disclosure.

6.25 Which of the following is true about electronic cash confirmations obtained through Confir- mation.com? a. Responses to electronic confirmations are often delayed compared with manual

confirmations. b. Electronic cash confirmations provide more convincing evidence for the completeness

assertion than manual confirmations. c. Auditors must obtain evidence supporting the reliability of controls surrounding the Con-

firmation.com process. d. It is more difficult to determine the authenticity of an electronic confirmation obtained

through Confirmation.com compared with confirmations mailed to the auditors.

6.26 Allison Everhart, an employee in accounts payable, believes she can run a fictitious invoice through the accounts payable system and collect the money. She knows payments are subject to an audit. Which account would be the best place to hide the fraud? a. Inventory. b. Wage expense. c. Consulting service expense. d. Property tax expense.

6.27 Which of these arrangements of duties could most likely lead to an embezzlement or theft? a. The inventory warehouse manager has responsibility for making the physical inventory

observation and reconciling discrepancies to the perpetual inventory records. b. The cashier prepared the bank deposit, endorsed the checks with a company stamp, and

delivered the cash and checks to the bank for deposit (no other bookkeeping duties). c. The accounts receivable clerk received a list of payments received by the cashier so he

could make entries in the customers’ accounts receivable subsidiary accounts. d. The financial vice president received checks made out to suppliers and the supporting

invoices, signed the checks, and mailed the checks.

6.28 Which of the following would the auditor consider to be an incompatible operation if the cashier receives remittances? a. The cashier prepares the daily deposit. b. The cashier makes the daily deposit at a local bank. c. The cashier posts the receipts to the accounts receivable subsidiary ledger cards. d. The cashier endorses the checks.

6.29 Which of the following is an effective audit procedure that an auditor might use to detect kiting between intercompany banks? a. Review the composition of authenticated deposit slips. b. Review subsequent bank statements. c. Prepare a schedule of the bank transfers. d. Prepare a year-end bank reconciliation.

6.30 Immediately upon receipt of cash, a responsible employee should a. Record the amount in the cash receipts journal. b. Prepare a remittance listing. c. Update the subsidiary accounts receivable records. d. Prepare a deposit slip in triplicate.

(AICPA adapted)

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6.31 Each morning the controller gets the prior day’s list of remittances, a copy of the payment report, and a copy of the deposit slip returned from the bank. When comparing these items, the controller would be able to determine that a. No checks were returned for insufficient funds. b. The cash received and remittance advice received were maintained in a single batch. c. The accounts receivable system has controls over unauthorized access. d. The assistant controller does not also reconcile the subsidiary accounts payable.

6.32 Upon receipt of customers’ checks in the mail room, a responsible employee should prepare a remittance list that is forwarded to the cashier. A copy of the list should be sent to the a. Internal auditor to investigate the list for unusual transactions. b. Treasurer to compare the list with the monthly bank statement. c. Accounts receivable bookkeeper to update the subsidiary accounts receivable records. d. Entity’s bank to compare the list with the cashier’s deposit slip.

(AICPA adapted)

6.33 Cash receipts from sales on account have been misappropriated. Which of the following acts would conceal this defalcation and be least likely to be detected by an auditor? a. Understating the sales journal. b. Overstating the accounts receivable control account. c. Overstating the accounts receivable subsidiary ledger. d. Overstating the sales journal.

6.34 Embezzlement is a type of fraud that involves a. An employee’s misappropriating an employer’s money or property not entrusted to him

or her. b. A manager’s falsification of financial statements for the purpose of misleading investors

and creditors. c. An employee’s mistaken representation of opinion that causes incorrect accounting

entries. d. An employee misappropriating an employer’s money or property entrusted to the employ-

ee’s control in the employee’s normal job.

6.35 Which of the following control activities would best protect against the preparation of improper or inaccurate cash disbursements? a. All checks must be signed by an officer designated by the board of directors. b. All signed checks must be reviewed and compared with supporting documentation by the

treasurer before mailing. c. All checks must be sequentially numbered and accounted for by internal auditors. d. All checks must be perforated or otherwise effectively canceled when they are returned

with the bank statement.

6.36 During an audit of cash, the auditor is most concerned with the management assertion of a. Existence. b. Rights and obligations. c. Valuation or allocation. d. Occurrence.

6.37 In preparing for the audit of cash, the auditors perform analytical procedures concerning cash balances. Which of the following would be the best source of information for use in the estimate of cash? a. Prior-years’ balances. b. Management inquiry. c. Cash budgets. d. Aged accounts receivable reports.

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6.38 Which of the following control activities could prevent a paid disbursement voucher from being presented for payment a second time? a. Vouchers should be prepared by individuals who are responsible for signing disburse-

ment checks. b. Disbursement vouchers should be approved by at least two responsible management

officials. c. The date on a disbursement voucher should be within a few days of the date the voucher

is presented for payment. d. The official signing the check should compare it with the voucher and should stamp

“paid” on the voucher documents.

6.39 Fraud risk factors are events or conditions that indicate which of the following? a. An opportunity to carry out a fraud. b. An attitude or rationalization that justifies a fraudulent action. c. An incentive or pressure to perpetrate fraud. d. All of these are correct.

6.40 If the auditor believes that a misstatement is or might be intentional and the effect on the financial statements could be material or cannot be readily determined, the auditor should do which of the following? a. Inquire of management as to the possibility of fraud. b. Discuss with the audit committee what should be done to prevent possible future

misstatements. c. Perform procedures to obtain additional audit evidence to determine whether fraud has

occurred or is likely to have occurred. d. Both a and b are correct. e. None of these is correct.

6.41 In what way can audit procedures be modified to address assessed fraud risks? a. Obtain more reliable information. b. Perform procedures close to year-end. c. Apply computer-assisted techniques to all items. d. All of these are valid modifications.

6.42 Incorporating elements of unpredictability in the selection of audit procedures to be per- formed by auditors include all of the following except a. Varying the timing of the audit procedures. b. Selecting items for testing that have lower amounts or are otherwise outside customary

selection parameters. c. Performing audit procedures on an unannounced basis. d. Sending attorney letters to every attorney listed under the legal expense account. e. None of these is correct.

6.43 Fraud risk factors are events or conditions that indicate I. An incentive or pressure to perpetrate fraud. II. An opportunity to carry out the fraud. III. An attitude or rationalization that justifies the fraudulent action. Which of the following statements is true? a. I is a fraud risk factor. b. I and II are fraud risk factors. c. II and III are fraud risk factors. d. None of these is a fraud risk factor. e. I, II, and III are fraud risk factors.

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258 Part Two The Financial Statement Audit

6.44 Tests of Controls over Cash Disbursements. The Runge Controls Corporation manufac- tures and markets electrical control systems: temperature controls, machine controls, burglar alarms, and the like. The company acquires electrical and semiconductor parts from outside vendors and assembles systems in its own plant. The company incurs other administrative and operating expenditures. Liabilities for goods and services purchased are entered in a vouchers payable journal, at which time the debits are classified to the asset and expense accounts to which they apply.

The company has specified control activities for approving vendor invoices for payment, for signing checks, for keeping records, and for reconciling the checking accounts. The pro- cedures appear to be well specified and in operation.

You are the senior auditor on the Runge engagement and need to specify a list of test of control procedures to evaluate the effectiveness of the controls over cash disbursements.

Required: Using management’s assertions over transactions as a guide, specify two or more tests of control procedures to audit the effectiveness of typical control activities. (Hint: From one sample of recorded cash disbursements, you can specify procedures related to several objec- tives. See Exhibit 6.9 for examples of test of control procedures over cash disbursements.) Organize your list according to the following example for the “completeness” assertion.

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All applicable Exercises and Problems are available with Connect.

Exercises and Problems

Completeness Assertion Test of Controls

All valid cash disbursements are  recorded and none are omitted.

Determine the numerical sequence of  checks issued during the period and  scan the sequence for missing numbers.

(AICPA adapted)

6.45 Internal Control Questionnaire for Book Buy-Back Cash Fund. Taylor, a CPA, has been engaged to audit the financial statements of University Books, Incorporated. University Books maintains a large cash fund exclusively for the purpose of buying used books from students for cash. The cash fund is active all year because the nearby university offers a large variety of courses with varying starting and completion dates throughout the year.

Receipts are prepared for each purchase. Reimbursement vouchers periodically are sub- mitted to replenish the fund.

Required: Construct an internal control questionnaire to be used in evaluating the internal control over University Books’ repurchasing process using the revolving cash fund. The internal control questionnaire should elicit a yes or no response to each question. Do not discuss the internal controls over books that are purchased from publishers.

(AICPA adapted)

6.46 Test of Controls over Cash Receipts. You are the in-charge auditor examining the financial statements of the Gutzler Company for the year ended December 31. During late Octo- ber, with the help of Gutzler’s controller, you completed an internal control questionnaire and prepared the appropriate memoranda describing Gutzler’s accounting procedures. Your comments relative to cash receipts are as follows: ∙ All cash receipts are sent directly to the accounts receivable clerk with no processing

by the mail department. The accounts receivable clerk keeps the cash receipts journal, prepares the bank deposit slip in duplicate, posts from the deposit slip to the subsidiary accounts receivable ledger, and mails the deposit to the bank.

∙ The controller receives the validated deposit slips directly (unopened) from the bank. She also receives the monthly bank statement directly (unopened) from the bank and promptly reconciles it.

∙ At the end of each month, the accounts receivable clerk notifies the general ledger clerk by journal voucher of the monthly totals of the cash receipts journal for posting to the general ledger.

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∙ With regard to the general ledger cash account, the general ledger clerk makes an entry each month to record the total debits to cash from the cash receipts journal. In addition, the gen- eral ledger clerk, on occasion, makes debit entries in the general ledger cash account from sources other than the cash receipts journal, for example, funds borrowed from the bank. In the audit of cash receipts, you have already performed certain standard audit procedures:

∙ All columns in the cash receipts journal have been totaled and cross-totaled. ∙ Postings from the cash receipts journal have been traced to the general ledger. ∙ Remittance advices and related correspondence have been traced to entries in the cash

receipts journal.

Required: Considering Gutzler’s internal control over cash receipts and the standard audit procedures already performed, list all other audit procedures that should be performed to obtain sufficient appropriate audit evidence regarding controls over cash and give the reasons for each procedure. Do not discuss the procedures for cash disbursements and cash balances. Also, do not discuss the extent to which any of the procedures are to be performed. Assume that adequate controls exist to ensure that all sales transactions are recorded. Organize your answer sheet as follows:

(AICPA adapted)

Other Audit Procedure Reason for Other Audit Procedures

6.47 Internal Control over Sales Returns. You are the auditor for Konerko’s Office Supply Store, which is opening for business next week. The store owner has established all the controls you have recommended for ensuring that sales are recorded properly and cash is accounted for. The owner has heard from other small business owners that employees often used returned goods as means of skimming money from the register.

Required: a. How might an employee use returned goods to skim money from the register? b. What controls would you recommend to prevent or detect fraudulent returns? c. What audit procedures might you perform to detect fraudulent returns?

6.48 Procedures for Auditing a Client’s Bank Reconciliation. Auditors typically will find the items lettered A–F in a client-prepared bank reconciliation.

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GENERAL COMPANY Bank Reconciliation: 1st National Bank

September 30 A. Balance per bank   $28,375  B. Deposits in transit          Sept 29 $ 4,500        Sept 30 1,525      6,025 

  34,400  C. Outstanding checks:           988 Aug 31 $ 2,200        1281 Sept 26 675        1285 Sept 27 850        1289 Sept 29 2,500        1292 Sept 30 7,255  (11,450)     20,950  D. Customer note collected by the bank:   (3,000) E. Error: Check #1282, written on Sept. 26 for $270, was erroneously

charged by bank as $720; bank was notified Oct. 2  

     450  F. Balance per books   $20,400 

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Required: Assume these facts: On October 11, the auditor received a cutoff bank statement dated October 7. The September 30 deposit in transit; the outstanding checks 1281, 1285, 1289, and 1292; and the correction of the bank error regarding check 1282 appeared on the cutoff bank statement. a. For each of the preceding lettered items A–F, select one or more of the following pro-

cedures 1–10 that you believe the auditor should perform to obtain evidence about the item. These procedures may be selected once, more than once, or not at all. Be prepared to explain the reasons for your choices. 1. Trace to cash receipts journal. 2. Trace to cash disbursements journal. 3. Compare to the September 30 general ledger. 4. Confirm directly with the bank. 5. Inspect bank credit memo. 6. Inspect bank debit memo. 7. Ascertain reason for unusual delay, if any. 8. Inspect supporting documents for reconciling items that do not appear on the cutoff

bank statement. 9. Trace items on the bank reconciliation to the cutoff bank statement. 10. Trace items on the cutoff bank statement to the bank reconciliation.

b. Auditors ordinarily foot a client-prepared bank reconciliation. If the auditors had per- formed this recalculation on the preceding bank reconciliation, what might they have found? Be prepared to discuss any findings.

(AICPA adapted)

6.49 Manipulated Bank Reconciliation. You can use the computer-based Electronic Workpa- pers on the textbook website to prepare the bank reconciliation solution.

Caulco Inc. is the audit client. The February bank statement is shown in Exhibit 6.3 in the text. You have obtained the client-prepared bank reconciliation as of February 28 (see the following).

Required: Check 2231 was the first check written in February. All earlier checks cleared the bank, some during January and some during February. Assume that the only February-dated canceled checks returned in the March bank statement are 2239 and 2240 showing the amounts listed in the February bank reconciliation. They cleared the bank on March 3 and March 2, respectively. The first deposit on the March bank statement was $1,097.69 credited on March 3. Assume also that all checks entered in Caulco’s cash disbursements journal through February 29 have either cleared the bank or are listed as outstanding checks in the February bank reconciliation.

Determine whether any errors exist in the following bank reconciliation. If errors exist, prepare a corrected reconciliation and explain the problem.

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CAULCO INC. Bank Reconciliation

February 28

Balance per bank     $7,374.93

Deposit in transit     1,097.69

Outstanding Checks      

Number Date Payee Amount  

2239 Feb 26 Alpha Supply 500.00  

2240 Feb 28 L.C. Stateman 254.37  

Total outstanding             (754.37) General ledger balance Feb. 28     $7,718.25 

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6.50 Investigating a Fraud. Suppose you are auditing cash disbursements and discover several payments to a company you are unfamiliar with and cannot find information about this com- pany on the Internet or in the local telephone directory. The invoices from this company have numbers very close to each other in the sequence, there is no phone number on the invoice, and each bill is for a dollar amount just under the amount that would require additional approvals before payment. Based on this information, you now suspect this may be a fraud.

Required: Based on your suspicions, how would you change the audit procedures you would perform, and how might you change the evidence you gather?

6.51 Fraud in Purchasing. Consider the following scenario: Adam worked for the local hardware store as an outside sales representative. His job was to visit local companies and contractors in an attempt to identify their needs for tools and mate- rials and provide a bid to supply those items. When a local contractor accepted a new job, Adam would get its material requirements, come back to the store, and prepare and submit a proposal for the items. After some initial success with Big Builder, a large contractor, the number of jobs awarded to Adam had decreased dramatically.

One day, Adam was back at the store after losing a bid to Big Builder when he noticed someone in the store purchasing the exact items and quantities that were in the specification for that bid. The combination of items was unusual, and it would be an unlikely coincidence for someone else to want such a combination in that exact quantity. The customer paid the retail price for the merchandise and left.

Adam decided to contact Big Builder, but he knew he could not do so and make any accusations. Adam set up a meeting with the president of Big Builder and inquired as to how Adam might “increase his business and better meet the needs of Big Builder.” Eventually, the recent bid entered the conversation. Adam showed his copy of the bid to the president. The president retrieved a copy of the purchase order and recognized that the amount on it was more than the bid Adam had submitted. The company that submitted the bid was K. A. Supplies Inc. Adam had never heard of K. A. Supplies and noted its address on the purchase order. The president of Big Builder promised to investigate the bidding process.

Adam drove to the address of K. A. Supplies and found a packaging and shipping store at that address. Furthermore, Adam went to the county courthouse and inquired about K. A. Supplies. The company was listed in the county records, and one of the purchasing agents for Big Builder was listed as an officer.

Required: a. Given the information that Adam knows, what do you believe is occurring at Big Builder? b. What other information would you want to obtain, and how might you retrieve that

information? c. What controls might be instituted at Big Builder to prevent improprieties in the bidding

and purchasing process?

6.52 The Perfect Crime? Consider the following story of an actual embezzlement: This was the ingenious embezzler’s scheme: (a) He hired a print shop to print a private stock of Ajax Company checks in the company’s numerical sequence. (b) In his job as an accounts payable clerk at Ajax, he intercepted legitimate checks written by the accounts payable department and signed by the Ajax treasurer and destroyed them. (c) He substituted the same numbered check from the private stock, payable to himself in the same amount as the legitimate check, and he “signed” it with a rubber stamp that looked enough like the Ajax Company treasurer’s signature to fool the paying bank. (d) He deposited the money in his own bank account. The bank statement reconciler (a different person) was able to agree the check numbers and amounts listed in the cleared items in the bank statement to the recorded cash disbursement (check number and amount) and thus did not notice the embez- zler’s scheme. The embezzler was able to process the vendor’s “past due” notice and the next month’s statement with complete documentation, enabling the Ajax treasurer to sign another check the next month paying both the past due balance and current charges. The embezzler was careful to scatter the double-expense payments among numerous accounts (telephone, office supplies, inventory, etc.) so the double-paid expenses did not distort any accounts very much. As time passed, the embezzler was able to recommend budget amounts

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that allowed a large enough budget so his double-paid expenses in various categories did not often pop up as large variances from the budget.

Required: List and explain the ways and means you believe someone might detect the embezzlement. Think first about the ordinary everyday control activities. Then think about extensive detec- tion efforts assuming a tip or indication of a possible fraud has been received. Is this a “perfect crime”?

6.53 Select Effective Extended Procedures. The following are some “suspicions.” You have been requested to select some effective extended procedures designed to confirm or deny the suspicions.

Required: Write the suggested procedures for each case in definite terms so another person can know what to do. a. The custodian of the petty cash fund may be removing cash on Friday afternoon to pay

for weekend activities. b. A manager noticed that eight new vendors were added to the purchasing department’s

approved vendor list after the assistant purchasing agent was promoted to chief agent three weeks ago. She suspects all or some of them might be fictitious companies set up by the new chief purchasing agent.

c. The payroll supervisor may be stealing unclaimed paychecks of employees who resigned and did not collect their last check.

d. Although no customers have complained, cash collections on accounts receivable have decreased, and the counter clerks may have stolen customers’ payments.

e. The cashier may have “borrowed” cash receipts, covering this by holding each day’s deposit until cash from the next day(s) collection is enough to make up the shortage from an earlier day and then sending the deposit to the bank.

6.54 Forensic Accounting: Assurance Engagement 1: Expenditure Analysis. Expenditure analysis is used when fraud has been discovered or strongly suspected and the information to calculate a suspect’s income and expenditures can be obtained (e.g., asset and liability records, bank accounts). Expenditure analysis consists of establishing the suspect’s known expenditures for all purposes for the relevant period, subtracting all known sources of funds (e.g., wages, gifts, inheritances, bank balances), and identifying the difference as “expendi- tures financed by unknown sources of income.”

The law firm of Gleckel and Morris has hired you. The lawyers have been retained by Blade Manufacturing Company in a case involving a suspected kickback by a purchasing employee, E. J. Cunningham. Cunningham is suspected of taking kickbacks from Mason Varner, a salesman for Tanco Metals. Cunningham has denied the charges, but Lanier Gleckel, the lawyer in charge of the case, is convinced the kickbacks have occurred.

Gleckel filed a civil action and subpoenaed Cunningham’s financial records, including last year’s bank statements. The beginning bank balance January 1 was $3,463, and the end- ing bank balance December 31 was $2,050. Over the intervening 12 months, Cunningham’s per-month gross salary was $3,600 with a net of $2,950. His house payments were $1,377 per month. In addition, he paid $2,361 per month on a new Mercedes 500 SEL and a total of $9,444 last year toward a new Nissan Maxima (including $5,000 down payment). He also purchased new state-of-the-art audio and video equipment for $18,763 with no down pay- ment and made total payments of $5,532 on the equipment last year. A reasonable estimate of his household expenses during the period is $900 per month ($400 for food, $200 for utilities, and $300 for other items).

Required: Using expenditure analysis, calculate the amount of income, if any, from “unknown sources.”

6.55 Forensic Accounting: Assurance Engagement 2: Net Worth Analysis. You can use the computer-based Electronic Workpapers on the textbook website to prepare the net worth analysis required in this problem.

Net worth analysis is performed when fraud has been discovered or is strongly suspected and the information to calculate a suspect’s net worth can be obtained (e.g., asset and liabil- ity records, bank accounts). The procedure used is to calculate the person’s change in net

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worth (excluding changes in market values of assets) and to identify the known sources of funds to finance the changes. Any difference between the change in net worth and the known sources of funds is called funds from unknown sources, which might include ill-gotten gains.

Nero has worked for Bonne Consulting Group (BCG) as the executive secretary for administration for nearly 10 years. Her dedication has earned her a reputation as an out- standing employee and has resulted in increasing responsibilities. Nero is also a suspect in a fraud.

During Nero’s first five years of employment, BCG subcontracted all of its feasibility and marketing studies through Jackson & Company. This relationship was terminated because Jackson & Company merged with a larger, more expensive consulting group. At the time of termination, Nero and her supervisor were forced to select a new firm to conduct BCG’s market research. However, Nero never informed the accounting department that the Jackson & Company account had been closed.

Because her supervisor allowed Nero to sign the payment voucher for services rendered, she was able to continue to process checks made payable to Jackson’s account. Nero was trusted to be the only signature required to authorize payments less than $10,000. The accounting department continued to write the checks and Nero took responsibility for deliv- ering the checks. She opened a bank account in a nearby city under the name of Jackson & Company, where she made the deposits.

Nero’s financial records have been obtained by subpoena. The following table provides a summary of the data obtained from her records:

Nero’s Subpoenaed Records

Year 1 Year 2 Year 3 Assets:  Residence $100,000 $100,000 $100,000  Stocks and bonds 30,000 30,000 42,000  Automobiles 20,000 20,000 40,000  Certificate of deposit 50,000 50,000 50,000  Cash 6,000 12,000 14,000 Liabilities:  Mortgage balance 90,000 50,000 —  Auto loan 10,000 — — Income:  Salary 34,000 36,000  Other   6,000 6,000 Expenses:  Scheduled mortgage payments 6,000 6,000  Auto loan payments 4,800 —  Other living expenses 20,000 22,000

Required: You have been hired to estimate the amount of loss by estimating Nero’s “funds from unknown sources” that financed her comfortable life style. (Hint: Set up a working paper like the following:)

  End Year 1 End Year 2 End Year 3 Assets (list)       Liabilities (list)       Net worth (difference)       Change in net worth       Add total expenses       = Change plus expenses       Subtract known income       = Funds from unknown sources      

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6.56 Employee Embezzlement via Cash Receipts and Payment of Personal Expenses. Assume you have received a message from an informant regarding the following case. Your assignment is to write the “audit approach” portion of the case. a. Write a brief explanation of desirable controls, missing controls, and especially the kinds

of “deviations” that might arise from the situation described in the case. (Refer to con- trols explained in Chapter 5.)

b. Develop some procedures for obtaining evidence about existing controls, especially pro- cedures that could discover deviations from controls. If there are no controls to test, then there are no procedures to perform. Then just move on to part (c). (Refer to test of con- trols procedures explained in this chapter.) An audit “procedure” should instruct some- one about the source(s) of evidence to obtain and the work to perform.

c. Write some procedures for gathering evidence in this case. d. Write a short statement about the discovery you expect to accomplish with your procedures.

The Extra Bank Account The Ourtown Independent School District, like all others, had formal, often bureaucratic, procedures regarding school board approval of cash disbursements. To get around the rules and to make possible timely payment of selected bills, the superintendent of schools had a school bank account that was used in the manner of a petty cash fund. The board knew about it and had given blanket approval in advance for its use to make timely payment of minor school expenses. The board, however, never reviewed the activity in this account. The business manager had sole responsibility for the account subject to the annual audit. The account received money from transfers from other school accounts and from deposit of cafeteria cash receipts. The superintendent did not like to be bothered with details and often signed blank checks so the business manager would not need to obtain a signature all the time. The business manager sometimes paid her personal American Express credit card bills, charged personal items to the school’s Visa account, and pocketed some cafeteria cash receipts before deposit.

An informant called the state education audit agency and told the story that this business manager had used school funds to buy hosiery. When told of this story, the superintendent told the auditor to place no credibility in the informant, who was “out to get us.” The busi- ness manager had, in fact, used the account to write unauthorized checks to “cash,” put her own American Express bills in the school files (the school district had a Visa card, not American Express), and signed on the school card for gasoline and auto repairs during peri- ods of vacation and summer when school was not in session. (As for the hosiery, she pur- chased $700 worth with school funds one year.) The superintendent was genuinely unaware of the misuse of funds. The business manager had been employed for six years, was trusted, and embezzled an estimated $25,000.

6.57 Electronic Confirmations. As stated in the text, most banks require auditors to use elec- tronic audit confirmation requests, and as a result, nearly all audit firms now use them. At present, Confirmation is the market-leading technological platform for electronic audit con- firmations. To obtain a greater understanding of the process used to confirm accounts with electronic confirmation requests, watch the introduction video to Confirmation’s process at https://vimeo.com/301903513.

6.58 Case of the Missing Petty Cash The case below tells the actual story of a cash embezzle- ment scheme. The case has two major parts: (1) problem and (2) audit approach. For the case, please consider how the auditor may have discovered the cash embezzlement scheme.

Problem The petty cash custodian (1) brought postage receipts from home and paid them from the fund, (2) persuaded the supervisor to sign blank authorization slips the custodian could use when the supervisor was away and used them to pay for fictitious meals and minor supplies, and (3) took cash to get through the weekend, replacing it the next week. Postage receipts were from a distant post office station the company did not use. The blank authorization slips were dated on days the supervisor was absent. The fund was cash short during the weekend and for a few days the following week. The fund was small ($500), but the custo- dian replenished it about every two working days, stealing about $50 each time. With about 260 working days per year and 130 reimbursements, the custodian was stealing about $6,500

LO 6-1

LO 6-6

LO 6-2

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per year. The custodian was looking forward to getting promoted to general cashier and big- ger and better things!

Audit Approach The audit team should discuss petty cash procedures with the custodian and supervisor, especially those that relate to situations in which the custodian or supervisor is not available to provide needed petty cash. Next, a sample of petty cash reimbursement check copies with receipts and authorization slips attached should be studied for evidence of authorization and validity. On Friday, an audit team member should count the petty cash and receipts to see that they total $500. Then the fund should be recounted later in the afternoon. (The second count should be a surprise.) The custodian or supervisor should be present at all times so that the auditor will not be accused of theft.

Required: Based on the audit approach discussed, how would the auditor have caught this fraudulent scheme?

6.59 The Laundry Money Skim The case below tells the actual story of a cash embezzlement scheme. The case has two major parts: (1) problem and (2) audit approach. For the case, please consider how the auditor may have discovered the cash embezzlement scheme.

Problem Albert owned and operated 40 coin laundries around town. As the business grew, he could no longer visit each one, empty the cash boxes, and deposit the receipts. Each location grossed about $140 to $160 per day, operating 365 days per year—gross receipts of about $2 million per year. Each of four part-time employees visited 10 locations, collecting the cash boxes and delivering them to Albert’s office where he would count the coins and currency (from the change machine) and prepare a bank deposit. One of the employees skimmed $5 to $10 from each location visited each day.

The daily theft does not seem like much, but at an average of $7.50 per day from each of 10 locations, totaled about $27,000 per year. If all four of the employees had stolen the same amount, the loss could have been over $100,000 per year.

Audit Approach Controls over the part-time employees were nonexistent. There was no overt or covert sur- prise observation and no times when two people went to collect cash (thereby needing to agree, in collusion, to steal). There was no rotation of locations or other indications to the employees that Albert was concerned about control. With no controls, there is no test of control activities. Obviously, however, “thinking like a crook” leads to the conclusion that the employees could simply pocket money.

Assuming that some employees are honest, periodically rotating the stores assigned to each employee and performing revenue comparisons (analytical procedures) on a store-by- store basis may be helpful. If revenues consistently decline for stores assigned to a specific employee, further investigation may be warranted.

Required: Based on the audit approach discussed, how might an auditor devise a procedure to catch this fraudulent scheme?

LO 6-2

Apollo Shoes Audit of the Cash Account You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Water- shed and have been assigned to the engagement team of a new audit client, Apollo Shoes Inc. You have been asked to perform certain procedures for the audit of the cash account. A detailed audit program for performing the audit of cash, as well as bank reconciliations and supporting documentation, can be found in Connect.

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Appendix 6A

Internal Control Questionnaires

EXHIBIT 6A.1 Internal Control Questionnaire—Cash Receipts Processing

  Yes No Comments

1. Are cash receipts deposited daily, intact, and without delay?      

2. Does someone other than the cashier or accounts receivable bookkeeper take the deposits to the bank?      

3. Are the duties of the cashier entirely separate from record keeping for notes and accounts receivable? From general ledger record keeping?

     

4. Is the cashier denied access to receivables records or monthly statements?      

5. Is a bank reconciliation performed monthly by someone who does not have cash custody or record-keeping responsibility?

     

6. Are the cash receipts journal entries compared to the remittance lists and deposit slips regularly?      

7. Does the person who opens the mail make a list of cash received (a remittance list)?      

8. Are currency receipts controlled by mechanical devices? Are machine totals checked by the internal auditor?

     

9. Are prenumbered cash receipts listings used? Is the numerical sequence checked for missing documents?      

10. Does the accounting manual contain instructions for dating cash receipts entries the same day as the date of receipt?

     

11. Is a duplicate deposit slip retained by someone other than the employee preparing the deposit?      

12. Is the remittance list compared to the deposit by someone other than the cashier?      

13. Does the accounting manual contain instructions for classifying cash receipts credits?      

14. Does someone reconcile the accounts receivable subsidiary to the control account regularly (to determine whether all entries were made to customers’ accounts)?

     

15. Is the duty of processing credit card payments separated from the process of processing voids?      

16. If the company processes credit cards, does it maintain documentation that it is PCI (Payment Card Industry) compliant?

     

EXHIBIT 6A.2 Internal Control Questionnaire—Cash Disbursements Processing

  Yes No Comments

1. Are persons with cash custody or check-signing authority denied access to accounting journals, ledgers, and bank reconciliations?

     

2. Is access to blank checks denied to unauthorized persons?      

3. Are all disbursements except petty cash made by check?      

4. Are check signers prohibited from drawing checks to cash?      

5. Is signing blank checks prohibited?      

6. Are voided checks mutilated and retained for inspection?      

7. Are invoices, receiving reports, and purchase orders reviewed by the check signer?      

8. Are the supporting documents stamped “paid” (to prevent duplicate payment) before being returned to accounts payable for filing?

     

9. Are checks mailed directly by the signer and not returned to the accounts payable department for mailing?

     

(continued)

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  Yes No Comments

10. Do checks require two signatures? Is there dual control over machine signature plates?      

11. Are blank checks prenumbered and the numerical sequence checked for missing documents?      

12. Are checks dated in the cash disbursements journal with the date of the check?      

13. Are bank accounts reconciled by personnel independent of cash custody or record keeping?      

14. Do internal auditors periodically conduct a surprise audit of bank reconciliations?      

15. Do the chart of accounts and accounting manual give instructions for determining debit classifications of disbursements not charged to accounts payable?

     

16. Is the distribution of charges checked periodically by an official? Is the budget used to check on gross misclassification errors?

     

17. Are special disbursements (e.g., payroll and dividends) made from separate bank accounts?      

18. Is the bank reconciliation reviewed by an accounting official with no conflicting cash receipts, cash disbursements, or record-keeping responsibilities?

     

19. Are electronic banking access rights maintained on a timely basis and do not contain employees who have left the company?

     

20. Is dual authorization required to process electronic payments?      

21. For accounts with highly significant amounts of cash, is a third individual required to process electronic transfers or payments?

     

EXHIBIT 6A.2 (concluded)

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Audit Plans

Appendix 6B

EXHIBIT 6B.2 Audit Plan—Selected Substantive Procedures—Cash

EXHIBIT 6B.1 Audit Plan—Tests of Controls—Cash Receipts

  Documentation

Reference Performed By

1. Inquire of management concerning employees who a. Receive remittances from customers. b. Record payments in accounts payable. c. Prepare and deliver deposits to the bank.

2. Observe the opening of the mail and ensure that a. Two employees are opening the mail. b. Checks are restrictively endorsed. c. A listing of all checks is being prepared.

3. Observe the flow of checks and remittance advices and ensure that a. Checks are delivered directly to the cashier. b. Remittance advices are delivered to the accounting department.

4. Examine reconciliations of cash listings, accounts receivable payments, and bank deposits.

5. Examine reconciliations of bank statements for a. Initials of proper review. b. Investigation of all outstanding items reviewed for propriety.

6. Inspect evidence of payment card industry (PCI) compliance for acceptance of credit card payments.

  Documentation

Reference Performed By

1. Obtain confirmations from banks (standard bank confirmation).

2. Obtain reconciliations of all bank accounts. a. Trace the bank balance on the reconciliation to the bank confirmation. b. Trace the reconciled book balance to the general ledger. c. Recompute the bank reconciliation for mathematical accuracy.

3. Examine the bank confirmation for evidence of loans and collateral.

4. Inquire of the client to request a cutoff bank statement for each account, to be mailed directly to the audit firm.

a. Vouch deposits in transit on the reconciliation to the bank cutoff statement. b. Trace the outstanding checks that have cleared the cutoff statement back to the list of

outstanding checks on the bank reconciliation.

5. Prepare a schedule of interbank transfers for a period of 10 business days before and after the year-end date. Document dates of book entry transfer and correspondence with bank entries and reconciliation items, if any.

6. Count cash funds in the presence of a client representative.

7. Obtain management representations concerning compensating balance agreements.

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LEARNING OBJECTIVES This is the first of four “cycle chapters” in which you will go through the process of evaluating the audit risks present in a specific cycle and learning how to apply the auditing standards to the identified risks. First, we give a general overview of the typical activities in the revenue and collection cycle. Next, we discuss the significant accounts and relevant assertions in the revenue cycle. After that, we discuss the risk of material misstatement in the revenue

cycle. Many recent frauds have consisted of improper revenue recognition, which also results in an overstatement of assets, usually receivables. Next, we examine the appropriate design of controls normally included in the cycle and how the auditor evaluates the operating effectiveness of these controls. Finally, we discuss substantive procedures, including common analytical procedures. You will note that accounts receivable confirmations are a central part of accounts receivable auditing and are required by GAAS. You will see examples of confirmations and

Thomas Paine, English-American political philosopher and revolutionary (1737–1809)

What at first was plunder, assumed the softer name of revenue.

Revenue and Collection Cycle

C H A P T E R 7

Professional Standards References

Topic AU-C/ISA Section

PCAOB Reference

Audit Documentation 230 AS 1215

Consideration of Fraud in a Financial Statement Audit 240 AS 2401

Audit Planning 300 AS 2101

Identifying and Assessing the Risks of Material Misstatement 315 AS 2110

The Auditor’s Responses to Risks of Material Misstatement 330 AS 2301

Audit Evidence 500 AS 1105

External Confirmations 505 AS 2310

Substantive Analytical Procedures 520 AS 2305

Auditing Accounting Estimates 540 AS 2501

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INTRODUCTION In January 2018, Carillion was the second largest construction firm in the United Kingdom (UK). Less than a month later, the name Carillion was associated far less with construc- tion and much more with being the company whose fraud led to calls in the UK to break up the Big Four accounting firms for failing to report Carillion’s “accounting tricks,” as was discussed in a May 2018 Parliamentary report:

“Richard Adam, as Finance Director between 2007 and 2016, was the architect of Car- illion’s aggressive accounting policies. He, more than anyone else, would have been aware of the unsustainability of the company’s approach. His voluntary departure at the end of 2016 was, for him, perfectly timed. He then sold all his Carillion shares for ₤776,000 just before the wheels began very publicly coming off and their value plummeted. These were the actions of a man who knew exactly where the company was heading once it was no longer propped up by his accounting tricks.”*

In the construction industry, a common method of estimating revenues is to recog- nize the percentage of revenue earned to date based on the percentage of expected costs already incurred. Carillion used this type of accounting estimate as the primary tool to manipulate its earnings. Specifically, by underestimating the total expected costs, the company was able to materially overstate revenues, and show profits when losses existed. The company accomplished this by using management estimates of costs and ignoring independent peer reviews which indicated far higher expected costs and project losses, which should have been recognized immediately. One large project resulted in the recog- nition of an expected profit margin of 4.9%, when independent estimates indicated a loss of 12.7%.

In the U.S., the estimation of revenue is often a significant audit risk under the accounting standard for revenue from contracts with customers (under ASC 606), which will be discussed in detail in this chapter. High degrees of estimation uncertainty and the need for experts in estimating revenue almost always results in the occurrence of contract revenue being evaluated as both a fraud risk and a significant risk of material misstatement. In fact, the PCAOB has placed special emphasis on audits of estimates and the use of specialists in standards updates adopted in December 2018 for audits of fiscal years ending after December 15, 2020. These new standards will be covered in greater detail in Chapter 10, but as the Carillion example shows, are equally relevant in auditing revenue.

House of Commons, Business, Energy and Industrial Strategy and Work and Pensions Committees, May 16, 2018.

a discussion of procedures auditors perform when sending those confirmations. We conclude with an application of what you have learned to a specific audit issue within the revenue and collection cycle.

Your objectives are to be able to:

LO 7-1 Describe the revenue and collection cycle, including typical source documents.

LO 7-2 Identify significant accounts and relevant assertions related to the revenue and collection cycle.

LO 7-3 Discuss the risk of material misstatement in the revenue and collection cycle, with a specific focus on improper revenue recognition.

LO 7-4 Identify important internal control activities present in a properly designed system to mitigate the risk of material misstatements for each relevant assertion in the revenue and collection cycle.

LO 7-5 Give examples of tests of controls to test the operating effectiveness of internal controls in the revenue and collection cycle.

LO 7-6 Give examples of substantive procedures in the revenue and collection cycle and relate them to assertions about significant account balances at the end of the period.

LO 7-7 Apply your knowledge to perform audit pro- cedures in the revenue and collection cycle and evaluate the findings of your tests.

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REVENUE AND COLLECTION CYCLE: TYPICAL ACTIVITIES There is no such thing as a typical revenue and collection cycle. Companies come in all shapes and sizes, and the actual revenue generation process can vary greatly among indus- tries. For example, banks and other financial services firms do not sell tangible goods. Restaurants typically do not grant credit to customers. Further, many companies accept all payments electronically. For the purposes of our discussions in the four cycle chapters, we assume a typical manufacturing company that sells products of some kind to customers— often other businesses—on credit. The basic activities in the revenue and collection cycle for a company like this are (1) receiving and processing customer orders, including credit approval; (2) delivering goods and services to customers; (3) billing customers and account- ing for accounts receivable; and (4) collecting and depositing cash received from custom- ers. See Exhibit 7.1 for the activities and transactions involved in a revenue and collection cycle. Note that collecting and depositing cash received from customers was covered in Chapter 6. As you follow the discussion in the text, you can track some of the highlighted elements of the cycle. The numbers listed next to the headings correspond to the numbers in Exhibit 7.1. We will discuss how different companies may vary from this “typical” cycle.

LO 7-1 Describe the revenue and collection cycle, including typical source documents.

EXHIBIT 7.1 Revenue and Collection Cycle

Cash Custody

Credit Files, Reports

Sales Authorization

Physical Custody

Cash Reconciliation

Cash Receipts Recording

Accounts Receivable Recording

Start Here

Customer Orders

Collections

Credit Granting

Bill Customers

Warehousing Shipping and

Delivery

Monthly Statements

Bank Statements

Shipping Docu- ments (Copy)

Shipping Documents

(Copy)

Customer’s Purchase Orders, Contracts

Customer Order

Sales Invoice (Copy)

Sales Invoice

To Customer

To Customer

To Customer

Deposit Cash in Bank

Customer Payments

(Cash Receipts)

Shipping Documents

Shipping Document

Transaction File

Sales Revenue

Account(s) File

Accounts Receivable

Master File

Cash Receipts

Transaction File

Cash Balances (Account)

File

Perpetual Inventory Records

Accounts/Records

Cash in Bank Cash Receipts Accounts Receivable Allowance for Doubtful Accounts, Write-O�s Bad Debt Expense Sales Revenue Sales Returns, Allowances, Discounts Perpetual Inventory Records, Shipping Records

4*

3

2

1

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Giant retailer Target Corp. had its customers’ credit card and debit card data breached over the Black Friday weekend in 2013. The theft was not limited to any one location of the company’s business and included stores nationally. Target estimates that approximately 42  million customers had their personal credit or debit card informa- tion stolen. In response to a class-action lawsuit, Target agreed to pay $10 million to the hacking victims.

Note how important it is to protect information received during the revenue cycle.

Source: “Target Offers $10 Million Settlement in Data Breach Lawsuit,” http:// www.npr.org/sections/thetwo-way/2015/03/19/394039055/target-offers- 10-million-settlement-in-data-breach-lawsuit, March 19, 2015.

Missing the Target?AUDITING INSIGHT

Receiving and Processing Customer Orders, Including Credit Granting 1 Customers initiate sales orders in a variety of ways. They can mail purchase orders, call or fax orders, e-mail orders, place orders on a website, or simply come to the company’s place of business and buy their goods. In some cases, companies are directly linked to production schedules in their customers’ computer files (via electronic data interchange, EDI), so they can ship goods automatically as the customer needs them. Electronic or Internet sales orders require special software controls that protect against unauthorized orders and protect customer information.

If a company sells its goods or services for something other than cash, it is important that someone authorize credit sales to ensure that the customer will be able to pay for the goods or services. Because various authorizations are embedded in a computerized sys- tem, access to the customer master file for additions, deletions, and other changes must be limited to responsible people. If these controls fail, orders might be processed for ficti- tious customers, credit might be approved for bad credit risks, and shipping documents might be created for goods that do not exist in the inventory.

Although many companies directly grant credit to customers, others rely on third- party credit, such as accepting credit cards from Visa or American Express. When a retailer accepts a third-party credit card, the authorization function is performed elec- tronically, and the risk of nonpayment generally shifts to the third party in exchange for a processing fee. Sales such as this are considered cash sales to the retailer. Although authorization controls are minimized in this situation, data security becomes a significant issue. Retailers who accept third-party credit cards must maintain compliance with Pay- ment Card Industry Data Security Standard requirements (PCI Dss). When companies fail to adequately protect information, they can become liable for losses to customers, as discussed in the following Auditing Insight.

Customer orders, shipping documents, and invoices should be in prenumbered sequence so the system can check the sequence and determine whether any transactions have not been recorded (completeness assertion) or have been duplicated (occurrence assertion). Prenumbered documents are an example of an internal control (i.e., control activity).

Another authorization in the system is the price list master file. This file contains the product unit prices for billing customers. Persons who have power to alter this file have the power to authorize price changes and customer billings.

Delivering Goods and Services to Customers 2 Physical custody of inventory goods starts in the storeroom or warehouse where inven- tory is kept. Custody is transferred to the shipping department upon the authorization of the shipping order that permits the inventory clerk to release goods to the shipping department. Proper authorization is important: Employees performing each of these steps should sign transfer documents so they are held accountable. This control procedure

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prevents employees from misappropriating the goods or shipping product to friends with- out billing them. A bill of lading is a form that the carrier signs to verify the goods are shipped. A packing slip, which describes the goods being shipped, and the quantity of goods shipped, is often included with the shipment.

Billing Customers and Accounting for Accounts Receivable 3 When a delivery or shipment is complete, the transaction is completed by filing a ship- ment record and preparing a final invoice for the customer (which is recorded as sales revenue and accounts receivable). A sales invoice is the bill sent to the customer that indi- cates the amount due and the payment terms. Any person who has the power to alter these transactions or to change the invoice before it is mailed to the customer should not have any custody or recording responsibilities.

Access to accounts receivable records implies the power to alter them directly or enter transactions (e.g., returns and allowance credits, write-offs) to alter them. Person- nel with this power have a combination of authorization and recording responsibility. Another important facet of control is physical protection of the files. If the files are lost or destroyed, it is unlikely the accounts will be collected, so the records are truly assets. Limited access, frequent backup, and disaster recovery plans are important controls to ensure the availability of information. Moreover, customer and employee information must be protected.

The most frequent reconciliation is the comparison of the sum of customers’ unpaid balances (customer database or subsidiary ledger kept in the accounts receivable depart- ment) with the accounts receivable control account total (maintained in corporate accounting). This reconciliation is accomplished by preparing a trial balance of the accounts receivable subsidiary ledger, adding it, and comparing its total with the control account balance in the general ledger. Internal auditors can perform periodic reviews of the customers’ balances by sending confirmations to the customers.

System Generated Reports and Data Files in the Revenue and Collection Cycle Because revenue and cash receipts transactions are generally processed using electronic systems, management is able to generate reports and data sets that can provide important information not just for management, but also for audits. Exhibit 7.2 represents a typical system for processing customer orders and accounts receivable. In this section, we dis- cuss the system-generated reports that are typically produced in this system that will be used to evaluate the risk of material misstatement and perform audit tests.

Pending Order and Back Order Master File Sales transactions that were initiated but are not yet completed, and thus not yet recorded as sales, are kept in the pending order master file. A back order master file contains orders for products that are out of stock currently. Long-standing orders may represent unfilled sales to a customer, which may result in low customer satisfaction and loss of potential revenue. They also may represent shipments that actually were made but for some reason were not recorded in the sales journal or could not be matched to a customer order. Typically, a pending or back order report will be reviewed by the company at least weekly, and exceptions should be reviewed. Auditors will review items in the pending orders file for evidence of the completeness of recorded sales and accounts receivable.

Customer Master File The system may make automatic credit checks, but up-to-date maintenance of customer information is very important. Credit checks based on dated or incomplete information are not good credit checks. A sample of the customer master file can be tested for cur- rent status, including up-to-date credit limit information. Alternatively, the company’s data change controls can be reviewed to ensure the files are accurately maintained.

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EXHIBIT 7.2 Sales and Accounts Receivable Processing

Sales Order

Invoices Back Order Report

Daily Sales Report

Packing Slip

Sales Analysis A/R Listing and Aging

Monthly Customer Statements

Customer Purchase Order

Inventory Master (Subsidiary)

A/R Master (Subsidiary)

Price List Master File

Pending Order Master

Sales Detail (Journal)

General Ledger Master

Order Entry

Shipping

Packing Slip

Stockroom

Terminal Logs

Terminal Logs

Online sales processing

• Authorized terminal ID • Sales order screen • Automatic credit check • Inventory-on-hand check • Immediate update of all databases • Online status query

Marketing Management

Credit Management• Automatic transfer from pending

order to A/R and G/L master files

Credit Check Files

Back Order Master

The company should regularly review credit limits to ensure appropriate limits are placed on customers, and auditors will often perform exception testing on credit checks. (See Application in the Field example later in this chapter.)

Price List Master File The system may produce customer invoices automatically, but if the price list master file is incorrect, the billings will be incorrect. The pricing file can be compared to an official price source for accuracy. The company should perform this comparison every time it changes its prices. Remember that prices typically change over the year. Therefore, when vouching invoices and sales journal entries to price lists, the auditor must be sure to have the price list that was in effect at the time of the customer’s order.

Sales Detail (Journal) File The detailed sales entries, which should correspond with the issuance of invoices to cus- tomers and should include the shipping references and dates, should be in the sales detail file. The file can be scanned using computer-assisted auditing techniques (CAATs) check- ing for entries without shipping references (fictitious sales?) and for matching record- ing dates with shipment dates (sales recorded before shipment?). The company should always compare daily credit sales totals in the sales journal to the total debits posted to accounts receivable.

Sales Analysis Reports A variety of sales analysis reports can be produced. Sales that are classified by product lines provide required information for the business segment disclosures. Sales classified by sales employee or region can show unusually high or low volume that might bear fur- ther investigation if an error or fraud is suspected. Analytical procedures, such as trend analysis or comparison among sales units, can be a great help to the auditor as illustrated by the following Auditing Insight.

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Accounts Receivable Listing and Aging The accounts receivable listing of customers’ balances contains the actual amounts spe- cifically identified with individual customers. If the control account total is higher than the sum of the customers’ balances (trial balance), it will have to be adjusted after the difference is thoroughly investigated. Remember, a receivable amount that cannot be identified with a customer cannot be collected! The trial balance is used as the starting point for selecting accounts for confirmation. The accounts receivable aging informa- tion is used in connection with assessing the allowance for doubtful accounts. Audi- tors must ensure that the calculation of the aging is accurate to verify that customer accounts are not listed as current when they are in fact past due. An example of this listing, also called an aged trial balance, is presented at Exhibit 7.10, which is shown later in this chapter.

Cash Receipts Listing The cash receipts journal contains all the detail entries for cash deposits and credits to various accounts. It contains the population of entries that should be reflected in the credits to accounts receivable for customer payments. It also contains adjusting and cor- recting entries that can result from the bank account reconciliation. These entries are important because they might signal the types of accounting errors or manipulations that occur in the cash receipts listing.

Customer Statements Probably the best control over whether cash is received and recorded is the customer. Therefore, sending customer statements of what has been billed, what has been paid, and ending balances on a monthly basis enables customers to spot discrepancies and notify the company. Statements should be sent if there is any activity in the account, even if the ending balances are zero.

During the year-end audit of a national manufacturer, the independent auditors imported the weekly sales volume reports classified by region into Tableau, a data visualization software used in many audits. By cre- ating graphical workbooks, the auditors noticed that sales volume was very high in Region 2 the last two weeks of March, June, September, and December. The volume was unusually low in the first two weeks of April, July, October, and January. In fact, the peaks far exceeded the

volume in all the other six regions. The analysis of the sales volume reports enabled the auditors to identify and focus their efforts on a potential overstatement of revenue in a specific region, increasing the effectiveness and efficiency of the audit. Further investigation revealed that the manager in Region 2 was holding open the sales journal at the end of each quarterly reporting period (i.e., including sales from the next period) in an attempt to make the quarterly reports look good.

Peaks and ValleysAUDITING INSIGHT

REVIEW CHECKPOINTS 7.1 What is the basic sequence of activities and accounting in a revenue and collection cycle? 7.2 What purpose is served by prenumbering sales orders, shipping documents, and sales invoices? 7.3 What controls should be implemented to safeguard accounts receivable files? 7.4 What computer-based files might auditors examine to find evidence of unrecorded sales? Of inad-

equate credit checks? Of incorrect product unit prices? 7.5 Suppose that you selected a sample of customers’ accounts receivable and wanted to find supporting

evidence for the entries in the accounts. Where would you go to vouch the debit entries? What would you expect to find? Where would you go to vouch the credit entries? What would you expect to find?

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SIGNIFICANT ACCOUNTS AND RELEVANT ASSERTIONS According to the professional standards, an account or disclosure is significant if there is a reasonable chance that it could contain a material misstatement. The auditor identifies significant accounts and relevant assertions by applying the audit risk model.

Chapter 4 introduced the audit risk model. As noted there, this model allows auditors to control audit risk to desired levels. Audit risk is defined as the risk that auditors will issue an unqualified opinion on financial statements that contain a material misstatement. Audit risk is manifested when a material misstatement enters the financial reporting pro- cess (inherent risk) that the client’s internal controls do not prevent or detect (control risk) and that the auditors’ substantive procedures do not detect (detection risk). Recall the basic three-step approach for using the audit risk model to plan an engagement:

1. Set audit risk at desired levels (normally, low). 2. Assess risk of material misstatement, which incorporates inherent risk based on the

nature of the account balance or class of significant transactions and control risk based on gaining an understanding of internal control. Remember that AS 2110 indicates that the auditor should presume that there is a fraud risk involving improper revenue recognition.

3. Set detection risk at the significant account and assertion level based on the level of audit risk and risk of material misstatement.

The components of the audit risk model are assessed for each significant account and relevant assertion. This assessment recognizes that certain accounts and assertions assume an increased level of importance and are of more interest to auditors than oth- ers. For example, because of the tendency to use fictitious sales to overstate assets and revenues, the existence assertion is extremely important in the audit of accounts receiv- able, and occurrence is important for sales. In addition, because material errors happen, auditors need to examine revenue and accounts receivable for completeness. However, the auditor generally presumes that management has an incentive to overstate revenues. Thus, auditors may assess inherent risk for the existence assertion to be higher than for the completeness assertion for these accounts, all other things being equal.

Once all of the significant accounts and disclosures have been identified, the auditor then needs to identify the relevant assertions. According to AS 2201.A9, a financial state- ment assertion is relevant if it has a “reasonable possibility of containing a misstatement or misstatements that would cause the financial statements to be materially misstated.”

Exhibit 7.3 identifies the significant accounts and relevant assertions in the revenue cycle. Although different companies may have other risks, in general, the most sig- nificant risks relate to the occurrence of revenues and the existence and valuation of accounts receivable. Because of the risk of unrecorded revenue, the completeness of revenue and accounts receivable is also considered a significant risk in the revenue and collection cycle. Although we will focus our discussion on revenue and accounts receiv- able, we will also discuss other accounts and assertions that may require consideration in the revenue cycle.

LO 7-2 Identify significant accounts and relevant assertions related to the revenue and collection cycle

EXHIBIT 7.3  Significant Accounts and Relevant Assertions in the Revenue and Collection Cycle

Significant Account Relevant Assertions

Revenue Occurrence

Completeness

Cutoff

Accounts Receivable Existence

Completeness

Valuation

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RISK OF MATERIAL MISSTATEMENT As part of the planning process, the auditor must determine the source of a misstatement that could cause the financial statements to be materially misstated. One way to assess the risk of material misstatement is to use the “what could go wrong?” (WCGW) approach when thinking of each financial statement assertion. The WCGW is a part of each audit firm’s process and enables a thorough assessment of the risk of material misstatement.

When considering WCGW in the revenue and collection cycle, auditors consider three primary concerns: (1) Is revenue recognized when appropriate? (2) Is there a possibility of customers returning the goods? (3) Are the accounts receivable collectible? Exhibit 7.4 summarizes the WCGW analysis for the revenue and collection cycle.

Revenue Recognition The IT Factory example at the beginning of this chapter is an extreme example of the violation of accounting standards related to revenue recognition (recording revenues in the entity’s books). To be recognized, revenues must be (1) realized or realizable and (2) earned.1

An entity’s revenue-earning activities involve delivering or producing goods, ren- dering services, or performing other activities that constitute its ongoing major or cen- tral operations, and revenues are considered to have been earned when the entity has substantially accomplished what it must do to be entitled to the benefits represented by the revenues.2

LO 7-3 Discuss the risk of material misstatement in the revenue and collection cycle, with a specific focus on improper revenue recognition.

1SFAC No. 5, “Recognition and Measurement in Finance Statements.” 2Ibid., ¶83(b).

REVIEW CHECKPOINTS 7.6 What makes an account significant or an assertion relevant? 7.7 Why do auditors focus on revenue as a significant account and the occurrence of revenue as a rel-

evant assertion in the revenue cycle? 7.8 Why is inherent risk for the existence assertion for accounts receivable often set higher than inher-

ent risk for the completeness assertion?

EXHIBIT 7.4 What Could Go Wrong in the Revenue and Collection Cycle?

Significant Account Relevant Assertions What Could Go Wrong?

Revenue Occurrence Management may overstate sales by adding fictitious transactions or inflating actual sales.

Management may fail to recognize the possibility of customer returns.

Completeness Not all sales are recorded.

Cutoff Sales have been recorded in incorrect periods.

Accounts Receivable Existence Accounts receivable are overstated and do not represent amounts owed from actual sales.

Completeness Not all accounts receivable have been recorded.

Valuation Receivables are not included in financial statements at the appropriate amount, and the uncollectible portion of the balance is not properly estimated.

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Similarly, the SEC believes that revenue generally is realized or realizable and earned when all of the following criteria are met:

∙ Persuasive evidence of an arrangement exists. ∙ Delivery has occurred or services have been rendered. ∙ The seller’s price to the buyer is fixed or determinable. ∙ Collectability is reasonably ensured.3

The SEC and the popular press have expressed concern about appropriate recog- nition of revenue in financial statements. A study by research firm Audit Analytics indicated that approximately 13.9 percent of all restatements in 2017 were related to revenue recognition. Since 2001, the percentage of restatements related to revenue rec- ognition has varied from 10.1 percent of all restatements in 2010 to 21.4 percent of all restatements in 2003.4 Some recent restatements are listed in Exhibit 7.5. The fact

3Staff Accounting Bulletin No. 104. Securities and Exchange Commission. December 17, 2003. 4Audit Analytics, 2017 Financial Restatements: A Seventeen Year Comparison May 2018.

EXHIBIT 7.5 Revenue Recognition Rogues

Company Cause of Misstatement Alleged Amount #

Bristol-Myers Company offered incentives to wholesalers to build their inventories so Bristol-Meyers could meet sales forecasts (channel stuffing).*

$2.5 billion

Computer Associates Company recognized revenue from several contracts in which it had either (1) agreed to make offsetting purchases (round trips) or (2) had contracts that contained undisclosed side letters that could have canceled the contracts.

$2.2 billion

Qwest Communications Company used fiber-optic “swaps.” It recorded sales of equipment when it agreed to pay hundreds of millions of dollars for Internet services. It recognized the revenue for the equipment but deferred the cost of the Internet services.

$2.2 billion

Nortel Company prematurely recorded revenue from equipment sales before the buyer had taken title to the equipment.

$1.5 billion

SeaView Video Technology

Company prematurely recorded revenues and accounts receivable for customer orders for security camera products prior to shipping.

$1.4 billion

AOL AOL recorded advertising revenue, some of which included one-time payments, stock sales, and “round-trip” deals in which money flowed both ways between AOL and the advertiser.

$1 billion

Royal Ahold Company induced third parties to provide false confirmations to auditors relating to sales and accounts receivable.

$700 million

Autonomy Company inflated revenues through backdated contracts and channel stuffing, among other approaches in order to inflate valuation for an acquisition by Hewlett-Packard.

$700 million

Household International Company employed incorrect timing of recognizing costs and revenues related to its MasterCard and Visa cobranding and affinity credit card relationships as well as a credit card marketing agreement with a third party.

$386 million

Xerox Several senior managers colluded to circumvent company’s accounting policies and administrative procedures. The restatement related to uncollectable long- term receivables, failure to record liabilities for amounts due to concessionaires, and, to a lesser extent, recording revenue for contracts that did not fully meet the requirements of sales-type leases.

$207 million

Interpublic Company improperly booked credits, creating double counting; included insurance proceeds that had not been realized; and understated liabilities.

$181 million

Gemstar Subsidiary TV Guide recorded $113 million in patent-licensing revenue from an expired Scientific-Atlanta Inc. contract.

$113 million

*Channel stuffing is a deceptive business practice that inflates sales and earnings by forcing more products along a company’s distribution channel without actual sales taking place. #Dollar amounts represent total misstatements and may include some non-revenue items. However, revenue recognition was the major issue in each of these cases.

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that the financial statements were restated means that the auditors missed the orig- inal misstatement or went along with the company’s accounting treatment. In some cases, predecessor auditors accepted the accounting treatment, but the current auditors demanded the restatement.

The PCAOB has also noted the difficulties with auditing revenue. In its Staff Preview of 2018 inspection results, the PCAOB noted that, “We observed frequent deficiencies related to the design and performance of audit procedures that address the assessed risk of material misstatement, particularly when auditing revenue.”5 These difficulties with revenue have always been present, but have perhaps become more challenging with the issuance of FASB ASC 606 (ASU 2014-09). The new standard requires a five-step pro- cess to achieve the core principle of revenue recognition:

1. Identify the contract(s) with a customer. 2. Identify the performance obligations in the contract. 3. Determine the transaction price. 4. Allocate the transaction price to the performance obligations in the contract. 5. Recognize revenue when (or as) the entity satisfies a performance obligation.

For some contracts, such as point of sale retail transactions, revenue recognition tim- ing and amount may be straight-forward. However, for licensing contracts and contracts involving multiple obligations, the estimation involved can be challenging for both the client and the auditor. This difficulty can be seen in the following Auditing Insight involving Apple, Inc.

When a customer buys a product off a grocery store shelf, the amount of the revenue is easy to determine—the price the customer paid. Sometimes, companies enter into contracts where the amount of a rev- enue isn’t that simple. Consider the sale of an iPad by Apple Inc. When a customer purchases an iPad, the purchase includes not just the hardware, but also a commitment from Apple to update the software included with the iPad, as well as a warranty, among other commit- ments. A contract such as this is referred to as a multiple deliverable contract. Therefore, the sales price of the iPad has to be divided among multiple revenue sources, some with obligations continuing long into the future. Until 2014, multiple deliverable contracts were subject to many different transaction and industry-specific accounting require- ments. With the issuance of a new standard on revenue from contracts with customers, FASB eliminated the multiple rules and replaced it with a new principle. Per FASB ASC 606-10-05-3, “The core principle of the revenue recognition standard is that an entity should recognize rev- enue to depict the transfer of goods or services to customers in an

amount that reflects the consideration to which the entity expects to be entitled in exchange for those goods or services.”*

For a company like Apple that enters into multiple deliverable con- tracts, this means that the revenue it recognizes on the sale of an iPad is based on some items, such as the iOS software updates, that are not sold separately and must be estimated. According to Apple, “For multi-element arrangements that include hardware products containing software essen- tial to the hardware product’s functionality, undelivered software elements that relate to the hardware product’s essential software, and undelivered non-software services, the Company allocates revenue to all deliverables based on their relative selling prices.”* Thus, Apple’s auditor (EY) must apply AS 2501, Auditing Accounting Estimates, to the amount of revenue that Apple distributes to each of the identifiable items sold with each iPad. This significantly increases the inherent risk in the audit of revenue.

Sources: Apple Inc. Form 10-K, fiscal year ended September 29, 2018; FASB Accounting Standards Update 2014-09—Revenue from Contracts with Cus- tomers (Topic 606).

The Amount Isn’t Always Obvious!AUDITING INSIGHT

Risks of improper revenue recognition are higher in high-growth companies that financial analysts often value at a multiple of total revenues. In addition, companies with complex transactions, related-party transactions, and reciprocal transactions have a higher likelihood of inflating revenues. An example of the latter occurred in

FASB Accounting Standards Update 2014-09—Revenue from Contracts with Customers (Topic 606) Apple Inc. Form 10-K, fiscal year ended September 29, 2018

5Public Company Accounting Oversight Board. “Staff Preview of 2018 Inspection Observations.” May 6, 2019.

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the telecommunications industry in which Global Crossing and other companies are alleged to have traded line rights in one geographic area to other companies for rights in another area. The rights given up were recorded as revenue, while the rights received were capitalized and the expense was spread over several years. Clearly, the issues in revenue recognition and accounts receivable are complex and can be difficult for the auditors. However, not all restatements are bad, as indicated in the following Auditing Insight.

Cubic Corp. said on Wednesday that it will restate earnings for the past three fiscal years after a review discovered errors in how the electronics company accounted for revenue from long-term develop- ment contracts as well as certain service contracts. Based on a pre- liminary review, the changes are expected to increase revenue and net income over the three years, Cubic said.

The company’s review found that financial statements for the fiscal years ending September 30 in 2009, 2010, and 2011, and the quarters ended March 31, 2012, and December 31, 2011, can no longer be relied upon. Cubic’s management recommended that adjustments be made due to errors in calculating revenue on  certain long-term fixed-price development contracts, and on certain long-term service contracts with non-U.S. government customers.*

The company has historically recognized development contract sales and profits using a “cost-to-cost percentage-of-completion” accounting method, with a modification that Cubic called a “formulary adjustment.” Using that method, it based sales and profits on the ratio of costs incurred to estimated total costs at completion of the contract. Cubic said the for- mulary adjustment had the effect of deferring a portion of the revenue and profits on contracts until later in the contract period. “Cubic believed that this methodology was an acceptable variation” of the cost-to-cost percentage-of-completion method as described in accounting stan- dards, the company said. But Cubic now believes that generally accepted accounting principles do not support the use of the formulary adjustment.*

Source: “Cubic Corp. to Restate Financial Statements,” Cubic Corporation Press Release, August 1, 2012,  https://www.cubic.com/News/Press-Releases/ ID/423/Cubic-Corporation-to-Restate-Financial-Statements.

It’s Not Always BadAUDITING INSIGHT

Collectability of Accounts Receivable In most companies, a portion of accounts receivable will not be collected. GAAP requires the client to provide an estimate of the amount that will likely be uncollectable and pro- vide an allowance for this amount. Estimation of the allowance for doubtful accounts can be subjective and difficult for the client and the auditor. This is particularly true when the client has changed products, credit policies, or its customer base, causing it to have little experience on which to make estimates. Changing economic conditions also make it difficult to estimate collectability. Therefore, valuation is a high risk assertion and the auditor evaluates the reasonableness of the allowance.

Customer Returns and Allowances In most industries, customers have a right to return unused or unsold merchandise. For example, consumers who purchase goods on Amazon.com typically can return the prod- ucts for a full refund. Similarly, most university bookstores can return unsold textbooks to the publisher. When these agreements are in the purchase contract and disclosed to the auditor, an appropriate evaluation of revenue can be performed. However, clients may enter into informal right of return agreements with customers unknown to the auditors. Liabilities for known rights of return, warranties, and other potential obligations are often very difficult to estimate. Companies with new products or technologies have an even higher inherent risk in these areas.

“Cubic Corp. to Restate Financial Statements.” Cubic Corporation Press Release, August 1, 2012, https://www.cubic.com/news-events/ news/cubic-corporation-restate-financial-statements.

“Cubic Corp. to Restate Financial Statements.” Cubic Corporation Press Release, August 1, 2012, https://www.cubic.com/news-events/ news/cubic-corporation-restate-financial-statements.

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INTERNAL CONTROL ACTIVITIES AND DESIGN EVALUATION Recall from the audit risk model that the auditor assesses inherent risk to determine where in the financial statements it is reasonably possible that a material misstatement could enter the process before the consideration of any internal controls. However, recall that risk of material misstatement is the combination of both inherent risk and control risk.

Professional standards require auditors to first gain an understanding of the internal controls that have been designed to mitigate the risk of material misstatement for each relevant assertion identified by the auditor. In a well-designed system, the internal control activity should be explicitly designed to be aligned with this relevant assertion that was identified in a WCGW analysis.

In effect, the question an auditor should ask is, “Has the audit client designed and implemented a control that, if operating effectively, would mitigate the identified risk of material misstatement? Would it prevent or detect the material misstatement?”

Auditors typically achieve an understanding of controls by completing a walkthrough of the processes in the revenue and collection cycle. To do so, the auditor identifies the points in the process where a misstatement might occur and then identifies the control activities that have been placed in operation to mitigate these risks.

Just as the auditor identified existence of accounts receivable as a significant account and relevant assertion and then identified overstatement of accounts receivable through recognition of invalid revenues as a WCGW scenario, the auditor must consider what management can do to prevent this misstatement from entering the financial statements or going undetected. One control that the auditor would expect management to imple- ment involves periodic reconciliation of debits to accounts receivable to sales invoices, customer purchase orders, and shipping documents. If management regularly evalu- ates the validity of recorded accounts receivable, fewer errors can proceed through the accounting system undetected.

Entity-Level Controls in the Revenue and Collections Cycle As discussed in Chapter 5, internal control is a top-down process. Thus, prior to dis- cussing specific control objectives in the revenue cycle in detail, the auditor must con- sider controls at the entity level. As part of the evaluation of internal control, the auditor typically begins in all cycles by considering the entity-level controls in place. Although the control environment is not specific to the revenue cycle, the auditor should always

LO 7-4 Identify important internal control activities present in a properly designed system to mitigate the risk of material misstatements for each relevant assertion in the revenue and collection cycle.

SEC Chair Mary Jo White indicated in 2014 that the SEC had increased enforcement actions on revenue recognition by more than 20 percent as a result of the new FASB revenue recognition standard. The SEC’s director of enforcements, Andrew Ceresney, called revenue recognition “the New Frontier” in enforcements. The increased focus has certainly had an effect as the SEC increased

independent enforcement actions overall from 341 in 2013 to 507 in 2015.

Sources: “Revenue Recognition Changes Could Spur SEC Fraud Probes,” http://ww2.cfo.com/gaap-ifrs/2014/12/revenue-recognition-changes-spur- sec-fraud-probes/; “SEC Announces Enforcement Results for FY 2015,” https:// www.sec.gov/news/pressrelease/2015-245.html.

Watchful EyesAUDITING INSIGHT

REVIEW CHECKPOINTS 7.9  What do we mean by revenue recognition? What does GAAP say about proper revenue recognition? 7.10 Why do you think companies use revenue recognition as a primary means for inflating profits? 7.11 Why is the audit of revenue recognition riskier for a new company?

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consider how control environment risk factors influence the assessment of control risk in the revenue cycle. For example, if the auditor is aware that the audit committee plays an active role in risk oversight, the control environment is significantly enhanced, which reduces the overall likelihood of material misstatement for all assertions. In the revenue process, overall performance review by management can serve as strong entity-level control. Management should have a process for continually reviewing rev- enue and comparing it to budgets and forecasts. Management should also constantly scrutinize total write-offs of accounts receivable, merchandise returns, and the timeli- ness of collections.

Control Considerations at the Account and Assertion Level An initial overall control consideration auditors evaluate is the level of separation of duties in the revenue cycle. By referring to Exhibit 7.1, you can see that proper separa- tion involves different people and different departments performing the sales and credit authorization; custody of goods and cash; and record keeping for sales, receivables, inventory, and cash receipts. Combinations of two or more of these responsibilities in one person, one office, or one computerized system might open the door for undetected errors or fraud.

It is not always possible to have complete separation of duties in a small business with few employees because the benefits of controls do not outweigh the costs involved. How- ever, to obtain reasonable assurance that financial controls are intact when duties are not appropriately separated, the owner must have active involvement in the accounting process—approving credit and discounts, reviewing the aged accounts receivable listing, occasionally opening mail, and preparing bank reconciliations. The owner usually is in direct contact with customers and can ensure that shipments are received. The owner also can follow up on past due accounts.

Exhibit 7.6 describes some of the important control factors that an auditor would con- sider when evaluating the design effectiveness of internal control in the revenue and col- lection cycle.

Perhaps the most important controls in the revenue and collection cycle for many com- panies involve ensuring that revenues are only recorded when the revenue generation process is complete, and ensuring that all revenues that are earned are recorded once and only once. These controls primarily involve the significant accounts of revenue and accounts receivable, and the relevant assertions of occurrence (existence), completeness, and cutoff.

Parker H. “Pete” Petit, spent over 50 years growing companies in the health care industry before retiring. After retirement, he felt a call- ing to come back and decided to make one more run at building up and selling a health care company, in this case MiMedx, a maker of skin grafts. However, the 80-year old CEO saw his career end with allegations of a massive revenue fraud and a federal case brought by the United States Department of Justice (DOJ) and Securities and Exchange Commission (SEC).

The 2019 SEC lawsuit alleges that MiMedx used both creative and tried and true methods of revenue manipulation to make earn- ings estimates in at least the last three quarters of 2015. MiMedx used the well-known fraudulent practice of channel stuffing—pushing out product to distributors for the sole purpose of recognizing revenue, without any real order. Further, the company is accused of offering

distributors a full right of return without adjusting revenue for this possibility.

The scheme seems traditional and simple, until you consider that the company’s product, skin grafts, are time-sensitive and per- ishable. To overcome this obstacle, Petit and COO William C. Taylor are accused of forming shell companies to purchase refrigerators for distributors to maintain the skin grafts! They also are accused of funneling loans to distributors through family-owned busi- nesses to help pay for the fraudulent product. Both Petit and Taylor deny all charges and the case is currently pending in the federal court system.

Sources: “SEC Charges MiMedx and ex-CEO with Accounting Fraud,” Account- ing Today, November 27, 2019; “Parker H. ‘Pete’ Petit Responds to Charges by the DOJ/SEC,”Businesswire.com, November 26, 2019.

An Unhealthy Way to Go OutAUDITING INSIGHT

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EXHIBIT 7.6 Internal Control Activities in the Revenue and Collection Cycle

Significant Account Relevant Assertions What Could Go Wrong? Internal Control Activity

Revenue Occurrence Management may overstate sales by adding fictitious transactions or inflating actual sales.

Invoices are supported by customer purchase orders. Bill of lading or other shipping documents exist for all invoices, and recorded sales in the Sales Revenue account file are supported by invoices.

Invoices, shipping documents, and sales orders are prenumbered, and the numerical sequence is checked.

Management may fail to recognize the possibility of customer returns.

Management analyzes sales returns regularly and estimates an allowance for returns.

Completeness Not all sales are recorded. Invoices, shipping documents, and sales orders are prenumbered, and the numerical sequence is checked.

Cutoff Sales have been recorded in incorrect periods.

The date of shipping document is compared to the invoice date. Management evaluates all new contracts to ensure revenue recognition compliance with ASC 606.

Accounts Receivable Existence Accounts receivable are overstated and do not represent amounts from actual sales.

Check the sales order and shipping document to make sure sales were earned and a customer owes a balance.

Completeness Not all accounts receivable have been recorded.

Check invoices with the shipping document to the A/R ledger.

Valuation Receivables are not included in financial statements at the appropriate amount, and the uncollectible portion of the balance is not properly estimated.

Authorize and record discounts when customers take them. Management evaluates the collectability of delinquent receivables on a timely basis.

System-generated reports are commonly used by audit clients in the revenue cycle to help ensure the appropriate timing for revenue to be recognized. For example, the three-way match internal control activity described above is nearly always entirely automated. In SAP, a widely used financial accounting and reporting software, a weekly exception

report is produced by the system for any exceptions for the three-way match that may exist. In a sense, the actual control activity implemented by the client is the follow-up to the weekly system generated report. Management evaluates all exceptions to the three-way match and then verifies that the appropriate amount of revenue has been recorded.

System-Generated Reports in the Revenue Cycle

AUDITING INSIGHT

A primary control in the revenue cycle is ensuring that revenue is only recorded when a complete set of matched sales documents is present. A three-way match of a customer sales order, evidence of shipment, and a customer invoice provides strong evidence that a sale has been completed and a revenue has been earned. By requiring all three documents to be present before recording a revenue, a company reduces the risk of overstating rev- enues and accounts receivable, providing assurance related to the existence of accounts receivable, and the occurrence of revenue.

Similarly, by ensuring that all three of these primary sales documents are prenum- bered, and the numerical sequence is checked, the company can ensure the completeness of recorded revenue and accounts receivable. Verifying the dates on the documents helps reduce risk of misstatement related to the cutoff assertion of revenue.

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The valuation assertion of accounts receivable is also a relevant assertion in the reve- nue cycle. Because collectability problems can be addressed prior to making a sale, com- panies should have controls in place to ensure that all credit sales are authorized based on a credit limit in the customer master file. Further, collectability of delinquent receivables should be considered on a regular basis, and management should regularly evaluate the adequacy of allowances for sales returns and discounts.

In addition to the critical controls discussed previously and in Exhibit 7.6, the follow- ing control activities should generally be in place to prevent and detect errors or fraud:

∙ Access to inventory and the shipping area should be restricted to authorized persons. ∙ Access to billing terminals and blank invoice forms should be restricted to authorized

personnel. ∙ Care should be taken to record sales and receivables as of the date the goods were

shipped and the cash receipts on the date the payments were received. ∙ Customer invoices should be compared with bills of lading and customer orders to

determine that the customer is sent the goods ordered at the proper location for the proper prices and that the quantity being billed is the same as the quantity shipped.

∙ Pending order files should be reviewed frequently to avoid failure to bill and record shipments.

Finally, procedures must be in place to ensure that errors noted by these steps are properly corrected. An error control log monitored by the information systems supervisor ensures that this is done. Such a log may aid in the identification of patterns that indicate either control weaknesses or possible fraudulent activities. This documentation and sub- sequent action is part of the information and communications aspect of internal controls.

Information about a company’s controls often is gathered by completing an internal control questionnaire. Questionnaires for both manual controls and computerized con- trols over the revenue and collection cycle are in Appendix 7A. You can study these ques- tionnaires for details of desirable control activities. They are organized under headings that address the assertions regarding classes of transactions. Auditors should also per- form a walkthrough to verify that they understand each of the process activities. The rev- enue and collection cycle walkthrough involves following a sale from the initial customer order through credit approval, billing, and delivery of goods to the entry in the sales journal and subsidiary accounts receivable records and then its subsequent collection and cash deposit to ensure that the sale and related transactions are accurately reflected in the financial statements.

REVIEW CHECKPOINTS 7.12 What are the primary control procedures to ensure completeness of recorded revenues? 7.13 The primary control procedure to ensure the occurrence of revenues requires which three docu-

ments to be matched prior to recording sales revenue? 7.14 What effect do entity level controls have on the control risk assessments of an auditor?

TESTS OF OPERATING EFFECTIVENESS OF INTERNAL CONTROL In order to rely on the design of the client’s internal controls and support a reduction in control risk, the auditor must determine if the control is operating as designed and whether the person operating the control has the authority and competence to do so. The auditor’s ultimate responsibility is to document enough support to conclude whether the control activity was operating effectively to mitigate the risk of material misstatement for the assertion.

LO 7-5 Give examples of tests of controls to verify the operating effectiveness of internal controls in the revenue and collection cycle.

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Auditors can perform tests of controls to determine whether company personnel are properly performing controls that are said to be in place. In general, the procedures used in tests of controls are client inquiry, observation, inspection of documents and records, reperformance, and walkthroughs. Understand that if a control is missing or ineffective, the risk of a material misstatement increases, but an error or fraud is by no means certain. For example, a person with both recordkeeping and custody of inventory has incompatible duties, but if that person is diligent and honest, no errors or frauds may exist. If controls are not in place or personnel in the organization are not performing their control activities effectively, auditors need to design substantive procedures to try to detect whether control failures have produced material misstatements in the financial statements.

Exhibit 7.7 begins with the internal control activities related to the significant accounts and relevant assertions in the revenue cycle and suggests auditor tests of controls that may be performed to support a reduction in control risk.

To be effective, auditor tests of control in the revenue cycle must be performed using dual- direction tests of controls. Exhibit 7.8 demonstrates how an auditor performs tests of control to assess control risk for both the occurrence assertion and the completeness assertion.

To verify that the client’s required three-way match is in effect and operating appro- priately to ensure the occurrence assertion, the auditor will select a sample of recorded sales from the sales journal and vouch the sales to supporting customer invoices, ship- ping documents, and customer purchase orders. The availability of electronic client data and audit software sometimes enables auditors to perform exception testing on the entire population of sales and identify any instances where the three-way match did not occur. The auditor can then directly address the specific situations where exceptions occurred and make a more accurate assessment of control risk.

To complete the dual-direction test, the auditor performs tests of control in the com- pleteness direction. Because shipment of goods is the event that generally leads to earned revenue, the auditor will select a sample of shipping documents and trace the documents to sales invoices and postings in the sales journal. This assures the auditor that goods shipped were invoiced and posted. The auditor will also scan data files for numerical sequence and will observe the client checking numerical sequence of shipping documents and invoices. Note, if the auditor can obtain the sales journal in electronic form, audit software (e.g., IDEA) can be employed to check the numerical sequence and duplication of invoice numbers.

One thing you may note is that these tests of controls described above also are gath- ering evidence on the assertions in the account balances. The audit processes to gather evidence on the assertions in account balances are called substantive procedures. Sub- stantive procedures differ from tests of controls in their basic purpose. Substantive procedures are designed to obtain direct evidence about the dollar amounts in account balances, while tests of controls are designed to obtain evidence about the company’s performance of its own control activities. Sometimes an audit procedure can be used for both purposes, and when it is, it is called a dual-purpose procedure. When the auditor tests the controls surrounding three-way matches of customer orders, shipping documents, and invoices, the items directly tested provide both evidence on controls and on the relevant assertions. Thus, these tests related to controls surrounding occurrence and completeness of revenues can be used as dual-purpose procedures.

To test the client’s controls related to the valuation assertion, the auditor will discuss procedures with the credit manager and examine credit file documentation for evidence of regular evaluation of credit limits and follow-up on delinquent accounts. The auditor will also examine evidence of credit approval prior to shipment for a sample of sales.

In addition to the critical controls discussed previously and in Exhibit 7.6, the auditor might also perform other tests of controls related to assertions in the revenue cycle, such as

∙ Completeness of revenue and accounts receivable—Examine evidence of client review and follow-up of sales data related to specific classes of products or locations.

∙ Accuracy of revenue and accounts receivable—Vouch prices to approved price listing.

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EX H

IB IT

7 .7

  Te

st s

of C

on tr

ol s

in R

ev en

ue a

nd C

ol le

ct io

n C

yc le

Si gn

ifi ca

nt A

cc ou

nt Re

le va

nt A

ss er

tio ns

W ha

t C ou

ld G

o W

ro ng

/R is

k of

M

at er

ia l M

is st

at em

en t

In te

rn al

C on

tr ol

A ct

iv ity

(M iti

ga te

R is

k) Te

st o

f I nt

er na

l C on

tr ol

Re ve

nu e

Oc cu

rre nc

e M

an ag

em en

t m ay

o ve

rs ta

te s

al es

by

a dd

in g

fic tit

io us

tr an

sa ct

io ns

o r

in fla

tin g

ac tu

al s

al es

.

In vo

ic es

a re

s up

po rte

d by

c us

to m

er p

ur ch

as e

or de

rs . B

ill o

f l ad

in g

or o

th er

s hi

pp in

g do

cu m

en ts

e xi

st fo

r a ll

in vo

ic es

, a nd

re co

rd ed

sa

le s

in th

e Sa

le s

Re ve

nu e

ac co

un t f

ile a

re

su pp

or te

d by

in vo

ic es

.

Vo uc

h sa

le s

in s

al es

d et

ai l f

ile to

in vo

ic es

, su

pp or

tin g

sh ip

pi ng

d oc

um en

ts , a

nd c

us to

m er

pu

rc ha

se o

rd er

s fo

r c us

to m

er n

am e,

p ro

du ct

de

sc rip

tio n,

te rm

s, d

at es

, a nd

q ua

nt iti

es .

M an

ag em

en t m

ay fa

il to

re co

gn ize

th e

po ss

ib ili

ty o

f c us

to m

er re

tu rn

s. M

an ag

em en

t a na

ly ze

s sa

le s

re tu

rn s

re gu

la rly

an

d es

tim at

es a

n al

lo w

an ce

fo r r

et ur

ns .

In sp

ec t d

oc um

en ts

fo r e

vi de

nc e

th at

m

an ag

em en

t e va

lu at

es th

e al

lo w

an ce

fo r

re tu

rn s

re gu

la rly

.

Co m

pl et

en es

s No

t a ll

sa le

s ar

e re

co rd

ed .

In vo

ic es

, s hi

pp in

g do

cu m

en ts

, a nd

s al

es

or de

rs a

re p

re nu

m be

re d,

a nd

th e

nu m

er ic

al

se qu

en ce

is c

he ck

ed .

Sc an

d oc

um en

ts fo

r n um

er ic

al s

eq ue

nc e,

ob

se rv

e cl

ie nt

-c he

ck in

g se

qu en

ce , a

nd tr

ac e

sh ip

pi ng

d oc

um en

t t o

re co

rd in

g in

s al

es d

et ai

l fil

e.

Cu to

ff Sa

le s

ha ve

b ee

n re

co rd

ed in

in co

rre ct

pe

rio ds

. Da

te o

f s hi

pp in

g do

cu m

en t i

s co

m pa

re d

to

in vo

ic e

da te

. M

an ag

em en

t e va

lu at

es a

ll ne

w c

on tra

ct s

to

en su

re re

ve nu

e re

co gn

iti on

c om

pl ia

nc e

w ith

AS

C 60

6.

Tr ac

e sh

ip pi

ng d

at a

on s

hi pp

in g

do cu

m en

ts

w ith

s al

es in

vo ic

e da

te , a

nd c

he ck

F OB

te rm

s.

In sp

ec t d

oc um

en ts

fo r e

vi de

nc e

th at

m

an ag

em en

t e va

lu at

es th

e tim

in g

of re

ve nu

e re

co gn

iti on

fr om

c on

tra ct

s.

Ac co

un ts

R ec

ei va

bl e

Ex ist

en ce

Ac co

un ts

re ce

iv ab

le a

re o

ve rs

ta te

d an

d do

n ot

re pr

es en

t a ct

ua l s

al es

. Ch

ec k

sa le

s or

de r a

nd s

hi pp

in g

do cu

m en

ts to

m

ak e

su re

s al

es w

er e

ea rn

ed a

nd a

c us

to m

er

ow es

a b

al an

ce .

W he

n pa

ym en

ts a

re re

ce iv

ed , v

ou ch

c he

ck s

lis te

d on

s am

pl e

de po

sit s

lip s

to th

e cu

st om

er

cr ed

its li

st ed

o n

th e

da y’

s po

st in

g to

c us

to m

er

ac co

un ts

re ce

iv ab

le .

Co m

pl et

en es

s No

t a ll

ac co

un ts

re ce

iv ab

le h

av e

be en

re

co rd

ed .

Ch ec

k in

vo ic

es w

ith s

hi pp

in g

do cu

m en

t t o

A/ R

le dg

er .

In sp

ec t d

oc um

en ts

fo r e

vi de

nc e

th at

th e

Bi lli

ng

de pa

rtm en

t s up

er vi

so r m

at ch

es p

re nu

m be

re d

sh ip

pi ng

d oc

um en

ts w

ith e

nt rie

s in

th e

sa le

s jo

ur na

l.

Va lu

at io

n Re

ce iv

ab le

s ar

e no

t i nc

lu de

d in

fin

an ci

al s

ta te

m en

ts a

t t he

a pp

ro pr

ia te

am

ou nt

, a nd

th e

un co

lle ct

ib le

po

rti on

o f t

he b

al an

ce is

n ot

p ro

pe rly

es

tim at

ed .

Au th

or ize

a nd

re co

rd d

isc ou

nt s

w he

n cu

st om

er s

ta ke

th em

. In

sp ec

t d oc

um en

ta tio

n fo

r e vi

de nc

e th

at

su bs

eq ue

nt c

as h

re ce

ip ts

fr om

th e

cu st

om er

ar

e re

vi ew

ed . I

nq ui

re o

f t he

c re

di t m

an ag

er

pr oc

ed ur

es re

ga rd

in g

un pa

id a

cc ou

nt s.

In sp

ec t

cr ed

it fil

es fo

r m os

t r ec

en t r

ev ie

w o

f c us

to m

er

cr ed

itw or

th in

es s.

M an

ag em

en t e

va lu

at es

th e

co lle

ct ab

ili ty

o f

de lin

qu en

t r ec

ei va

bl es

o n

a tim

el y

ba sis

. In

sp ec

t d oc

um en

ta tio

n fo

r e vi

de nc

e th

at

m an

ag em

en t e

va lu

at es

th e

co lle

ct ab

ili ty

o f

re ce

iv ab

le s.

First Pages

Chapter 7 Revenue and Collection Cycle 287

lou6920x_ch07_269-327.indd 287 03/17/20 03:59 PM

Clearly, a first line of defense against accounting fraud is to ensure that everyone is control conscious—unless you work at NutraCea. Nutra- Cea faked a $2.6 million sale in the second quarter of 2007 and a $1.9 million deal later that year. These deals made it look like the com- pany had met its sales forecast when, in fact, it had not. The Securities

and Exchange Commission alleges the fraud was so blatant that one executive, when told about the accounting problems by a colleague, covered his ears and said, “No, no, no, no, I don’t want to hear it.” Source: “NutraCea Ex-Execs Accused of Fraud,” Arizona Business & Money, January 15, 2011.

Is Everyone Control Conscious?AUDITING INSIGHT

∙ Accuracy of revenue—Observe client comparing shipping quantities to quantities recorded as sold. Examine evidence of client making the comparison.

∙ Cutoff of revenue—Trace shipping date on shipping documents to sales invoice date. Check FOB terms.

∙ Classification of accounts receivable—Trace posting of intercompany sales, sales returns, etc., to sales.

When a business receives many cash or check payments from customers on an account, a detailed audit should include a comparison of the checks listed on a sample of deposit slips to the customer credits listed on the day’s posting to customer accounts receivable (daily remittance list or other record of detail postings). This procedure is a test for accounts receivable fraud—also known as lapping (see Chapter 6). Auditors look for credits given to customers for whom no payments were received on the day in question.

See Appendix Exhibit 7B.1 for a test of controls audit plan. These steps are designed to direct the audit team in obtaining sufficient appropriate evidence about the effective- ness of controls and about the reliability of accounting records. Thus, the tests of controls produce evidence that helps auditors determine whether the specific control was properly designed and is operating effectively.

Summary: Control Risk Assessment Auditors must evaluate the evidence obtained from their understanding of internal con- trol and from tests of controls. The initial process of obtaining an understanding of the company’s controls and the later process of obtaining evidence from actual tests of con- trols are two of the phases of control risk assessment. If the control risk is assessed to be very low, the substantive procedures on the account balances can be reduced, resulting in audit efficiencies. For example, the accounts receivable confirmations can be sent on a date prior to the year-end, and the sample size can be small.

On the other hand, if tests of controls reveal weaknesses (such as posting sales with- out shipping documents, charging customers the wrong prices, or recording credits to

Did all recorded sales actually occur?

Vouch sample of invoices to

shipping documents (occurrence)

Trace sample of shipping documents to invoices (completeness)

Sales Invoice File (Journal)

Shipping Documents

Were all shipments invoiced?

EXHIBIT 7.8

First Pages

288 Part Two The Financial Statement Audit

lou6920x_ch07_269-327.indd 288 03/17/20 03:59 PM

REVIEW CHECKPOINTS 7.15 What specific control procedures (in addition to separation of duties and responsibilities) should

be in place and operating in internal controls governing revenue recognition? 7.16 What is a walkthrough of a sales transaction? How can the walkthrough work complement the use

of an internal control questionnaire? 7.17 What types of audit procedures are typically performed in testing operating effectiveness of con-

trols over the revenue and collection cycle? 7.18 What is dual-direction test of controls sampling in the revenue and collection cycle?

customers without supporting documentation), the substantive procedures need to be designed to lower the risk of failing to detect material misstatement in the account bal- ances (detection risk). For example, the confirmation procedure may need to be sched- uled on the year-end date with a large sample of customer accounts.

SUBSTANTIVE ANALYTICAL PROCEDURES AND TESTS OF DETAILS As you have learned previously while studying audit risk, the primary reason for evaluat- ing the internal control system at an audit client is to reach an overall assessment of the risk of material misstatement for each relevant assertion. In fact, the assessment of the risk of material misstatement is completed to help form the basis for determining the nature, timing, and extent of substantive testing. Risk of material misstatement at the assertion level is comprised of both inherent risk and control risk for each relevant assertion.

If inherent risk has already been assessed as high, this means there is high suscep- tibility for this account to be misstated. Recall that control risk is the “probability that an entity’s controls will fail to prevent or detect material misstatements due to errors or frauds.” Because the revenue cycle consists of routine transactions, the majority of audit clients have strong controls in the revenue cycle, and thus tests of controls often support a reduction in control risk. This reduction in control risk reduces the auditor’s assessment of the risk of material misstatement in the revenue cycle.

However, auditing standards also indicate that there is a presumptive risk of fraud in the revenue cycle. Further, according to professional standards, “for significant risks, the auditor should perform substantive procedures, including tests of details, that are specifically responsive to the assessed risks”* (AS 2301, para. 11). Because revenue is a presumptive high-fraud risk and an overall significant risk, the auditor always performs substantive procedures in the revenue cycle. These procedures are classified as substan- tive analytical procedures and substantive tests of details.

A substantive analytical procedure is one in which the auditor substantiates an account or disclosure by developing an independent estimate of the amount and then comparing the recorded balance to the estimate. As we will discuss later in this chapter, the evalua- tion of the accounting estimate for the allowance for doubtful accounts generally involves an analytical review of the adequacy of the provision for bad debt expense.

A substantive test of details is one in which the auditor substantiates an account or disclosure by directly testing the transactions that make up the account or the items that constitute the balance of the account. For example, auditors will generally send confirma- tions to customers to substantiate the existence and rights and obligations assertions of accounts receivable.

Exhibit 7.9 presents common substantive tests that are performed to address remaining risks of material misstatement related to the significant accounts and relevant assertions in the revenue cycle.

LO 7-6 Give examples of substantive procedures in the revenue and collection cycle and relate them to assertions about significant account balances at the end of the period.

“AS 2301: The Auditor’s Responses to the Risks of Material Misstatement, para. 11.” PCAOB, Dec. 15, 2010.

First Pages

289

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EX H

IB IT

7 .9

  Su

bs ta

nt iv

e P

ro ce

du re

s in

th e

R ev

en ue

a nd

C ol

le ct

io n

C yc

le

Si gn

ifi ca

nt

Ac co

un t

Re le

va nt

A ss

er tio

ns W

ha t C

ou ld

G o

W ro

ng ?

In te

rn al

C on

tr ol

A ct

iv ity

(M

iti ga

te R

is k)

Te st

o f I

nt er

na l C

on tr

ol Po

ss ib

le S

ub st

an tiv

e An

al yt

ic al

P ro

ce du

re s

Po ss

ib le

S ub

st an

tiv e

Te st

s of

D et

ai l

Re ve

nu e

Oc cu

rre nc

e M

an ag

em en

t m ay

o ve

rs ta

te

sa le

s by

a dd

in g

fic tit

io us

tra

ns ac

tio ns

o r i

nf la

tin g

ac tu

al

sa le

s.

In vo

ic es

a re

s up

po rte

d by

cu

st om

er p

ur ch

as e

or de

rs .

Bi ll

of la

di ng

o r o

th er

s hi

pp in

g do

cu m

en ts

e xi

st fo

r a ll

in vo

ic es

, a nd

re co

rd ed

s al

es in

th

e Sa

le s

Re ve

nu e

ac co

un t f

ile

ar e

su pp

or te

d by

in vo

ic es

.

Vo uc

h sa

le s

in s

al es

d et

ai l

fil e

to in

vo ic

es , s

up po

rti ng

sh

ip pi

ng d

oc um

en ts

, an

d cu

st om

er p

ur ch

as e

or de

rs fo

r c us

to m

er n

am e,

pr

od uc

t d es

cr ip

tio n,

te rm

s,

da te

s, a

nd q

ua nt

iti es

.

Co m

pa re

a ss

et a

nd

re ve

nu e

ba la

nc es

w ith

re

ce nt

h ist

or y t

o he

lp d

et ec

t ov

er st

at em

en ts

. S al

es

ra tio

s c an

b e

co m

pa re

d to

hi

st or

ica l d

at a

an d

in du

st ry

st

at ist

ics fo

r e vid

en ce

o f

ov er

al l r

ea so

na bl

en es

s.

Vo uc

h jo

ur na

l e nt

ry , s

al es

su

m m

ar y,

sa le

s i nv

oi ce

co

py , s

hi pp

in g

do cu

m en

ts ,

an d,

fi na

lly , t

he cu

st om

er ’s

pu rc

ha se

o rd

er .

M an

ag em

en t m

ay fa

il to

re

co gn

ize th

e po

ss ib

ili ty

o f

cu st

om er

re tu

rn s.

M an

ag em

en t a

na ly

ze s

sa le

s re

tu rn

s re

gu la

rly a

nd e

st im

at es

an

a llo

w an

ce fo

r r et

ur ns

.

In sp

ec t d

oc um

en ts

fo r

ev id

en ce

th at

m an

ag em

en t

ev al

ua te

s th

e al

lo w

an ce

fo

r r et

ur ns

re gu

la rly

.

Ob ta

in a

s um

m ar

y of

s al

es

re tu

rn s

su bs

eq ue

nt to

ye

ar -e

nd , a

nd e

va lu

at e

th e

ad eq

ua cy

o f t

he

al lo

w an

ce .

Se le

ct a

s am

pl e

of s

al es

re

tu rn

s su

bs eq

ue nt

to

ye ar

-e nd

, a nd

tr ac

e to

pr

op er

c ha

rg in

g ag

ai ns

t th

e al

lo w

an ce

a cc

ou nt

.

Co m

pl et

en es

s No

t a ll

sa le

s ar

e re

co rd

ed .

In vo

ic es

, s hi

pp in

g do

cu m

en ts

, an

d sa

le s

or de

rs a

re

pr en

um be

re d,

a nd

th e

nu m

er ic

al s

eq ue

nc e

is ch

ec ke

d.

Sc an

d oc

um en

ts fo

r nu

m er

ic al

s eq

ue nc

e,

ob se

rv e

cl ie

nt -c

he ck

in g

se qu

en ce

, a nd

tr ac

e sh

ip pi

ng d

oc um

en t t

o re

co rd

in g

in s

al es

d et

ai l

fil e.

Co m

pa re

c ur

re nt

y ea

r’s

sa le

s to

la st

y ea

r’s s

al es

by

g eo

gr ap

hi c

lo ca

tio n.

Se le

ct sa

m pl

es o

f s hi

pp in

g do

cu m

en ts

, a nd

tr ac

e to

sa

le s i

nv oi

ce a

nd th

e sa

le s

jo ur

na l.

Cu to

ff Sa

le s

ha ve

b ee

n re

co rd

ed in

in

co rre

ct p

er io

ds .

Th e

da te

o f s

hi pp

in g

do cu

m en

t is

co m

pa re

d to

th e

in vo

ic e

da te

.

Tr ac

e sh

ip pi

ng d

at e

on

sh ip

pi ng

d oc

um en

ts to

sa

le s

in vo

ic e

da te

, a nd

ch

ec k

FO B

te rm

s.

Co m

pa re

p rio

r y ea

r’s s

al es

in

s am

e m

on th

to c

ur re

nt

ye ar

’s sa

le s

in s

am e

m on

th .

Tr ac

e sh

ip pi

ng d

oc um

en ts

be

fo re

a nd

a fte

r y ea

r-e nd

to

th e

sa le

s j ou

rn al

to e

ns ur

e th

e sa

le w

as re

co rd

ed in

th

e pr

op er

p er

io d,

cr ed

it

m em

os fo

r r et

ur ns

a fte

r ye

ar -e

nd a

re vo

uc he

d to

re

ce ivi

ng re

po rts

, a nd

a ny

go

od s r

et ur

ne d

af te

r y ea

r- en

d th

at w

er e

so ld

d ur

in g

th e

ye ar

b ei

ng a

ud ite

d ha

ve

be en

d ed

uc te

d fro

m sa

le s.

M an

ag em

en t e

va lu

at es

a ll

ne w

co

nt ra

ct s

to e

ns ur

e re

ve nu

e re

co gn

iti on

c om

pl ia

nc e

w ith

AS

C 60

6.

In sp

ec t d

oc um

en ts

fo r

ev id

en ce

th at

m an

ag em

en t

ev al

ua te

s th

e tim

in g

of

re ve

nu e

re co

gn iti

on fr

om

co nt

ra ct

s.

In sp

ec t l

ic en

sin g

co nt

ra ct

s an

d pr

ep ar

e do

cu m

en ta

tio n

m em

o ev

al ua

tin g

re ve

nu e

re co

gn iti

on in

a cc

or da

nc e

w ith

F AS

B AS

C 60

6 Co nt

in ue

d

First Pages

290

lou6920x_ch07_269-327.indd 290 03/17/20 03:59 PM

Si gn

ifi ca

nt

Ac co

un t

Re le

va nt

A ss

er tio

ns W

ha t C

ou ld

G o

W ro

ng ?

In te

rn al

C on

tr ol

A ct

iv ity

(M

iti ga

te R

is k)

Te st

o f I

nt er

na l C

on tr

ol Po

ss ib

le S

ub st

an tiv

e An

al yt

ic al

P ro

ce du

re s

Po ss

ib le

S ub

st an

tiv e

Te st

s of

D et

ai l

Ac co

un ts

Re

ce iv

ab le

Ex ist

en ce

Ac co

un ts

re ce

iv ab

le a

re

ov er

st at

ed a

nd d

o no

t re

pr es

en t a

ct ua

l s al

es .

Ch ec

k sa

le s

or de

r a nd

sh

ip pi

ng d

oc um

en t t

o m

ak e

su re

s al

es w

er e

ea rn

ed a

nd a

cu

st om

er o

w es

a b

al an

ce .

W he

n pa

ym en

ts a

re

re ce

iv ed

, v ou

ch c

he ck

s lis

te d

on s

am pl

e de

po sit

sli

ps to

th e

cu st

om er

cr

ed its

li st

ed o

n th

e da

y’ s

po st

in g

to c

us to

m er

ac

co un

ts re

ce iv

ab le

.

Co m

pa re

p rio

r y ea

r’s A

/R

ba la

nc e

in re

la tio

n to

sa

le s

w ith

c ur

re nt

y ea

r’s

A/ R

ba la

nc e

in re

la tio

n to

sa

le s.

Co nf

irm a

cc ou

nt s

re ce

iv ab

le s

en t t

o ba

nk .

Co m

pl et

en es

s No

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When considering relevant assertions and obtaining evidence about accounts receiv- able and other assets, auditors must emphasize the existence assertion. This emphasis on existence is appropriate because a large number of restatements of reports on financial statements involve overstated assets and revenues. When credit sales are recorded too early or fictitious sales are posted, this results in overstated accounts receivable and over- stated sales revenue.

Discerning the population of assets to audit for existence is easy because the company has asserted their existence by putting them on the balance sheet. Despite the general presence of strong controls, obtaining substantive evidence supporting the existence of accounts receivable is required in audits where receivables are material. The auditor typi- cally obtains evidence about the existence of accounts receivable through a combination of analytical procedures and confirmations.

Revenue restatements can often take a long time to detect. In fact, sometimes restatements that resulted from errors and misapplica- tions, as opposed to fraud, can persist for a long period of time. Con- sider the case of Alphabet Inc., the parent company of Google. During 2015, Alphabet discovered that they had inappropriately accounted for revenues related to transactions between “legal entities” since 2008! The net result of the error was an increased income tax expense of $711 million.

According to Audit Analytics, Alphabet’s restatement was the larg- est restatement of the year. However, Alphabet determined that the amount was “immaterial” and did not separately disclose the restate- ment outside of their annual report. Nevertheless, the $711 million restatement was 0.9% of total revenues and 4.3% of net income, an amount auditors would often consider material.

Sources: Alphabet Inc. 2015 Annual Report, p. 21; Audit Analytics, 2017 Financial Restatements: A Seventeen Year Comparison, May 2018.

It Takes a Long Time to Catch It. . .AUDITING INSIGHT

Analytical Procedures During an audit, a variety of analytical procedures might be employed, depending on the circumstances and the nature of the business. Comparisons of asset and revenue balances with recent history might help detect overstatements. Such relationships as receivables turnover, days’ sales in receivables, amount of past due receivables, gross margin ratio, and sales/asset ratios can be compared to historical data and industry statistics for evidence of overall reasonableness. Account interrelationships also can be used in analytical procedures. For example, sales returns and allowances and sales commissions generally vary directly with dollar sales volume, bad debt expense usu- ally varies directly with credit sales, and freight expense varies with the physical sales volume. Accounts receivable write-offs may also be compared with estimates of doubtful accounts.

The auditors for one company prepared a schedule of the monthly credit sales totals for the current and prior years. They noticed sev- eral variations, but one in November of the current year stood out in particular. The current-year credit sales were almost twice as large as

in any prior November. Further investigation showed that a computer error had caused the November credit sales to be recorded twice in the control accounts. The accounts receivable and sales revenue were materially overstated as a result.

Simple Analytical ComparisonAUDITING INSIGHT

Confirmation of Accounts and Notes Receivable In general, the use of confirmations for accounts receivable is considered a required audit procedure by audit standards. If auditors decide not to use them, the burden of proof is on

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the auditors to justify their position. Auditors should document justifications for the deci- sion not to use confirmations for accounts receivable in a particular audit. Justifications might include (1) receivables are not material; (2) confirmations would be ineffective, based on prior-years’ experience or knowledge that responses could be unreliable; and (3) analytical procedures and other substantive procedures provide sufficient, competent evidence.

Sureparts Manufacturing Company sold all its production to three auto manufacturers and six aftermarket distributors. All nine of these customers typically paid their accounts in full by the 10th of each following month. The auditors were able to vouch the cash receipts for the full amount of the accounts receivable

in the bank statements and cash receipts records in the month following the Sureparts year-end. Confirmation evidence was not necessary in these circumstances because direct evidence of pay- ment provided full verification of the existence and valuation of the receivables.

A Decision Not to Use Accounts Receivable Confirmations

AUDITING INSIGHT

Confirmations provide evidence of existence as well as rights and obligations of accounts and notes receivable. However, they do not provide strong evidence on the valua- tion of accounts receivable. Remember that just because a customer owes an amount does not mean it will pay that amount. Customers in bankruptcy routinely confirm amounts owed, although the receivable’s value may be only a small fraction of that amount. The accounts to be confirmed are often documented with an aged trial balance. (An aged trial balance annotated to show the auditors’ work is shown in Exhibit 7.10.) Accounts for confirmation can be selected at random or in accordance with another sampling method consistent with the audit objectives. Statistical methods may be useful for determining the sample size. Audit software such as IDEA is often used to access receivables files, select, and even print the confirmations.

Unlike cash confirmations, which as described in Chapter 6 are almost always elec- tronic, accounts receivable confirmations are still largely manual. The primary reason is that most confirmation intermediaries, such as Confirmation, require the registra- tion and authentication of respondents. Unlike banks, which respond to confirmations for the majority of their larger business customers, other companies and individu- als do not receive many, if any, confirmation requests. As a result, the customers of most audit clients would not have the ability to securely authenticate and respond to electronic confirmations without a great deal of effort—which they may choose not to exert.

There are two primary methods of confirming accounts receivable: positive con- firmations and negative confirmations. A positive confirmation asks the customer to respond as to whether the balance is correct or incorrect. See Exhibit 7.11 for an example of a positive confirmation. A variation of the positive confirmation is the blank form. A blank confirmation does not contain the balance; customers are asked to fill it in themselves. The blank positive confirmation may produce better evidence because the recipients need to get the information directly from their own records instead of just signing the form and returning it with no exceptions noted. (How- ever, the effort involved on the part of the recipient may cause a lower response rate.) As illustrated in several of the Auditing Insights, the auditors must follow up on all exceptions. For example, they may choose to examine the bank deposit that includes a check mentioned by the customer. The reason for any discrepancy will have to be investigated by the client, and the audit team will examine corroborative evidence of the client’s resolution.

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EXHIBIT 7.11 Positive Confirmation Form

Bullseye 1359 Central Boulevard Derma, MS 39530 Attn: Accounts Payable Dept..

Our auditor, M. Chael Smith, is making his regular audit of our financial statements. Part of this audit includes direct verification of customer balances.

PLEASE EXAMINE THE DATA BELOW CAREFULLY AND EITHER CONFIRM ITS ACCURACY OR REPORT ANY DIFFERENCES DIRECTLY TO OUR AUDITORS USING THE ENCLOSED REPLY ENVELOPE.

This is not a request for payment. Please do not send your remittance to our auditors.

Your prompt attention to this request will be appreciated.

Samuel Carboy, Controller

The balance due Dunder-Mi�in Inc. as of December 31, 2020, is $1,013,239.57

This balance is correct except as noted below:

Date: By: Title:

Dunder-Mi�in Inc. Scranton, PA

C-2

See Exhibit 7.12 for the negative confirmation form for the same request in Exhibit 7.11. The positive form asks for a response. The negative form asks for a response only if some- thing is wrong with the balance; thus, lack of response to negative confirmations is con- sidered evidence that the account is fairly stated.

The positive form is by far the more common and is used when individual balances are relatively large or when accounts are in dispute. Positive confirmations generally ask for information about the entire account balance as of a specific date. However, when customers are less likely to be able to respond to entire account balances, auditors may confirm specific invoices. The negative form is used mostly when the risk of material misstatement is considered low, when a large number of small balances is involved, and when the client’s customers can be expected to consider the confirmations properly. Auditors must use these confirmations with great care. Occasionally, they use both forms by sending positive confirmations on some (large) customers’ accounts and negative con- firmations on others (usually smaller account balances).

Getting confirmations delivered to the intended recipient requires auditors’ care- ful attention. Auditors need to control the mailing of the confirmations, including the

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addresses to which they are sent, and the confirmations should be returned directly to the auditors. The confirmations should normally be addressed to the customer’s accounts payable department. There have been cases in which confirmations were mailed to com- pany accomplices, who provided false responses. The auditors should carefully consider features of the reply, such as postmarks, fax and telephone responses, letterhead, e-mail, or other characteristics that may indicate a false response. Auditors should follow up on electronic and telephone responses to determine their origin (e.g., returning the tele- phone call to a known number, looking up telephone numbers to determine addresses, or using a directory to determine the location of a respondent). On the other hand, an electronic confirmation process (e.g., confirmation.com) that creates a secure confirma- tion environment may mitigate the risks of human intervention and misdirection. For example, encryption, electronic digital signatures, and procedures to verify website authenticity may improve the security of the electronic confirmation process. Second and third requests should be sent to motivate responses to positive confirmations, and

EXHIBIT 7.12 Negative Confirmation Form

Bullseye 1359 Central Boulevard Derma, MS 39530 Attn: Accounts Payable Dept..

Our auditor, M. Chael Smith, is making his regular audit of our financial statements. Part of this audit includes direct verification of customer balances.

PLEASE EXAMINE THE DATA BELOW CAREFULLY AND COMPARE THEM TO YOUR RECORDS OF YOUR ACCOUNT WITH US. IF THE INFORMATION IS NOT IN AGREEMENT WITH YOUR RECORDS, PLEASE STATE ANY DIFFERENCES BELOW AND RETURN DIRECTLY TO OUR AUDITORS IN THE RETURN ENVELOPE PROVIDED. IF THE INFORMATION IS CORRECT, NO REPLY IS NECESSARY.

This is not a request for payment. Please do not send your remittance to our auditors.

Your prompt attention to this request will be appreciated.

Samuel Carboy, Controller

The balance due Dunder-Mi�in Inc. as of December 31, 2020, is $1,013,239.57

This balance is correct except as noted below:

Date: By: Title:

Dunder-Mi�in Inc. Scranton, PA

C-2

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auditors should audit nonresponding customers by alternative procedures. Furthermore, the lack of response to a negative confirmation is no guarantee that the intended recipient received it or read it. Exhibit 7.13 illustrates some common confirmation responses and the appropriate follow-up action.

If an exception cannot be resolved or it appears to indicate a misstatement, auditors should (1) determine the cause of the misstatement, (2) extrapolate the misstatements over the population, and (3) consider whether fraud may have occurred. If similar misstate- ments could exist, additional procedures are generally necessary to determine the extent of misstatements. In the case of fraud, an extensive investigation may be necessary.6

Confirmation of receivables may be performed at a date other than the year-end. When confirmation is done at an interim date, the audit firm is able to spread work throughout the year and avoid the pressures of overtime that typically occur during “busy season.” In addition, the audit can be completed sooner after the year-end date if confirmations have been done earlier. The primary consideration when planning confirmation of receivables before the balance sheet date is the client’s internal control over transactions affecting receivables. When confirmation is performed at an interim date, the following additional procedures should be considered:

1. Obtain a summary of receivables transactions from the interim date to the year-end date, and review them for unusual items.

2. Vouch a selected sample of transactions for the period. 3. Obtain a year-end trial balance of receivables, compare it to the interim trial balance,

and obtain evidence and explanations for large variations. 4. Consider the necessity for additional confirmations as of the balance sheet date if bal-

ances have significantly increased.

Alternative Procedures Often, the client’s customers are not willing or able to return the confirmation. They may not be able if, for example, they are on a voucher system that lists payables by invoice instead of by vendor account. The U.S. government is notorious for not return- ing confirmations because records may be kept at various agencies. In these cases, auditors must perform alternative procedures to ensure existence. These include examining (1) subsequent cash receipts; (2) sales orders, invoices, and shipping docu- ments; and (3) correspondence files for past-due accounts. Examining subsequent cash

6“AICPA Practice Alert 03-1: Audit Confirmations,” June 2007.

Response Follow-Up Action

“This amount was paid on December 28.” This account is probably valid because the check was likely received after year-end. However, it should be treated as an exception and the date of the receipt should be verified.

“We are unable to confirm this amount.” This is treated the same way as a nonresponse, and alternative procedures should be performed.

“We returned these items.” This is an exception that should be discussed with the client. The auditor should verify that there are no other returns included in receivables.

“We received these goods on January 3.” This is also probably valid because the shipment was likely made in late December. However, this should also be treated as an exception and the shipment should be verified. The auditor should also make sure the goods were removed from the year-end inventory.

EXHIBIT 7.13  Responses to Positive Confirmations (as of December 31)

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receipts is a particularly effective test because if the customer paid the account, it pro- vides strong evidence that the receivable existed. This examination is often performed even when the customer has confirmed the account, because subsequent collection of cash is the strongest evidence supporting the valuation assertion of accounts receiv- able. The cash receipt should be traced to the remittance advice and the deposit into the client’s cash account.

Additional Notes about Confirmations Because of the importance of confirmations for verifying the validity of accounts receivable, the auditor should take special care to consider the sufficiency of evidence obtained. Some other considerations that auditors should make when sending confir- mations follow:

∙ Confirmations returned by the postal service as “undeliverable” are always a red flag. The address should be double checked and evidence that the company actually exists obtained.

∙ Confirmations of accounts, loans, and notes receivable may not produce sufficient evidence of ownership by the client (rights assertion). Debtors may not be aware that the client sold the accounts, notes, or loans receivable to financial institutions or to the public (collateralized securities). Auditors should also consider whether their clients ever factor, or sell, receivables to third parties. Auditors need to perform additional inquiry and detailed procedures to get evidence of the ownership of the receivables and the appropriateness of disclosures related to financing transactions secured by receivables.

∙ Although confirmations are most often used for account balances, experienced audi- tors recognize that confirming a specific transaction, especially a large one, may be more effective. This is especially true if the balance consists primarily of a few large transactions. In your own life, you probably do not know what your current balance is on your credit cards, but you likely remember a recent large purchase (e.g., for textbooks).

∙ It is also possible for an auditor to receive an oral response to a confirmation. Such a response does not meet the definition of an external confirmation because there is no direct written response to the auditor. The auditor should request a written response, and if one is not forthcoming, the auditor should determine whether alternative audit procedures are warranted.

Dual-Purpose Nature of Accounts Receivable Confirmations Accounts receivable confirmation is a substantive procedure designed to obtain evidence of the existence and, secondarily, valuation of customers’ balances directly from the customer. However, if such confirmations show numerous exceptions, auditors are con- cerned with the controls over the details of sales and cash receipts transactions even if previous control evaluations seemed to show little control risk.

The goal in performing substantive procedures is to detect evidence of any material misstatement due to errors or fraud. If there is a risk of material misstatement involv- ing revenue recognition, auditors should consider confirming contract terms and inves- tigate the presence of side agreements with customers. Items to be considered would be acceptance criteria, delivery and payment terms, future or continuing vendor obligations, rights of return, guaranteed resale, and cancellation or refund provisions.

Review for Collectability  Even if the customer confirms that the account exists, this does not necessarily mean that the customer can or will pay it! Therefore, the primary evidence gained from confirma- tions relates to existence. However, the audit team must review accounts for collectability and determine the adequacy of the allowance for doubtful accounts in support of the

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valuation assertion. To do this, auditors review subsequent cash receipts from the cus- tomer, discuss unpaid accounts with the credit manager, and examine the credit files. In addition, a discussion of the bankruptcy of a large customer may appear in the minutes of the board of directors meetings, the audit committee meetings, or a meeting of an execu- tive committee. Credit files should contain the customer’s financial statements, credit reports, and correspondence between the client and the customer. Based on this evidence, the audit team estimates the likely amount of nonpayment for the customer, which is included in the estimate of the allowance for doubtful accounts. In addition, an allow- ance should be estimated for all other customers, perhaps as a percentage of the current accounts with a higher percentage of past due accounts. The auditors then compare their estimate to the recorded balance in the allowance account and propose an adjusting entry for the difference if needed.

Cutoff and Sales Returns The cutoff assertion is particularly relevant in the revenue cycle because of the signifi- cance of revenue as a benchmark for users of the financial statements. This high signifi- cance of revenues makes it highly appealing to managers for earnings management and fraud. Many questionable adjustments to revenues occur very close to year-end. As a result, auditors must make sure that sales are recorded in the proper period. To do this, they employ sales cutoff tests. Procedures include tracing shipping documents before and after year-end to the sales journal to ensure the sale was recorded in the proper period. Credit memos for returns after year-end are vouched to receiving reports. Any goods returned after year-end that were sold during the year being audited should be deducted from net sales.

Adjusting entries for cutoff errors (i.e., sales recorded in the current period for next month’s shipments) must be considered carefully because not only are accounts receiv- able and sales overstated, but also inventory is understated and cost of goods sold (COGS) is overstated.

Sushovan Hussein, the former CFO of Autonomy, a UK software com- pany, was sentenced to five years in prison and fined $4 million for his role in inflating the company’s value in anticipation of an $11  billion acquisition by computer giant Hewlett-Packard. The fraud was accomplished by backdating contracts and channel stuffing, among other revenue recognition frauds. The schemes inflated Autonomy’s

revenues by between 12.4% and 21.5% in various quarters between 2009 and 2011. Both the occurrence and cutoff assertions of revenue were violated by the company.

Source: M. Heller. Ex-Autonomy CFO Convicted of Massive Fraud, CFO.com, May 1, 2018.; J. Garside. ; Ex-Autonomy CFO jailed for five years over Hewlett- Packard fraud. Reuters, May 13, 2019.

Sure, We Are Worth over $11 BillionAUDITING INSIGHT

In addition to the substantive tests discussed earlier and in Exhibit 7.9, the auditor often performs other substantive tests related to assertions in the revenue cycle:

∙ Completeness of revenue and accounts receivable—Include a sample of zero-balance accounts in the confirmation process.

∙ Rights and obligations of accounts receivable—Inquire whether any receivables have been sold or factored.

∙ Rights and obligations of accounts receivable—Inspect the bank confirmations, loan agreements, and minutes of the board for indications of pledged, discounted, or assigned receivables.

Companies may sell or factor their accounts receivable to a financial institution to obtain cash immediately. It is difficult to determine whether receivables have been sold

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because the customers usually do not know that someone else actually owns their account. The cash goes to the original seller, who passes it on to the financial institution. Inquiring of management and examining support for large cash receipts is the best way to detect these transactions.

∙ Classification of accounts receivable—Scan receivables ledger for negative balances for reclassification to accounts payable.

∙ Presentation and disclosure of accounts receivable and revenues—Complete a disclo- sure checklist and ensure completeness and accuracy of required disclosures.

When auditors are satisfied that controls have been examined and transactions and balances have been appropriately tested, the job is not over. The accounts in the rev- enue cycle require certain disclosures. Revenue recognition policies and the amount of the allowance for doubtful accounts are some of the items requiring specific pre- sentation and disclosures. These disclosures must ensure that the presentation and disclosure assertions of occurrence, rights and obligations, completeness, classifica- tion, accuracy and valuation, and classification and understandability have been met. To ensure this, the auditor will often complete the audit of the revenue cycle with a disclosure checklist.

The SEC has settled financial fraud charges with Raymond Green, former treasurer and principal financial accounting officer, and Barry Budilov, former president, director, and chief executive, at defunct Ambassador Eyewear Group (an eyeglass frame distributor), which allegedly overstated assets by as much as 35 percent. To compen- sate for Ambassador’s large cash shortfalls, Budilov obtained an asset-based collateralized line of credit. Under the line of credit terms, Ambassador could borrow up to a percentage of the total value of accounts receivable and inventory value. Ambassador con- tinued to encounter cash shortfalls and subsequently began to falsify

accounts receivable and inventory values. On November 26, 2004, Green pleaded guilty to two counts of fraud and was sentenced to five years’ probation, including eight months of home custody and an order to pay restitution of nearly $17.5 million. On July 12, 2005, Budilov pleaded guilty to four counts of fraud and was sentenced to 27 months in prison and five years’ probation and was ordered to repay nearly $17.5 million.*

Source: “Mentor to Fraud? Two Former Execs Settle with SEC,” www.cfo.com, September 17, 2007.

Ambassador to FraudAUDITING INSIGHT

REVIEW CHECKPOINTS 7.19 Why is it important to emphasize the existence assertion when auditing accounts receivable? 7.20 Which audit procedures are usually the most useful for auditing the existence assertion? 7.21 What analytical procedures might be informative regarding the existence assertion? 7.22 Distinguish between positive and negative confirmations. Under what conditions would you

expect each type of confirmation to be appropriate? 7.23 What are some justifications for not using confirmations of accounts receivable on a particular

audit? 7.24 What special care should be taken with regard to examining the sources (e.g., faxed copy) of

accounts receivable confirmation responses? 7.25 What alternative procedures should be applied to accounts that do not return confirmations? 7.26 What procedures should be performed to determine the adequacy of the allowance for doubtful

accounts?

Taub, Stephen. “Mentor to Fraud? Two Former Execs Settle with SEC.” CFO, September 17, 2007.

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AUDIT RISK MODEL APPLIED Now that the inherent and control risk elements for the revenue and collection cycle along with some of the important substantive procedures have been presented, let’s exam- ine how an audit team might apply the audit risk model for the existence assertion.

Healthy Delights Ice Cream Inc. Healthy Delights is a publicly held company that sells health-based ice cream to gro- cery store chains in the United States. Annual sales have steadily remained at around $100 million. Marsha Fields has been assigned as the senior auditor. Her firm’s policy is always to set overall audit risk as low. She knows previous years’ errors were few and the food industry is sound. The company is generally profitable; management’s compensa- tion is based on long-term performance, not short-term goals; and the overall economy was strong during the year under audit, so she assesses inherent risk as low to moder- ate. Controls have been historically strong, including hiring of competent people; maxi- mum use of computer technology, which is reviewed by internal auditors; and careful reviews of detailed sales analyses by management. Testing of controls in accordance with AS 2201 found no design or operating deficiencies. Thus, Fields assesses the risk of material misstatement as low. In this situation, she can be comfortable setting detec- tion risk at a moderate to high level. This will allow her to limit her sample of accounts for positive confirmations to the largest accounts with a small random sample for nega- tive confirmations on smaller accounts. The confirmations will be sent at an interim date. She also can rely heavily on analytical procedures. In addition, a smaller sample of transactions will be selected for detail testing. This combination of low risk of material misstatement and moderate to high detection risk should lead Fields to an acceptably low overall audit risk.

APPLICATION IN THE FIELD Historically, auditors testing the revenue cycle would select samples of items to test significant assertions and the controls that help ensure the accurate and complete pro- cessing of transactions. With an increase in the ability to handle larger amounts of data, auditors can now test all instances of some controls and transactions instead of selecting a sample.

One way to subject all items in a population of occurrences for a particular control activity in the revenue cycle is to use exception testing. Exception testing is designed to identify a violation of a particular control activity through the use of an automated test procedure designed to test all items in a population. For example, companies often design an automated control activity that is designed to compare a customer’s credit limit to the sum of (1) a potential sales transaction and (2) that customer’s outstanding credit balance before approval of that sales transaction. If the control activity operated effec- tively throughout the year, a customer’s outstanding credit balance would not exceed its credit limit.

Given the nature of the control activity, one way for an auditor to test the operating effectiveness of this control would be through the use of exception testing. An auditor could obtain evidence about the control’s operating effectiveness by using a procedure that compares each customer’s credit limit to that customer’s outstanding credit balance at the end of each day for the year under audit. Such a testing strategy would not have been possible (at least economically) previously. However, due to advances in informa- tion technology, such testing is now possible. Using IDEA or other audit software, the computer can make these comparisons and provide a listing of exceptions, as outlined in the following example. As a direct result, entry-level audit professionals are now expected to consider the full extent of client data available for testing purposes before proceeding with audit tests.

LO 7-7 Apply your knowledge to perform audit procedures in the revenue and collection cycle and evaluate the findings of your tests.

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AUDIT CASES: EXTENDED AUDIT PROCEDURES This part of the chapter uses a set of cases that provide specific examples of tests of controls and substantive procedures (recalculation, observation, confirmation, inquiry, vouching, tracing, scanning, and analytical procedures). The case stories are better than listing schemes and detection procedures in the abstract.

The cases follow a standard format that first tells about an error or fraud situation in terms of the problem, the audit approach, and the discovery. The first part of each case gives you the “inside story” that auditors seldom know before they perform the audit work. The next part is an audit approach section, which discusses the audit objective (assertion), controls, tests of controls, and substantive procedures that could be consid- ered in approaching the situation. The audit approach section presumes that the auditors do not know everything about the situation.

At the end of the chapter, some similar discussion cases are presented, and you can write the audit approach to test your ability to design audit procedures for detecting errors and frauds. Appendix 7B provides a substantive audit plan for reference.

Case 7.1

The Canny Cashier

PROBLEM D. Bakel was the assistant controller of Sports Equipment Inc. (SEI), an equipment retailer. SEI maintained accounts receivable for school districts in the region; otherwise, customers received credit by using their own credit cards.

As company cashier, Bakel received all incoming mail payments on school accounts, credit card accounts, and cash and checks taken over the counter. He prepared the bank deposit, listing all checks and currency, and prepared a remittance worksheet (daily cash report) that showed amounts received, discounts allowed on school accounts, and amounts to credit to the accounts receivable. Another accountant used the remittance worksheet to post credits to the accounts receivable. Bakel delivered the deposit to the bank and reconciled the bank statement. No one else reviewed the deposits or the bank statements except the independent auditors.

Bakel opened a bank account in the name of Sport Equipment Company (SEC) after prop- erly incorporating the company in the secretary of state’s office. Over-the-counter cash, checks, and school district payments were taken from the SEI receipts and deposited in the SEC account. (None of the customers noticed the difference between the rubber stamp endorsements for the two similarly named corporations, and neither did the bank.) SEC kept the money a while, earning

One opportunity for auditors to take advantage of the availability of improved data analytic tools is to perform exception testing on grant- ing credit to customers. For example, an auditor may want to test whether any customers were granted credit when they either had no approved credit limit or had exceeded their credit limit.

To accomplish this, the auditor will most likely join two related client data files—an Accounts Receivable subsidiary ledger and a Customer Master list with credit authorizations—based on customer identification. In IDEA, this can be accomplished using the Join com- mand from within the Analysis tab.

After joining the data, the auditor can perform a direct extraction using the Direct command from the Extract group in the Analysis tab and create a new database of any transactions that caused a cus- tomer to exceed the credit limit. This enables the auditor to identify exceptions to authorization controls, leading to more accurate assess- ments of control risk and more efficient selection of substantive tests.

At the end of this chapter, you can perform this exception test in Exercise 7.78.

Credit Authorization Controls

USING IDEA IN THE AUDIT

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interest, and then Bakel wrote SEC checks to SEI to replace the “borrowed” funds, in the meantime taking new SEI receipts for deposit to SEC.

Bakel also stole payments made by the school districts, depositing them to SEC. Later he depos- ited SEC checks in SEI, giving the schools credit, but approved an additional 2 percent discount in the process. Thus, the schools received proper credit later, and SEC paid less by the amount of the extra discount.

SEI’s bank deposits systematically showed small currency deposits. Bakel was nervous about taking too many checks, so he preferred cash. The deposit slips had to include the SEC checks because bank tellers compare the deposit slip listing to the checks submitted. The remittance work- sheet showed different details: Instead of showing SEC checks, it showed receipts from school districts and currency but not many over-the-counter checks from customers.

The transactions became complicated enough that Bakel had to use the office computer to keep track of the school districts that needed to receive credit. There were no vacations for this hard- working cashier because a substitute might notice the discrepancies, and Bakel needed to give the districts credit later.

Over a six-year period, Bakel built up a $150,000 average balance in the Sport Equipment Company (SEC) account that earned a total of $67,500 interest that Sports Equipment Inc. (SEI) should have earned. By approving the “extra” discounts, Bakel skimmed 2 percent of $1 million in annual sales, for a total of $120,000. Because SEI would have had net income before taxes of about $1.6 million over these six years (about 9 percent of sales), Bakel’s embezzlement took about 12.5 percent of the income.

AUDIT APPROACH Authorization related to cash receipts, custody of cash, recording cash transactions, and bank state- ment reconciliation should be separate duties designed to prevent errors and frauds. Some supervi- sion and detail review of one or more of these duties should be performed as a next-level control designed to detect errors and frauds, if they have occurred. For example, someone else should prepare the remittance worksheet, or at least the controller should approve the discounts; someone else should prepare the bank reconciliation.

Bakel performed incompatible duties. (While he did not actually perform the recording, Bakel provided the source document—the remittance worksheet—the other accountant used to make the cash and accounts receivable entries.) According to the company president, the “control” was the diligence of “our long-time, trusted, hard-working assistant controller.” (Note: A vigilant auditor who “thought like a crook” might have been able to imagine ways Bakel could have commit- ted fraud and thus prevented or detected this cash embezzlement and accounts receivable lapping scheme.)

Because the “control” purports to be Bakel’s honest and diligent performance of the accounting and control activities that might have been performed by two or more people, the test of controls is an audit of cash receipts transactions as they relate to accounts receivable credit. The dual- direction samples and procedures are these:

Occurrence direction. The auditors selected a sample of customer accounts receivable and vouched payment credits to remittance worksheets and bank deposits, including recalculation of discounts allowed in comparison to sales terms (2 percent), classification (customer name) identification, and correspondence of receipt date to recording date. Completeness direction. The auditors selected a sample of remittance worksheets (or bank deposits), vouched details to bank deposit slips (traced details to remittance worksheets if the sample is bank deposits), and traced to complete accounting posting in customer accounts receivable.

Because there was a control risk of incorrect accounting, accounts receivable were confirmed as of year-end using positive confirmations. The sample included all school district accounts.

When prompted by notice of an oddity (noted in the following discovery summary), the audit team used the Internet, chamber of commerce directory, local crisscross directory, and a visit to the secretary of state’s office to determine the location and identity of Sport Equipment Company.

DISCOVERY SUMMARY The test of controls samples showed four cases of discrepancy, one of which is discussed here.

The auditors sent positive confirmations on all 72 school district accounts. Three of the responses stated the districts had paid the balances before the confirmation date. Follow-up

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procedures on their accounts receivable credit in the next period showed they had received credit in remittance reports and the bank deposits had shown no checks from the districts but had contained a check from Sports Equipment Company.

Investigation of SEC revealed the connection of Bakel, who was confronted and then confessed.

Cash Remittance Report

Bank Deposit Slip Name Amount Discount AR Sales

Jones 25 Jones 25 0 0 25

Smith 35 Smith 35 0 0 35

Hill District 980 Hill District 980 20 1,000 0

Sport Equipment 1,563 Marlin District 480 20 500 0

Currency 540 Waco District 768 32 800 0

Deposit 3,143 Currency 855 0 0 855

Totals 3,143 72 2,300 915

Case 7.2

The Taxman Always Rings Twice

PROBLEM J. Shelstad was the tax assessor-collector in the Ridge School District, serving a large metropoli- tan area. The staff processed tax notices on a computerized system and generated 450,000 tax notices each October. An office copy was printed and used to check off “paid” when payments were received. Payments were processed by computer, and a master file of “accounts receivable” records (tax assessments, payments) was kept on the computer hard drive.

Shelstad was a good personnel manager and often took over the front desk at lunchtime so the teller staff could enjoy lunch together. During these times, she took payments over the counter, gave the taxpayers a counter receipt, and pocketed some of the money, which was never entered in the computerized system.

Shelstad resigned when she was elected to the Ridge school board. The district’s assessor-collector office was eliminated upon the creation of a new countywide tax agency.

The computerized records showed balances due from many taxpayers who had actually paid their taxes. The book of printed notices was not marked “paid” for many taxpayers who had received counter receipts. These records and the daily cash receipts reports (cash receipts journal) were available when the independent auditors had performed the most recent annual audit in April. When Shelstad resigned in August, a power surge permanently destroyed the hard drive receiv- ables file, and the cash receipts journals could not be found.

The new county agency managers noticed that the total of delinquent taxes disclosed in the audited financial statements was much larger than the total turned over to the county attorney for collection and foreclosure.

Shelstad had been the assessor-collector for 15 years. The “good personnel manager” pocketed 100–150 counter payments each year in amounts of $500–$2,500, stealing about $200,000 a year for a total of approximately $2.5 million. The district had assessed about $800–$900 million per year, so the annual theft was less than 1 percent. Nevertheless, the taxpayers got mad.

AUDIT APPROACH The school district had a respectable system for establishing the initial amounts of taxes receivable. The professional staff of appraisers and the independent appraisal review board established the tax base for each property. The school board set the price (tax rate). The computerized system authori- zation for billing was validated on these two inputs.

The cash receipts system was well designed, calling for preparation of a daily cash receipts report (cash receipts journal that served as a source input for computerized entry). The “boss,” Shelstad, always reviewed this report.

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Unfortunately, Shelstad had the opportunity and power to override the controls and become both cash handler and supervisor. She made the decisions about sending delinquent taxes to the county attorney for collection and withheld the ones known to have been paid but stolen.

The auditors performed dual-direction sampling to test the processing of cash receipts:

Occurrence direction. The auditors selected a sample of receivables from the computer hard disk and vouched (1) charges to the appraisal record, recalculating the amount using the autho- rized tax rate and (2) payments, if any, to the cash receipts journal and bank deposits. (The auditors found no exceptions.) Completeness direction. The auditors selected a sample of properties from the appraisal rolls and determined that tax notices had been sent and tax receivables (charges) recorded in the computer file. They next selected a sample of cash receipts reports, vouched them to bank deposits of the same amount and date, and traced the payments forward to credits to taxpayers’ accounts. They also selected a sample of bank deposits and traced them to cash receipts reports of the same amount and date. Finally, they compared the details on bank deposits to the details on the cash receipts reports to determine whether the same taxpayers appeared on both docu- ments. (The auditors found no exceptions.)

The auditors confirmed a sample of unpaid tax balances with taxpayers. In such cases, response rates may not be high, follow-up procedures determining the ownership (county title files) may need to be performed, and new confirmations may need to be sent.

DISCOVERY SUMMARY Shelstad persuaded the auditors that the true receivables were the delinquencies turned over to the county attorney. The confirmation sample and other work were based on this popula- tion. Thus, confirmations were not sent to the “unpaid” balances that Shelstad knew had been paid,  therefore, the auditors never had the opportunity to receive “I paid” complaints from taxpayers.

Shelstad did not influence the new managers of the countywide tax district. They questioned the discrepancy between the delinquent taxes in the audit report and the lower amount turned over for collection. Because the computer file was not usable, the managers had to use the printed book of tax notices in which paid accounts had been marked “paid.” (Shelstad had not marked the stolen ones “paid,” so the printed book would agree with the computer file.) Tax due notices were sent to the taxpayers with unpaid balances, and they began to show up bringing their counter receipts and loud complaints.

Acting overzealously in their documentation, the independent auditors had earlier photocopied the entire set of cash receipts reports (cash journal) and were then able to determine that the coun- ter receipts (all signed by Shelstad) had not been deposited or entered. Shelstad was prosecuted and sentenced to a jail term.

Case 7.3

Bill Often, Bill Early

PROBLEM McGossage Company experienced profit pressures for two years in a row. Actual profits were squeezed in a recessionary economy, but the company reported net income decreases that were not as severe as other companies’ in the industry.

Sales for orders that had been prepared for shipment but not actually shipped until later were recorded in the grocery products division. Employees backdated the shipping documents. Gross profit on these “sales” was about 30 percent. Customers took discounts on payments, but the company did not record them, leaving the debit balances in the customers’ accounts receivable instead of charging them to the sales discounts and allowances account. Company accountants were instructed to wait 60 days before recording discounts taken.

The division vice president and general manager knew about these accounting practices, as did a significant number of the 2,500 employees in the division. The division managers were under orders from headquarters to achieve profit objectives they considered unrealistic.

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The customers’ accounts receivable balances contained amounts due for discounts the custom- ers already had taken. The cash receipts records showed payments received without credit for discounts. Discounts were entered monthly by a special journal entry.

The unshipped goods were on the shipping dock at year-end with papers showing earlier ship- ping dates.

As misstatements go, some of these were on the materiality borderline. Sales were overstated 0.3 percent and 0.5 percent in the prior and current years, respectively. Accounts receivable were overstated 4 percent and 8 percent, respectively. The combined effect was to overstate the divi- sion’s net income by 6 percent and 17 percent. Selected data follow:

AUDIT APPROACH The accounting manual should provide instructions to record sales on the date of shipment (or when title passes, if later). Management subverted this control procedure by having shipping employees date the shipping papers incorrectly.

Cash receipts procedures should provide for authorizing and recording discounts when custom- ers take them. Management overrode this control instruction by giving instructions to delay the recording.

Questionnaires and inquiries should be used to determine the company’s accounting policies. It is possible that employees and managers would lie to the auditors to conceal the policies. It is also possible that pointed questions about revenue recognition and discount recording policies would elicit answers to reveal the practices.

For detail procedures, the auditors select a sample of cash receipts, examine them for authoriza- tion, recalculate the customer discounts, and trace them to accounts receivable input for recording the proper amount on the proper date. They select a sample of shipping documents, vouch them to customer orders, and then trace them to invoices and to the accounts receivable account with proper amounts on the proper date. These tests follow the tracing direction—starting with data that represent the beginning of transactions (cash receipts, shipping) and tracing them through the company’s accounting process.

The audit team should confirm a sample of customer accounts and use analytical procedures to determine relationships of past years’ discount expense to a relevant base (sales, sales volume) to calculate an overall test of the discounts expense.

DISCOVERY SUMMARY The managers lied to the auditors about their revenue and expense timing policies. The sample of shipping documents showed no dating discrepancies because the employees had inserted incorrect dates. The analytical procedures on discounts did not show the misstatement because the historical relationships were too erratic to show a deficient number. However, the sample of cash receipts transactions showed that discounts had not been calculated and recorded at time of receipt. Addi- tional inquiry led to the discovery of the special journal entries and knowledge of the recording delay. Two customers in the sample of 65 confirmations responded with exceptions that turned out to be unrecorded discounts.

Two other customers in the confirmation sample complained that they did not owe for late invoices on December 31. Follow-up showed that the shipments were noticed on the shipping dock. Auditors taking the physical inventory noticed the goods on the shipping dock during the December 31 inventory taking. Inspection revealed the shipping documents dated December 26. When the auditors traced these shipments to the sales recording, they found them recorded bill and hold on December 29. (These procedures were performed and the results obtained by a new audit firm in the third year!)

One Year Ago* Current Year*

Reported Actual Reported Actual

Sales $330.0 $329.0 $350.0 $348.0

Discounts expense         1.7         1.8         1.8        2.0

Net income        6.7        6.3        5.4        4.6

*Dollars in millions.

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Case 7.4

Thank Goodness It’s Friday

PROBLEM Alpha Brewery Corporation generally has good controls related to authorization of transactions for accounting entry, and the accounting manual has instructions for recording sales transactions in the proper accounting period. The company regularly closes the accounting process each Friday at 5 P.M. to prepare weekly management reports. The year-end date (cutoff date) is December 31, and this year, December 31 was a Monday. However, the accounting was performed through Friday as usual and the accounts were closed for the year on January 4.

AUDIT TRAIL All entries were properly dated after December 31, including the sales invoices, cash receipts, and shipping documents. However, the trial balance from which the financial statements were prepared was dated December 31 (this year). Nobody noticed the slip of a few days because the Friday clos- ing was normal.

Alpha recorded sales of $672,000 and gross profit of $268,800 over the January 1–4 period. Cash collections on customers’ accounts were recorded in the amount of $800,000.

AUDIT APPROACH The company had in place the proper instructions for people to date transactions on the actual date on which they occurred, to enter sales and cost of goods sold on the day of shipment, and to enter cash receipts on the day received in the company offices. An accounting supervisor should have checked the entries through Friday to make sure the dates corresponded with the actual events and that the accounts for the year were closed with Monday’s transactions.

In this case, the auditors need to be aware of the company’s weekly routine closing and the possibility that the December 31 date might cause a problem. Asking the question: “Did you cut off the accounting on Monday night this week?” might elicit the “Oh, we forgot!” response. Other- wise, it is normal to sample transactions around the year-end date to determine whether they were recorded in the proper accounting period.

Select transactions 7–10 days before and after the year-end date and inspect the dates on sup- porting documentation for evidence of accounting in the proper period.

The audit for sales overstatement is partly accomplished by auditing the cash and accounts receivable at December 31 for overstatement. Confirm a sample of accounts receivable. If the accounts are too large, the auditors expect the debtors to say so, thus leading to detection of sales overstatements.

Cash overstatement is audited by auditing the bank reconciliation to see whether deposits in transit (the deposits sent late in December) actually cleared the bank early in January. Obviously, the January 4 cash collections could not reach the bank until at least Monday, January 7. That is too long for a December 31 deposit to be in transit to a local bank.

The completeness of sales recordings is audited by selecting a sample of sales transactions (and supporting shipping documents) in the early part of the next accounting period (January next year). One way this year’s sales could be incomplete would be to postpone recording December ship- ments until January, and this procedure will detect those deferred sales if the shipping documents are dated properly.

The completeness of cash collections (and accounts receivable credits) is examined by auditing the cash deposits early in January to see whether there is any sign of holding cash without entry until January.

In this case, the existence objective is more significant for discovery of the problem than the completeness objective. After all, the January 1–4 sales, shipments, and cash collections did not “exist” in December this year.

DISCOVERY SUMMARY The test of controls sample from the days before and after December 31 quickly revealed the prob- lem. Company accounting personnel were embarrassed, but there had been no effort to misstate the financial statements. This was a simple error. The company readily made the following adjustment:

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Debit Credit

Sales $672,000

Inventory   403,200

Accounts receivable   800,000

Accounts receivable $672,000

Cost of goods sold   403,200

Cash   800,000

REVIEW CHECKPOINTS 7.27 What are the goals of dual-direction testing regarding an audit of the accounts receivable and

cash collection system? 7.28 In the case of The Canny Cashier, name one control that could have revealed signs of the

embezzlement. 7.29 What feature(s) could SEI have installed in its cash receipts internal controls that would have been

expected to prevent the cash receipts journal and recorded cash sales from reflecting more than the amount shown on the daily deposit slips?

7.30 In the case of The Taxman Always Rings Twice, what information could have been obtained from confirmations directed to the real population of delinquent accounts?

7.31 In the case of Bill Often, Bill Early, what information might have been obtained from inquiries? From tests of controls? From observations? From confirmations?

7.32 With reference to the case of Thank Goodness It’s Friday, what contribution could an understand- ing of the business and the management reporting system have made to discovery of the open cash receipts journal cutoff error?

Even with proper diligence and due professional care, it may be difficult to identify all issues related to the revenue cycle. This is illustrated in the following Auditing Insight that lists matters identified as audit deficiencies by the Public Company Accounting Oversight Board (PCAOB) during its annual inspections for audits conducted by large registered accounting firms.

• The Firm’s procedures related to revenue at certain of the issuer’s locations, which represented a significant amount of the issuer’s total revenue and presented a reasonable possibility of material misstatement, were insufficient. Specifically • The Firm selected for testing one control over revenue at

these locations, which consisted of a comparison of operating results to the prior-periods’ results and to forecasted results and the investigation of variances above established thresh- olds. The Firm’s procedures to test this control were limited to (1) inquiring of the control owner, (2) inspecting documenta- tion as evidence of review, (3) noting that all comparisons as required by the control description were performed, and (4) determining whether explanations were provided for all vari- ances over the investigation thresholds. The Firm’s testing

was insufficient, as it did not include evaluating the nature of the procedures performed by the control owner, including whether items identified for investigation were appropriately resolved.

• The Firm failed to perform any substantive procedures to test revenue at these locations.

• In this audit of an issuer in the materials industry sector, the Firm failed to obtain sufficient appropriate audit evidence to support its audit opinions on the financial statements and on the effective- ness of ICFR, as its procedures related to revenue were insuffi- cient. Specifically • The issuer recorded the majority of its revenue based on the

weight of the goods sold or the weight of the raw materials

Deficiencies from PCAOB Inspection Reports in the Revenue and Collections Cycle

AUDITING INSIGHT

Continued

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The revenue and collection cycle consists of customer order processing, credit checking, shipping goods, billing customers, accounting for accounts receivable, and collecting and accounting for cash receipts. Companies reduce control risk by having a suitable separation of authorization, custody, recording, and periodic reconciliation duties. Error-checking activities of comparing customer orders and shipping documents are important for billing customers the correct prices for the delivered quantities. Otherwise, many things could go wrong—ranging from making sales to fictitious customers or customers with bad credit to erroneous billings for the wrong quantities at the wrong prices at the wrong time.

Confirmation is the primary substantive audit procedure accompanied by analytical procedures, application of subsequent cash receipts, and other alternative procedures. Confirmations of loans, accounts receivable, and notes receivable are required unless auditors can justify substituting other procedures in the circumstances of a particular audit. Confirmations for accounts and notes receivable can be in positive or negative form, and the positive form may be a blank confirmation. Confirmations yield evidence about existence and gross valuation. Other procedures must be undertaken to audit the collectability of the accounts. Nevertheless, confirmations can give some clues about

Summary

“2017 Inspection of PricewaterhouseCoopers LLP.” PCAOB, February 28, 2019. “2017 Inspection of Deloitte & Touche LLP.” PCAOB, December 20, 2018. “2017 Inspection of RSM US LLP.” PCAOB, November 19, 2018.

used to produce the goods. The Firm’s procedures to test controls over this revenue were not sufficient, as it failed to identify and test any controls over the accuracy of the weights that were entered into the revenue systems and used to deter- mine the quantity to be billed to customers. 

• The Firm used the work of the issuer’s information technology management group (“IT group”) as evidence of the effectiveness of the controls over the accuracy and completeness of reports the issuer used in the operation of certain controls over this revenue that the Firm tested. The IT group used a benchmarking strategy for its testing in which the baselines had been established in prior years. The Firm’s procedures to evaluate the effectiveness of the IT group’s work were not sufficient, as the Firm failed to 

• Assess the (1) objectivity of the issuer’s IT group, other than noting that the IT group was not involved in the per- formance of the relevant controls, and (2) competence of the individual from the issuer’s IT group who performed the testing of the majority of the reports in prior years, beyond inquiring of management, and

• Evaluate the work of the issuer’s IT group, or perform other procedures, to determine that a benchmarking strategy was appropriate for these controls.

• The Firm designed certain of its substantive procedures— including the sample sizes used in those procedures—based on a level of control reliance that was not supported due to the deficiencies in the Firm’s testing of controls that are discussed above. As a result, the sample sizes that the Firm used to test this revenue were too small to provide sufficient evidence.*

• For certain of the issuer’s subsidiaries, which generated a significant portion of total revenue, the issuer entered into contracts that con- tained multiple deliverables. For each contract, the contract terms,

the identified deliverables, and the amount of consideration allo- cated to each deliverable were entered into the issuer’s system to create sales orders and record revenue. The Firm failed to identify and test any controls over the accuracy and completeness of the entry of these data into the issuer’s system.*

• The Firm failed to sufficiently test the issuer’s controls over rev- enue, as follows: • The Firm selected for testing five automated application controls

placed in operation within three service organizations’ applica- tions. The Firm’s procedures to test these controls consisted of inquiring of management and evaluating the service organization controls 1 (“SOC 1”) reports for two of the three service organiza- tions. The Firm failed to perform sufficient procedures to deter- mine whether the identified automated application controls were implemented and operating effectively at the service organiza- tions, as the SOC 1 reports for the two service organizations did not include within its scope the automated application controls; and it did not perform other procedures to test the automated application controls at any of the service organizations.

• The Firm selected for testing a configuration control related to a ser- vice organization’s system, which operated over the largest portion of the issuer’s revenue, intended to ensure the accurate calculation of revenue. The Firm used a benchmarking strategy implemented by IA in prior years. The Firm’s procedures were limited to review- ing documentation of IA’s walkthrough procedures performed dur- ing the year prior to the year under audit. The Firm failed to perform procedures to determine whether the configuration control had changed since IA established its prior year baseline.*

Source: 2017 PCAOB Inspection of RSM US LLP; 2017 PCAOB Inspection of Deloitte & Touche LLP; 2017 PCAOB Inspection of Ernst & Young LLP; and 2017 Inspection of PricewaterhouseCoopers LLP. All reports can be found on the PCAOB’s website, https://pcaobus.org/Inspections/Reports/Pages/default.aspx.

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aged trial balance: A schedule that lists each receivable and indicates whether it is current or past due and if past due, for how long; the total should equal the accounts receivable general ledger balance, 275 bill and hold: A fraudulent financial reporting activity by which a company recognizes a sale even though it does not ship the merchandise to the customer but holds it in its own warehouse, 305 bill of lading: A contract between the shipper and the carrier; includes shipping information such as ship dates and origination, purchase order number, and signatures for receipt of merchandise, 273 dual-purpose procedure: An audit procedure that simultaneously serves the substantive purpose (obtain direct evidence about the dollar amounts in account balances) and the test of controls purpose (obtain evidence about the company’s performance of its own control activities), 285 factor: The action to sell accounts receivable to another party (the factor) at a discount from face value, 298 negative confirmation: A form sent to a customer by auditors requesting that the customer respond only if the balance shown on it is incorrect, 294 packing slip: A document included with a shipment that shows the description and quantity of the goods being shipped, 273 positive confirmation: A letter sent to a customer by auditors requesting that the customer respond as to whether the balance shown on it is correct or not, 292 revenue recognition: The recording of revenues in the general ledger, often done fraudulently by schemes such as bill and hold, 277 sales cutoff tests: The tests that ensure that sales are recorded in the proper period—generally, when they are shipped—and that the cost of sales is recorded and removed from inventory, 298 sales invoice: A bill sent to customers for payment showing the amount due and payment terms, 273

Key Terms

collectability when customers tell about balances in dispute. Confirmations of accounts, notes, and loans receivable should not be used as the only evidence of the ownership (rights assertions) of these financial assets.

Although these procedures may seem to be common sense, auditing the revenue and collection cycle is not straightforward. The Auditing Insight that appears at the end of the section Audit Case in chapter 7, discusses some deficiencies the PCAOB noted in its inspections of registered public accounting firms regarding audits of this cycle. Note that these issues can involve more than a slap on the wrist and added staff training. In December 2007, the PCAOB fined Deloitte & Touche $1 million for failing to exercise due professional care and obtain sufficient evidential matter regarding revenues in the audit of Ligand Pharmaceuticals.

7.33 Revenues are normally considered to have been earned when a. All possibility of return has expired. b. The company has substantially accomplished what it must to be entitled to the benefits. c. The cash is collected. d. Goods have been shipped.

7.34 Sales are normally recorded on the date of the a. Customer purchase order. b. Bill of lading. c. Sales invoice. d. Payment check.

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7.35 When auditing the revenue and collection cycle, auditors normally select balances to con- firm from the a. Sales journal. b. Accounts receivable listing. c. General ledger. d. Cash receipts listing.

7.36 Which of the following accounts is not normally part of the revenue and collection cycle? a. Sales. b. Accounts Receivable. c. Cash. d. Purchases Returns and Allowances.

7.37 The control procedure “credit sales approved by credit department” is directed toward which assertion? a. Existence/Occurrence. b. Completeness. c. Valuation/Accuracy. d. Cutoff.

7.38 Which of the following would be the best protection for a company that wishes to prevent the “lapping” of trade accounts receivable? a. Separate duties so that the bookkeeper in charge of the general ledger has no access to

incoming mail. b. Separate duties so that no employee has access to both checks from customers and cur-

rency from daily cash receipts. c. Have customers send payments directly to the company’s depository bank. d. Request that customer’s payment checks be made payable to the company and addressed

to the treasurer. 7.39 Which of the following internal control activities will most likely prevent the concealment

of a cash shortage by improperly writing off a trade account receivable? a. Write-offs must be approved by a responsible officer after review of credit department

recommendations and supporting evidence. b. Write-offs must be supported by an aging schedule showing that only receivables over-

due several months have been written off. c. Write-offs must be approved by the cashier who is in a position to know whether the

receivables have, in fact, been collected. d. Write-offs must be authorized by company field sales employees who are in a position to

determine customers’ financial standing. 7.40 Auditors sometimes use comparisons of ratios as audit evidence. An unexplained decrease

in the ratio of gross profit to sales may suggest which of the following possibilities? a. Unrecorded purchases. b. Unrecorded sales. c. Merchandise purchases being charged to selling and general expense. d. Fictitious sales.

7.41 An audit team is auditing sales transactions. One step is to vouch a sample of debit entries from the accounts receivable subsidiary ledger back to the supporting sales invoices. The purpose of this audit procedure is to establish that a. Sales invoices represent bona fide sales. b. All sales have been recorded. c. All sales invoices have been properly posted to customer accounts. d. Entries in the accounts receivable subsidiary ledger were properly invoiced. Use the following information to answer questions 7.42 and 7.43:

An auditor noted that client sales increased 10 percent for the year. At the same time, Cost of Goods Sold as a percentage of sales had decreased from 45 percent to 40 percent and year-end accounts receivable had increased by 8 percent.

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7.42 Based on this information, the auditor is most likely concerned about a. Unrecorded costs. b. Improper credit approvals. c. Improper sales cutoff. d. Fictitious sales.

7.43 Based on this information, the auditor interviewed the sales manager, who stated that the increase in sales without a corresponding increase in cost of goods sold was due to a price increase enacted by the company during the year. How would the auditor test the sales man- ager’s representation? a. Perform additional inquiries with sales personnel. b. Obtain copies of all price lists in use during the year and vouch the prices to sales

invoices. c. Send confirmations asking customers about unit prices paid for product. d. Vouch vendor invoices to payments made after year-end.

7.44 To conceal a theft involving receivables, a dishonest bookkeeper might charge which of the following accounts? a. Miscellaneous income b. Petty cash c. Miscellaneous expense d. Sales returns

7.45 Which of the following responses to an accounts receivable confirmation at December 31 would cause an audit team the most concern? a. “This amount was paid on December 30.” b. “We received this shipment on January 2.” c. “These goods were returned for credit on November 15.” d. “The balance does not reflect our sales discount for paying by January 5.”

7.46 A client has a separate sales group for its largest “preferred” customers, a select group of customers who normally make purchases in excess of $250,000 and often have accounts receivable balances in excess of $1 million. Which of the following audit procedures would the auditor most likely perform? a. Prepare a schedule of purchases and payments for these customers. b. Send out negative confirmations on a large sample of these customers. c. Inquire of the sales manager regarding the accounts receivable terms. d. Send out positive confirmations on a large sample of these customers.

7.47 Audit documentation often includes a client-prepared, aged trial balance of accounts receiv- able as of the balance sheet date. The audit team uses this aging primarily to a. Evaluate internal control over credit sales. b. Test the accuracy of recorded charge sales. c. Estimate credit losses. d. Verify the existence of the recorded receivables.

7.48 Which of the following might be detected by auditors’ cutoff review and examination of sales journal entries for several days prior to the balance sheet date? a. Lapping year-end accounts receivable. b. Inflating sales for the year. c. Kiting bank balances. d. Misappropriating merchandise.

7.49 Confirmation of individual accounts receivable balances directly with debtors will, of itself, normally provide the strongest evidence concerning the a. Collectability of the balances confirmed. b. Ownership of the balances confirmed. c. Existence of the balances confirmed. d. Internal control over balances confirmed.

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7.50 Which of the following is the best reason for prenumbering in numerical sequence docu- ments such as sales orders, shipping documents, and sales invoices? a. Enables company personnel to determine the accuracy of each document. b. Enables personnel to determine the proper period recording of sales revenue and

receivables. c. Enables personnel to check the numerical sequence for missing documents and unre-

corded transactions. d. Enables personnel to determine the validity of recorded transactions.

7.51 When a sample of customer accounts receivable is selected for vouching debits, auditors will vouch them to a. Sales invoices with shipping documents and customer sales invoices. b. Records of accounts receivable write-offs. c. Cash remittance lists and bank deposit slips. d. Credit files and reports.

7.52 In the audit of accounts receivable, the most important emphasis should be on the a. Completeness assertion. b. Existence assertion. c. Rights and obligations assertion. d. Presentation and disclosure assertion.

7.53 When accounts receivable are confirmed at an interim date, auditors need not be concerned with a. Obtaining a summary of receivables transactions from the interim date to the year-end

date. b. Obtaining a year-end trial balance of receivables, comparing it to the interim trial bal-

ance, and obtaining evidence and explanations for large variations. c. Sending negative confirmations to all customers as of the year-end date. d. Considering the necessity for some additional confirmations as of the balance sheet date

if balances have increased materially. 7.54 The negative request form of accounts receivable confirmation is useful particularly when the

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Assessed Level of Risk of Material Misstatement Relating to Receivables Is

Number of Small Balances Is

Proper Consideration by the Recipient Is

a. Low Many Likely

b. Low Few Unlikely

c. High Few Likely

d. High Many Likely

(AICPA adapted) 7.55 When an audit team traces a sample of shipping documents to the related sales invoice cop-

ies, they are trying to find relevant evidence that a. Shipments to customers were invoiced. b. Shipments to customers were recorded as sales. c. Recorded sales were shipped. d. Invoiced sales were shipped.

(AICPA adapted) 7.56 Write-offs of doubtful accounts should be approved by

a. The salesperson. b. The credit manager. c. The treasurer. d. The cashier.

7.57 When an audit team does not receive a response on a positive accounts receivable confirma- tion, auditors should do all of the following except a. Send a second request. b. Do nothing for immaterial balances.

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c. Examine shipping documents. d. Examine client correspondence files.

7.58 Cash receipts from sales on account have been misappropriated. Which of the following acts would conceal this defalcation and be least likely to be detected by an auditor? a. Understating the sales journal. b. Overstating the accounts receivable control account. c. Overstating the accounts receivable subsidiary ledger. d. Understating the cash receipts journal.

(AICPA adapted) 7.59 Which of the following internal control activities most likely would deter lapping of collec-

tions from customers? a. Independent internal verification of dates of entry in the cash receipts journal with dates

of daily cash summaries. b. Authorization of write-offs of uncollectable accounts by a supervisor independent of

credit approval. c. Separation of duties between receiving cash and posting the accounts receivable ledger. d. Supervisory comparison of the daily cash summary with the sum of the cash receipts

journal entries. (AICPA adapted)

7.60 The financial records of the Movitz Company show that R. Dennis owes $4,100 on an account receivable. An independent audit is being carried out, and the auditors send a posi- tive confirmation to R. Dennis. What is the most likely reason as to why a positive confirma- tion rather than a negative confirmation was used here? a. Control risk was particularly low for accounts receivable. b. Inherent risk was particularly high for accounts receivable. c. Dennis’s account was not yet due. d. Dennis’s account was not with a related party.

7.61 An audit client sells 15 to 20 units of product annually. A large portion of the annual sales occur in the last month of the fiscal year. Annual sales have not materially changed over the past five years. Which of the following approaches would be most effective concerning the timing of audit procedures for revenue? a. The auditor should perform analytical procedures at an interim date and discuss any

changes in the level of sales with senior management. b. The auditor should inspect transactions occurring in the last month of the fiscal year

and review the related sale contracts to determine that revenue was posted in the proper period.

c. The auditor should perform tests of controls at an interim date to obtain audit evidence about the operational effectiveness of internal controls over sales.

d. The auditor should review period-end compensation to determine whether bonuses were paid to meet earnings goals.

(AICPA adapted) 7.62 An auditor is required to confirm accounts receivable if the accounts receivable balances are

a. Older than the prior year. b. Material to the financial statements. c. Smaller than expected. d. Subject to valuation estimates.

(AICPA adapted) 7.63 During the confirmation of accounts receivable, an auditor receives a confirmation via the

client’s fax machine. Which of the following actions should the auditor take? a. Not accept the confirmation and select another customer’s balance to confirm. b. Not accept the confirmation and treat it as an exception. c. Accept the confirmation and file it in the working papers. d. Accept the confirmation but verify the source and content through a telephone call to the

respondent. (AICPA adapted)

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7.64 Control Objectives and Procedures Associations. The following exhibit contains an arrangement of examples of transaction errors (lettered a–g) and a set of client control procedures and devices (numbered 1–15). Make a copy of the exhibit page and complete the following requirements.

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Exercises and Problems

a. Sales recorded, goods not shipped b. Goods shipped, sales not recorded c. Goods shipped to a bad credit risk customer d. Sales billed at the wrong price or wrong quantity e. Product line A sales recorded as Product line B f. Failure to post charges to customers for sales g.

1. 2. 3. 4. 5. 6. 7. 8. 9.

10.

11. 12.

13.

14. 15.

January sales recorded in December CONTROL PROCEDURES

Sales order approved for credit Prenumbered shipping doc prepared, sequence checked Shipping document quantity compared to sales invoice Prenumbered sales invoices, sequence checked Sales invoice checked to sales order Invoiced prices compared to approved price list General ledger code checked for sales product lines Sales dollar batch totals compared to sales journal Periodic sales total compared to same period accounts receivable postings Accountants have instructions to date sales on the date of shipment Sales entry date compared to shipping doc date Accounts receivable subsidiary totaled and reconciled to accounts receivable control account Intercompany accounts reconciled with subsidiary company records Credit files updated for customer payment history Overdue customer accounts investigated for collection

EXHIBIT

Required: a. Opposite the examples of transaction errors lettered a–g, write the name of the transac-

tion assertion clients wish to achieve to prevent, detect, or correct the error. b. Opposite each numbered control procedure, place an “X” in the column that identifies

the error(s) the procedure is likely to control by prevention, detection, or correction. 7.65 Assertion Associations. The exhibit in Exercise 7.64 contains an arrangement of examples

of transaction errors (lettered a–g) and a set of client control procedures and devices (num- bered 1–15).

Required: For each error/control objective, identify the assertion about classes of transactions and events most benefited by the control.

7.66 Client Control Procedures and Audit Tests of Controls. The exhibit in Exercise 7.64 contains an arrangement of examples of transaction errors (lettered a–g) and a set of client control procedures and devices (numbered 1–15).

Required: For each client control procedure numbered 1–15, write a test of controls that could produce evidence on the question of whether the client’s control procedure has been implemented and is in operation.

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7.67 Confirmation of Trade Accounts Receivable. L. King, CPA, is auditing the financial state- ments of Cycle Company, a client that has receivables from customers arising from the sale of goods in the normal course of business. King is aware that the confirmation of accounts receivable is a generally accepted auditing procedure.

Required: a. Under what circumstances could King justify omitting the confirmation of Cycle’s

accounts receivable? b. In designing confirmation requests, what factors are likely to affect King’s assessment of

the reliability of confirmations that King sends? c. What alternative procedures could King consider performing when replies to positive

confirmation requests are not received? (AICPA adapted)

7.68 Audit Objectives and Procedures for Accounts Receivable. In the audit of accounts receivable, auditors develop specific audit assertions related to the receivables. They then design specific substantive procedures to obtain evidence about each of these assertions. Here is a selection of accounts receivable assertions: a. Accounts receivable represent all amounts owed to the client company at the balance

sheet date. b. The client company has a legal right to all accounts receivable at the balance sheet date. c. Accounts receivable are stated at net realizable value. d. Accounts receivable are properly described and presented in the financial statements.

Required: For each of these assertions, select the following audit procedure (numbered 1–7) that is best suited for the audit plan. Select only one procedure for each audit objective. A procedure may be selected once, not at all, or more than once. 1. Analyze the relationship of accounts receivable and sales and compare with relationships

for preceding periods. 2. Perform sales cutoff tests to obtain assurance that sales transactions and corresponding

entries for inventories and cost of goods sold are recorded in the same and proper period. 3. Review the aged trial balance for significant past due accounts. 4. Obtain an understanding of the business purpose of transactions that resulted in accounts

receivable balances. 5. Review loan agreements for indications of whether accounts receivable have been fac-

tored or pledged. 6. Review the accounts receivable trial balance for amounts due from officers and

employees. 7. Analyze unusual relationships between monthly accounts receivable and monthly

accounts payable balances. 7.69 Overstated Sales and Accounts Receivable. This case is designed like the ones in the

chapter. Your assignment is to write the “audit approach” portion of the case, organized around these sections: Objective. Express the objective in terms of the facts supposedly asserted in financial records, accounts, and statements. Control. Write a brief explanation of desirable controls, missing controls, and especially the kinds of “deviations” that might arise from the situation described in the case. Tests of controls. Write some procedures for getting evidence about existing controls, especially procedures that could discover deviations from those controls. If there are no controls to test, then there are no procedures to perform; go then to the next section. A “procedure” should instruct someone about the source(s) of evidence to tap and the work to do. Audit of balance. Write some procedures for getting evidence about the existence, complete- ness, valuation, ownership, or disclosure assertions identified in the objective section you wrote. Discovery summary. Write a short statement about the discovery you expect to accomplish with your procedures.

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Ring around the Revenue Mattel toy manufacturing company had experienced several years of good business. Income had increased steadily, and the common stock was a favorite among investors. Management had confidently predicted continued growth and prosperity. However, business turned worse instead of better. Competition became fierce.

In earlier years, Mattel had accommodated a few large retail customers with the practice of field warehousing coupled with a “bill and hold” accounting procedure. These large retail customers executed noncancelable written agreements, asserting their purchase of toys and their obligation to pay. The toys were not actually shipped because the customers did not have available warehouse space. The toys were set aside in segregated areas on the Mat- tel premises and identified as the customers’ property. Mattel would later ship the toys to various retail locations upon instructions from the customers. The “field warehousing” was explained as Mattel’s serving as a temporary warehouse and storage location for the custom- ers’ toys. In the related bill and hold accounting procedure, Mattel prepared invoices billing the customers, mailed the invoices to the customers, and recorded the sales and accounts receivable.

When business took a downturn, Mattel expanded its field warehousing and its bill and hold accounting practices. Invoices were recorded for customers who did not execute the written agreements used in previous arrangements. Some customers signed the noncancel- able written agreements with clauses permitting subsequent inspection, acceptance, and determination of discounted prices. The toys were not always set aside in separate areas, and this failure later gave shipping employees problems with identifying shipments of toys that had been “sold” earlier and those that had not.

Mattel also engaged in overbilling. Customers who ordered closeout toys at discounted prices were billed at regular prices, even though the customers’ orders showed the dis- counted prices to which Mattel sales representatives had agreed.

In a few cases, the bill and hold invoices and the closeout sales were billed and recorded in duplicate. In most cases, the customers’ invoices were addressed and mailed to specific individuals in the customers’ management instead of the routine mailing to the customers’ accounts payable departments.

Audit trail. The field warehousing arrangements were well known and acknowledged in the Mattel accounting manual. Related invoices were stamped “bill and hold.” Customer orders and agreements were attached in a document file. Sales of closeout toys also were stamped “closeout,” indicating the regular prices (basis for salespersons’ commissions) and the invoice prices. Otherwise, the accounting for sales and accounts receivable was unex- ceptional. Efforts to record these sales in January (last month of the fiscal year) caused the month’s sales revenue to be 35 percent higher than the January of the previous year.

In the early years of the practice, inventory sold under the field warehousing arrange- ments (both regular and closeout toys) was segregated and identified. The shipping orders for these toys left the “carrier name” and “shipping date” blank, even though they were signed and dated by a company employee in the spaces for the company representative and the carrier representative signatures.

The lack of inventory segregation caused problems for the company. After the fiscal year- end, Mattel solved the problem by reversing $6.9 million of the $14 million bill and hold sales. This caused another problem because the reversal was larger than the month’s sales, causing the sales revenue for the first month of the next year to be a negative number!

Amount. Company officials gave persuasive reasons for the validity of recognizing sales revenue and receivables on the bill and hold procedure and field warehousing. After con- sidering the facts and circumstances, the company’s auditors agreed that the accounting practices appropriately accounted for revenue and receivables.

Mattel’s abuse of the practices caused financial statements to be materially misstated. In January of the year in question, the company overstated sales by about $14 million, or 5 percent of the sales that should have been recorded. The gross profit of $7 million on these sales caused the income to be overstated by about 40 percent.

7.70 Systems Application—Receivables Confirmation. You are using computer audit software to prepare accounts receivable confirmations during the annual audit of the Eastern Sunrise Services Club. The company has the following data files: Master file—debtor credit record. Master file—debtor name and address.

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Master file—account detail: Ledger number. Sales code. Customer account number. Date of last billing. Balance (gross). Discount available to customer (memo account only). Date of last purchase.

The discount field represents the amount of discount available to the customer if the customer pays within 30 days of the invoicing date. The discount field is cleared for expired amounts during the daily updating. You have determined that this is properly executed.

Required: From the data files shown, list the information that you would include on the confirmation requests. Identify the file from which the information can be obtained.

7.71 Rock Island Quarry—Evidence Collection in an Online System. Your firm has audited the Rock Island Quarry Company for several years. Rock Island’s main revenue comes from selling crushed rock to construction companies from several quarries owned by the company in Illinois and Iowa. The rock is priced by weight, quality, and crushed size.

Past procedure. Trucks owned by purchasing contractors or by Rock Island needed to display a current certified empty weight receipt or be weighed in. The quarry yard weigh master recorded the empty weight on a handwritten “scale ticket” along with the purchasing company name, the truck number, and the date. After the truck was loaded, it was required to leave via the scale where the loaded weight and rock grade were recorded on the scale tickets. The scale tickets were sorted weekly by grade and manually recorded on a summary sheet that was forwarded to the home office. Scale tickets were prenumbered and an accoun- tant in the home office checked the sequence for missing numbers.

Audit procedures for revenue (and receivables) involved evaluating the controls at selected quarries (rotated each year) and vouching a statistical sample of scale tickets to weekly summaries. Weekly summaries were traced through pricing and invoicing to the general ledger on a sample basis, and general ledger entries were vouched back to weekly summaries on a sample basis. Few material discrepancies were found.

New procedures. At the beginning of the current year, Rock Island converted to a local area network of personal computers to gather the information formerly entered manually on the scale ticket. This conversion was done with your knowledge but without your advice or input. Now all entering trucks must weigh in. The yard weigh master enters “NEW” on the terminal keyboard and a form appears on the screen that is similar to the old scale ticket except that the quarry number, transaction number, date, and incoming empty weight are automatically entered. Customer and truck numbers are keyed in. After the weigh-in, the weigh master enters “HOLD” through the terminal. The weight ticket record is stored in the computer until weigh-out.

When a truck is loaded and stops on the scale, the weigh master enters “OLD” and a direc- tory of all open transactions appears on the screen. The weigh master selects the proper one and enters “OUT.” The truck out-weighs and the rock weights are computed and entered automati- cally. The weigh master must enter the proper number for the rock grade but cannot change any automatically entered field. When satisfied that the screen weight ticket is correct, the weigh master enters “SOLD,” and the transaction is automatically transmitted to the home office computer, and the appropriate accounting database elements are updated. One copy of a scale ticket is printed and given to the truck driver. Rock Island keeps no written evidence of the sale.

Required: It is now midyear for Rock Island, and you are planning for this year’s audit. a. What control procedures (manual and computerized) should you expect to find in this

system for recording quarry sales? b. The computer programs that process the rock sales and perform the accounting reside

at the home office and at the quarries. What implication does this have for your planned audit procedures?

c. What are you going to do to gather substantive audit evidence now that there are no writ- ten scale tickets?

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7.72 Organizing a Risk Analysis. You are the director of internal auditing of a large municipal hospital. You receive monthly financial reports prepared by the accounting department, and your review of them has shown that total accounts receivable from patients has steadily and rapidly increased over the past eight months. Other information in the reports shows the following conditions: a. The number of available hospital beds has not changed. b. The bed occupancy rate has not changed. c. Hospital billing rates have not changed significantly. d. The hospitalization insurance contracts have not changed since the last modification 12

months ago. Your internal audit department audited the accounts receivable 10 months ago. The audit

file for that assignment contains financial information, a record of the risk analysis, docu- mentation of the study and evaluation of management and internal risk mitigation controls, documentation of the evidence-gathering procedures used to produce evidence about the existence and collectability of the accounts, and a copy of your report, which commented favorably on the controls and collectability of the receivables.

However, the current increase in receivables has alerted you to a need for another audit so that things will not get out of hand. You remember news stories last year about the manager of the city water system who got into big trouble because his accounting department double- billed all the residential customers for three months.

Required: You plan to perform a risk analysis to get a handle on the problem if one indeed exists. Write a memo to your senior auditor listing at least eight questions to use to guide and direct the risk analysis. (Hint: The questions used last year were organized under these headings: (1) Who does the accounts receivable accounting? (2) What information processing procedures and policies are in effect? and (3) How is the accounts receivable accounting done? This time, you will add a fourth category: What financial or economic events have occurred in the past 10 months?)

(AICPA adapted)

7.73 Study and Evaluation of Management Control. The study and evaluation of management risk mitigation control is not easy. First, auditors must determine the risks and the controls subject to audit. Then they must find a standard by which performance of the control can be evaluated. Next they must specify procedures to obtain the evidence on which an evaluation can be based. Insofar as possible, the standards and related evidence must be quantified. The following description gives certain information (in italics) that internal auditors would know about or be able to determine on their own. Fulfilling the requirement thus amounts to taking some information from the scenario and figuring out other things by using accountants’ and auditors’ common sense.

The Scenario Ace Corporation ships building materials to more than a thousand wholesale and retail cus- tomers in a five-state region. The company’s normal credit terms are net/30 days, and no cash discounts are offered. Fred Clark is the chief financial officer, and he is concerned about risks related to maintaining control over customer credit. In particular, he has stated two management control principles for this purpose: 1. Sales are to be billed to customers accurately and promptly. Clark knows that errors

will occur but thinks company personnel ought to be able to hold quantity, unit price, and arithmetic errors down to 3 percent of the sales invoices. He considers an invoice error of $1 or less not to matter. He believes prompt billing is important because cus- tomers are expected to pay within 30 days. Clark is very strict in thinking that a bill should be sent to the customer one day after shipment. He believes he has staffed the billing department well enough to be able to handle this workload. The relevant com- pany records consist of an accounts receivable control account; a subsidiary ledger that enters customers’ accounts by billing (invoice) date and credits and by date of payment receipts; a sales journal that lists invoices in chronological order; and a file of shipping documents cross-referenced by the number on the related sales invoice copy kept on file in numerical order.

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2. Accounts receivable are to be aged and followed up to ensure prompt collection. Clark has told the accounts receivable department to classify all customer accounts in catego- ries of (a) current, (b) 31–59 days overdue, (c) 60–90 days overdue, and (d) more than 90 days overdue. He wants this trial balance to be complete and to be transmitted to the credit department within five days after each month-end. In the credit department, prompt follow-up means sending a different (stronger) collection letter to each category, cutting off credit to customers over 60 days past due (putting them on cash basis), and giving the over-90-days accounts to an outside collection agency. These actions are sup- posed to be taken within five days after receipt of the aged trial balance. The relevant company records, in addition to the others listed, consist of the aged trial balance, copies of the letters sent to customers, copies of notices of credit cutoff, copies of correspon- dence with the outside collection agent, and reports of results—statistics of subsequent collections.

Required: Take the role of a senior internal auditor and write a memo to the internal audit staff to inform them about comparison standards for the study and evaluation of these two man- agement control policies. You also need to specify two or three procedures for gathering evidence about performance of the controls. The body of your memo should be structured as follows: 1. Control: Sales are billed to customers accurately and promptly.

a. Accuracy. (1) Policy standard . . . (2) Audit procedures . . .

b. Promptness. (1) Policy standard . . . (2) Audit procedures . . .

2. Control: Accounts receivable are aged and followed up to ensure prompt collection. a. Accounts receivable aging.

(1) Policy standard . . . (2) Audit procedures . . .

b. Follow-up prompt collection. (1) Policy standard . . . (2) Audit procedures . . .

7.74 Cash Receipts and Billing Control. The following narrative description of a company’s cash receipts and billing system is in the auditors’ audit files: Rural Building Supplies Inc. is a single-store retailer that sells a variety of tools, garden sup- plies, lumber, small appliances, and electrical fixtures. About half of the sales are to walk-in customers and about half to construction contractors. Rural employs 12 salaried sales asso- ciates, a credit manager, three full-time clerical workers, and several part-time cash register clerks and assistant bookkeepers. The full-time clerical workers are the cashier who handles the cash and the bank deposits, the accounts receivable supervisor who prepares invoices and does the accounts receivable work, and the bookkeeper who keeps journals and ledgers and sends customer statements. Their work is described more fully in the narrative.

Control Narrative Rural’s retail customers pay for merchandise by cash or credit card at cash registers when they purchase merchandise. A building contractor can purchase merchandise on account if approved by the credit manager. The credit manager bases approvals on general knowledge of the contractor’s reputation. After credit is approved, the sales associate files a prenum- bered charge form with the accounts receivable (A/R) supervisor to set up the contractor’s account receivable.

The A/R supervisor independently verifies the pricing and other details on the charge form by reference to a management-authorized price list, corrects any errors, prepares the sales invoice, and supervises a part-time employee who mails the invoice to the contractor. The A/R supervisor electronically posts the details of the invoice in a customer database, and the computerized system simultaneously transmits the transaction details to the book- keeper. The A/R supervisor also prepares (1) a monthly computer-generated A/R subsidiary

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ledger without reconciliation to the A/R control account and (2) a monthly report of overdue accounts.

The cashier performs the cash receipts functions, including supervising the cash regis- ter clerks. The cashier opens the mail, compares each check with the enclosed remittance advice, stamps each check “for deposit only,” and lists the checks on the deposit slip. The cashier then gives the remittance advices to the bookkeeper for recording. The cashier deposits the checks each day and prepares a separate deposit of the cash from the cash reg- isters. The cashier retains the verified bank deposit slips (stamped and dated at the bank) to use in reconciling the monthly bank statements. The cashier sends to the bookkeeper a copy of the daily cash register summary. The cashier does not have access to the bookkeeper’s journals or ledgers.

The bookkeeper receives information for journalizing and posting to the general ledger from the A/R supervisor (details of credit transactions) and from the cashier (cash reports). After recording the remittance advices received from the cashier, the bookkeeper electroni- cally transmits the information to the A/R supervisor for subsidiary ledger updating. Upon receipt of the A/R supervisor’s report of overdue balances, the bookkeeper sends monthly statements of account to contractors with unpaid balances. The bookkeeper authorizes the A/R supervisor to write off accounts as uncollectable six months after sending the first over- due notice. At this time, the bookkeeper notifies the credit manager not to approve additional credit to that contractor.

Required: Take the role of the supervising auditor on the Rural engagement. Your assistants pre- pared the narrative description. Now you must analyze it and identify the internal control weaknesses. Organize them under the heading of employee job functions: credit manager, accounts receivable supervisor, cashier, and bookkeeper. (Do not give advice about correct- ing the weaknesses.)

Optional Requirement: Discuss the possibilities for fraud you notice in this control system.

7.75 Tests of Controls and Errors/Frauds. The following four questions are taken from an internal control questionnaire. For each question, state (a) one test of controls procedure you could use to find out whether the control technique was really functioning and (b) what error or fraud could occur if the question were answered “no” or if you found the control was not effective. 1. Are blank sales invoices available only to authorized personnel? 2. Are sales invoices prenumbered and are all numbers accounted for? 3. Are sales invoices checked for the accuracy of quantities billed? Prices used? Mathemati-

cal calculations? 4. Are the duties of the accounts receivable bookkeeper separate from all cash functions? 5. Are customer accounts regularly balanced with the control account? 6. Do customers receive a monthly statement even when the ending balance on the account

is zero? 7.76 Revenue Recognition and Ethics. The following article was published in Newsday on

February 9, 2009:

Call for Probe of Ticket Sales Bruce Springsteen fans were victims of a “classic bait and switch” scam by the nation’s larg- est concert ticket seller, Senator Charles Schumer said yesterday, as he called for a federal investigation into the company, Ticketmaster. Schumer wants the Federal Trade Commission to look into whether the Ticketmaster website withheld the best tickets from the public and then shuttled fans to TicketsNow, a fully owned subsidiary. TicketsNow had the best seats available immediately—at sky-high prices—after Springsteen tickets went on sales at 10 A.M. on February 2. A federal investigation would look into whether Ticketmaster was instantly scalping the tickets, never giving fans a chance to buy them at face value, Schumer said. Customers who tried to buy tickets originally priced at $95 on Ticketmaster’s website were directed to Tick- etsNow where they were priced at more than $2,000. Since buying TicketsNow in February, Ticketmaster has faced similar criticism for its handling of Elton John tickets in Canada and numerous U.S. concert tours, including

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Radiohead. Law enforcement agencies in Connecticut and New Jersey have also launched investigations.*

Required: a. During the course of an audit, do you believe that the auditor should look into how rev-

enues are being generated? Do you think the auditors should have looked at the business practices of Ticketmaster?

b. Assume that Ticketmaster had properly accounted for the revenue it received from the Springsteen concert. Should the auditors have asked Ticketmaster to make adjustments or disclosures regarding its sales practices?

c. Should Ticketmaster disclose the investigations being conducted in Connecticut and New Jersey?

7.77 Substantive Analytical Procedures You have been selected to audit football ticket revenues for the 2020 Championship State University (CSU) football season. Because CSU handles its own tickets, you cannot rely on internal counts of sold tickets to estimate ticket revenue. However, you do know all of the following facts:

∙ For the 2020 Football Season, unaudited ticket revenues are reported as $26,600,000. ∙ For the 2019 Football Season, total ticket sales were $18,900,000. Ticket prices for 2019

were $54 per ticket. During the 2019 season, there were 5 home games, 4 of which were in-conference games (average attendance 75,000) and 1 non-conference game against a smaller school opponent (attendance 50,000). CSU’s Stadium has a capacity of 88,300.

Your supervisor believes that this amount absolutely must be overstated due to the large increase, and he asks you to audit ticket revenues. Tolerable misstatement is set at $500,000 for this procedure. You realize that doing detailed tests of ticket sales would be cost prohibi- tive. You decide to perform analytical procedures on the reported revenues as a substantive procedure. You gather the following information:

∙ During the 2020 season, CSU had seven home football games. two of these games were non- conference games against a smaller school opponent, four were in-conference games, and the final game was against the the school’s biggest rival, which always sells out. You anticipate that average attendance at other games will be similar to comparable games from 2019.

∙ Ticket prices were increased to $56 for the 2020 season.

Required: a. Estimate 2020 season ticket revenue for Championship State University football. b. Based on your estimate, do you believe that ticket revenues are fairly stated in all material

respects? Why or why not? What further substantive procedures, if any, would you sug- gest your firm should perform?

c. The facts stated that you chose to use this analytical procedure as substantive audit evi- dence. Do Generally Accepted Auditing Standards allow you to use analytical procedures as substantive evidence? Note: See Exercises G.18 - G.23 for a similar scenario Data and Analytics applications of this exercise.

7.78 Authorization of Credit Tests of Controls—Using IDEA For this exercise, your client, Bright IDEAs Inc., has provided you with data for two related files, a listing of sales invoices, and a listing of customers with credit limits. To test whether credit authorization controls are in place, the auditor must complete a series of related steps: 1. Import the client’s database of sales invoices. 2. Summarize the Accounts Receivable balance by customer. 3. Import the client’s customer credit limit data into IDEA. 4. Join the Accounts Receivable balances by customer with the credit limit data. 5. Extract customers with exceeded credit limits. Required Data and IDEA workbook page references for current version are available on Connect

Mallia, Joseph. “Bruce Springsteen Fans Victim of ‘Bait and Switch,’ Schumer Says.” Newsday, February 8, 2009.

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Required: Complete the preceding steps and answer the following questions: a. How many customers were granted credit with no indication that they had any credit

limit assigned to them? b. How many customers exceeded their credit limit? c. What effects would the findings in parts (a) and (b) have on the auditor’s assessment of

the risk of material misstatement? What accounts and assertions are most likely influ- enced by these findings?

Source: C1202 IDEA Data Analysis Workbook: IDEA Version Ten. 2016. CaseWare IDEA, Inc. Toronto, CA.

Applying IDEA to the Revenue Cycle—Elm Manufacturing Company Exercises 7.78, 7.79, and 7.80 require the application of IDEA in the revenue cycle audit. Elm Manufacturing Company (ELM) is a small manufacturer of backpacks located in Rochelle, Illinois. You have access to ELM’s electronic records on Connect. The appropri- ate file for these exercises is the Sales 2020 – 4th Q dataset. Detailed information about ELM, instructions for accessing datasets, and a data directory for data sets can be found on Connect.

7.79 Tests of Control Exceptions with IDEA. You have identified relevant controls for several assertions within the revenue cycle, and you must use IDEA to perform several tests of controls.

Required: a. ELM has a policy of using prenumbered customer order forms to help control for the

completeness assertion. Inquiry of the client determined that order forms 17001–17405 were used during the quarter. Using IDEA, create a schedule of missing customer order forms. How many missing order forms were there?

b. Each customer order should be entered into the system once and only once. Using IDEA, search for duplicate customer order forms. What is the total dollar amount of duplicate orders?

c. To assist with the collectability of accounts receivable, ELM has a policy that all cus- tomer orders must be approved and marked as approved in the order system. Create a schedule of exceptions to this policy.

d. To ensure the posting of sales in a timely manner and increase the collectability of accounts receivable, ELM has a policy to always invoice customers within two days of shipping. Create a schedule of exceptions to the invoicing policy.

e. Draft a memo outlining the findings of your tests of controls. Address not only your find- ings, but also the effects of your findings on your assessment of control risk related to specific financial statement assertions.

7.80 Tests of Controls with IDEA—Payment Receipts. Use the information related to ELM’s payment and discount policy (referenced earlier) to analyze the company’s discount program and late payments. All dates for payments are based off the date the customer is invoiced.

Required: a. Are there any companies that made their payments after the stated due date? How many

companies, and what is the total dollar amount of the payments? (Hint: Each company has a two-day grace period beyond the stated due date.)

b. Refer to ELM’s discount policy. Are any companies receiving discounts when the invoice terms indicate they should never be eligible for discounts? What is the total dollar amount of the discounts taken by these companies? (Hint: This refers to the terms of the invoices, not whether these companies paid too late to receive discounts.)

c. Refer to ELM’s discount policy. Are there any companies receiving discount percentages greater than the amount accounting to the policy?

d. Are any companies taking the discount even if they are not paying within the 10-day period? (Hint: Each company has a two-day grace period beyond the stated discount period.)

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7.81 Testing the Valuation Assertion with IDEA—Aging Accounts Receivable. You have been instructed to create an aging schedule for ELM’s accounts receivable using IDEA. For the purposes of this exercise, assume the aging begins on the date that the customer is invoiced and should only include valid accounts receivable (e.g., amounts not yet fully paid by the customer). You can assume that rounding differences on discounts taken by custom- ers are considered to be fully paid. Your senior has instructed you to create a schedule with the following tranches: Current, 0–30 days delinquent, 31–60 days delinquent, 60+ days delinquent.

Required: a. Create an aged accounts receivable according to your senior’s instructions. Assume

there are no receivables still outstanding prior to January 1, 2020. Note that the data set includes all orders received between January 1, 2020, and March 31, 2020. This includes orders that have already been paid for, orders received at the end of March that were shipped but have not been invoiced, and orders that have been received that have not shipped. These orders would not be considered a receivable as of March 31; therefore, these items need to be excluded from the data for this schedule and in other requirements within this assignment.

b. What is the total amount of accounts receivable as of March 31, 2020? c. What is the total amount of accounts receivable that are past due less than 30 days?

Recall that invoices are due n/30, thus they become past due 30 days after invoice date. d. What is the total amount of accounts receivable that are more than 30 days past due?

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Apollo Shoes Accounts Receivable Audit You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Water- shed and have been assigned to the engagement team of a new audit client, Apollo Shoes Inc. You have been asked to perform certain procedures for the audit of the accounts receivable. Detailed instructions for performing the accounts receivable audit, as well as working papers and supporting documents, can be found in Connect.

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Appendix 7A

Internal Control Questionnaires

EXHIBIT 7A.1 Internal Control Questionnaire—Revenue and Collection Cycle

Yes/No Comments

Occurrence  1. Is the customer database maintained by someone who does not have access to cash?  2. Is access to sales invoice blanks restricted?  3. Are prenumbered bills of lading or other shipping documents prepared or completed in the shipping

department?  4. Are customers’ statements mailed monthly by the accounts receivable department?  5. Are direct confirmations of accounts and notes obtained periodically by the internal auditor?  6. Are differences reported by customers routed to someone outside the accounts receivable department for

investigations?  7. Are returned goods checked against receiving reports?  8. Are returned sales credits and other credits supported by documentation as to receipt, condition, and quantity

and approved by a responsible officer?  9. Are write-offs, returns, and discounts allowed after discount date subject to approval by a responsible officer? 10. Are large loans or advances to related parties approved by the directors? Completeness 11. Are sales invoice forms prenumbered? 12. Is the sequence checked for missing invoices? 13. Is the numerical sequence for shipping documents checked for missing bills of lading numbers? 14. Are credit memo documents prenumbered and the sequence checked for missing documents? Accuracy 15. Is customer credit approved before orders are shipped? 16. Are delinquent accounts listed periodically for review by someone other than the credit manager? 17. Is the credit department separated from the sales department? 18. Are sales prices and terms based on approved standards? 19. Are shipped quantities compared to invoice quantities? 20. Are sales invoices checked for error in quantities, prices, extensions and footings, and freight allowances and

checked with customers’ orders? 21. Do the internal auditors confirm customer accounts periodically to determine accuracy? 22. Does someone reconcile the accounts receivable subsidiary to the control account regularly? Cutoff 23. Does the accounting manual contain instructions to date sales invoices on the shipment date? Classification 24. Does the accounting manual contain instructions for classifying sales? 25. Are summary journal entries approved before posting? 26. Are sales of the following types controlled by the same procedures described: sale to employees, cash-on-

delivery sales, disposals of property, cash sales, and scrap sales? 27. Are receivables from officers, directors, and affiliates identified separately in the accounts receivable records?

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EXHIBIT 7A.2 Internal Control Questionnaire—Sales and Accounts Receivable System Controls

Yes/No Comments

1. Does each terminal perform only designated functions? For example, the terminal at the shipping dock cannot be used to enter initial sales information or to access the payroll database.

2. Are an identification number and password (issued on an individual person basis) required to enter the sale and each command that a subsequent action has been completed? Unauthorized entry attempts are logged and immediately investigated. Furthermore, certain passwords have “read-only” (cannot change any data) authorization. For example, the credit manager can determine the outstanding balance of any account or view online “reports” summarizing overdue accounts receivable but cannot enter credit memos to change the balances.

3. Is all input information immediately logged to provide restart processing should any terminal become inoperative during the processing?

4. Does a transaction code call up on the terminals a full-screen “form” that appears to the operator in the same format as the original paper documents? Each clerk must enter the information correctly or the computer will not accept the transaction. This is called online input validation and utilizes validation checks such as missing data, check digit, and limit tests.

5. Are all documents prepared by the system numbered with the number stored as part of the sales record in the accounts receivable database?

6. Is a daily search of the pending order database made by the system with sales orders outstanding more than seven days listed on the terminal in marketing management?

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Audit Plan

Appendix 7B

EXHIBIT 7B.1

DUNDER-MIFFLIN INC. Audit Plan for Tests of Controls in the Revenues and Collection Cycle

12/31/17

Performed By Ref.

Sales 1. Select a sample of recorded sales from the sales journal. a. Vouch to supporting shipping documents. b. Vouch to supporting sales order. c. Inspect sales orders for credit approval. d. Vouch prices to the approved price list. e. Vouch the quantity billed to the quantity shipped. Recalculate the invoice arithmetic. g. Compare the shipment date with the sales journal record date. h. Trace the invoice to posting in the general ledger control account and in the correct customer’s account. i. Inspect for proper revenue account classification. 2. Select a sample of shipping documents from the shipping department file and trace shipments to entries in

the sales journal. 3. Scan recorded sales invoices and shipping documents for missing numbers in sequence.

Accounts Receivable 1. Select a sample of customers’ accounts from the accounts receivable database. a. Vouch recorded sales to supporting sales invoices. b. Vouch recorded payments to supporting cash receipts documents. 2. Select a sample of credit memos. a. Inspect for proper approval. b. Trace to posting in customers’ accounts. 3. Scan the accounts receivable control for postings from sources other than the sales and cash receipts

journals (e.g., general journal adjusting entries, credit memos). Vouch a sample of such entries to supporting documents.

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EXHIBIT 7B.2

DUNDER-MIFFLIN INC. Audit Plan for Accounts and Notes Receivable and Revenue

12/31/17

Performed By Ref.

A. Accounts and Notes Receivable 1. Obtain an aged trial balance of individual customer accounts. Recalculate the total and trace to the general

ledger control account. 2. Review the aging for large and unusual items. 3. Send confirmations to all accounts over $X.* Select a random sample of all remaining accounts for

confirmation. a. Investigate exceptions reported by customers. b. Investigate any confirmations returned by the post office as undeliverable. c. Perform alternative procedures on accounts that do not respond to positive confirmation requests.

(1) Vouch cash receipts after the confirmation date for subsequent payment. (2) Vouch sales invoices and shipping documents.

4. Review the adequacy of the allowance for doubtful accounts. a. Inquire of management regarding assumptions used in calculating the allowance for doubtful accounts. b. Vouch a sample of current amounts in the aged trial balance to sales invoices to determine whether

amounts aged current should be aged past due. c. Compare the current-year write-off experience to the prior-year allowance. d. Vouch cash receipts after the balance sheet date for collections on past due accounts. e. Obtain financial statements or credit reports and inquire of the credit manager about collections on large

past due accounts. f. Calculate an allowance estimate using prior relations of write-offs and sales, taking under consideration

current economic events. 5. Inspect the bank confirmations, loan agreements, and minutes of the board for indications of pledged,

discounted, or assigned receivables. 6. Inspect or obtain confirmation of notes receivable. 7. Recalculate interest income and trace to the income account. 8. Obtain management representations regarding pledge, discount, or assignment of receivables, and about

receivables from officers, directors, affiliates, or other related parties. 9. Review the adequacy of control over recording all charges to customers (completeness) audited in the sales

transaction test of controls audit plan. B. Revenue 1. Select a sample of sales recorded in the sales journal and vouch to underlying shipping documents. 2. Select a sample of shipping documents and trace to sales invoices. 3. Obtain production records of physical quantities sold and calculate an estimate of sales dollars based on

average sale prices. 4. Compare revenue dollars and physical quantities with prior-year data and industry economic statistics. 5. Select a sample of sales invoices prepared a few days before and after the balance sheet date and vouch to

supporting documents for evidence of proper cutoff. *The auditor will determine a threshold for large accounts based on performance materiality.

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LEARNING OBJECTIVES This chapter contains an overview of the cycle for the acquisition of goods and services as well as the expenditure of cash in connection with paying for purchases and acquisitions. This cycle affects more general ledger accounts than any other cycle.

Major accounts discussed include accounts payable, expenses, and long-term assets. For accounts payable, the focus shifts to the completeness assertion. A series of short cases is used to show the application of audit procedures when errors or fraud might be discovered. Payroll is a subcycle related to the acquisition and expenditure cycle and to the

Professional Standards Reference

Topic AU-C/ISA Section

PCAOB Reference

Consideration of Internal Controls in an Integrated Audit 265 AS 2201

Audit Documentation 230 AS 1215

Auditors’ Responses to Risks of Material Misstatement 240 AS 2301

Audit Planning 300 AS 2101

Identifying and Assessing the Risks of Material Misstatement 315 AS 2110

Materiality 320 AS 2105

Audit Considerations Relating to an Entity Using a Service Organization 402 AS 2601

Audit Evidence 500 AS 1105

External Confirmations 505 AS 2310

Substantive Analytical Procedures 520 AS 2305

Auditing Accounting Estimates 540 AS 2501

Written Representations 580 AS 2805

C H A P T E R 8

Acquisition and Expenditure Cycle

—Buddy Yates, director of WorldCom Inc. general accounting, to an employee asking for an explanation of a large accounting discrepancy

Show those numbers to the damn auditors and I’ll throw you out the

$%*@@ window.

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INTRODUCTION Rita Crundwell was the treasurer of Dixon, Illinois, a small town about two hours west of Chicago best known as the birth place of Ronald Reagan. Crundwell started working for the city in 1970 while still in high school. By 1983, she had gained such trust from city officials that they appointed her Dixon’s comptroller/treasurer. By the late 1980s, she con- trolled every aspect of the city’s money. She wrote the checks, made the deposits, requested the funds, and advised the city on the availability of funds for projects. Bank statements were sent to the city’s post office box that Crundwell controlled. On February 14, 2013, she was sentenced to more than 19 years in prison for embezzling more than $53 million using a special capital account that she established and only she knew existed.

In 1990, Crundwell created at First Bank South (now Fifth Third Bank) a special account called the Reserve Sewer Capital Development Account (RSCDA) on which she was the only authorized signer. The bank, which handled the other accounts for the city of Dixon, thought nothing of it. Crundwell was the treasurer and controller and, as such, was authorized to do the banking. She created false invoices for work requiring payments from the city’s capital development fund. The payments for these fictitious invoices were made payable to “Treasurer” and deposited in the RSCDA. Crundwell then wrote checks from the RSCDA to pay for all types of personal items. The fraud started in 1991 with a theft of $181,000. In 2008, the fraud netted Crundwell $5.8 million. During this time per- iod, Crundwell consistently counseled the city government on the need for spending cuts because of the lack of sufficient funds. For example, she turned down requests for addi- tional police equipment and slashed the budget for the municipal band (a city favorite) while she looted the town coffers.

Furthermore, the city of Dixon is governed by a commissioner form of government. In this system, members of the city council are not elected by district but to oversee a segment of the government (e.g., parks commissioner). The individual elected finance commissioner (a job paying $2,700 per year in 2012) has oversight responsibilities for the financial management and operations of the city. This is clearly a part-time position and may be filled with a person who does not have the required background to understand proper finance and accounting policies and procedures. So Crundwell, acting as trea- surer, controller, check writer, authorizer of funds, and keeper of the post office box, had little competent supervision.

The bulk of the stolen money went to fund Crundwell’s horse business, which, at the time of her arrest, had grown to 400 quarter horses. In addition, Crundwell had a stable on 6.9 acres of land; purchased an additional 88 acres for $540,000; built a

production cycle. A discussion of payroll controls and audit tests is included in Appendix 8C.

Your objectives are to be able to:

LO 8-1 Describe the acquisition and expenditure cycle, including typical source documents.

LO 8-2 Identify significant accounts and relevant assertions related to the acquisition and expenditure cycle.

LO 8-3 Discuss the risk of material misstatement in the acquisition and expenditure cycle.

LO 8-4 Identify important internal control activities present in a properly designed system to mitigate the risk of material misstatements

for each relevant assertion in the acquisition and expenditure cycle.

LO 8-5 Give examples of tests of controls to test the operating effectiveness of internal controls in the acquisition and expenditure cycle.

LO 8-6 Give examples of substantive procedures in the acquisition and expenditure cycle and relate them to assertions about significant account balances at the end of the period.

LO 8-7 Apply your knowledge to perform audit procedures in the acquisition and expenditure cycle and evaluate the findings of your tests.

LO 8-8 Describe the payroll cycle including risks, source documents, and controls (Appendix 8C).

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20,000-square-foot showing barn with an arena, office, and stall; purchased a $2 million motor home; and spent hundreds of thousands of dollars on jewelry. All on a salary that never exceeded $83,000. Townspeople thought the money came from the horse business.

At the time of her sentence, the judge commented, “You have much better compassion for your horses than the people of Dixon you were supposed to represent.”1 In a remark- able rarity, the city of Dixon was able to gain 100 percent restitution by selling the assets of Crundwell and by settling lawsuits against the bank, the CPA firm that performed the compilations, and the audit firm. The city used the money to pay down its debt. Accord- ing to the mayor, the city did not want any assets for which someone might say “we bought that with the Rita Crundwell money.”

As you can see from the Dixon example, manipulating expense accounts and payments can lead to significant misstatements and frauds. GAAP prescribes that expenses be charged to income to reflect the consumption of economic benefits. The FASB Statement of Concepts discusses three ways to recognize expenses:

1. When they can be matched with related revenues (e.g., cost of goods sold with sales) and those revenues are recognized.

2. In the period in which they are incurred. 3. When they are allocated to the future periods benefited by a “systematic and rational”

process (e.g., depreciation).2

It is imperative that the auditor understand these concepts of expense recognition and ascertain that the client is correctly applying the appropriate concept to the expense at hand and is properly valuing the expense.

ACQUISITION AND EXPENDITURE CYCLE: TYPICAL ACTIVITIES The basic acquisition and expenditure activities include (1) purchasing goods and services, (2) receiving the good or service, (3) recording the asset or expense and related liability, and (4) paying the vendor. (Note that paying the vendor was covered in Chapter 6.) See Exhibit 8.1 for the activities and transactions involved in an acquisition and expenditure cycle. The exhibit also lists the accounts and records typically found in this cycle. As you follow the exhibit, you can track the elements of internal control described in the follow- ing sections.

Purchasing Goods and Services 1 The expenditure cycle begins when an individual or department needs supplies, materi- als, equipment, or services. The individual or department requests these items by sending a purchase requisition, often electronically, to the purchasing department. The purchase requisition will include the name of the department asking for the items, a listing of the items being requested, an account number where the cost of the material is to be charged when received, and an authorization signature from someone with the authority to com- mit the department to that amount of expense. The requisition may also include a recom- mended vendor.

The purchasing department reviews the purchase requisition and, if everything is in order, seeks to order the items where the best price, quality, and appropriate delivery can be obtained. Generally, the vendor must be on the approved vendor list. The approved vendor list includes only vendors that have been inspected by the organization and are authorized for purchases. It often requires several departments to approve a vendor. Pur- chasing usually approves the vendor for appropriate pricing, payment terms, and deliv- ery; quality control may approve a vendor for both the quality of the product it makes

1www.forbes.com/sites/walterpavlo/2013/02/14/fmr-dixon-il-comptroller-rita-crundwell-sentenced-to-19-12-years-in-prison/; www.chicagomag.com/Chicago-Magazine/December-2012/Rita-Crundwell-and-the-Dixon-Embezzlement/. 2SFAC No. 5, “Recognition and Measurement in Finance Statements.”

LO 8-1 Describe the acquisition and expenditure cycle, including typical source documents.

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and its system of quality control used during the vendor’s manufacturing process; and production (or engineering) may approve the items as appropriate for its purposes on the purchasing company’s production line. There have been several frauds where only one person approved a vendor for inclusion on the approved vendor list. The individual was able to add to the list fictitious companies or disreputable firms willing to provide kick- backs to the individual.

There may be instances where material must be purchased from a vendor not on the approved vendor list. For example, the current vendors cannot deliver the needed material or a new part is required that cannot be manufactured by existing approved vendors. In this instance, there should be a process where multiple individuals and departments approve the purchase and steps must be taken to approve the vendor as soon as possible.

Once purchasing identifies the appropriate vendor for the purchase, a purchase order is sent to the selected vendor. In most companies, if a purchase or series of purchases from a vendor exceed a certain dollar amount, there is a requirement to receive bids from several vendors (usually at least three). The bidding process ensures that the company gets the best price, delivery, and payment terms. However, because of the large amounts at stake in this process (often multimillion-dollar orders), vendors may wish to get “an edge” in the process. To control for kickbacks, information leaks, and corruption, bids should come to someone other than the purchasing agent and be secured until the bidding process is complete. As a manager (or auditor), what would you think if one company was always the last bidder and its bids were always just below the second lowest bidder?

*Paying the vendor is discussed in the “Cash Disbursements” section of Chapter 6.

EXHIBIT 8.1 Acquisition and Expenditure Cycle

Custody (inventory)

Enter Accounts Payable

Receive Vendor Invoice

Receive Goods and Services

Custody (cash)

Purchase RequisitionChecks

Accounts Payable Master

File

Cash Disbursement

Transaction File

Asset and Expense

Accounts

Perpetual Inventory Record

Accounts/Records

Inventory/Raw Materials Prepaid Expenses Property, Plant, and Equipment Intangible Assets Accrued Liabilities Various Expenses Cash Accounts Payable

Receiving Report

Vendor Invoice

Purchase Order

Cash Disbursement

Start Here

Request for Purchases

Authorization Recording

To Vendor

Put goods in inventory Put services to use

To Vendor

Voucher

Invoice Receiving Report

Purchase Order Requisition

Check Copy

4*

3

2

1

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Often inventory is automatically ordered from approved vendors through automatic replenishment systems. When production plans indicate a need for the inventory, auto- matic links to the vendor results in a system-generated purchase order. Sometimes purchasing writes a blanket purchase order. For example, purchasing gives the vendor an order for 1 million parts; however, the purchase order tells the vendor to deliver 100,000 on the 10th of each month for the next 10 months. The company may get a discount for ordering a million parts, and the vendor has the flexibility to make the parts during slow times in its production schedule. Further, the company could give the vendor access to the inventory record for that particular item and instruct the vendor to monitor the inventory with the instructions that “every time the inventory drops below 10,000 parts deliver 100,000 parts as soon as possible but no longer than two weeks.”

Robert Watson, a top ingredient buyer for Kraft Foods, needed $20,000 to pay his taxes. He called a broker for SK Foods, a large California tomato processor that, for years, had been paying him bribes to get its products into Kraft factories. The check would soon be in the mail, the broker promised. “We’ll have to deduct it out of your commissions as we move forward,” he said, using the term “commis- sions” as a euphemism for bribes. Days later, U.S. government agents descended on Kraft’s offices near Chicago and confronted Watson. He admitted his role in the bribery scheme.

Prosecutors next took aim at SK Foods. They stated that, for years, SK Foods had shipped its customers millions of pounds of bulk tomato paste and puree that fell short of basic quality standards and falsified documen- tation to hide the practice. Bribes to purchasing agents at Kraft Foods and three other large food companies, along with the false documentation, masked shipments of old tomatoes or tomatoes with mold counts so high that the sale of the tomatoes should have been prohibited under U.S. laws. Source: “Bribes Let Tomato Vendor Sell Tainted Food,” The New York Times, February 24, 2010.

Do You Want Tomatoes on Your Salad?AUDITING INSIGHT

The purchasing department is an area of high-fraud risk because employees who have the authority to purchase assets and services for the company are in a unique position to take advantage of their authority to enrich themselves or their friends. The abuse can simply be giving business to vendors that do not supply the best quality or price to the company. This may occur because of a conflict of interest. An employee might have an ownership interest in a supplier, might receive a kickback (the vendor provides the pur- chasing agent a gift or payment), or the employee might set up a “shell” company (a com- pany created by the employee to provide fictitious invoices and receipt of payment). The abuse can extend to misdirecting purchases for the employee’s personal benefit. These abuses are difficult to detect because vendors are often reluctant to lose favor with pur- chasing decision makers.

Although expense fraud is often listed as one of the most common types of employee fraud in terms of number of incidents, many companies do not put in much effort to detect it. Why? On average, employees who commit expense fraud admit to stealing $100-$499 annually, an amount that may not justify detection costs and is much smaller than other types of employee frauds. As AI systems become better, detection and flagging of unusual expenses becomes easier. Further, expense frauds are nearly always less than materiality and are not a significant focus for auditors.

Nonetheless, an interesting aspect of expense fraud is that it happens at all. As one CEO, Alan Rich of Chrome River, says, “The fascinating human element of this is that usually the amount of money that people are steal- ing through expense fraud is small, but the risk they are taking for their personal lives and career is very large.”

Source: Andrew Sheivachman, “Why Companies Aren’t That Worried About Expense Fraud,” https://skift.com/2018/10/04/why-companies-arent-that- worried-about-expense-fraud/, October 4, 2018.

Is It Worth the Time to Detect It?AUDITING INSIGHT

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REVIEW CHECKPOINTS 8.1 What is a voucher? What is a voucher package? 8.2 How can purchasing managers use their position to defraud the company? What can be done to

prevent it? 8.3 Why is a “blind” purchase order used as a receiving report document?

Receiving the Goods or Services 2 When goods arrive at a company, the trucker will have a bill of lading that should include the purchase order number of the company receiving the delivery. It is imperative that the bill of lading be matched to the purchase order on file at receiving. If a company obtains a reputation for receiving any goods that show up at its receiving department, any “undeliver- able” item on a truck may find its way to the company’s receiving docks. After the delivery is verified as the company’s purchase, the receiving department inspects the goods received for quantity and quality and prepares a receiving report. The items are sent to the area des- ignated by the department that originally requisitioned the material (e.g., engineering may order a piece of equipment but want it delivered to the production facility). A receiving report is completed to indicate the quantity and description of the item. Receiving depart- ments should receive a “blind” purchase order that has all purchase information except the quantity, which is left blank for the receiving department to fill in after an independent inspection and count. Services are not “received” in this manner, but responsible persons indicate that the service was satisfactorily performed by signing the invoice or some other form that can be used like a receiving report to verify that the service was completed.

Recording the Asset or Expense and Related Liability 3 Accounts payable usually are recorded when the purchaser receives the goods or services ordered. The accounts payable department attaches a voucher to the purchase order, a vendor’s invoice, and a receiving report. The combined documents are often called the voucher package. The voucher shows the accounts that are debited and indicates who checked the invoice for proper date, price, math, and reconciled the purchase order, receiving report, and vendor invoice. After the voucher package has been completed, accountants enter the accounts (or vouchers) payable with debits to proper inventory, fixed asset, or expense accounts with a corresponding credit to accounts payable.

SIGNIFICANT ACCOUNTS AND RELEVANT ASSERTIONS

Obtain (or Retain)

Engagement

Engagement Planning

Risk Assessment

Reporting

STAGES OF AN AUDIT

Audit Evidence

Remember that an account or disclosure is significant if there is a reasonable chance that it could contain a material misstatement. The auditor identifies significant accounts and relevant assertions by applying the audit risk model.

We introduced the audit risk model in Chapter 4 and reviewed it in Chapter 7. There- fore, this chapter and subsequent chapters will not review the components of the model again. Instead, these chapters will focus on the use of the audit risk model in assessing risk and planning the engagement in the specific areas addressed in these chapters.

Exhibit 8.2 identifies the significant accounts and assertions in the expenditure cycle. In this cycle, the most significant risks usually relate to the completeness of expenditures

LO 8-2 Identify significant accounts and relevant assertions related to the acquisition and expenditure cycle.

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and the valuation of acquisitions. It is also possible that individuals will attempt to run personal expenses through accounts payable and receive reimbursement for the purchase of these items. Therefore, the validity of expenses is also a significant risk in the expen- diture cycle.

Accounts Payable In many ways, the purchasing process, including accounts payable, is the most important to the organization. If purchasing is not done well, manufacturers may need to cease pro- duction because of raw material shortages, retailers may have insufficient inventory for customer needs, and needed services may not be obtained. Purchasing and the subsequent receipt of goods and services gives rise to an accounts payable—the obligation to pay the vendor for the goods and services acquired. If accounts payable does not pay the vendor on time and for the proper amount, vendors may raise the price charged to that client to cover the cost of capital in the delayed payment, ask for orders to be paid in advance, or cease to provide products or services to the organization. We have already learned that audit firms will not do business with clients if the relationship is improper. Vendors may also decide not to do business with a customer who does not appropriately honor his or her obligations.

EXHIBIT 8.2 Significant Accounts and Assertions in the Expenditure and Acquisition Cycle

Significant Account Relevant Assertions

Accounts Payable Completeness Cutoff Existence Presentation Valuation

Expenses* Completeness Cutoff Accuracy Classification

* Expense valuation risk is especially high for services.

Aeropostale, a large fashion retailer, filed for Chapter 11 bankruptcy protection in a New York court and quickly closed 113 of its 739 U.S. stores and all 41 of its Canada stores. The bankruptcy filing comes after a dispute with one of its largest suppliers, MGF Sourcing, which demanded cash on delivery (C.O.D.).

Source: Nathan Bomey, “Aeropostale Files for Chapter 11 Bankruptcy” USA Today, May 5, 2016.

Give Me All Your MoneyAUDITING INSIGHT

There are three primary relevant assertions for accounts payable: completeness, cut- off, and valuation. Completeness and cutoff go hand-in-hand because management may desire to improve the books by not recording an obligation in the correct period. An incomplete listing of accounts payable at the end of the period lowers current liabilities (and corresponding expenses). Because vendors do need to be paid eventually, manage- ment may accomplish this by delaying the recording of accounts payable until the sub- sequent period—in other words, by closing the books early so end-of-period obligations become the obligations of the subsequent period. Accounts payable may also be under- stated. Obligations may not reflect the total cost of the purchase such as freight, tariff, and taxes. On large purchases, this may be substantial and may be the result of an error or an intentional act to reduce the accounts payable liability.

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Auditors should be cautious not to discount other assertions. While management would not intentionally create a fictitious accounts payable, the item may not reflect an obligation of the company. A vendor account may have been paid, but the payment has not been recorded in the proper account. The liability remains on the books but no longer reflects an obligation. Individuals may try to run personal expenses through the payable system. This is especially true in companies where the duties of authorization and cus- tody are not segregated. If this is the case, the payable does not represent an obligation of the firm and may be fictitious or an obligation of an employee.

Nathan Mueller’s wife was pregnant, and his $80,000 salary was not allowing him to pay all his bills. He believed if he could just catch up with the bills, then everything would be all right.

Mueller had the authority to approve checks up to $250,000 for his company ING. He had the ability to log onto the accounts payable system as someone else and issue checks made out to Universal. ING did business with an insurance company that had Universal as part of its name, and Mueller’s credit card company had Universal as part of its name. In June 2003, he ran a check for $1,100 to pay his credit card bill in order to “test his scheme.” Once that check went through and his credit card was paid, he transferred all his outstanding debt to that credit card and, over several months, paid $88,000 in credit card debt.

According to Mueller, “in our small accounting department, we knew everyone else’s system passwords. This was a practical

workaround for when we needed to get something done when some- one was out of the office. We logged in as someone else to get the job done.” Eventually, Mueller logged on to the system as someone else and requested a check for Ace Business Consulting. (Remember, service expenses are easier for fraudsters.) The check request was routed to Mueller for approval. He received his first check for $27,000 a few days later and deposited it in a bank account he opened in the name of Ace Business Consulting. Using this method, he stole approxi- mately $8 million from 2004 to 2007. According to Mueller, after get- ting his $88,000 “bonus” he couldn’t help himself. “I wanted to do it again, even though I didn’t really need the money like before.”

Source: Mark J Nigrini, and Nathan J. Mueller, “Lessons from an $8 Million Fraud: What the Criminal Was Thinking and What Can Be Done to Prevent or Uncover Similar Crimes,” Journal of Accountancy, August 2014, pp. 32–37.

Would You Like Me to Pay Your Credit Card Bill?AUDITING INSIGHT

Expenses The corresponding entry to the accounts payable is often an expense account. Because expenses affect the income statement, the misstatement of expenses is often the objective of misstating a purchase or payable. Again, not recording expenses in the current period or delaying the recognition of expenses to the subsequent period is often the method for financial statement fraud. Closing the books early for expenses (say, December 22 for December 31 year-end clients) forces ensuing expenses into the next period. Further, an unethical controller might lock in her desk several large bills received near the year-end and place them into the payables system after year-end, thereby violating the cutoff assertion.

Another issue for expenses is classification. There may be many reasons to classify expenses in the wrong account. WorldCom Inc. is an example of a company that sim- ply placed ordinary expenses in capital accounts, thus lowering expenses and increasing assets by billions of dollars. While capitalizing expenses increases net income in the year in which they should have been completely expensed, the expenses do not go away. (Amounts would be expensed over a number of years as depreciation or amortization expense.) When forced to restate these expenses, WorldCom recorded nearly $5 billion in immediate recognition of expenses. WorldCom is just one of many companies that used expenses to inflate their financial statements. Exhibit 8.3 shows some of the more egre- gious misstatements in recent years.

Other reasons may exist for improper classification of expenses. For example, some projects are performed under cost-plus contracts. These are often large construction projects, such as military ship building, where changes to the contract specifications are expected during construction. Here, the construction company submits bills for material and labor and is reimbursed for all expenses and paid a set percentage over the costs (say, an 8 percent profit). There may be little incentive for a disreputable contractor to restrain costs and few restrictions for a dishonest contractor to place costs from one project to another as in the following Auditing Insight.

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EXHIBIT 8.3 Cost and Expense Capers

Company Alleged Fraud Strategy Restatement Amount

MCI (WorldCom) The telecommunications company improperly capitalized expense items. $11 billion

Waste Management Inc. The waste disposal giant used “top-level adjustments” to improperly eliminate and defer current-period expenses and avoided depreciation on garbage trucks by assigning unsupported, inflated, and arbitrary salvage values and extending the useful lives.

$1.1 billion

Adelphia Communications Corporation

The cable company did not report off-balance-sheet liabilities. $210.0 million

Orbital Sciences Corporation

The satellite manufacturer improperly capitalized costs. $124.0 million

Aurora Food, Inc. The food company did not record trade-marketing expenses (e.g., case discounts to induce grocery stores to stock its goods).

$81.5 million

Dixon, Illinois The treasurer/controller created a fictitious account that she used to pay for her personal expenses.

$53.0 million

Collins and Aikman The automotive supply company booked rebates as lump sums that should have been spread out over time.

$16.0 million

REVIEW CHECKPOINTS 8.4 Why do auditors focus on completeness of expenditures as a significant account and relevant

assertion in the expenditure cycle? 8.5 Why is inherent risk for the existence of inventory an issue in the expenditure cycle audit? 8.6 Why is a service expense a good account for recording a fictitious expense?

Auston International Group’s former chief financial officer, Chua Peck Wee, was sentenced to seven months in jail for playing a part in the falsification of the company’s accounts four years ago. Chua is the first to be convicted and sentenced out of three parties who have been charged in connection with the Auston accounting fraud.

The former CFO admitted creating false documents and sending them to the Auston accounts staff, with instructions to record a pay- ment of $268,525 as “academic cooperation fees” to Upper Iowa University for FY2003. This amount was actually a payment made by Auston to the University of Wollongong for university fees for FY2002.

By falsely recording the amount as academic cooperation fees instead of university fees, Auston could classify it as a development cost and amortize the amount over three to five years instead of having to record the full amount as an expense in FY2002. The falsification reduced the amount of expenses recorded for FY2002 and increased the net profit Auston reported in its initial public offering (IPO) pro- spectus in 2003.

Source: Michelle Quah, “Ex-Auston CFO Gets Seven Months’ Jail; This Comes after Chua Pleaded Guilty to One Charge of Abetting Fraud,” The Business Times Singapore, January 12, 2007.

My Money Went to Higher EducationAUDITING INSIGHT

RISK OF MATERIAL MISSTATEMENT Audit Analytics reported that, for 2018, there were 54 financial statement restatements for expenses (including general and administrative expenses, payroll, and related liabilities). This accounted for 10.5 percent of all restatements and ranked as number 6 on the list of reasons for financial statement restatements. The Audit Analytics report indicates that restatements as

LO 8-3 Discuss the risk of material misstatement in the acquisition and expenditure cycle.

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a whole have declined since 2007 (a finding attributed to the PCAOB rigorous inspections), with expense recognition errors continuing to decrease over time (104 in 2014; 236 in 2007).3

In many accounting systems, liabilities are not recorded until receiving reports have been matched to purchase orders and invoices. This is often referred to as a “three-way match,” and is perhaps the most important control in the purchasing cycle. Often, when there is a problem in matching the documents, the recording of the liability is delayed or not recorded, thus understating costs and overstating profits. Further, in an attempt to make the financial statements appear better, management may decide to delay the record- ing of expenses and related liabilities until after the fiscal year-end. Additionally, noncan- celable purchase agreements may exist where goods are ordered for future delivery (as with blanket purchase orders). If market forces or technology causes a permanent decline in the value of those goods, the company must recognize any related losses immediately, even though no liability or expense exists because the goods have not been received. Therefore, risks in the acquisition and expenditure cycle include unrecorded liabilities and noncancelable purchase agreements.

Remember from Chapter 7 that as part of the planning process, the auditor must deter- mine the source of a misstatement that could cause the financial statements to be materi- ally misstated. We established the idea of assessing the risk of material misstatement by using the “what could go wrong?” approach when thinking of each financial statement assertion. The WCGW is a part of each audit firm’s process and enables a thorough assessment of the risk of material misstatement.

When considering WCGW in the expenditure and acquisition cycle, auditors consider five primary concerns:

1. Have liabilities and corresponding expenses or assets been recorded (completeness)? 2. Have liabilities and corresponding expenses or assets been recorded in the proper per-

iod (cutoff)? 3. Do liabilities reflect the actual needs and obligations of the company (occurrence and

obligation)? 4. Have liabilities and corresponding expenses or assets been recorded at their proper

amount (valuation)? 5. Have expenses been recorded in the proper account (classification)?

Exhibit 8.4 summarizes the WCGW analysis for the expenditure and acquisition cycle. We have seen in several of the Audit Insights multimillion-dollar accounts payable

schemes perpetrated to enhance the financial statements or for an employee’s benefit.

3Audit Analytics, “2017 Financial Restatements: A 17-Year Comparison,” May 2018.

EXHIBIT 8.4 Assertions and What Could Go Wrong

Significant Account Relevant Assertions What Could Go Wrong?

Accounts Payable Completeness Liabilities are not recorded.

  Cutoff Liabilities have been recorded in incorrect periods.

  Existence Liabilities may not represent actual obligations of the company.

  Presentation Liabilities are not recorded in the proper accounts and properly disclosed in the footnotes.

  Valuation Payables are recorded at an incorrect amount.

Various Expenses Completeness Not all expenses are recorded.

  Cutoff Expenses have not been recorded in incorrect periods.

  Accuracy Expenses are recorded at an incorrect amount.

  Classification Expenses have been improperly recorded as capitalized expenses.

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Clearly, these frauds can result in material misstatements. Remember, while large dollar frauds and errors that occur in well-known companies are widely reported in the financial news, most frauds are perpetrated in smaller companies where $100,000 may be the dif- ference between success and bankruptcy.

REVIEW CHECKPOINTS 8.7 What are the short-term effect and the long-term effect of improperly capitalizing expenditures on

the financial statements? 8.8 If an account payable is left off the end of the period balance, what are the possible other accounts

that may be misstated?

INTERNAL CONTROL ACTIVITIES AND DESIGN EVALUATION Control risk assessment is important because it governs the nature, timing, and extent of substantive procedures that will be applied in the audit of account balances in the acquisi- tion and expenditure cycle. The primary accounts discussed in this chapter are accounts payable and expenses, and the assertions and significant internal control activities are summarized in Exhibit 8.5. However, you should not lose sight of the fact that many other accounts are affected by activities in this cycle. These accounts include the following:

∙ Prepaid expenses ∙ Fixed assets ∙ Inventory ∙ Accrued liabilities ∙ Supplies

Entity-Level Controls It is important that auditors consider entity-level controls in all processes and procedures. In the expenditure process, management should have a process for continually review- ing expenses and comparing them to budgets and forecasts. Proper authorization for all expenditures should be established and included in company policy and procedures. Cor- porate values and ethics that have been established should be communicated to suppliers and other partners of the entity along with a place where inappropriate behavior (such as the solicitation of a bribe or kickback) may be reported. The security of items such as blank purchase orders and blank receiving reports is an important control, as are the proper delivery and safeguarding of all material received by the entity.

Control Considerations Control activities for proper separation of responsibilities should be in place and operating. By referring to Exhibit 8.1, you can see that proper separation involves different people and different departments performing the purchasing, receiving, and cash disbursement authorization; custody of inventory, fixed assets, and cash; record keeping for purchases and payments; and reconciliation of assets, cash, and accounts payable. Combinations of two or more of these responsibilities in one person, one office, or one computerized system can open the door for errors and frauds. Specifically, the persons authorizing pur- chases should not be responsible for recording them. Persons who actually handle the receipt and storage of goods should neither authorize nor account for them. The persons who sign checks should not prepare the vouchers, nor should they mail the checks.

In addition, the internal controls should provide for detailed control-checking activi- ties. For example, purchase requisitions and purchase orders should be signed or initialed

LO 8-4 Identify important internal control activities present in a properly designed system to mitigate the risk of material misstatements for each relevant assertion in the acquisition and expenditure cycle.

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EXHIBIT 8.5 Internal Control Activities in the Expenditure and Acquisition Cycle

Significant Account Relevant Assertion What Could Go Wrong? Internal Control Activity

Accounts Payable Completeness Liabilities are not recorded Receiving reports should be prenumbered and used in order. All receiving reports completed by the end of the period should be accounted for in that period.

  Cutoff Liabilities are recorded in the incorrect period. Payables recorded in the first weeks of a period should be compared to receiving reports and invoices for the recording period.

  Existence Liabilities may not represent actual obligations of the company.

Voucher packages for payments to vendors should include purchase orders and receiving reports. Vendors should be on the approved vendor list. A three-way match should be performed for purchase orders, receiving reports, and vendor invoices.

  Presentation Liabilities are not recorded in the proper accounts and properly disclosed in the footnotes

Chart of accounts used for classifying purchase transactions.

  Valuation Payables recorded at an incorrect amount. Vendor invoices are traced to approved price listing and tested for mathematical accuracy.

Expenses Completeness Not all expenses are recorded. Use of prenumbered vouchers, receiving reports, purchase order, and check and the numerical sequence is checked.

  Cutoff Expenses have been recorded in the incorrect period.

Comparison by managers of actual expenses with budgeted amounts.

  Accuracy Expenses are recorded at an incorrect amount. Expenses should be matched with vendor invoices or work orders for the proper cost of items or service performed.

  Classification Expenses have been improperly recorded in the wrong account.

Expenses should be reviewed to determine that they have been recorded in the proper account.

by authorized personnel. System-generated purchase orders should come from a system where master file specifications for reordering and vendor identification are restricted to changes by authorized persons.

Improper recording of expenses may occur intentionally, as illustrated by the follow- ing Auditing Insight, or may be due to a mistake in judgment as to the proper account- ing for invoices. Many accounting systems use automated processes for the recording of expenses. A three way match control is a common automated control to ensure the proper recording of expenses. When an approved purchase order, vendor invoice, and receiving report are all present in the system, an expense should be recorded automatically. The sys- tem generates exception reports which enable management to detect errors. For example, a listing of unmatched receiving reports should be produced by the system and evaluated by management to detect received items which may have incorrectly not been recorded. Similarly, a listing of unmatched vendor invoices can help prevent payment for fraudulent billings and also can detect missing receiving reports leading to unrecorded liabilities.

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REVIEW CHECKPOINTS 8.9 What primary functions should be separated in the acquisition and expenditure cycle?

8.10 What feature of the acquisition and expenditure control would be expected to prevent an employee’s embezzling cash through creation of fictitious vouchers?

A headline in the March 14, 2003, issue of The New York Times announced that WorldCom Inc. was going to write down assets by more than $70 billion to correct the company’s accounting records for a massive fraud that had been uncovered. To put this number in perspective, the amount of the write-off almost equaled the entire gross domestic product for the country of Ireland.

A large part of the restatement was a result of the company’s practice of capitalizing (rather than properly expensing) certain trans- actions to fixed asset accounts. The improper charges were not part of the regular system but were hidden in computerized files of adjusting entries to intercompany receivables. Only the determined pursuit of the facts led by the company’s director of internal audit and

2002 Time Person of the Year Cynthia Cooper uncovered the massive fraud. The  internal auditors’ search included midnight hacking into the computerized system to sort through hundreds of thousands of transactions—a process that discovered $2 billion of question- able items in the first week! When Andersen, the company’s public accounting firm, was first apprised of the problems, the firm allegedly told Cooper that it had approved some of the very accounting prac- tices she questioned. At the time of its discovery, the WorldCom fraud represented the largest fraud ever perpetrated in the United States.

Source: Simon Romero, “WorldCom to Write Down $79.8 Billion of Good Will,” The New York Times, March 14, 2003.

What Were Those Charges Again?AUDITING INSIGHT

Custody Access to inventory and other physical assets must be restricted by placing them in locked areas when possible. Responsibility must be established by having someone sign for receipt of the assets when they are moved. Cash “custody” rests largely in the hands of the person or persons authorized to sign checks.

Another aspect of custody involves access to blank documents such as purchase orders, receiving reports, and checks. If unauthorized persons can obtain blank copies of these internal business documents, they can forge a false purchase order to a fictitious vendor, forge a false receiving report, send a false invoice from a fictitious supplier, and receive a company check, thereby accomplishing embezzlement. In addition, a blank purchase order can be used to order merchandise, material, or services for personal use. If this material can be diverted and if sound controls are not in place, the company may end up paying for an employee’s home improvement project.

Periodic Reconciliation A periodic comparison or reconciliation of existing assets to recorded amounts is not shown in Exhibit 8.1, but it occurs in several ways, including the following:

∙ Preparing an accounts payable trial balance and comparing it to the accounts payable control account.

∙ Comparing accounts payable records to vendors’ monthly statements. ∙ Reviewing unmatched purchase orders, receiving reports, and invoices. ∙ Taking a physical inventory and comparing it to inventory records. ∙ Inspecting fixed assets and comparing them to detailed fixed asset records.

Information about the control system is often gathered by completing an internal control questionnaire. Appendix 8A provides examples of questionnaires for both manual controls and system controls. These questionnaires can be studied for details of desirable control activities. They are organized under headings that identify the management assertions.

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TESTING OF OPERATING EFFECTIVENESS OF INTERNAL CONTROL

Tests of Controls An organization should have controls in place and operating to prevent, detect, and cor- rect accounting errors. Arguably, the most risks in the expenditure cycle are in the pur- chasing activity. Purchasing itself is not an account (except in government accounting), but it does affect the occurrence and valuation of other accounts. Exhibit 8.6 continues with the example of some of the most important considerations in the expenditure and acquisition cycle and relates the test of controls to what could go wrong.

LO 8-5 Give examples of tests of controls to verify the operating effectiveness of internal controls in the acquisition and expenditure cycle.

EXHIBIT 8.6 Tests of Controls in the Expenditure and Acquisition Cycle

Significant Account

Relevant Assertion What Could Go Wrong? Internal Control Activity Tests of Internal Control

Accounts Payable

Completeness Liabilities are not recorded Receiving reports should be prenumbered and used in order. All receiving reports completed by the end of the period should be accounted for in that period.

Scan receiving reports for numerical sequence. Inspect evidence of management review of system-generated unmatched receiving reports output.

Cutoff Liabilities are recorded in the incorrect period.

Payables recorded in the first weeks of a period should be compared to receiving reports and invoices for the recording period.

Trace sample of recorded payables to related receiving reports and invoices.

Existence Liabilities may not represent actual obligations of the company.

Voucher packages for payments to vendors should include purchase orders and receiving reports. Vendors should be on the approved vendor list. A three-way match should be performed for purchase orders, receiving reports, and vendor invoices.

Vouch a sample of payments to vendors to completed three-way match. Trace vendors to approved vendor list.

Test automated system for accurate performance of three-way match procedure and managerial review of exception reports.

Presentation   Liabilities are not recorded in the proper accounts and properly disclosed in the footnotes.

Chart of accounts used for classifying purchase transactions

Observe that client reporting software includes a pre-populated chart of accounts.

Valuation Payables recorded at an incorrect amount.

Vendor invoices are traced to approved price listing and tested for mathematical accuracy.

Vouch prices to approved price listing. Observe client testing invoices for mathematical accuracy.

Expenses Completeness Not all expenses are recorded. Use of prenumbered vouchers, receiving reports, purchase order, and check and the numerical sequence is checked.

Inspect evidence of client verifying numerical sequence.

  Cutoff Expenses have been recorded in the incorrect period.

Comparison by managers of actual expenses with budgeted amounts.

Examine evidence that managers review actual versus budget and follow up on unusual amounts

  Accuracy Expenses are recorded at an incorrect amount.

Expenses should be matched with vendor invoices or work orders for the proper cost of items or service performed.

Inspect evidence of comparison between recorded expenses and vendor invoices.

  Classification Expenses have been improperly recorded in the wrong account.

Expenses should be reviewed to determine that they have been recorded in the proper account.

Inspect evidence of journal entry review procedures.

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Auditors can perform tests of controls to determine whether company controls actually are in place and operating effectively. Tests of controls consist of identification of (1) the control that will be relied on to reduce assessed control risk and (2) the data population from which a sample of items will be selected for audit. In general, the actions in tests of controls involve inspecting, inquiry, observing, scanning, matching, and recalculating.

An auditor might select a sample of voucher packages and inspect the documents for indications that reconciliations and approvals for payment are evident. If personnel in the organization are not performing control activities effectively, auditors need to design substantive procedures to try to detect whether control failures have produced materially incorrect account balances. Procedures such as matching, recalculating, and scanning for unusual items often can be performed electronically using computer-assisted audit techniques (CAATs). For example, CAATs can scan the accounts payable balances for debit balances. Exhibit 8.7 shows some additional control considerations in the purchas- ing cycle.

Tests of controls over occurrence involve tests of the additions to the expense accounts. The chart in Exhibit 8.8 shows the direction of the test for tests of controls in the acqui- sition and expenditure cycle. Selecting a sample of closed purchase orders, receiving reports, or vendor invoices and tracing them to the accounts payable journal provides evidence of completeness. At the same time, the auditor can inspect these documents for proper authorization. Taking a sample of payments to vendors and vouching those payments to the receiving report and purchase order provides evidence that the delivery occurred and the purchase existed. Further, vouching payments to receiving reports and purchase orders may find fictitious vendors (there is usually no receiving report because fictitious vendors don’t deliver product) or payments for employee personal use (often, the purchase order is missing or lacks the proper approval).

Summary: Control Risk Assessment The auditor should evaluate the evidence obtained from understanding internal controls and from the tests of controls. This evaluation of control risk along with the auditor’s understanding of the inherent risk leads to the auditor’s determination of the risk of mate- rial misstatement (RMM). If the control risk is assessed below the maximum, the sub- stantive procedures can be reduced in cost-saving ways. For example, if completeness controls are strong, only large items in purchases, accounts payable, cash disbursements, and fixed assets need to be examined in the search for unrecorded liabilities in accounts payable, and if occurrence controls are strong, vouching of expenses can be limited to sig- nificant items. On the other hand, if the tests of controls reveal weaknesses, the substan- tive procedures need to be designed to lower the detection risk for the account balances. For example, if completeness controls are weak, the auditor might send confirmation letters to vendors with small or zero balances. If occurrence controls are weak, the audi- tor may have to perform substantive tests of significant transactions by recalculating and testing a sample of payments for the period for monetary errors rather than just evidence of control effectiveness. Other substantive procedures that can be affected include vouch- ing of debits to assets and expenses.

REVIEW CHECKPOINTS 8.11 How should an auditor test for proper authorization in the expenditure cycle? 8.12 Where would an auditor find the proper authorization that indicates it is okay to pay a vendor?

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EXHIBIT 8.7 Purchasing Transactions and Events: Acquisition and Expenditure Cycle - Additional Control Activities and Tests of Controls

What Could Go Wrong? Controls Tests of Control

Completeness - Purchases received have not been properly recorded.

• Separation of duties between purchasing, receiving, and accounting

• Use of prenumbered vouchers, receiving reports, purchase orders, and checks and the numerical sequence checked

• Purchase orders supported by authorized requisitions.

• Purchases received are matched with receiving report and vendor invoices

• Purchases from approved vendors listed on an approved vendor list

• Overall comparisons of purchases by a statistical or product line analysis made periodically

• Comparison by managers of actual expenses with budgeted amounts

• Observe separation of duties. • Trace receiving reports to recording in

purchases journal. • Scan purchases journal for numerical

sequence of purchase orders and receiving reports.

• Scan cash disbursements journal for client checking sequence.

• Vouch purchase orders to requisitions and review requisitions for authorizations.

• Review and reconcile voucher packages for three-way match of purchase order, receiving reports, and invoice.

• Vouch purchase order to the approved vendor list, and review the purchase order for correct customer name, address, product description, terms, dates, and quantities.

• Examine evidence that managers review statistical analyses, and follow up on unusual relationships.

• Examine evidence that managers review actual versus budget, and follow up on unusual items.

Completeness - Purchase amounts and other data related to significant purchase transactions and events have not been recorded properly.

• Purchase contracts authorized at the appropriate level

• Comparison of invoice quantities and prices with purchase orders and receiving reports

• Vendor statements reviewed and approved by appropriate personnel

• Prices and mathematical accuracy independently checked before approving voucher for payment

• Journal entries reviewed at the appropriate level

• Individual accounts payable reconciled to general ledger

• Examine contracts for authorization. Inquire how accounting is notified of pending contracts.

• Observe client comparing receiving quantities, and inspect documentary evidence of comparison.

• Inspect evidence of client review of vendor statements.

• Recalculate price extensions and discounts. • Inspect evidence of approval for payment. • Inspect evidence of managerial review of

journal entries • Review reconciliation and support for

reconciling items.

Cutoff - Purchases have been recorded in the incorrect period.

• Date of receiving report compared with invoice date

• Trace the date of receipt to date recorded in voucher journal.

• Inspect evidence of client comparison of dates.

• Inspect purchases occurring near year-end for recording in appropriate period.

Classification - Purchases have not been recorded in the proper accounts.

• Purchases from subsidiaries and affiliates classified as intercompany purchases and payables

• Purchase returns and allowances properly classified

• Observe correct account classification for intercompany transactions.

• Inspect sample of purchase returns for appropriate accounting

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EXHIBIT 8.8 Direction of Tests

Receiving Reports

Vendor Invoices

Did all recorded purchases actually

occur?

Did all invoiced purchases actually

occur?

Vouch sample of purchases to

vendor invoices (occurrence)

Vouch sample of vendor invoices

to receiving reports

(occurrence)

Trace sample of receiving reports

to vendor invoices (completeness)

Trace sample of vendor invoices to purchases journal

(completeness)

Were all receipts invoiced by the

vendors?

Were all vendor invoices

recorded?

Purchases Journal (voucher register)

SUBSTANTIVE ANALYTICAL PROCEDURES AND TESTS OF DETAILS

Obtain (or Retain)

Engagement Engagement

Planning

Risk Assessment AuditEvidence Reporting

STAGES OF AN AUDIT

Recall that management can always override controls. For this reason, the high fraud risk in the Revenue and Collection cycle leads to a strong need for substantive procedures. Although employee expenditure fraud is fairly common in the expense cycle, financial reporting fraud is considered to be a lower risk compared with the revenue cycle. The pri- mary reason for this is that purchasing activities are not considered as important a metric to many outside users, thus management incentives to manipulate purchases are lower. In some ways, however, it is easier for errors to occur in the purchasing cycle because many different vendors, billing processes, and departments within the company are involved in purchasing goods and services. Thus, the audit approach in the purchasing cycle is one that relies almost entirely on testing controls within the system, and far less on proce- dures. For this reason, we do not present a table of substantive procedures as we did for the sales cycle. In fact, much of the substantive evidence obtained in the purchasing cycle is obtained through testing three-way match controls and system-generated exception reports. These procedures can sometimes result in testing 100% of purchase transactions as described in the following auditing insight.

LO 8-6 Give examples of substantive procedures in the acquisition and expenditure cycle and relate them to assertions about significant account balances at the end of the period.

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The Completeness Assertion When considering assertions and obtaining evidence about accounts payable and other liabilities, auditors must emphasize the completeness assertion. (Remember from Chap- ter 7 that the emphasis is on the existence assertion for asset and occurrence for revenue accounts.) This emphasis on completeness is rightly placed because financial statement users are typically more concerned if a company understates expenses and liabilities than if management overstates those accounts.

Evidence is much more difficult to obtain to support the completeness assertion than the existence assertion. Auditors cannot rely entirely on a management assertion of com- pleteness, even in combination with a favorable assessment of the risk of material mis- statement. The search for unrecorded liabilities is the set of procedures designed to yield audit evidence of liabilities that were not recorded in the reporting period. Such a search normally should be performed from the audit client’s balance sheet date to the date of the auditors’ report.

The following is a list of procedures useful in the search for unrecorded liabilities. The audit objective is to search all places where evidence of liabilities could exist.

∙ Inquire of client personnel about their procedures for ensuring that all liabilities are recorded.

∙ Scan the open purchase order file at year-end for indications of material purchase com- mitments at fixed prices. Obtain current prices, and determine whether any adjust- ments for loss and liability for purchase commitments are needed.

∙ Examine the unmatched vendor invoices, and determine when the goods were received, focusing on the unmatched receiving reports and receiving reports prepared around year-end. Determine which invoices, if any, should be recorded by tracing them to the payables listing.

∙ Review the unmatched receiving reports, and determine whether entries are recorded in the proper accounting period.

∙ Select a sample of cash disbursements from the accounting period following the bal- ance sheet date. Vouch them to supporting documents (invoice, receiving report) to determine whether the related liabilities were recorded in the proper accounting period.

∙ Confirm accounts payable with vendors, especially those most likely to be understated (regular suppliers showing small or zero balances in the year-end accounts payable ledger). Unlike accounts receivable confirmations, accounts payable confirmations are not required by auditing standards. Such confirmations are not commonly used because they are primarily directed at the existence assertion, and the main concern regarding liabilities is completeness. However, accounts payable confirmations might be used under the following circumstances:

∙ Internal controls are weak. ∙ The company is in a tight cash position, and bill paying is slow.

When a client has a well-defined purchasing process, the auditor may obtain a majority of its substantive evidence through testing excep- tions to the process. Consider an organization that follows a standard process of obtaining a purchase order, and requiring a receiving report and vendor invoice matched to the purchase order to record the pur- chase. The auditor tests the process and validates the completeness and accuracy of the system data. By testing the system,the auditor

has gained assurance related to the large majority of transactions that follow the standard process, sometimes over 95% of all purchasing transactions. The auditor can then evaluate and test the exceptions to understand why some transactions do not follow the standard pro- cess. The auditor’s additional substantive testing will focus on those items that did not follow the standard process.

Automated Three-Way Match ControlsAUDITING INSIGHT

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∙ Physical inventories exceed general ledger inventory balances by significant amounts.

∙ Certain vendors do not send statements. ∙ Vendor accounts are pledged by assets. ∙ Vendor accounts include unusual transactions. ∙ Perform analytical procedures appropriate in the circumstances. In general, accounts

payable volume and period-end balances should increase when the company experi- ences increases in physical production volume or engages in inventory stockpiling. Some liabilities can be functionally related to other activities; for example, sales taxes are functionally related to sales dollar totals, payroll taxes to payroll totals, excise taxes to sales dollars or volume, and income taxes to income.

∙ Purchase cutoff must be tested both at year-end and in conjunction with the observa- tion of the physical inventory count. Receiving reports issued and unissued at the end of the period are examined and listed. Later, auditors check to ensure that the goods received on the issued reports are included in inventory and payables and to ensure that no goods are recorded for the unissued receiving reports.

A valuable source of testing for unrecorded liabilities involves testing open purchase orders and other unmatched receiving reports and vendor invoices, as described below.

Open Purchase Orders Purchase orders are “open” from the time they are issued until all goods and services have been received. They are held in an open purchase order file. Generally, no liability exists until the transactions have been completed (i.e., the merchandise or services are received). However, auditors can find evidence of losses on purchase commitments in this file if market prices have fallen below the purchase price shown in purchase orders.

Lone Moon Brewing purchased bulk aluminum sheets and manufac- tured its own cans. To ensure a source of raw materials supply, the com- pany entered into a long-term purchase agreement for 6 million pounds of aluminum sheeting at 40 cents per pound. At the end of the year, it

had purchased and used 1.5 million pounds, but the market price had fallen to 32 cents per pound. Lone Moon was on the hook for a $360,000 (4.5 million pounds at 8 cents) purchase commitment in excess of current market prices that should be recognized as a loss in the period.

Thinking AheadAUDITING INSIGHT

Unmatched Receiving Reports Liabilities should be recorded on the date the goods and services are received and accepted by the receiving department or by another responsible person. Sometimes, however, vendor invoices arrive later. In the meantime, the accounts payable department holds the purchase order and receiving reports unmatched with invoices, awaiting enough information to record an accounting entry. Auditors can inspect the unmatched receiving report file to determine whether the company has material unrecorded liabilities on the financial statement date for goods that were received but not matched to invoices.

Unmatched Vendor Invoices Sometimes vendor invoices arrive in the accounts payable department before the receiving activity is complete. Such invoices are held unmatched with receiving reports, awaiting information that the goods and services were actually received and accepted. Auditors can inspect the unmatched invoice file and compare it with the unmatched receiving report file to determine whether liabilities that have been incurred are unrecorded. Systems failures and human coding errors can cause unmatched invoices and related unmatched receiv- ing reports to sit around unnoticed when all of the information for recording a liability

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is actually in hand. Sometimes, however, unmatched invoices are indicators of fraudsters looking for an easy score, as noted in the following Auditing Insight.

REVIEW CHECKPOINTS 8.13 Where could an auditor look to find evidence of (a) losses on purchase commitments or (b) unre-

corded liabilities to vendors? 8.14 List the management reports and computer files that can be used for audit evidence. What infor-

mation in them can be useful to auditors?

A Toronto man received more than $7 million by mailing thousands of phony invoices to companies around the world. Emanuel Medeiros mailed fake “renewal notices” in the amount of $297.83 and received payments from more 25,000 companies. Medeiros hired a com- mercial mailing company in New York to send out 200 to 400 bills stamped “RENEWAL” in large, bold letters every two weeks. The bills were sent in the name of two companies, Bradstreet International and Boom Global Media. One company tried to contact Boom to can- cel the service. When the next bill arrived for twice the amount and

threatened that the account would be turned over for collection, the company immediately sent a check for $595.66.

After receiving complaints, the U.S. Postal Service stopped the mail- ing, and after some communications, Medeiros agreed to come to New York. He pleaded guilty to fraud, agreed to pay $300,000, and was sen- tenced to 46 months in prison. In addition, the U.S. Attorney’s Office in New York notified victim companies who may file for restitution.

Source: “Fake Invoices Net $7M and Four Years,” National Post, January 29, 2009.

Paying for NothingAUDITING INSIGHT

In addition to unmatched purchasing documents, several other client records provide the auditor with additional substantive evidence.

Accounts (Vouchers) Payable Trial Balance This trial balance is a list of payable amounts by vendor, and the total should agree with the accounts payable control account. (Some organizations keep records by individual vouchers instead of vendor names, so the trial balance is a list of unpaid vouchers. The total still should agree with the control account balance.) The best type of trial balance for audit purposes is one that contains the names of all vendors with whom the organiza- tion has done business, even those whose balances are zero. The search for unrecorded liabilities should emphasize accounts with small and zero balances, especially for regular vendors, because these accounts can be the places where unrecorded liabilities may exist.

Purchases Journal A list of all purchases may or may not be printed. It may exist only in a computer transac- tion file. In either event, it provides information for (1) the analysis of purchasing pat- terns that can exhibit characteristics of errors and frauds and (2) the sample selection of transactions for tests of controls. (A company could have already performed analyses of purchases that auditors can use for analytical procedures, provided the analyses are pro- duced under reliable control activities.)

Fixed Asset Reports Many large purchases are for fixed assets. Auditors should trace large purchases to the fixed asset reports and ensure that the details of fixed assets in control accounts are con- sistent with purchase orders. Furthermore, additions to fixed assets should be vouched to the purchasing documents to ensure that items were acquired in accordance with policy and procedure.

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Additional procedures are included in a sample audit plan in Appendix 8B.

REVIEW CHECKPOINTS 8.15 How would substantive procedures for accounts payable be affected by (a) a low risk of material

misstatement or (b) a high risk of material misstatement? 8.16 Describe the purpose and give examples of audit procedures in the search for unrecorded liabilities. 8.17 In substantive procedures, why is the emphasis on the completeness assertion for liabilities

instead of on the existence assertion as in the audit of assets?

There are other accounts affected by the expenditure and acquisition cycle that the auditor needs to review. We have not covered inventory in this chapter because inventory is a main focus of Chapter 9.

Prepaid Expenses and Accrued Liabilities Some of the other accounts affected by the acquisition and expenditure cycle are listed in Exhibit 8.1. Performing substantive procedures for cash and inventory accounts are discussed in other chapters. Many accounts, particularly expense accounts, can be tested using analytical procedures, such as horizontal and vertical analyses. Other accounts such as prepaid expenses can be analyzed by a schedule similar to Exhibit 8.9. In addition to vouching payments, related expense accounts are cross-referenced to expense workpa- pers (X-10, 11, 12 in Exhibit 8.9). A sample audit plan for prepaid, deferred, and accrued expenses is shown at Appendix Exhibit 8B.2.

Accrued Income Taxes Income taxes are a special audit area because the accounting and underlying federal tax laws are so complex. State and local tax differences add to the complexity. Approximately one-third of the first round of adverse opinions on internal controls under Sarbanes–Oxley requirements cited tax accounting control weaknesses.4 In addition, income tax expense is one of the largest items on the income statement. Accounting Standard Codification 740

4K. Frieswick, CFO Magazine, November 7, 2005, www.cfo.com/article.cfm/5077959/c_2984354/?f5archives.

DUNDER-MIFFLIN INC. Prepaid Expenses

For Year Ended 12/31/2017 Prepared by Client

Acct # Account Title

(Audited) Balance

12/31/2016 Additions Amortization/

Disposals

Unaudited Balance

12/31/2017 14100 Prepaid insurance $706,148.66 PY $941,531.55 v $904,365.83 C $743,314.38

X-10 14200 Prepaid rent 190,000.00 PY 760,000.00 v 750,000.00 C 200,000.00

X-11 14300 Office supplies 7,036.48 PY 26,025.00 v 25,654.66 C 7,406.82

X-12 $903,185.14 $1,727,556.55 $1,680,020.49 $950,721.20 CF

F F F F TB PY = Agreed to prior-year documentation.

v = Vouched to policies or agreements and vendor invoice. C = Calculated.

CF = Crossfooted. F = Footed.

TB = Carried forward to the Trial Balance.

E-1 Prepared by RJR 1/16/18

Reviewed by TJL 1/18/18

EXHIBIT 8.9 Account Analysis for Prepaid Expenses

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(ASC 740) requires companies to estimate deferred income tax assets and liabilities, both of which are very subjective. An important aspect of ASC 740 requires a higher stan- dard for tax benefits before they can be recognized in a company’s financial statements. Public accounting firms normally include tax specialists on the audit team to assess tax liabilities and estimates. The procedures for auditing estimates (discussed in detail in Chapter 10) are generally followed, including evaluating controls over management’s procedures for determining assumptions and calculating the amounts. Basic audit proce- dures are similar to those discussed for accrued liabilities: Auditors vouch payments, test the expense, and recalculate the liability. All tax returns and government communications are carefully reviewed.

As part of its ongoing work to remediate control weaknesses in its corpo- rate tax function, H&R Block restated its results for fiscal years 2005 and 2004 as well as previously reported quarterly results for fiscal 2006. The restatement pertains principally to errors in determining the company’s

state income tax rate, resulting in a cumulative understatement of its state income tax liability of approximately $32 million as of April 30, 2005.

Source: H&R Block press release, February 23, 2006.

H&R Block Is TaxingAUDITING INSIGHT

Property, Plant, and Equipment and Intangible Assets Management makes assertions about existence, completeness, rights and obligations, and valuation and allocation. Typical specific assertions relating to property, plant, and equipment (PP&E) and intangible assets include these:

∙ Recorded PP&E exist. ∙ All PP&E are recorded (completeness). ∙ PP&E are owned (rights). ∙ Repair and maintenance expense does not include items that should have been capital-

ized (completeness). ∙ Freight-in is included as part of purchase and added to equipment costs (valuation). ∙ Purchased goodwill is properly valued (valuation). ∙ Goodwill is not impaired (valuation). ∙ Capitalized intangible costs relate to intangibles acquired in exchange transactions

(existence). ∙ Amortization and depreciation expenses are properly allocated (valuation). ∙ Items listed in PP&E are used in operations (classification).

The two primary means of gathering evidence supporting management’s assertions with respect to PP&E are physical inspection and vouching. The principal goal of the physical inspection of PP&E is to determine actual existence and condition of the prop- erty (valuation). The auditor should compare the inspection of equipment to the detailed PP&E records. Unlike current assets, most of the items in PP&E were also in the account in the previous year. Therefore, if the company was audited last year, the audit team can trace existing items to the previous-year audit documentation. The cost of newly acquired PP&E can be vouched to invoices, purchase documents, or physically inspected (existence, valuation), and title documents (for items such as land, buildings) may be inspected (rights and obligations). Disposals of items that were on last year’s list should also be traced to cash receipts records if they were sold or to other documentation if they were traded in, donated, or abandoned. Auditors also should prepare or obtain a schedule of casualty insurance on buildings and equipment and determine the adequacy of insur- ance in relation to asset market values. Auditors should always keep their eyes open for

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buildings or equipment not in use. Equipment not in use with no intention of being used in the future (e.g., held for disposal or sale) should not be included in PP&E.

The depreciation schedule is audited by recalculating the depreciation expense (valua- tion or allocation), using the company’s methods, estimates of useful life, and estimates of residual value. Auditors also must evaluate the useful lives and residual values assigned by the client for reasonableness. Industry groups often publish tables of useful lives of assets commonly found in the industry. The asset acquisition and disposition informa- tion in the schedule gives auditors some key information for auditing the asset additions and disposals. When the schedule covers hundreds of assets and numerous additions and disposals, auditors can use (1) CAATs to recalculate the depreciation expense and (2) sampling to choose additions and disposals for tests of controls and substantive proce- dures. See Exhibit 8.10 for an abbreviated illustration of audit documentation for PP&E and depreciation. Note that the ending balances of PP&E, accumulated depreciation, and depreciation expense are carried forward to the trial balance.

DUNDER-MIFFLIN INC. Building and Land Improvements

For Year Ended 12/31/2017 Prepared By Client

Asset Cost ($) Accumulated Depreciation ($)

Description Beginning Balance Added Sold

Ending Balance

Beginning Balance

Depreciation Expense Sold

Ending Balance

Building 1 $218,367 PY $          0 $                   0 $218,367 $54,591 PY $10,918 C $                  0  $65,509 Building 2     0 155,976  v  0  155,976 0  1,050 C   0    1,050 Building 1 improvements 149,737 PY 109,825 v 10,000 E  249,562 37,434

PY 10,232 C 2,500

C   45,166

Total buildings and improvements $368,104 $265,801 $10,000 $623,905 $92,025 $22,200 $2,500 $111,725

F F F F/CF F F F F/CF PY = Agreed to prior-year documentation. C = Recalculated. v = Vouched to purchase contract. E = Examined sales agreement and related cash receipts.

F = Footed. CF = Crossfooted.

F-1 Prepared by RJR 2/18/18

Reviewed by TJL 2/20/18

EXHIBIT 8.10 Sample PP&E and Depreciation

Auto Parts & Repair Inc. kept perpetual inventory records and equip- ment records on a computerized system. Because of the size of the files (8,000 parts in various locations and 1,500 asset records), the company never printed reports for visual inspection. Auditors ran a computer-audit “sign test” on inventory balances and equipment net

book balances that called for a printed report for all balances less than zero. The auditors discovered 320 negative inventory balances that were caused by employees’ failure to record purchases and 125 negative net asset balances caused by depreciating assets more than their cost.

The Sign of the Credit BalanceAUDITING INSIGHT

With respect to intangible assets, official documents of patents, copyrights, and trade- mark rights can be inspected to see that they are recorded in the client’s name. Goodwill is of special interest to companies and auditors. A 2011 study by KPMG indicates $39 billion in goodwill impairment for U.S. companies in 2010.5 The client must review 5“Goodwill Impairment Slide Continues in U.S., Says KPMG Study,” Press Release, www.kpmg.com/us/en/issuesandinsights /articlespublications/press-releases/pages/goodwill-impairment-slide-continues-2011-study.aspx.

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goodwill for impairment, and the auditors must review and evaluate management’s cal- culations and decisions to ensure that goodwill is correctly valued and impairments are properly recorded. Amortization of other intangibles should be recalculated. Similar to depreciation expense, this expense owes its existence to a calculation, and recalculation based on audited costs and rates is sufficient appropriate audit evidence.

Auditors inquire of company counsel about knowledge of any lawsuits or defects relat- ing to patents, copyrights, trademarks, or trade names. Questions about lawsuits challeng- ing patents, copyrights, or trade names can produce early knowledge of problem areas for further investigation. Likewise, discussions and questions about research and develop- ment successes and failures can alert the audit team to problems of valuation of intan- gible assets and related amortization expenses. Responses to questions about licensing of patents can be used in the audit of related royalty revenue accounts. Auditors can confirm royalty income from patent licenses received from a single licensee and review licensing and royalty contracts. However, such income amounts usually are audited by vouching the licensee’s reports and the related cash receipt.

Vouching may be extensive in the areas of research and development (R&D) and deferred software development costs. The principal evidence problem is to determine whether costs are properly classified as assets or as R&D expenses. Recorded amounts generally are selected on a sample basis and the purchase orders, receiving reports, payroll records, authorization notices, and management reports are compared with them. Some R&D costs can resemble non-R&D costs (such as supplies, payroll costs), so auditors must be very careful in the vouching to be alert for costs that appear to relate to other operations.

Merger and acquisition transactions should be reviewed in terms of the appraisals, judgments, and allocations used to assign portions of the purchase price to tangible assets, intangible assets, liabilities, and goodwill. In the final analysis, nothing really substitutes for the inspection of transaction documentation, but verbal inquiries can help auditors to understand the circumstances of a merger. An illustrative plan of substantive procedures for PP&E and related accounts can be found in Appendix Exhibit 8B.3.

Northrop Grumman Corporation announced a fourth-quarter non- cash, after-tax charge of $3.0 to $3.4 billion for impairment of good- will in accordance with Accounting Standards Codification 350 (ASC 350), “Goodwill and Other Intangible Assets.” Because of this charge, the company reported a net loss for the fourth quarter and in 2008. The company performed its required annual testing of goodwill as of November 30, 2008, using a discounted cash flow analysis supported

by comparative market multiples to determine the fair values of its busi- nesses versus their book values. Testing as of November 30, 2008, indi- cated that book values for shipbuilding and space technology exceeded the fair values of these businesses. The charge is attributable to good- will recorded in connection with acquisitions made in 2001 and 2002.

Source: Northrop Grumman press release, January 22, 2009, www.irconnect. com/noc/press/pages/news_releases.html?d5158124.

How Good Is Goodwill?AUDITING INSIGHT

Other Expenses As mentioned earlier, most expense accounts can be tested in conjunction with tests of related assets and liabilities (e.g., depreciation) or through analytical procedures. How- ever, if risk of material misstatement is high, expenses can be tested by tests of details, by which a sample of significant transactions is tested much like a test of controls except that auditors look for evidence that the significant transactions are properly recorded rather than that controls are operating. Payroll expense is usually audited by testing con- trols or using substantive tests of transactions and performing analytical procedures (see Appendix 8C). Some expenses should be examined separately because of their unique nature. For example, the client should list legal and professional expenses, and signifi- cant amounts should be vouched so the auditors can determine what legal and profes- sional services the client is using. Miscellaneous expenses likewise should be listed and

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examined for significant unusual items. Finally, maintenance and repairs should be exam- ined to determine whether any items should be capitalized.

Presentation and Disclosure Once auditors are satisfied that controls have been examined and significant transactions and balances have been appropriately tested, the job is not over. The accounts in the acquisition and expenditure cycle require many disclosures. Depreciation methods, asset impairments, leases, and details about income taxes are only a few of the essential items with specific presentation and disclosure requirements. These disclosures must ensure that the presentation and disclosure assertions of occurrence and rights and obligations, com- pleteness, classification and understandability, and accuracy and valuation are all met.

REVIEW CHECKPOINTS 8.18 How do audit procedures for prepaid expenses and accrued liabilities also provide audit evidence

about related expense accounts? 8.19 What assertions found in PP&E, investments, and intangibles accounts are of interest to an auditor

during the examination of the expenditure and acquisition cycle? 8.20 What items in a client’s PP&E and depreciation schedule give auditors points of departure

( assertions) for audit procedures? 8.21 What methods are used to audit other expense accounts?

AUDIT RISK MODEL APPLIED Now that the elements of risk of material misstatement for the acquisition and expendi- ture cycle as well as some of the important substantive procedures have been presented, let’s examine how auditors might apply the audit risk model for the completeness and classification assertions.

Chi-Chi’s Clothing Stores Inc. Example Chi-Chi’s Clothing Stores Inc. is a chain of women’s clothing stores that sells upscale fashions, mostly in the northeastern United States. Chi-Chi’s is a public company with annual sales increasing at a rate of almost 30 percent per year. David Escobar has been assigned as the senior auditor. The policy of his firm is to always set overall audit risk as low. Chi-Chi’s accounting department and systems have not kept up with the rapid growth. As a result, numerous audit adjustments have been required every year, and the company received an adverse report on internal controls in the previous year. One prob- lem has been that invoices do not come from the stores on a timely basis. The com- pany has been very profitable, causing enormous increases in management stock options, which are a significant part of management compensation. Although the economy has taken a downturn, management and analyst forecasts still project a 30 percent growth rate. Escobar is concerned that management could be biased toward understating costs and liabilities and therefore sets inherent risk at high.

As mentioned, controls have not kept pace with company growth. Chi-Chi’s has been working to improve the systems, but the accounting department and internal audit depart- ment are overworked. Their staff members have not had time to sufficiently test new systems or train new personnel. Thus, Escobar assesses control risk as high and plans to test only year-end controls sufficiently to comply with AS 2201. In this situation, Escobar believes he must set risk of material misstatement as high and set detection risk at low. He will perform an extensive search for unrecorded liabilities, examining a large sample of disbursements after the balance sheet date, and he will send confirmations to vendors that

LO 8-7 Apply your knowledge to perform audit procedures in the acquisition and expenditure cycle and evaluate the findings of your tests.

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historically have had activity but have small or zero year-end balances. Escobar also will vouch a sample of additions to PP&E accounts to ensure they are not items that should be expensed. The combination of high inherent risk, high control risk, and low detection risk should lead Escobar to an acceptably low overall audit risk.

Finding Fraud Signs in Accounts Payable Fraudsters can have a field day generating false payments through a company’s acquisition and expenditure systems. A common scheme is to send false invoices on the letterhead of a fictitious vendor to the company and have an insider manipulate supporting documents or controls to make payments. Sometimes, a company’s own employees engage in unauthorized “business” as suppliers to their employers. In these cases, the perpetrators receive company payments from these “vendors” for personal use.

Olaronke Fakunle pleaded guilty to defrauding Star Air Ambulance Service of $210,000 between September 7, 2007, and October 9, 2008. Fakunle was able to divert money from the organization by set- ting up Blackbaud, a false corporation, and creating fictitious invoices for that company. A week after the controller at Star began an internal

investigation into payments to Blackbaud, Fakunle gave her two weeks’ notice. She then went to work for Rosen Canada Ltd., where she fraud- ulently received $54,885 using a similar fictitious vendor scheme.

Source: “Stars Bilked for $210,000,” The Daily Herald-Tribune (Grande Prairie, Alberta, Canada), November 9, 2010.

Did We Take Him to the Hospital?AUDITING INSIGHT

These frauds can proceed undetected for a long time as long as auditors and managers do not identify the signs and signals the perpetrators leave behind. If the review for fraud risk indicates that a potential significant risk of fraud exists in the acquisition and expen- diture cycle, auditors can try several types of searches and matches in the company’s records. These searches and matches are often performed using CAATs.

∙ Inspect the invoices in the files for photocopies. Fraudsters alter real invoices for false or duplicate payments and make photocopies to hide whiteout and cut-and-paste changes.

∙ Inspect vendor’s invoices submitted in numerical order. False vendors sometimes use the same pad of prenumbered invoices (easily purchased at an office supply store) to send bills to the company. Either the company is the vendor’s only customer, or the company is a victim of a false billing scheme.

∙ Inspect vendor’s invoices for invoices that always are in round numbers. Prices, shipping charges, and taxes too often come in penny amounts, making a vendor’s invoice in even dollars an unusual occurrence.

∙ Scan vendor’s invoices for invoices that are always slightly lower than a review thresh- old. Insiders know that a company gives special attention and approval to invoices over a specified dollar amount (e.g., $10,000). Therefore, the fraudster always avoids invoices for more than that amount.

∙ Scan vendor files for vendors with only post office box addresses. Although many businesses use post office box addresses for receiving payments, files also should show a street address location.

∙ Scan vendor invoices for invoices with no listed telephone number. Legitimate busi- nesses normally do not hide behind unlisted telephone numbers. In addition, cheap fraudsters sometimes do not buy a phone line for their false companies.

∙ Match vendor and employee addresses and telephone numbers. Many companies have policies that their employees cannot also be vendors. Insiders (employees) often know how to circumvent controls when their business with the employer could be suspicious.

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∙ Scan multiple vendors at the same address and telephone number. Many invoices from the same location, especially invoices for different kinds of products and services, could simply come from a front organization conducting a false invoice scheme. How- ever, legitimate suppliers often operate under several company names and conduct business from the same location and office parks with multiple offices at the same street address exist. This procedure can be done quickly with CAATs and is a red flag that should be investigated.

∙ Vouch a sample of vendor invoices to the approved vendor list. All vendors should be approved. If a company is doing business with a vendor not on the approved vendor list, this relationship should be investigated. Look for names that are similar, but not the same. For example, the company may be doing business with Dan’s Hardware Supply and a fraudster may submit invoices for Don’s Hardware Service (an account the fraudster has established at a bank).

∙ Review invoices for addresses of the local mail drops (e.g., shipping and packaging stores that accept client mail). These stores provide a street address for fraudulent companies, adding false legitimacy to their fraudulent invoices. However, legitimate companies use these services as well. The use of such a mail drop is a red flag that needs further investigation.

REVIEW CHECKPOINTS 8.22 What items could indicate a significant risk of fraud in the acquisition and expenditure cycle (i.e.,

be red flags)? 8.23 Describe the purpose and give examples of specific fraud detection procedures in the acquisition

and expenditure cycle. 8.24 Are these specific fraud detection procedures designed to detect fraudulent financial reporting or

misappropriation of assets? Explain.

Significant issues in accounts payable occur when vendors that are not on the approved vendor list are paid. Auditors can take advan- tage of CAATs by comparing all vendor payments to the approved vendor list. In the past, such a complete test was virtually impossible, and the best the auditors could do was to test a sample of payments. In addition, auditors can search for duplicate payments to vendors. Only a few vendor payments should reoccur each month for the exact amount (e.g., loan payments, insurance payments, rents). A vendor

being paid for goods or services repeatedly for the exact amount of money may indicate a fraud.

To gather evidence in these situations, an auditor will most likely join the approved vendor list with the cash disbursements list or pur- chase journal. In addition, the auditor can request the program to provide a listing of identical payments to the same vendor. The result- ing reports should be carefully reviewed by the auditor and evidence gathered as to the propriety of the items.

Using IDEA in the Audit Credit Authorization Controls

AUDITING INSIGHT

At the end of this chapter, you can perform this exception test in Exercise 8.59.

FRAUD CASES: EXTENDED AUDIT PROCEDURES The audit of account balances consists of making procedural efforts to detect errors and frauds that could exist in the balances, thus making them misleading in financial statements.

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Case 8.1

Printing (Copying) Money

PROBLEM Argus Productions Inc., a motion picture and commercial production company, assigned M.  Welby the authority and responsibility for obtaining copies of scripts used in production. Established procedures permitted Welby to arrange for outside script-copying services, receive the copies, and approve the bills for payment. In effect, Welby was the “purchasing department” and the “receiving department” for this particular service. To a certain extent, he was also the “accounting department” by virtue of approving bills for payment and coding them for assignment to projects. Welby did not make the actual accounting entries or sign the checks.

Welby set up a fictitious company under the registered name Quickprint Company with himself as the incorporator and stockholder complete with a post office box number, letterhead station- ery, and nicely printed invoices but no printing equipment. Legitimate copy services were “sub- contracted” by Quickprint to perform the actual printing and then billed Quickprint. Welby then prepared Quickprint invoices billing Argus, usually at the legitimate shop’s rate, but for a few extra copies each time. Welby also submitted Quickprint bills to Argus for fictitious copying jobs on scripts for movies and commercials that never went into production. As the owner of Quickprint, Welby endorsed Argus’s checks with a rubber stamp and deposited the money in the business bank account, paid the legitimate printing bills, and took the rest for personal use.

Argus’s production cost files contained all of the Quickprint bills sorted under the names of the movie and commercial production projects. Welby even created files for proposed films that never went into full production and thus should not have had script-copying costs. There were no copy- ing service bills from any shop other than Quickprint Company.

Welby conducted this fraud for five years, embezzling $475,000 in false and inflated billings. (Argus’s net income was overstated a modest amount because copying costs were capitalized as part of production cost and then amortized over a two- to three-year period.)

AUDIT APPROACH Management should assign the authority to request copies and the purchasing authority to differ- ent responsible employees. Other persons also should perform the accounting, including coding cost assignments to projects. Managerial review of production results could result in notice of excess costs.

The request for the quantity (number) of copies of a script should come from a person involved in production who knows the number needed. This person also should sign off for the receipt (or approve the bill) for this requested number of copies, thus acting as the “receiving department.” This procedure could prevent waste (excess cost), especially if the requesting person also were held responsible for the profitability of the project. A company agent always performs actual purchas- ing, and in this case, the agent was Welby. Purchasing agents generally have latitude to seek the best service at the best price with or without bids from competitors. A requirement to obtain bids is usually a good idea, but much legitimate purchasing is done without bid. However, an approval process should be employed before vendors are placed on the approved vendor list.

Someone in the accounting department should be responsible for coding invoices for charges to authorized projects, thus making it possible to detect costs charged to projects not actually in pro- duction. Someone with managerial responsibility should review project costs and the purchasing practices. However, this is an expensive use of executive time. It was not spent in the Argus case.

In gaining an understanding of the internal controls, auditors could learn of the trust and respon- sibility vested in Welby. Because the embezzlement was about $95,000 per year, the total copying cost under Welby’s control must have been around $1 million or more. (It might attract unwanted attention to inflate a cost more than 10 percent.)

Controls were very weak, especially in the combination of duties performed by Welby and in the lack of managerial review. For all practical purposes, there were no controls to test other than to see whether Welby had approved the copying cost bills and coded them to active projects. This provides an opportunity because proper classification is a control objective.

The auditors should select a sample of project files and vouch costs charged to them to support source documents (occurrence direction of the test). Select a sample of expenditures and trace them to the project cost records shown coded on the expenditures (completeness direction of the test).

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Substantive procedures are directed at obtaining evidence about the existence of film projects, com- pleteness of the costs charged to them, valuation of the capitalized project costs, rights in copyright and ownership, and proper disclosure of amortization methods. The most important procedures are the same as the tests of control activities; thus, when performed at the year-end date on the capitalized cost balances, they are dual-purpose audit procedures. Either of the procedures described earlier as tests of controls should show evidence of projects that had never gone into production. (Auditors should be careful to obtain a list of actual projects before they begin the procedures.) Chances are good that the discovery of bad project codes with copying cost will reveal a pattern of Quickprint bills.

Knowing that controls over copying cost are weak, auditors could be tipped off to the possi- bility of a Welby-Quickprint connection. Efforts to locate Quickprint should be taken (telephone book, chamber of commerce, other directories). Inquiry with the secretary of state for names of the Quickprint incorporators should reveal Welby’s connection. The audit findings can then be turned over to a trained investigator to arrange an interview and confrontation with Welby.

DISCOVERY SUMMARY In this case, internal auditors performed a review of project costs at the request of the manager of production, who was worried about profitability. The auditors performed the procedures described earlier, noticed the dummy projects and the Quickprint bills, investigated the ownership of Quick- print, and discovered Welby’s association. They had first tried to locate Quickprint’s shop but could not find it in the telephone, chamber of commerce, or other city directories. They were careful not to direct any mail to the post office box for fear of alerting the then-unknown parties involved. A sly internal auditor already had used a ruse at the post office and learned that Welby rented the box, but the auditors did not know whether anyone else was involved. Alerted, the inter- nal auditors gathered all Quickprint bills and determined the total charged for nonexistent projects. Carefully, under the covert observation of a representative of the local district attorney’s office, Welby was interviewed and readily confessed.

Case 8.2

Real Cash Paid to Phony Doctors

PROBLEM As manager of the medical claims processing department, Martha Lee was considered one of Beta Magnetic’s best employees. She had never missed a day of work in 10 years, and her department had one of the company’s best efficiency ratings. Controls were considered good, including the verification by a claims processor that (1) the patient was a Beta employee, (2) medical treatments were covered in the plan, (3) the charges were within approved guidelines, (4) the cumulative claims for the employee did not exceed $50,000 (paid all claims less than $50,000 but submitted claims more than $50,000 to an insurance company), and (5) the calculation for payment was cor- rect. After verification processing, claims were sent to the claims payment department to pay the doctor directly. No payments ever went directly to employees.

Lee prepared false claims on real employees, forging the signatures of various claims pro- cessors, adding her own review approval, and naming bogus doctors who would be paid by the payment department. The payments were mailed to various post office box addresses and to her husband’s business address.

Nobody ever verified claims information with the employees. The employees received no reports of medical benefits paid on their behalf. Although the department had performance reports by claims processors, these reports did not show claim-by-claim details. No one verified the cre- dentials of the doctors. As noted, Martha never missed a day of work for vacation or sickness. She was considered an ideal employee.

The falsified claim forms were in Beta’s files, containing all fictitious data on employee names, processor signatures, doctors’ bills, and phony doctors and addresses. The canceled checks were returned by the bank and were kept in Beta’s files, containing “endorsements” by the doctors. Lee and her husband were clever: They deposited the checks in various banks in accounts opened in the names of the “doctors.”

Lee did not stumble on the audit trail. She drew the attention of an auditor who saw her take her 24 claims processing employees out to an annual staff appreciation luncheon in a fleet of stretch limousines.

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Over the seven years, Lee and her husband had stolen $3.5 million, and until the last, no one noticed anything unusual about the total amount of claims paid.

AUDIT APPROACH The controls were good as far as they went. The claims processors used internal data in their work: employee files for identification, treatment descriptions submitted by doctors with comparisons with plan provisions, and mathematical calculations. This work amounted to all approval neces- sary for the claims payment department to prepare a check. No controls connected the claims data with outside sources such as employee acknowledgment or doctor investigation. Employees cer- tainly should be notified of any payments made on their behalf.

By never taking a day off, Lee was able to make sure she saw all documents related to her scheme. The company needed an enforced vacation and employee rotation policy.

The processing and control work in the claims payment department can be audited for deviations from controls. The auditors should select a sample of paid claims and re-perform the claims pro- cessing procedures to verify the employee status, coverage of treatment, proper guideline charges, cumulative amount of less than $50,000, and accurate calculation. However, this procedure would not help answer the question, “Does Martha Lee steal the money to pay for the limousines?”

“Thinking like a crook” points out the holes in the controls. Nobody seeks to verify data with external sources. However, the audit team must be careful in an investigation not to cast aspersions on a manager by letting rumors start when interviewing employees to find out whether they actu- ally had the medical attention whose claim is paid on their behalf. If money is being taken, the company check must be intercepted in some manner.

The balance under audit is the sum of the charges in the employee medical benefits expense account, and the objective relates to the valid existence of the payments.

The first procedure can be as follows: Obtain a list of doctors paid by the company and look them up in the state medical society directory. Look up their business addresses and determine whether they are valid. You could try comparing claims processors’ signatures on various forms, but this is difficult and requires training. An extended procedure would be as follows: Compare the doctors’ addresses to addresses known to be associated with Lee and other claims processing employees.

DISCOVERY SUMMARY The comparison of doctors to the medical society directory showed eight “doctors” who were not licensed in the current period. Five of these eight had post office box addresses, and dis- crete inquiries and surveillance showed that Lee rented them. The other three had the same mailing address as her husband’s business. Further investigation involving the district attorney and police was necessary to obtain personal financial records and reconstruct the thefts from prior years.

REVIEW CHECKPOINTS 8.25 What key control concept was missing at Argus Productions? 8.26 What evidence could the verbal inquiry audit procedure provide in “Printing (Copying) Money”? 8.27 If Lee had not been seen taking employees out in a limousine, how else could she have been

caught? 8.28 How would a policy of mandatory vacations have helped discover the Beta fraud?

AUDIT ISSUES IN THE EXPENSE AND ACQUISITION CYCLE Even with proper diligence and due professional care, it may be difficult to identify all issues related to expenses, purchases, and unrecorded items. This is illustrated in the fol- lowing Auditing Insight that lists matters identified by the Public Company Accounting Oversight Board (PCAOB) during its annual inspections for audits conducted by the Big Four firms.

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• The Firm’s analytical procedures to test operating expenses did not meet the requirements for substantive analytical procedures because, in one procedure, the Firm did not set a threshold for investigation and evaluation that allowed it to achieve the desired level of assurance and, in another procedure, there was no evi- dence in the audit documentation, and no persuasive other evidence, that the Firm had obtained corroboration of manage- ment’s explanations for significant differences from the Firm’s expectations.

• The issuer completed a significant acquisition during the year. The Firm failed to perform audit procedures regarding the revenues and expenses of the acquired company from the date of acquisi- tion to year-end.

• The Firm failed to perform sufficient substantive procedures to test certain long-lived assets and related accounts payable because it designed its procedures based on a level of reliance on internal control that was excessive due to the deficiencies in the Firm’s testing of controls.

• [For the control], which consisted of management’s review of cer- tain expense calculations, the Firm’s procedures were limited to inquiring of management and inspecting email correspondence as evidence that the reviews had occurred. The Firm’s procedures to test these controls did not include evaluating whether the con- trols operated at a level of precision that would prevent or detect material misstatements, as it failed to evaluate the criteria used by the control owner to identify matters for investigation and the pro- cess for investigating and resolving such matters. In addition, the Firm failed to evaluate whether misstatements that had not been prevented by the issuer’s controls should have had an effect on its conclusion about the effectiveness of controls.

Sources: 2005, 2008, 2011 PCAOB Inspection of Deloitte & Touche (Novem- ber 30, 2006; April 16, 2009, November 28, 2012); 2011 PCAOB Inspection of Ernst & Young (December 6, 2012); 2006, 2014 Inspection of KPMG (January 11, 2007; October 15, 2015); and 2008 PCAOB Inspection of Pricewater- houseCoopers (March 25, 2009). All reports can be found on the PCAOB’s website, http://pcaobus.org/Inspections/Reports/Pages/default.aspx.

Deficiencies from PCAOB Inspection Reports in the Expenditure and Acquisition Cycle

AUDITING INSIGHT

approved vendor list: A record of vendors that have been vetted to ensure that they meet company policy and procedure in terms of price, quality, delivery, etc. This control activity provides evidence of vendor existence to auditors, 330 bill of lading: A contract between the shipper and the carrier; includes shipping information such as ship dates and origination, purchase order number, and signatures for receipt of merchandise, 333 clearing accounts [Appendix 8C]: The temporary storage places for transactions awaiting final accounting that should eventually have zero balances, 381

Key Terms

The acquisition and expenditure cycle consists of purchase requisitioning, purchase order- ing, receiving goods and services, recording vendors’ invoices, recording accounts pay- able, and making cash disbursements. Companies reduce control risk by having a suitable separation of authorization, custody, recording, and periodic reconciliation duties. Error- checking procedures requiring the comparison of purchase orders, receiving reports, and vendor invoices are important for recording proper amounts of accounts payable liabili- ties. Having a separation of duties between preparing cash disbursement checks and actu- ally signing them provides supervisory control. Otherwise, many things—ranging from processing false or fictitious purchase orders to failing to record liabilities for goods and services received—could go wrong.

Purchases are executed for a myriad of items, including inventory; property, plant, and equipment; supplies; and all other items necessary for a business to operate. Large pur- chases for capital equipment may be significant items requiring the auditors’ inspection and review. Reviewing the accruals for income taxes may be complex, especially if the organization is operating in multiple tax jurisdictions. The use of a tax specialist may be appropriate in auditing income tax expense.

The completeness assertion is important in the audit of liabilities because misleading financial statements often have involved unrecorded liabilities and expenses. The search for unrecorded liabilities is an important set of audit procedures.

Summary

laser
Callout
We have not include the "capitalizing" and "matching" from the Key Terms list as there is no definition

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ghost employees [Appendix 8C]: The fictitious or separated employees fraudulently maintained on the payroll to obtain checks, 380 imprest bank account [Appendix 8C]: An account used for special purposes such as payroll or branch banking that is maintained at a zero or fixed balance in the general ledger. Checks written on the account are offset by deposits of the same amount, 381 purchase order: A formal contractual document (may be a computer document) between a buyer and seller issued by the buyer establishing price, delivery point, delivery dates, and other information pertinent to the purchase, 331 purchase requisition: An internal document initialed by a department or person within the entity asking the purchasing department to buy specific goods or services, 330 receiving report: The documentation completed by the receiving department that includes receiving date and time, purchase order number, condition of material received, and amount of material received; provides evidence regarding the receipt of materials by the entity, 333 search for unrecorded liabilities: A substantive procedure to test the completeness assertion for liability accounts, 345 tests of details: The tests of a sample of transactions during the period for monetary errors, 351 vendor’s invoice: A bill sent from the vendor to the entity purchasing the goods or services, 333 voucher/voucher package: A document used as a source for recording payables. It shows approvals, accounts, and amounts to be recorded, usually attached to the supporting purchase order, receiving report, and vendor invoice, 333 W-2 [Appendix 8C]: The annual report of gross salaries and wages and the income, Social Security, and Medicare taxes withheld, 382

8.29 Which of the following accounts does not appear in the acquisition and expenditure cycle? a. Cash b. Purchases returns c. Sales returns d. Prepaid insurance

8.30 For which of the following accounts would the matching concept be the most appropriate? a. Cost of goods sold. b. Research and development. c. Depreciation expense. d. Sales.

8.31 An audit team was testing source documents in the purchasing cycle and identified the fol- lowing circumstances. Which of the following would be the most indicative of source docu- ment fraud? a. The same purchase order number appears on two invoices from the same vendor. b. The same item code appears on different invoices from the same vendor. c. The same invoice number appears on different invoices from the same vendor. d. The same invoice date appears on different invoices from the same vendor.

8.32 Which of the following would not overstate current-period net income? a. Capitalizing an expenditure that should be expensed. b. Failing to record a liability as an expense. c. Failing to record a check paying an item in Vouchers Payable. d. All of the above would overstate net income.

LO 8-1

LO 8-1

LO 8-1

LO 8-1

All applicable Exercises and Problems are available with Connect.

Multiple-Choice Questions for Practice and Review

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8.33 A client’s purchasing system ends with the recording of a liability and its eventual payment. Which of the following best describes the control objective that auditors are most interested in when performing tests of liabilities? a. Accounts payable are not materially understated. b. Authority to incur liabilities is restricted to one designated person. c. Acquisition of materials is not made from one vendor or one group of vendors. d. Commitments for all purchases are made only after established competitive bidding pro-

cedures are followed. 8.34 An audit firm is testing controls within the purchasing cycle. In which of the following pro-

cedures would the firm most likely apply sampling techniques? a. Risk assessment procedures performed to obtain an understanding of internal control in

the purchasing cycle. b. Tests of automated application controls involving check amount limits when effective

information technology general controls are present. c. Analyses of controls to determine the appropriate segregation of duties in the purchasing cycle. d. Testing of operating effectiveness of controls over authorization of purchase orders.

8.35 Which of the following results of analytical procedures would most likely indicate possible unrecorded liabilities? a. Current ratio of 3:1 as compared to 6:1 for the prior period. b. Ratio of accounts payable to total current liabilities of 3:1, compared to 5:1 for the prior

period. c. Accounts payable turnover of 4, compared to 8 for the prior period. d. Accounts payable balance increase greater than 10 percent over the prior period.

(AICPA adapted) 8.36 Which of the following is an internal control activity that could prevent a paid disbursement

voucher from being presented for payment a second time? a. Vouchers should be prepared by individuals who are responsible for signing disburse-

ment checks. b. Disbursement vouchers should be approved by at least two responsible management

officials. c. The date on a disbursement voucher should be within a few days of the date the voucher

is presented for payment. d. The official who signs the check should compare the check with the voucher and should

stamp “PAID” on the voucher documents. 8.37 Budd, the purchasing agent of Lake Hardware Wholesalers, has a relative who owns a retail

hardware store. Budd arranged for hardware to be delivered by manufacturers to the retail store on a cash-on-delivery (C.O.D.) basis, thereby enabling his relative to buy at Lake’s wholesale prices. Budd was probably able to accomplish this because of Lake’s poor internal control over a. Purchase requisitions. b. Cash receipts. c. Perpetual inventory records. d. Purchase orders.

8.38 Which of the following is the best audit procedure for determining the existence of unre- corded liabilities? a. Examine confirmation requests returned by creditors whose accounts are on a subsidiary

trial balance of accounts payable. b. Examine a sample of cash disbursements in the period subsequent to year-end. c. Examine a sample of invoices a few days prior to and subsequent to the year-end to ascer-

tain whether they have been properly recorded. d. Examine unusual relationships between monthly accounts payable and recorded purchases.

8.39 Which of the following procedures is least likely to be performed before the balance-sheet date? a. Observation of inventory. b. Review of internal control over cash disbursements.

LO 8-2

LO 8-3

LO 8-3

LO 8-4

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c. Search for unrecorded liabilities. d. Confirmation of receivables.

8.40 To determine whether accounts payable are complete, auditors perform a test to verify that all merchandise received has been recorded. The population for this test consists of all a. Vendors’ invoices. b. Purchase orders. c. Receiving reports. d. Canceled checks.

(AICPA adapted) 8.41 When verifying debits to the perpetual inventory records of a nonmanufacturing company,

auditors would be most interested in examining a sample of purchase a. Approvals. b. Requisitions. c. Invoices. d. Orders.

8.42 A furniture company ordered 84 tables from a supplier. The supplier accidentally sent only 48 tables, but the receiving department at the furniture company accepted the tables. The invoice was eventually received but was for the original 84 tables. The furniture com- pany paid the entire amount. Which of the following controls would have been least likely to have prevented this erroneous payment? a. The copy of the purchase order sent to the furniture company’s receiving department

should not have shown an expected quantity. b. Personnel in the furniture company’s accounts payable department should compare the

receiving report to the purchase invoice before creation of the voucher. c. Personnel in the furniture company’s cash disbursements department should compare the

check that is prepared to all of the backup documentation. d. Personnel in the furniture company’s purchasing department should compare the pur-

chase requisition with the purchase order. 8.43 Curtis, a maintenance supervisor, submitted maintenance invoices from a phony repair com-

pany and received the checks at a post office box. This should have been prevented by a. Comparison of the company name to the approved vendor list by the check signer. b. Recognition of the excess maintenance costs by Curtis’s supervisor. c. Refusal by the purchasing department to approve the vendor. d. All of the above.

8.44 An audit team would most likely examine the detail support for charges to which of the fol- lowing accounts? a. Payroll expense b. Cost of goods sold c. Supplies expense d. Legal expense

8.45 Which of the following accounts would most likely be audited in connection with a related balance-sheet account? a. Property tax expense b. Payroll expense c. Research and development d. Legal expense

8.46 When auditing account balances of liabilities, auditors are most concerned with manage- ment’s assertion about a. Existence. b. Rights and obligations. c. Completeness. d. Valuation and allocation.

LO 8-6

LO 8-6

LO 8-4

LO 8-4

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8.47 In a test of controls, auditors may trace receiving reports to vouchers recorded in the voucher register. This is a test for a. Occurrence. b. Completeness. c. Classification. d. Cutoff.

8.48 A company employs three accounts payable clerks and one treasurer. Their responsibilities are as follows:

Employee Responsibility

Clerk 1 Reviews vendor invoices for proper signature approval. Clerk 2 Enters vendor invoices into the accounting system and verifies payment terms. Clerk 3 Posts entered vendor invoices to the accounts payable ledger for payment and mails checks. Treasurer Reviews the vendor invoices and signs each check.

Which of the following would indicate a weakness in the company’s internal control? a. Clerk 1 opens all of the incoming mail. b. Clerk 2 reconciles the accounts payable ledger with the general ledger monthly. c. Clerk 3 mails the checks and remittances after they have been signed. d. The treasurer uses a stamp for signing checks.

(AICPA adapted) 8.49 Which of the following tests of details most likely would help an auditor determine whether

accounts payable have been misstated?

a. Examining reported purchase returns that appear too low. b. Examining vendor statements for amounts not reported as purchases. c. Searching for customer-returned goods that were not reported as returns. d. Reviewing bank transfers recorded as cash received from customers.

(AICPA adapted)

LO 8-5

LO 8-4

LO 8-6

8.50 Payable ICQ Items: Assertions, Tests of Controls, and Possible Errors or Frauds. Following is a selection of items from internal control questionnaires. 1. Are purchase orders above a certain level approved by an officer? 2. Are the quantity and quality of goods received determined at the time of receipt by

receiving personnel independent of the purchasing department? 3. Are vendors’ invoices matched against purchase orders and receiving reports before a

liability is recorded? 4. Are journal entries authorized at appropriate levels?

Required: For each preceding item

a. Identify the management assertion to which it applies. b. Specify one test of controls auditors could use to determine whether the control was

operating effectively. c. Give an example of an error or fraud that could occur if the control were absent or

ineffective. d. Write a substantive procedure that could find errors or frauds that could result from the

absence or ineffectiveness of the control items.

LO 8-1, LO 8-2, LO 8-5

All applicable Exercises and Problems are available with Connect.

Exercises and Problems

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8.51 Unrecorded Liabilities Procedures. You are in the final stages of your audit of the finan- cial statements of Ozine Corporation for the year ended December 31, 2020, when the cor- poration’s president consults you. The president believes there is no point to your examining the 2021 voucher register and testing data in support of 2021 entries. She stated that any bills pertaining to 2020 that were received too late to be included in the December voucher regis- ter were recorded by a year-end journal entry and the internal auditor tested for unrecorded liabilities after the year-end. The president will provide you a letter certifying that there are no unrecorded liabilities.

Required: a. Should your procedures for unrecorded liabilities be affected by the fact that the client

made a journal entry to record 2020 bills that were received later? Explain. b. Should your test for unrecorded liabilities be affected by the fact that a letter is obtained

in which a responsible management official certifies that, to the best of that person’s knowledge, all liabilities have been recorded? Explain.

c. Should your test for unrecorded liabilities be eliminated or reduced because of the inter- nal audit work? Explain.

d. What sources, in addition to the 2021 voucher register, should you consider for locating possible unrecorded liabilities?

(AICPA adapted) 8.52 Accounts Payable Confirmations. Partners Clark and Kent, both CPAs, are preparing their

audit plan for the audit of accounts payable on Marlboro Corporation’s annual audit. Sat- urday afternoon they reviewed the thick file of last year’s documentation, and they both remembered too well the six days they spent last year on accounts payable.

Last year, Clark had suggested that they mail confirmations to 100 of Marlboro’s sup- pliers. The company regularly purchases from about 1,000 suppliers, and these account payable balances fluctuate widely, depending on the volume of purchase and the terms Marlboro’s purchasing agent is able to negotiate. Clark’s sample of 100 was designed to include accounts with large balances. In fact, the 100 accounts confirmed last year covered 80 percent of the total dollars in accounts payable. Both Clark and Kent had spent many hours tracking down minor differences reported in confirmation responses. Nonrespond- ing accounts were investigated by comparing Marlboro’s balance with monthly statements received from suppliers.

Required: a. Identify the accounts payable audit objectives that auditors must consider in determining

the audit procedures to be performed. b. Identify situations when auditors should use accounts payable confirmations, and discuss

whether they are required to use them. c. Discuss why the use of large dollar balances as the basis for selecting accounts pay-

able for confirmation is not the most effective approach, and indicate a more effective sample selection procedure that could be followed when choosing accounts payable for confirmation.

8.53 Search for Unrecorded Liabilities. C. Marsh, CPA, is the independent auditor for Compufast Corporation, which sells personal computers, peripheral equipment (print- ers, data storage), and a wide variety of programs for business and games. From experi- ence on Compufast’s previous audits, Marsh knew that the company’s accountants were very much concerned with timely recording of revenues and receivables and somewhat less concerned with keeping up-to-date records of accounts payable and other liabilities. Marsh knew that the control environment was strong in the asset area and weak in the liability area.

Required: List substantive procedures that Marsh and the audit staff can perform to obtain reasonable assurance that Compufast’s unrecorded liabilities are discovered and adjusted in the finan- cial statements currently under audit.

LO 8-6

LO 8-3, LO 8-6

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8.54 Fictitious Vendors, Theft, and Embezzlement. The following case is designed like the ones in the chapter. Your assignment is to write the audit approach portion of the cases orga- nized around these sections:

Objective. Express the objective in terms of the facts supposedly asserted in financial records, accounts, and statements.

Control. Write a brief explanation of desirable controls, missing controls, and especially the kinds of “deviations” that could arise from the situation described in the case.

Tests of controls. Write some procedures for getting evidence about existing con- trols,  especially procedures that could discover deviations from controls. If there are no controls to test, then there are no procedures to perform; go to the next section. A “procedure” should instruct someone about the source(s) of evidence to tap and the work to do.

Audit of balance. Write some procedures for getting evidence about the existence, com- pleteness, valuation or allocation, or rights and obligations assertions identified in your objective section.

Discovery summary. Write a short statement about the discovery you expect to accom- plish with your procedures.

Bailey Books Inc. is a retail distributor of upscale books, periodicals, and magazines. Bailey has 431 retail stores throughout the southeastern states. Three full-time purchasing agents work at corporate headquarters. They are responsible for purchasing all inventory at the best prices available from wholesale suppliers. They can purchase with or without obtaining competitive bids. The three purchasing agents are R. McGuire in charge of pur- chasing books, M. Garza in charge of purchasing magazines and periodicals, and L. Collins (manager of purchasing) in charge of ordering miscellaneous items such as paper products and store supplies.

One of the purchasing agents is suspected of taking kickbacks from vendors. In return, Bailey is thought to be paying inflated prices, which first are recorded in inventory and then in cost of goods sold and other expense accounts as the assets are sold or used.

The duties of Collins, the manager in charge, do not include audit or inspection of the performance of the other two purchasing agents. No one audits or reviews Collins’s performance.

The purchasing system is computerized and detail records are retained. An extract from these records is in Exhibit 8.47.1.

This kickback scheme has been going on for two or three years. Bailey Books could have overpaid by several hundred thousand dollars.

(ACFE adapted) 8.55 Bidding Process. Maine Construction builds office buildings. The buildings generally cost

between $5 million and $8 million to build, and the plumbing can cost between $300,000 and $600,000 depending on the building requirements. Therefore, Maine always sends the plumbing work out for bid before deciding on whom to use as a subcontractor. The company has had 21 projects over the past five years with $10 million dollars in plumbing contracts being sent out for bids.

Over the past five years, Maine has asked for bids from three contractors: Beltran Plumb- ing, Delgado Plumbing Services, and Wright Contracting–Plumbing Specialists. Each ven- dor has been reviewed by Maine and is on Maine’s approved vendor list.

Required: For each of the following situations (each situation is independent), determine whether the auditor should be concerned about the controls over the bidding process. If yes, what control would you recommend to Maine to ensure a fair and honest bidding process?

a. Of the 21 projects sent out for bid, Wright had the winning bid on 12 of the projects. b. Of the 21 projects sent out for bid, Wright had the winning bid on 12 of the projects. In

each of these bidding processes, Wright’s bid was the last bid received. c. Of the 21 projects sent out for bid, each vendor had the winning bid on 7 of the projects. d. Of the 21 projects sent out for bid, Delgado was awarded 5 contracts even though he did

not have the lowest bid.

LO 8-4, LO 8-5, LO 8-6

LO 8-1, LO 8-4

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EXHIBIT 8.51.1 BAILEY BOOKS, INC

Selected Purchases 2018–2020

Vendor Items Purchased 2018 2019 2020 Date of Last Bid Percent of Purchases Bid

(3-yr. period)

Armour Books $ 83,409 $ 02,929 $ 810,103  12/01/16 87% Burdick Canon DeBois, Inc. Elton Books Fergeson Guyford Hyman, Inc. Intertec Jerrico Julian-Borg King Features Lycorp Medallian Northwood Orion Corp. Peterson Quick Robertson Steele Telecom Union Bay Victory Williams

Sundries Magazines Paper Books Books Magazines Supplies Books Paper Magazines Magazines Sundries Books Books Paper Supplies Supplies Books Magazines Sundries Books Magazines Sundries

62,443 1,404,360

321,644 874,893 921,666

2,377,821 31,640

821,904 186,401 431,470 436,820

16,280 —

861,382 86,904

114,623 —

2,361,912 621,490

81,406 4,322,639

123,844 31,629

70,949 1,947,601

218,404 781,602

1,021,440 2,868,988

40,022 898,683 111,923 589,182 492,687

17,404 61,227

992,121 416,777

— 96,732

3,040,319 823,707 101,193

4,971,682 141,909

35,111

76,722 2,361,149

121,986 649,188

1,567,811 3,262,490

46,911 949,604

93,499 371,920 504,360

21,410 410,163

— 803,493

— 110,441

3,516,811 482,082 146,316

5,368,114 143,286

42,686

— 11/03/18 06/08/18 07/21/18 09/08/18 10/08/18 10/22/18 11/18/18 10/04/18 02/07/18 11/18/18

— 12/15/18 12/07/17 11/02/17

N/A 11/03/18 12/01/18 11/03/18

— 12/03/18 06/09/18

— 94 57 91 88 81 —

86 72 44 89 —

99 —

15 N/A 86 96 90 —

97 89 —

8.56 Grounds for Dismissal. This case is designed like the ones in the chapter. Your assign- ment is to write the “audit approach” portion of the case organized around these sections: Objective. Express the objective in terms of the facts supposedly asserted in financial records, accounts, and statements.

Control. Write a brief explanation of desirable controls, missing controls, and especially the types of “deviations” that might arise from the situation described in the case.

Tests of controls. Write some audit procedures for getting evidence about existing con- trols, especially procedures that could discover deviations from controls. If there are no con- trols to test, then there are no procedures to perform; go to the next section. A “procedure” should instruct someone about the source(s) of evidence to tap and the work to do.

Audit of balance. Write some procedures for getting evidence about the existence, com- pleteness, valuation or allocation, or rights and obligations assertions identified in your objective section.

Discovery summary. Write a short statement about the discovery you expect to accom- plish with your procedures.

A. Doe, IT application manager for The Coffee Company, signed a consulting services agreement with Fictitious Consulting Company (FCC). Doe was required to obtain written approval of the contract from a supervisor but forged the supervisor’s signature. More than 100 invoices came in, which were approved with Doe’s initials. Even though Doe’s approval authority was only $5,000, many of the invoices were for more than $40,000.

FCC was not registered in the state or listed in telephone directories. The phone number was for a cell phone registered to Doe, and the mailing address was a post office box. When Doe’s supervisor asked to meet the FCC consultants, Doe was evasive, saying they “had just left” or “they were working away from the office.” Ultimately, Doe told her supervisor that she had dismissed FCC, but she simply moved the charges to capital accounts that the supervisor did not monitor.

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The Coffee Co. paid more than $3.7 million to FCC between December 1999 and August 2000. (Source: M. Atkinson and M. Biliske, “Grounds for Dismissal,” Internal Auditor, February 2005.)

8.57 Audit the PP&E and Depreciation Schedule. Bart’s Company has prepared the PP&E and depreciation schedule shown in Exhibit 8.50.1. The following information is available. (Assume the beginning balance has been audited:)

∙ The land was purchased eight years ago when building 1 was erected. The location was then remote but now is bordered by a major freeway. The appraised value of the land is $35 million.

∙ Building 1 has an estimated useful life of 35 years and no residual value. ∙ Building 2 was built by a local contractor this year. It also has an estimated useful life of

35 years and no residual value. The company occupied it on May 1 this year. ∙ Computer A system was purchased January 1 six years ago when the estimated useful life

was eight years with no residual value. It was sold on May 1 for $500,000. ∙ Computer B system was placed in operation as soon as Computer A system was sold. It

is estimated to be in use for six years with no residual value at the end. ∙ The company estimated the useful life of the press at 20 years with no residual value. ∙ Auto 1 was sold during the year for $1,000. ∙ Auto 2 was purchased on July 1. The company expects to use it five years and then sell it

for $2,000. ∙ All depreciation is calculated on the straight-line method using months of service.

Required: a. Verify the depreciation calculations. Are there any errors? Put the errors in the form of

an adjusting journal entry, assuming that 90 percent of the depreciation on the buildings and the press has been charged to Cost of Goods Sold and 10 percent is still capitalized in the inventory, and the other depreciation expense is classified as General and Administra- tive Expense (i.e., building and press depreciation is considered a product cost; inventory on hand includes 10 percent of the depreciation expense for buildings and the press: $180,700; Cost of Goods Sold contains the other 90 percent: $1,626,300).

b. List two audit procedures for auditing the additions to PP&E. c. What will auditors expect to find in the Gain and Loss on Sale of Assets account? What

amount of cash flow from investing activities will be in the statement of cash flows?

LO 8-6, LO 8-7

Asset Cost (000s) Accumulated Depreciation (000s)

Description Beginning

Balance Added Sold Ending

Balance Beginning Balance Added Sold

Ending Balance

Land 10,000     10,000        

Building 1 30,000     30,000 6,857 857   7,714

Building 2   42,000   42,000   800   800

Computer A 5,000   5,000 0 3,750 208 3,958 0

Computer B   3,500   3,500   583   583

Press 1,500     1,500 300 150   450

Auto 1 15   15 0 15   15 0

Auto 2   22   22   2   2

Total 46,515 45,522 5,015 87,022 10,922 2,600 3,973 9,549

EXHIBIT 8.54.1  PP&E and Depreciation

8.58 PP&E Assertions and Substantive Procedures. This question contains three items that are management assertions about property and equipment. Following them are several substan- tive procedures for obtaining evidence about management’s assertions.

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Assertions 1. The entity has legal right to property and equipment acquired during the year. 2. Recorded property and equipment represent assets that actually exist at the balance-sheet

date. 3. Net property and equipment are properly valued at the balance-sheet date.

Substantive Procedures a. Trace opening balances in the summary schedules to the prior-year audit documentation. b. Review the provision for depreciation expense and determine whether depreciable lives

and methods used in the current year are consistent with those used in the prior year. c. Determine whether the responsibility for maintaining the property and equipment records

is separated from the responsibility for custody of property and equipment. d. Examine deeds and title insurance certificates. e. Perform cutoff tests to verify that property and equipment additions are recorded in the

proper period. f. Determine whether property and equipment are adequately insured. g. Physically examine all major property and equipment additions.

Required: For each of the three assertions (1, 2, and 3), select the one best substantive audit procedure (a–g) for obtaining competent evidence. A procedure may be selected only once or not at all.

(AICPA adapted) 8.59 Assertions and Substantive Procedures for Property, Plant, and Equipment (PP&E).

Following are the four assertions about account balances that can be applied to the audit of a company’s PP&E, including assets the company has constructed itself: existence, rights and obligations, completeness, and valuation and allocation.

Required: For each of the following substantive procedures, (1) cite one assertion most closely related to the evidence the procedure will produce (the primary assertion) and (2) when appropri- ate, cite one or more other assertions that also are related to the evidence the procedure will produce—the secondary assertion(s).

a. For major amounts charged to PP&E and a sample of smaller charges, examine supporting documentation for expenditure amounts, budgetary approvals, and capital work orders.

b. For a sample of capitalized PP&E, examine construction work orders in detail. c. For a sample of construction work orders, vouch time and material charges to supporting

payroll and material usage records. Review the reasonableness of the hours worked, the work description, and the material used.

d. Evaluate the policy and procedures for allocating overhead to the work orders, and recal- culate their application.

e. Determine whether corresponding retirements of replaced PP&E have occurred and have been properly entered in the detail records.

f. Select major additions for the year and a random sample of other additions, and inspect the physical assets.

g. Vouch a sample of charges in the Repairs account, and determine whether they are proper repairs, not capital items.

h. Review the useful lives, depreciation methods, and salvage values for reasonableness. Recalculate depreciation.

i. Study loan documents for terms and security of loans obtained for purchase of PP&E. j. Inspect title documents for automotive and real estate assets. k. Analyze the productive economic use of PP&E to determine whether any other-than-

temporary impairment is evident. (AICPA adapted)

8.60 CAATs Application—PP&E. You are supervising the audit fieldwork of Sparta Springs Com- pany and need certain information from Sparta’s equipment records, which are maintained on a computer file. The particular information is (1) net book value of assets so that your assistant

LO 8-2, LO 8-6

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can reconcile the subsidiary ledger to the general ledger control accounts (the general ledger contains an account for each asset type at each plant location) and (2) sufficient data to enable your assistant to find and inspect selected assets. The record layout of the master file follows:

Asset number. Description. Asset type. Location code. Year acquired. Cost. Accumulated depreciation, end of year (includes accumulated depreciation at the begin- ning of the year plus depreciation for year to date). Depreciation for the year to date. Useful life. From the data file described earlier,

a. Lis’t the information needed to verify correspondence of the subsidiary detail records with the general ledger accounts. Does this work complete the audit of PP&E?

b. What additional data are needed to enable your assistant to inspect the assets? 8.61 Search for Unrecorded Liabilities. The list of vouchers payable for Potter’s Magic Shoppe

at December 31 follows: LO 8-7

Vendor Invoice Date Amount

Hagrid Cleaning Services 11/15 $ 4,322.43

Hermione’s Hats 12/02 2,167.76

Lockhart Magic Books 12/31 6,489.11

Malfoy Financial Consultants 12/28 23,752.63

McGonagall Veterinary Supplies 12/23 4,590.60

Moaning Myrtle’s Mystical Capes 10/14 11,529.88

Nicholas Fancy Headwear 12/29 51,268.62

Snape’s Snakes 12/28 36,152.45

Weasley’s Wands 12/28 6,400.55

Hogwart’s Rentals 12/15 53,000.00

   Total vouchers payable   $199,674.03

Check Number Payee Description Invoice Date Amount

1842 Malfoy Financial Consultants Professional services 12/28 $23,752.63

1843 Hagrid Cleaning Services October monthly cleaning 11/15 4,322.43

1844 Hogwart’s Rentals January rent 12/15 53,000.00

1845 Lockhart Magic Books Inventory 12/31 6,489.11

1846 Dudley Pastries Catering for office Christmas party 1/15 6,300.00

1847 Weasley’s Wands Inventory 12/28 6,400.55

1848 Rowlin’ Enterprises Trademark 1/1 10,000.00

1849 McGonagall Veterinary Supplies Inventory 12/23 4,590.60

1850 Nicholas Fancy Headwear Inventory 12/29 51,268.62

1851 Weasley’s Wands Inventory 12/31 6,400.55

1852 Hermione’s Hats Inventory 12/02 2,167.76

1853 Lockhart Magic Books Inventory 12/31 5,932.89

1854 Hagrid Cleaning Service November monthly cleaning 12/15 4,322.43

1855 Malfoy Financial Consultants Professional services 1/28 13,888.56

Checks written in the following January are

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Required a. Prepare an audit plan for the audit of unrecorded liabilities for Potter’s Magic Shoppe. b. Prepare an adjusting journal entry to correct accounts payable. Potter’s maintains per-

petual inventory records, and the inventory was counted and adjusted on December 31. 8.62 Identifying Assertions, Control Activities, and Substantive Procedures Related to

Misstatements 1. During your audit of the December 31, 2020 financial statements of Bramble Thorn-

burg, Inc., a wholesaler of “pointy objects”, you conduct your testing on the inventory and purchasing cycle. There are several misstatements in the company’s inventory and accounts payable, but of course you don’t know that before the audit begins. For each of the misstatements, write the letter in the box for (1) the management assertion violated, (2) a specific internal control procedure the company could implement to prevent this misstatement from occurring in the future, and (3) a specific substantive audit procedure the auditor would most likely perform to detect the misstatement. Any selection may be used once, more than once, or not at all. Each box can have only one letter written in it. It is possible that there may be multiple correct responses for some questions.

LO 8-2, 8-4, 8-6

Assertion Control Activity/Procedure Substantive Audit Procedure

a. Existence of Inventory a. Segregate authorization from record keeping and custody

a. Perform an inventory count

b. Completeness of Inventory

b. Three way match of POs, receiving reports, and vendor invoices

b. Confirm Accounts Payable with vendors

c. Valuation of Inventory c. Pre-numbered receiving reports with daily reconciliation of sequence

c. Perform purchase cutoff tests

d. Classification of Inventory

d. All purchases require authorization d. Agree purchases to board of directors minutes

e. Existence of Accounts Payable

e. Regular comparisons to budgets are made by management

e. Vouch recorded purchases to vendor invoices

f. Completeness of Accounts Payable

f. Daily reconciliations from recorded postings to supporting documents.

f. Obtain management representation letter

g. Classification of Accounts Payable

g. Pre-numbered checks with daily reconciliation of sequence

g. Perform substantive analytical procedures

a. Payments to suppliers made on December 31, 2020 were not recorded until January 3, 2021.

Assertion: Control Activity: Substantive Procedure:

b. Invoices for purchases were posted to incorrect vendor accounts. Assertion: Control Activity: Substantive Procedure:

c. Inventory is being stolen upon receipt prior to being placed in the company warehouse. Assertion: Control Activity: Substantive Procedure:

d. Inventory costing $1,254,721 was shipped to customers on January 3, 2021, and was recorded as COGS on December 31, 2020.

Assertion: Control Activity: Substantive Procedure:

e. Some purchase transactions were not recorded. Assertion: Control Activity: Substantive Procedure:

8.63 Identifying Payments to Unauthorized Suppliers For this exercise, your client, BrightIDEAs Inc., has provided you with data for two related files, an accounts payable history file and a supplier master file. To test the authorization of purchases to only legitimate suppliers, the auditor must complete a series of related steps:

1. Import the client’s database of accounts payable. 2. Import the client’s authorized supplier list.

LO 8-7

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3. Merge the accounts payable and supplier databases. 4. Identify payments to unauthorized suppliers.

Required: Produce a listing of payments to unauthorized suppliers. Required Data and IDEA Workbook page references are available on Connect.

Source: C1202 IDEA Data Analysis Workbook: IDEA Version Ten. 2016. CaseWare IDEA, Inc. Toronto, CA.

Applying IDEA to the Purchasing Cycle—Elm Manufacturing Company Exercises 8.64, 8.65, and 8.66 require the application of IDEA in the purchasing cycle

audit. Elm Manufacturing Company (ELM) is a small manufacturer of backpacks located in Rochelle, Illinois. You have access to ELM’s electronic records in Connect. The appropriate files for these exercises are the Purchases 2020–4th Q dataset, as well as the Cash Disburse- ments 2020–4th Q dataset. You will also require the Approved Vendors dataset to complete these assignments. Detailed information about ELM, instructions for accessing datasets, and a data directory for data sets can be found in Connect.

8.64 Summarizing Purchasing Data with IDEA. You have been assigned the task of under- standing the client’s purchasing habits, including their use of authorized vendors and pay- ment time frames, and you must use IDEA to gather this information.

Required: a. Determine the total dollar amount ordered from each vendor. What companies are the

three largest vendors by dollar amount? How would this information assist an auditor in planning the audit?

b. Determine what products are ordered most often. What item is ordered most often? How might this information affect the audit?

c. Determine the accounts payable amount for each vendor as of March 31. What compa- nies have the three largest accounts payable balances? How would this information assist an auditor in planning the audit?

d. Were any orders made to vendors not on the approved vendor list? How would this infor- mation assist an auditor in planning the audit?

e. Were there any discounts available that were not taken? Why is this important? f. Were there any vendors paid late? Why is this important? g. Were there any items that did not pass inspection? Why is this information important to

the auditor? 8.65 Tests of Controls in the Purchasing Cycle with IDEA. You have identified relevant con-

trols for several assertions within the purchasing cycle, and you must use IDEA to perform several tests of controls.

Required: a. Are all checks accounted for? If there are checks that are not accounted for, how would

this affect the audit? b. Are there any duplicate check numbers? If there are duplicate checks, how would this

affect the audit? c. Are there any payments to vendors not on the approved vendor list? If there are checks to

such vendors, how would this affect the audit? d. Were any checks voided? Were any checks written to at cash or bearer? How would this

affect the audit? 8.66 Testing for Unmatched Invoices. A concern in all audits is the risk that payments are

made that do not represent valid expenses. One common test is to match payments to valid invoices, and you must use IDEA to perform this test.

Required: Match the paid invoice numbers in the purchases data set with the invoice numbers in the cash disbursements data set. Are there unmatched invoices from the purchase data? Are there any disbursements with invoices that do not match to the purchase data? What are the possible causes for discrepancies between these data sets? How would the auditor address these discrepancies?

LO 8-7

LO 8-7

LO 8-7

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Apollo Shoes Audit of Liabilities You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Water- shed and have been assigned to the engagement team of a new audit client, Apollo Shoes Inc. You have been asked to audit Apollo’s liability accounts, which includes evaluating documents such as debt confirmations, vendor invoices, etc. Detailed instructions, sup- porting documents, and working papers needed to complete the audit of liabilities can be found in Connect.

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Internal Control Questionnaires

Appendix 8A

APPENDIX EXHIBIT 8A.1 Internal Control Questionnaire—Acquisitions and Expenditures

  Yes/No Comments

Occurrence 1. Are the purchasing department, accounting department, receiving department, and shipping department

independent of each other? 2. Are receiving reports prepared for each item received and copies transmitted to inventory custodians? To

purchasing? To the accounting department? 3. Are purchases made by employees authorized through standard purchases procedures? 4. Are quantity and quality of goods received determined at the time of receipt by receiving personnel

independent of the purchasing department? 5. Are vendors’ invoices reconciled against purchase orders and receiving reports before a liability is recorded? 6. Do managers compare actual expenses to budget? 7. Are all documents in the vouchers package canceled with a PAID stamp when paid? 8. Are shipping documents authorized and prepared for goods returned to vendors? 9. Are invoices approved for payment by a responsible officer?

Completeness 1. Are the purchase order forms prenumbered and the numerical sequence checked for missing documents? 2. Are receiving report forms prenumbered and the numerical sequence checked for missing documents? 3. Is the accounts payable department notified of goods returned to vendors? 4. Are vendors’ invoices recorded immediately on receipt? 5. Are unmatched receiving reports reviewed frequently and investigated for proper recording? 6. Is statistical analysis used to examine overall purchasing levels? 7. Are vendors’ monthly statements reconciled with individual accounts payable accounts?

Accuracy 1. Are competitive bids received and reviewed for certain items? 2. Are all purchases made only on the basis of approved purchase requisitions? 3. Are all purchases, whether for inventory or expense, routed through the purchasing department for approval? 4. Does the accounts payable department check invoices against purchase orders and receiving reports for

dates, quantities, prices, and terms? 5. Does the accounting department check invoices for mathematical accuracy? 6. Is the accounts payable listing balanced periodically with the general ledger control account? 7. Are purchase prices approved by a responsible purchasing officer? 8. Is accounts payable reconciled to the general ledger every period? 9. Are monthly statements reviewed by senior officials?

Classification 1. Do the chart of accounts and the accounting manual give instructions for classifying debit entries when

purchases are recorded? 2. Are journal entries authorized at appropriate levels?

Cutoff 1. Does the accounting manual give instructions to date purchase/payable entries on the date of receipt of

goods?

   

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APPENDIX EXHIBIT 8A.2 Selected System Questionnaire Items—General and Application Controls

Yes/No Comments

General Controls 1. Are computer operators and programmers excluded from participating in the input and output control

functions? 2. Are programmers excluded from entering transactions or performing other routine computer operations? 3. Is there a database administrator who is independent of computer operations, systems, programming,

and users? 4. Are computer personnel restricted from initiating, or authorizing, transactions or adjustments to the

general ledger master database or the subsidiary ledger master database? 5. Is access to the computer room restricted to authorized personnel? 6. Is online access to data and programs controlled with the use of department account codes, personal

ID numbers, and passwords? 7. Are systems, programs, and documentation stored in a fireproof area? 8. Can current files, particularly master files, be reconstructed from files stored in an offsite location?

Application Controls 1. Are process manuals for purchasing and accounts payable current? 2. Are process documents (e.g., purchase requisitions, purchase orders, bills of lading) signed as evidence

of review and authorization? 3. Are all data fields subject to input validation tests—missing data tests, limit and range tests, check

digits, valid codes, and so forth? 4. Are input error reports generated daily? Are they returned to the accounting department for correction

of errors? 5. Is an accounting department person assigned the responsibility for promptly correcting input errors and

reentering the data for inclusion with the next report? 6. Are controls used to reconcile computerized output to input control data? 7. Are reports reviewed for reasonableness, accuracy, and legibility by the responsible department

personnel?

APPENDIX EXHIBIT 8A.3 Acquisitions and Expenditures Questionnaire—System Controls

  Yes/No Comments

 1. Is each terminal restricted to designated functions? For example, the receiving clerk’s terminal cannot accept a purchase order entry.

 2. Are identification numbers and passwords required to enter purchase orders, vendors’ invoices, and the receiving report information?

 3. Are certain personnel authorized to determine the status of various records, such as an open voucher, but not authorized to enter data? Do these personnel have “read only” authorization?

 4. Is all input immediately logged to provide restart processing should any terminal become inoperative during the processing?

 5. Do transaction codes call up a full screen “form” on the terminals that appears to the operators in the same format as the original paper documents?

 6. Does the system reject incomplete or incorrect information (online input validation)?  7. Are all printed documents computer numbered, and are the numbers stored as part of the record?  8. Do all records in the open databases have the vendor’s number as the primary search and matching

field key?  9. Can status searches be made by another field? For example, the inventory number can be the search

key to determine the status of a purchase of an item in short supply. 10. Is a daily search of the open databases made—for example, open purchase orders more than 10 days

past the delivery date? 11. Is the check signature printed using a signature plate that is installed on the computer printer only

when checks are printed? 12. Does a designated person in the treasurer’s office maintain custody of this signature plate and take it

to the computer room to be installed when checks are printed? 13. Is this person restricted from access to blank check stock? 14. Are the printed checks taken immediately from the computer room for mailing?

   

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APPENDIX EXHIBIT 8A.4 Acquisitions and Expenditures Questionnaire—Property and Equipment Controls 

  Yes/No Comments

Occurrence 1. Is the accounting department notified of actions of disposal, dismantling, or idling a productive asset?

For terminating a lease or rental? 2. Are assets inspected periodically and physically counted?

Completeness 1. Are detailed property records maintained for the various assets included in PP&E? 2. Are property tax assessments periodically analyzed? When was the last analysis? 3. Are purchase contracts for major assets provided to the accounting department?

Accuracy 1. Are capital expenditure and leasing proposals prepared for review and approval by the board of

directors or by responsible officers? 2. When actual expenditures exceed authorized amounts, is the excess approved? 3. Is there a uniform policy for assigning depreciation rates, useful lives, and salvage values? 4. Are depreciation calculations checked by internal auditors or other officials? 5. Are subsidiary records periodically reconciled to the general ledger accounts?

Classification 1. Does the accounting manual contain policies for capitalization of assets and expensing repair and

maintenance? 2. Are memorandum records of leased assets maintained?

Cutoff 1. Does the accounting manual give instructions for recording PP&E additions on a proper date of

acquisition?

   

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Audit Plans

Appendix 8B

APPENDIX EXHIBIT 8B.1

DUNDER-MIFFLIN, INC. Audit Plan for Accounts Payable

12/31/20

  Performed by Ref.

1. Obtain a trial balance of recorded accounts payable as of year-end. a. Foot and trace the total to the general ledger account. b. Vouch a sample of balances to vendors’ statements. Review the trial balance for related-party payables. 2. Send confirmations to creditors, especially those with small or zero balances and those with which the company

has done significant business. 3. Inquire of client personnel about their procedures for ensuring that all liabilities are recorded. 4. Scan the open purchase order file at year-end for indications of material purchase commitments at fixed prices.

Obtain current prices and determine whether any adjustments for loss are needed. 5. Obtain a list of unmatched vendor invoices, and review receiving reports for receipt of goods. 6. For goods received before year-end, trace the unmatched receiving reports to accounts payable, and determine

whether items recorded in the next accounting period need to be adjusted. 7. Select a sample of cash disbursements from the accounting period following the balance-sheet date. Vouch

them to supporting documents (invoice, receiving report) to determine whether the related liabilities were recorded in the proper accounting period.

   

APPENDIX EXHIBIT 8B.2

DUNDER-MIFFLIN, INC. Audit Plan for Prepaid Expenses, Accrued Expenses, Deferred Costs

12/31/20

  Performed by Ref.

1. Obtain a schedule of all prepaid expenses, deferred costs, and accrued expenses. 2. Review documentation to determine whether each item is properly allocated to the current or future accounting

periods. 3. Select significant additions to deferred and accrued amounts, and vouch them to supporting invoices, contracts,

or calculations. 4. Examine documentation for the basis for deferral and accrual, and recalculate the recorded amounts. 5. Review the nature of each item, inquire of management, and determine whether the remaining balance will be

recovered from future operations. 6. Scan income and expense items for items that should be considered prepaid, deferred, or accrued and allocated

to current or future accounting periods. 7. Scan the expense accounts in the trial balance and compare to prior year. a. Investigate an unusual difference that could indicate failure to account for a prepaid or accrual item. b. Review each item to determine the proper current or noncurrent balance sheet classification.

   

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APPENDIX EXHIBIT 8B.3

DUNDER-MIFFLIN, INC. Audit Plan for Property, Plant and Equipment

12/31/20

  Performed by Ref.

Property, Plant, and Equipment 1. Summarize and foot detailed asset subsidiary records, and reconcile to general ledger control account(s). 2. Select a sample of detail asset subsidiary records: a. Perform a physical observation (inspection) of the assets recorded. b. Inspect title documents, if any, to ensure ownership by the client. 3. Prepare, or have client prepare, a schedule of asset additions and disposals for the period: a. Vouch to documents indicating proper approval. b. Vouch costs to invoices, contracts, or other supporting documents. c. Review all costs of shipment, installation, testing, and other appropriate costs for proper capitalization. d. Vouch proceeds (on dispositions) to cash receipts or other asset records. e. Recalculate gain or loss on dispositions. f. Trace amounts to detail asset records and general ledger control account(s). 4. Observe the taking of a physical inventory of the assets, and compare with detailed asset records. 5. Obtain written representations from management regarding pledge of assets as security for loans and leased

assets. 6. Select a sample of repair and maintenance expense entries, and vouch them to supporting invoices for evidence

of property that should be capitalized.

Depreciation 1. Review depreciation expense for overall reasonableness with reference to costs of assets and average

depreciation rates. 2. Prepare, or have client prepare, a schedule of accumulated depreciation showing beginning balance, current

depreciation, disposals, and ending balance. a. Review the schedule for appropriate asset costs, useful life, and salvage value. 3. Trace equipment listed to depreciation expense and asset disposition analyses. 4. Recalculate depreciation expense and trace to general ledger account(s). 5. Trace amounts to general ledger account(s).

Other Accounts 1. Review prepaid insurance for proper recording and adequacy of coverage. 2. Review accrued property taxes to determine whether taxes due on assets have been paid or accrued. 3. Recalculate prepaid and/or accrued insurance and tax expenses. 4. Select a sample of rental expense entries and vouch to rent/lease contracts to determine whether any leases

qualify for capitalization.

Intangibles and Related Expenses 1. Review merger documents for proper calculation of purchased goodwill. 2. Inquire of management about legal status of patents, leases, copyrights, and other intangibles. 3. Review documentation of new patents, copyrights, leaseholds, and franchise agreements. 4. Select a sample of recorded research and development expenses. Vouch to supporting documents for evidence

of proper classification. 5. Recalculate amortization of goodwill, patents, and other intangibles. 6. Perform tests for goodwill impairment.

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The Payroll Cycle Martin Bodner, the former finance chief of Tommy Hilfiger Group Handbags and Small Leather Goods Inc., pleaded guilty to mail fraud and wire fraud for allegedly stealing more than $19 million, according to Michael Garcia, U.S. Attorney for the Southern District of New York. According to Garcia, Bodner began working at the Hilfiger licensee in March 2000, eventually rising to CFO. Among his responsibili- ties was to supervise the company’s payroll. Beginning in 2000, Bodner began stealing money from his employer by secretly increasing the amount of money that he was to be paid in salary and bonus and arranging to be reimbursed by the handbag and leather goods unit for phony expenses he purportedly had incurred. In addition, during 2004 and 2005, Bodner added one of his sons, who did not work for the company, to the company’s payroll. He arranged for  his  son to be paid about $225,500 during those years. Bodner was fired on December 21, 2007.

Bodner entered into a plea deal in which he agreed to forfeit a home in Sands Point, New York, along with a Manhattan apartment, three cars, and various other properties. Bodner also was accused of causing hundreds of checks to be issued to various recipients for the purpose of paying off his personal credit card bills; purchasing a luxury automo- bile for himself; paying for insurance for a home, apartments, and automobiles owned by Bodner; and paying for decorating services.6

Every company has payroll. It can include manufacturing labor, research scientists, administrative personnel, or all of these. Payroll may take different forms. Personnel management and the payroll accounting cycle not only include transactions that affect the wage and salary accounts, but also the transactions that affect pension benefits, deferred compensation contracts, compensatory stock option plans, employee benefits (such as health insurance), payroll taxes, and related liabilities for these costs. An important aspect of the payroll cycle is that it is self-policing. If employees are not paid, they will complain. If someone commits fraud by overpaying an employee and then diverts the difference, the employee will complain because his or her W-2 will be overstated and the employee will owe too much tax. As a result, company employees report many misstate- ments (both intentional and unintentional).

Typically, balance sheet accounts such as accrued payroll and accrued taxes are not material to companies’ financial position. In addition, because of the self-policing nature of the accounts and the regulatory restrictions of the Internal Revenue Service and the Department of Labor, controls over payroll are normally stronger than over other areas. Therefore, most audit procedures related to payroll consist of evaluation of internal con- trol and analytical procedures.

THE PAYROLL CYCLE: TYPICAL ACTIVITIES Appendix Exhibit 8C.1 shows a payroll cycle. It starts with hiring (and firing) people and determining their wage rates and deductions, proceeds to attendance and work (timekeep- ing), and ends with payment followed by preparation of governmental (tax) and internal reports.

The elements that follow are part of the payroll internal control system.

Personnel 1 A human relations department that is independent of the other functions should have authority to add new employees to the payroll, delete terminated employees,

LO 8-8 Describe the payroll cycle, including typical source documents and controls.

6“Hilfiger Unit Ex-CFO Pleads Guilty to $19M Fraud,” CFO.com, September 16, 2008.

Appendix 8C

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obtain authorizations for deductions, and transmit authority for pay rate changes to the payroll department. A process should exist to ensure that terminated employees are removed from the payroll. This is often done in conjunction with an exit inter- view performed by human resources. Final checks and W-2s should be mailed to the employee’s home.

Supervision 2 Supervisors assign the employees to their jobs and approve any overtime. The imme- diate supervisor should approve all employee activity data (number of hours worked, job number, absences, time off allowed for emergencies, and the like). Finally, super- visors compare production plans and budget reports to actual employee costs for discrepancies.

Timekeeping 3 Employees paid by the hour or on various incentive systems require records of time, production, piecework, or other measures of the basis for their pay. (Salaried employees do not require such detailed records.) Timekeeping or similar records are collected in a variety of ways. The traditional time clock is still used in many organizations. More sophisticated computerized systems perform the same function without the paper time card. Production employees may clock in for various jobs or production processes in the system for assigning labor cost to various stages of production.

Supervisors should approve timekeeping records. In computerized systems, this approval may be automatic by virtue of the supervisory passwords used to input data into a computerized payroll system.

EXHIBIT 8C.1 Typical Activities in the Payroll Cycle

Employment Application

Record Keeping

Custody

Start here

Authorization

Accounts/Records

Wages expense and accrual Payroll tax expense and liability Pension expense and liability Post-retirement benefits expense and liability Cash disbursements

Termination Notice

Union Contract Other Approval

Deduction Authorizations Employee Benefits

Government Payroll Tax Reports Employees‘

W-2 Forms

Labor Cost Analyses

Payroll Checks 4

3

2

1

Production Cycle

Cost Accounting

Payroll Register

Year-to-Date Earnings Records

Timekeeping Records

Personnel Files

Acquisition and Payment Cycle

Cash Disbursement (reconciliation)

Cash Disbursement

Compensation Determination

Personnel Hiring/Firing

Payroll Distribution

Payroll Accounting

Supervision, Attendance, and Work

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Record Keeping 4 The payroll accounting function should prepare individual paychecks and pay envelopes or make electronic transfers using rate and deduction information supplied by the per- sonnel function and data supplied by the timekeeping–supervision functions. Persons in charge of the hiring, supervision, and timekeeping functions should not also prepare the payroll. They could be tempted to get checks for fictitious or terminated employees. Pay- roll accounting maintains individual year-to-date earnings records and prepares the state and federal tax reports. The payroll tax returns and the annual W-2 report to employees are useful records for audit recalculation and analytical procedures.

The main feature of custody in the payroll cycle is the possession of the paychecks, cash, or electronic transfer codes for direct payments. A payroll distribution function should control the delivery of pay to employees so that unclaimed checks, cash, or incomplete electronic transfers are not returned to persons involved in any of the other functions. The functional duties and responsibilities just described relate primarily to nonsalaried (hourly) employees. For salaried employees, the system is simplified by not having to collect timekeeping data. In nonmanufacturing businesses, the cost accounting operations can be very simple or even nonexistent.

Direct deposit is an excellent control for payroll distribution. Employees on vacation, ill, or otherwise not at the facility will still have their check delivered, and unclaimed pay- checks are almost nonexistent. Further, there is no opportunity for employees to alter a paycheck in any manner. Be aware that some individuals do not have (and do not want) a bank account. Also, the client cannot require an employee to have a bank account. There- fore, even if the client has a direct deposit system, the auditor should make inquiries as to those employees paid by check.

The relative importance of each of these four areas should be determined for each engagement in light of the nature and organization of the company’s operations.

Leonid Fridman, 60, owned and operated Millennium Commercial Corp., a Brooklyn-based company that performed tile work for the Port Authority of New York and New Jersey. The defendant and his company performed tile restoration work as a subcontractor on the renovation of the TWA Flight Center at John F. Kennedy Airport in 2009 and 2010. Under the Port Authority contract for the project and labor law, the defendant was required to pay his laborers and mason tenders more than $50 per hour and more than $70 per hour for tile setters.

According to court records, Fridman was aware that he was required to pay the prevailing wages but still paid his workers only

$10 to $30 per hour. To avoid detection, Fridman filed false certified payroll reports stating he paid his workers the prevailing wages and issued paychecks to the workers that matched those payroll reports. Fridman then made his workers cash the checks at his bank and kick back, or return, a majority of the cash to him, according to the New York Attorney General’s office.

Prosecutors say that Fridman then hid more than $100,000 of the money he stole by moving it into the account of a Florida corporation, Green Investments Inc., that he controlled. Source: “NYC Contractor Charged with Payroll Fraud, Larceny, and Launder- ing,” CPA Practice Advisor, February 6, 2013.

Why Am I Underpaid?AUDITING INSIGHT

Hospital Corporation of America (HCA) runs more than 160 facilities across the United States and in London and treats millions of people a year. In 2006, HCA was bought by a consortium including its manage- ment, the family of former Senate majority leader Bill First (Tennes- see), and three major financial firms for about $33 billion in the largest leveraged buyout ever at the time. The Securities and Exchange

Commission has opened a probe into whether HCA violated securi- ties laws by manipulating books and records. Part of the investigation has focused on HCA’s London subsidiary and whether the company fabricated tens of thousands of payments for phantom nursing shifts. Source: “SEC Probing Biggest Hospital Company: Nursing Shifts Examined in HCA London Unit,” The Washington Post, October 7, 2009.

Nurse, I Need You?AUDITING INSIGHT

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REVIEW CHECKPOINTS 8C.1 What functional responsibilities are associated with the payroll cycle? 8C.2 Which duties should be separated in the payroll cycle? 8C.3 How does a company ensure that terminated employees are removed from the payroll?  8C.4 Describe a walkthrough of the payroll transaction flow from hiring authorization to payroll check

disbursement. (a) What document copies would be collected? (b) What controls should be noted?

Significant Accounts and Relevant Assertions The major risks in the payroll cycle include

∙ Paying ghost employees, employees who do not exist (invalid transactions). ∙ Paying terminated employees (who have not been removed from payroll) whose pay-

checks are then endorsed with forged signatures by their supervisors. ∙ Overpaying for time or production (inaccurate transactions, improper valuation). ∙ Accounting incorrectly for costs and expenses (incorrect classification, improper or

inconsistent presentation and disclosure). ∙ Not ensuring that related taxes and third parties (e.g., insurance providers) are appro-

priately paid.

Because of these risks, and the desire of employees to obtain more money, the valuation of payroll is the most relevant assertion. This is illustrated in the next Auditing Insight. The potential for ghost employees makes existence a key assertion as well. Management may also gain from misclassifying payroll so the auditor must consider the classification assertion a risk. Certainly, if an employee was left off the payroll, the employee would make that known to the organization, therefore, completeness is a very low risk.

Prosecutors told the Winchester Crown Court in southern England that Jaswinder Bains, 45, was “blatantly dishonest” on the time cards for his job as a social worker on at least 24 occasions. In one instance, Bains allegedly claimed he worked 23 hours in one day on 29 case files, even though his credit card records show he was on a shopping spree in Paris that day. Bains testified that he did not

falsify his work hour records. “I was working very long hours with- out sleep,” he said. “I do not need a lot of sleep.” He did not explain what was behind his records on another day, when he claimed he worked 28 hours. Source: “Social Worker ‘Claimed for 28-Hour Day,’” The Guardian, www. theguardian.com.

A Dedicated EmployeeAUDITING INSIGHT

Payroll systems produce numerous reports. Some are internal reports and bookkeep- ing records. Others are government tax reports.

Personnel Files The personnel, human relations, or labor relations department keeps individual employee files. The files usually include an employment application, a background investigation report, a notice of hiring, a job classification with pay rate authorization, and employee authorizations for deductions. When employees retire, resign, or are otherwise dismissed, appropriate notices of termination are filed.

A personnel file should establish a person’s existence and employment. The back- ground investigation report is important for employees in such sensitive areas as account- ing, finance, and asset custody positions. News reports are rich with reports of errors and frauds perpetrated by people who falsified their credentials.

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Payroll Register The payroll register is a special journal. It typically contains a row for each employee with columns for the gross regular pay, gross overtime pay, income tax withheld, Social Security and Medicare tax withheld, other deductions, and net pay. The net pay amount usually is transferred from the general bank account to a special imprest bank account that maintains a zero or fixed balance.

Payroll department records contain the canceled checks (or a similar computerized deposit record). The checks have the employees’ endorsements on the back.

Marsha Marston, an assistant accountant, was instructed to look at the endorsements on the back of a sample of canceled payroll checks. She noticed three occurrences of the payee’s signature followed by a second signature. Although scrawled almost illegibly, the second signa- tures were identical and were later identified as the handwriting of Fred

Holmes (the payroll accountant). Holmes had taken unclaimed checks and converted (stole) them. When cashing these “third-party checks,” banks and stores had required him to produce identification and endorse the checks that already had been “endorsed” by the employee payee. The lesson is that second endorsements are a red flag.

Who Signed That?AUDITING INSIGHT

Labor Cost Analysis One of the internal reports in the payroll cycle is a report of labor cost to the cost account- ing department, thus linking the payroll cycle with cost accounting in the production cycle. The cost accounting department can receive its information in more than one way. Some companies have systems that independently report time and production work data from the production floor directly to the cost accounting department. Other companies let their cost accounting department receive labor cost data from the payroll department. When the data are received independently, they can be reconciled with a report from the payroll department.

The cost accounting department (or a similar accounting function) is responsible for labor distribution. This is the most important part of the classification assertion with respect to payroll. Labor distribution is an assignment of payroll to the accounts where it belongs for internal and external reporting.

Payroll data flow from the hiring process, through the timekeeping function, into the payroll department, then to the cost accounting department, and finally to the accounting entries that record the payroll for inventory cost determination and financial statement presentation. The same data are used for various governmental and tax reports.

Beware the “Clearing Account” Clearing accounts are temporary storage places for transactions awaiting final accounting. All clearing accounts should have zero balances after the accounting is completed. A bal- ance in a clearing account means that some amounts have not been classified properly in the accounting records. When the dollars in the clearing account are material, auditors usually investigate the nature of the account with a great deal of skepticism.

Governmental and Tax Reports One of the main objectives of a payroll system is to calculate the payments due to third parties, including insurance fees, union dues, retirement funds, and so on. Of most impor- tance is the calculation of payroll taxes due to the federal, state, and local governments. Large fines, mounting interest, or business closure is a possible ramification if these taxes are not paid timely and accurately. These issues cause payroll systems to be complicated and change almost every year as tax law and tax rates change. The payroll system pro- duces several reports. Auditors can use these reports in tests of controls and substantive procedures produced by accumulating numerous payroll transactions.

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Companies in financial difficulty have been known to try to postpone payment of employee taxes withheld. However, the consequences can be serious. The IRS can and will padlock the business and seize its assets for nonpayment.

Year-to-Date Earnings Records The year-to-date (YTD) earnings records are the cumulative subsidiary records of each employee’s gross pay, deductions, and net pay. Each time a periodic payroll is produced, the YTD earnings records are updated for the new information. The YTD earnings records are a subsidiary ledger of the wages and salaries cost and expense in the financial statements. Like any subsidiary and control account relationship, their sum (i.e., the gross pay amounts) should be equal to the costs and expenses in the financial statements. These YTD records provide the data for periodic governmental tax forms. They can be recon- ciled to the tax reports. Details can be compared to the company’s YTD earnings records.

Employee W-2 Reports The W-2 is the annual report of gross salaries and wages and the income, Social Secu- rity, and Medicare taxes withheld. Copies are filed with the Social Security Administra- tion and the IRS, and copies are sent to employees for use in preparing their income tax returns. The W-2s contain the annual YTD accumulations for each employee. Auditors can use the name, address, Social Security number, and dollar amounts in certain proce- dures to obtain evidence about the existence of the employees. The W-2s can be recon- ciled to the payroll tax reports.

W-2s should be mailed directly to employees’ homes so if someone has been collect- ing additional pay in an employee’s name (e.g., if an employee leaves and the supervisor continues to send in a time card), the employee can spot the added income.

The assessment of payroll-cycle control risk normally takes on added importance because most companies have fairly elaborate and well-controlled personnel and payroll functions. The significant transactions in this cycle are numerous during the year yet result in small amounts in balance-sheet accounts at year-end. Therefore, in most audit engagements, the review of controls, tests of controls, and substantive tests of transac- tions constitute the major portion of the evidence gathered for these accounts. On most audits, the substantive procedures devoted to auditing the payroll-related account bal- ances are limited.

Internal Control Activities and Evaluation In the payroll function, auditors pay special attention to the controls that have been put in place. In a large company, tens of thousands of payroll checks or direct deposit payments may be made during the year. While auditors may test the detail of some transactions, it is the evaluation of internal controls that is deemed most important.

Control activities for proper separation of responsibilities should be in place and oper- ating. By referring to Exhibit 8C.1, you can see that proper separation involves authoriza- tion (personnel department hiring and termination, pay rate, and deduction authorizations) by persons who do not have payroll preparation, paycheck distribution, or reconciliation duties. Payroll distribution (custody) is in the hands of persons who do not authorize employees’ pay rates or time or prepare the payroll checks. Record keeping is performed by payroll and cost accounting personnel who do not make authorizations or distribute pay. Combinations of two or more of the duties of authorization, payroll preparation and record keeping, and payroll distribution in one person, one office, or one computerized system can open the door for errors and frauds.

In addition, the internal controls should provide for detailed control checking proce- dures. Examples of these controls are

∙ Periodic comparison of the payroll register to the personnel department files to check hiring authorizations and any terminated employees who have not been deleted.

∙ Periodic rechecking of wage rate and deduction authorizations.

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∙ Reconciliation of time and production material to cost accounting calculations. ∙ Quarterly reconciliation of YTD earnings records with tax returns. ∙ Payroll bank account reconciliation.

Some companies send each supervisor a copy of the payroll register, showing the employees paid under the supervisor’s authority and responsibility. The supervisor has a chance to reapprove the payroll after it has been completed. Managers also should receive a comparison of actual labor costs to standards to review any unusual differences. The payroll report sent to cost accounting can be reconciled to the labor records used to charge labor cost to production. The cost accounting function should determine whether the labor paid is the same as the labor cost used in the cost accounting calculations. Finally, the payroll bank account can be reconciled like any other bank account.

Information about the payroll cycle control often is gathered initially by completing an internal control questionnaire (ICQ). An example of an ICQ for payroll controls is in Exhibit 5.25. You can study this questionnaire for details of desirable controls. It is orga- nized with headings that identify the important assertions.

COMPUTERIZED PAYROLL Complex computerized systems that gather payroll data, calculate payroll amounts, print checks, and transfer computerized deposits are found in many companies. Even though the technology is complex, the basic management and control functions of ensuring a flow of data to the payroll department should be in place. Various paper records and approval signatures may not exist. They may be embedded in computerized payroll sys- tems. Companies often use service organizations to process their payroll because it is a specialized function that can be performed effectively and efficiently by an organization whose specialty is to keep up with and apply changes in tax laws and rates. Thus, auditors should refer to the requirements of AU-C 402 (“Service Organizations”) in addressing this function.

Service Organizations Service organizations are widely used for payroll preparation. This process can range from the calculation of payroll including the amounts due to third parties and to the actual payment of the payroll to individuals and third parties. Even when service bureaus are used to process payroll, the client is still responsible for payroll. For example, if the calculation for federal taxes is incorrect, the IRS will be auditing the client, not the service bureau payroll provider. Therefore, the auditor must review the payroll controls both at the client and the service organization for processing payroll. This would include getting a report on controls from the service bureau’s auditor and ensuring that controls at the client are in place. The client should verify that the number of checks issued by the service bureau equals the number of employees eligible for compensation during the period. The client should review reports from the third party such as a payroll register (a listing of changes made to the payroll file), and a report of payments due to third parties should be reviewed by the client. The auditor should ensure that payroll numbers are reasonable given the activity level at the client. Analytical procedures can be a powerful test in these situations.

Substantive Analytical Procedures and Tests of Details As stated, for the payroll process, auditors rely heavily on tests of controls. However, there are substantive tests that can be performed. If the workforce is stable, payroll from one period to the next will be relatively consistent. If a weekly payroll significantly declines or increases, the auditor should inquire of management about the inconsistency. Layoffs, overtime, or seasonality may explain the discrepancy, and the auditor can review the payroll register for that period to corroborate the change in the number of paychecks or the increase in overtime.

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There are times when the auditor is concerned about payroll controls or inexplicable changes in payroll expenses. In these cases, the auditor may select a sample of items from the payroll register (remember completeness is low risk so the register should include all employees) and vouch the information to the time cards (hours worked), payroll master file (wage), and the personnel file for authorizations for deductions (insurance, withhold- ing, pension) and wage rate. Personnel files are excellent sources of information when ghost employees are expected. Few ghost employees have life or health insurance. Audi- tors may scan the payroll register looking for employees with no voluntary deductions from their paycheck and vouch the employee information to the personnel files in human resources.

Robert Kenneth Dromm, owner of Pay 1 Plus Payroll Administrators, admitted to siphoning money from clients who hired his company to process quarterly payroll tax payments. Dromm’s firm processed quarterly payroll tax payments for hundreds of clients around the Tampa Bay area. The clients would send Dromm’s company their esti- mated tax payments. Pay 1 Plus Payroll was supposed to handle the paperwork and send the money to the IRS. Between 1999 and 2004, Dromm submitted false, understated filings to the IRS but gave many clients what appeared to be correct payroll tax returns. That allowed him to skim off money and direct it to his personal accounts. Accord- ing to the plea deal concerning this, Dromm used these accounts for personal and business expenses as well as real estate investments.

Defense attorney Anthony LaSpada said the diversion began as a way to pay off old tax debts, not to defraud anyone. Some of Dromm’s

clients had financial needs (to pay debts, rents, wages, taxes, etc.) According to LaSpada, in the mid-1990s, Dromm advanced them money. When a number of these clients went out of business, Pay 1 Plus Payroll was left in a precarious position, and Dromm began to divert funds. During that time, he paid $1.3 million in old tax debts to the IRS, LaSpada added that the company hit another snag in 2003 with the discovery that chief bookkeeper Robert M. Crawford Jr. had embezzled $1.5 million to $2 million on his own. “I strongly believe that had it not been for that embezzlement by Mr. Crawford, that he would have been able to pay,” LaSpada said. Dromm pleaded guilty and was sentenced to four years in federal prison and ordered to pay $1.6 million in restitution. Source: “Payroll Tax Scam Nets 4-Year Term,” Tampa Bay Times, November 3, 2007.

Who Is Your Help Helping?AUDITING INSIGHT

REVIEW CHECKPOINTS 8C.5 What documents should be included in an employee’s personnel file? 8C.6 What features of a payroll system could be expected to prevent or detect the (a) payment of a

fictitious employee and (b) omission of payment to an employee? 8C.7 What are the most common errors and frauds in the personnel and payroll cycle? Which control

characteristics are auditors looking for to prevent or detect these errors and frauds?

FRAUD CASE: EXTENDED AUDIT PROCEDURES 

Case 8C.1

Time Card Forgeries PROBLEM

A personnel agency that leased employees to hospitals assigned Nurse Jane Kent to work at County Hospital. She claimed payroll hours on agency time cards that showed approval signatures of a hospital nursing shift supervisor. The hospital had terminated the shift supervisor several months prior to the periods covered by the time cards in

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question. Kent worked one or two days per week but submitted time cards for a full 40-hour workweek. The personnel agency paid Kent and then billed County Hospital for the wages and benefits. Supporting documents were submitted with the personnel agency’s bills.

Each hospital workstation keeps ward shift logs, which are sign-in sheets showing nurses on duty at all times. Nurses sign in and sign out when going on and going off duty. County Hospital maintains personnel records showing, among other things, the period of employment of its own nurses, supervisors, and other employees.

Kent’s wages and benefits were billed to the hospital at $22 per hour. False time cards overcharging about 24 extra hours per week cost the hospital $528 per week. Kent was assigned to County Hospital for 15 weeks during the year, so she caused overcharges of about $7,900. However, she told three of her friends about the procedure, and they over- charged the hospital another $24,000.

AUDIT APPROACH Control activities should include a hiring authorization to put employees on the pay- roll. When temporary employees are used, this authorization includes contracts for nursing time, conditions of employment, and terms including the contract reimburse- ment rate. Control records of attendance and work should be kept (ward shift log). Supervisors should approve time cards or other records used by the payroll depart- ment to prepare paychecks. In this case, the contract with the personnel agency pro- vided that approved time cards had to be submitted as supporting documentation for the agency billings.

Although the activities and documents for control were in place, the controls did not operate because no one at the hospital ever compared the ward shift logs to time cards, and no one examined the supervisory approval signatures for their validity. The fraud was easy in the personnel agency situation because the nurses submitted their own time cards to the agency for payment. The same fraud could be operated by the hospital’s own employees if they, too, could write their time cards and submit them to the payroll department.

Auditors should make inquiries (e.g., internal control questionnaire) about the error- checking activities performed by hospital accounting personnel. Tests of controls are designed to determine whether control activities are followed properly by the organiza- tion. Because the comparison and checking activities were not performed, there is noth- ing to test.

Select a sample of personnel agency billings and their supporting documentation (time cards). Vouch rates billed by the agency to the contract for agreement to proper rate. Vouch time claimed to hospital work attendance records (ward shift logs). Obtain hand- writing examples of supervisors’ signatures and compare them to the approval signatures on time cards. Use personnel records to determine whether supervisors were actually employed by the hospital at the time they approved the time cards. Use available work attendance records to determine whether supervisors were actually on duty at the time they approved the time cards.

DISCOVERY SUMMARY The auditors quickly found that Kent (and others) had not signed in on ward shift logs for days they claimed to have worked. Further investigation showed that the supervisors who supposedly signed the time cards were not even employed by the hospital at the time their signatures were used for approvals. Handwriting comparison showed that the signatures were not those of the supervisors.

The personnel agency was informed and refunded the $31,900 overpayment that the auditors had proved. The auditors continued to comb the records for more! Source: Adapted from vignette published in Internal Auditor.

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8C.8 An audit team most likely would assess control risk at the maximum if the payroll depart- ment supervisor is responsible for a. Examining authorization forms for new employees. b. Comparing payroll registers with original batch transmittal data. c. Authorizing payroll rate changes for all employees. d. Hiring all subordinate payroll department employees.

(AICPA adapted) 8C.9 Which of the following departments most likely would approve changes in pay rates and

deductions from employee salaries? a. Personnel b. Treasurer c. Controller d. Payroll

(AICPA adapted) 8C.10 Matthew Corp. has changed from a system of recording time worked on clock cards to a

computerized payroll system in which employees record time in and out with magnetic cards. The computerized system automatically updates all payroll records. Because of this change a. A generalized computer audit plan must be used. b. Part of the audit trail is altered. c. The potential for payroll-related fraud is diminished. d. Transactions must be processed in batches.

(AICPA adapted) 8C.11 Effective control over the cash payroll function would mandate which of the following?

a. The payroll clerk should fill the envelopes with cash and a computation of the net wages. b. Unclaimed payroll envelopes should be retained by the paymaster. c. Each employee should be asked to sign a receipt. d. A separate checking account for payroll should be maintained.

8C.12 A large retail enterprise has established a policy that requires the paymaster to deliver all unclaimed payroll checks to the internal audit department at the end of each payroll distri- bution day. This policy was most likely adopted to a. Ensure that employees who were absent on a payroll distribution day are not paid for that day. b. Prevent the paymaster from cashing checks that are unclaimed for several weeks. c. Prevent a bona fide employee’s check from being claimed by another employee. d. Detect any fictitious employee who may have been placed on the payroll.

(AICPA adapted) 8C.13 Auditors ordinarily ascertain whether payroll checks are properly endorsed during the audit of

a. Clock cards. b. The voucher system. c. Cash in bank. d. Accrued payroll.

(AICPA adapted) 8C.14 In determining the effectiveness of an entity’s policies and procedures relating to the occur-

rence assertion for payroll transactions, auditors most likely would inquire about and a. Observe the separation of duties concerning personnel responsibilities and payroll

disbursement. b. Inspect evidence of accounting for prenumbered payroll checks.

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Multiple-Choice Questions for Practice and Review

All applicable Exercises and Problems are available with Connect.

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c. Recompute the payroll deductions for employee benefits. d. Verify the preparation of the monthly payroll account bank reconciliation.

(AICPA adapted) 8C.15 Which of the following activities most likely would be considered a weakness in an entity’s

internal control over payroll? a. A voucher for the amount of the payroll is prepared in the general accounting depart-

ment based on the payroll department’s payroll summary. b. Payroll checks are prepared by the accounts payable department and signed by the treasurer. c. The employee who distributes payroll check returns unclaimed payroll checks to the

payroll department. d. The personnel department sends employees’ termination notices to the payroll department.

8C.16 Which of the following payroll control activities would most effectively ensure that pay- ment is made only for work performed? a. Require all employees to record arrival and departure by using the time clock. b. Have a payroll clerk recalculate all time cards. c. Require all employees to sign their time cards. d. Require employees to have their direct supervisors approve their time cards.

(AICPA adapted) 8C.17 Which of the following activities performed by a department supervisor most likely would

help to prevent or detect a payroll fraud? a. Distributing paychecks directly to department employees. b. Setting the pay rate for departmental employees. c. Hiring employees and authorizing them to be added to payroll. d. Approving a summary of hours each employee worked during the pay period.

(AICPA adapted)

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8C.18 Major Risks in Payroll Cycle. Prepare a schedule of the major risks in the payroll cycle. Identify the financial statement assertions related to each. Create a two-column schedule like this:

Payroll Cycle Risk Assertion

8C.19 Payroll Authorization in a Computerized System. Two accountants were discussing control activities and tests of controls for payroll systems. The senior accountant in charge of the engagement said: “It is impossible to determine who authorizes transactions when the payroll account is computerized.”

Required: Evaluate the senior accountant’s statement about control in a computerized payroll system. List the points in the flow of payroll information where authorization takes place.

8C.20 Payroll Processed by a Service Organization. Assume that you are the audit senior conduct- ing a review of a new client’s payroll system. In the process of interviewing the payroll depart- ment manager, she makes the following statement: “We don’t need many controls because our payroll is done outside the company by Automated Information Processing, a service bureau.”

Required: Evaluate the payroll department manager’s statement and describe how a service organiza- tion affects an auditor’s review of controls.

8C.21 Payroll Audit Procedures, Computers, and Sampling. You are the senior auditor in charge of the annual audit of Onward Manufacturing Corporation for the year ending December 31. The company is of medium size with only 300 employees. All 300 employees are union members paid by the hour at rates set forth in a union contract, a copy of which is furnished to you. Job and pay rate classifications are determined by a joint union– management confer- ence, and a formal memorandum is placed in each employee’s personnel file.

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All applicable Exercises and Problems are available with Connect.

Exercises and Problems

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Diagram of Payroll Tests of Controls

Clock Cards

Bank Statements

YTD Records

Management Reports

General LedgerPayrolls

Sample

Sample

Recalculate

Reconcile

Trace Time

Vouch Time

Trace

Trace

Trace

Vouch Checks

Vouch Transfer

All

Every week, clock cards prepared and approved in the shop are collected and trans- mitted to the payroll department. The total of labor hours is summed on a calculator and entered on each clock card. Batch and hash totals are obtained for the following: (1) labor hours and (2) last four digits of Social Security numbers. These data are input into a disk file, batch balanced, and batch processed. The clock cards (with cost classification data) are sent to the cost accounting department.

The payroll system is computerized. As each person’s payroll record is processed, the Social Security number is matched to a table (in a separate master file) to obtain job clas- sification and pay rate data, then the pay rate is multiplied by the number of hours, and the check is printed. (Ignore payroll deductions for the following requirements.)

Required: What audit procedures would you recommend to obtain evidence that payroll data are accurately totaled and transformed into machine-readable records? What deviation rate might you expect? What tolerable deviation rate would you set? What “items” would you sample? What factors should you consider in setting the size of your sample?

What audit procedures would you recommend to obtain evidence that the pay rates are appropriately assigned and used in figuring gross pay? In what way, if any, would these procedures be different if the gross pay were calculated by hand instead of on a computer?

8C.22 Payroll Tests of Controls. The following diagram describes several payroll tests of controls. It shows the direction of the tests, leading from samples of clock cards, payrolls, and cumu- lative year-to-date earnings records to blank squares.

Required: For each blank square in the diagram, write a payroll test of controls procedure and describe the evidence it can produce. (Hint: Refer to Exhibit 5.15.)

LO 8-8

Apollo Shoes Payroll Audit You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Watershed and have been assigned to the engagement team of a new audit client, Apollo Shoes Inc. You have been asked to perform certain procedures for the audit of the payroll process. A detailed audit program for payroll and supporting documentation, including working papers, can be found in Connect.

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LEARNING OBJECTIVES For most nonfinancial service companies, inventory is a material and risky area of the audit. For nonmanufacturing companies, inventory is purchased in the purchasing cycle, as described in Chapter 8. However, manufacturers have an additional cycle. In the production cycle, materials, labor, and overhead are converted into finished goods (inventory) and services. This chapter introduces the production cycle but focuses on the audit of inventory in general, especially determining the existence and valuation of a client’s inventory,

as well as cost of goods sold. Observation of the client’s physical inventory count is such an important audit procedure that auditing standards require it. This chapter discusses procedures to be followed in observing the physical inventory count. It also discusses procedures for auditing the accumulation and pricing of inventory and recording it in the financial statements.

This chapter includes several short cases to illustrate the application of audit procedures in situations in which errors and frauds can be discovered.

Henry Ford

There is one rule for industrialists and that is: Make the best-quality of goods

possible at the lowest cost possible, paying the highest wages possible.

The Production Cycle and Auditing Inventory

C H A P T E R 9

Professional Standards References

Topic AU-C/ISA Section

PCAOB Reference*

Audit Documentation 230 AS 1215

Auditors’ Responses to the Risks of Material Misstatements 240 AS 2301

Audit Planning 300 AS 2101

Identifying and Assessing the Risks of Material Misstatement 315 AS 2110

Materiality 320 AS 2105

Audit Evidence 500/501 AS 1105

Substantive Analytical Procedures 520 AS 2305

Auditing Accounting Estimates 540 AU 2501

Using the Work of an Audit Specialist 620 AU 1210

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Your objectives are to be able to:

LO 9-1 Describe the production cycle, including typical source documents.

LO 9-2 Identify significant accounts and relevant assertions related to the audit of inventory.

LO 9-3 Discuss the risk of material misstatement in the audit of inventory.

LO 9-4 Identify important internal control activities present in a properly designed system to mitigate the risk of material misstatements for each relevant assertion in inventory management.

LO 9-5 Give examples of tests of controls to test the operating effectiveness of internal controls in managing inventory.

LO 9-6 Give examples of substantive procedures in audits of inventory and relate them to assertions about significant account balances at the end of the period.

LO 9-7 Apply your knowledge to perform audit procedures in the audit of inventory and evaluate the findings of your tests.

KEEPING COUNT Nearly every auditor who has audited a nonfinancial services company has participated in an inventory count and has stories to tell. From the young, professionally dressed staff auditor climbing a grain silo while every employee from the client cheers, to celebrat- ing New Year’s Eve in a warehouse, inventory observation is a procedure that provides critical and required evidence in an audit. Inventory is considered so important that the procedures for evaluating the existence and condition of material amounts of inventory are specifically outlined in the auditing standards.1

Similar to practice, auditing courses often spend considerable time discussing the dif- ficulties of specific interesting inventory count issues. For example, the issues associated with free-range livestock can be challenging. Counts often entail moving cows, sheep, or other animals through a gate, while having two people keep a count. Because the animals are uncontrollable and the farms often have issues with dust flying everywhere, obtain- ing an accurate count can be challenging, tedious, and definitely not much fun. Similarly, controlling the movement of raw materials in a production process, or goods in retail stores can involve shutting down production or sales, and the possibility for human error.

Advances in technology are beginning to change the landscape of inventory counts. Advanced, programmable drones have the capability to count an entire warehouse and even detect any movement of items during the count. Another application of drone technology is in the counting of livestock. Consider the example mentioned in the last paragraph—a farm with thousands of free-range sheep. As an alternative to the tedious, messy, and error-prone process of counting the sheep manually as they charge through a gate often 4 or 5 at a time, a professionally trained drone pilot, licensed through the Federal Aviation Administration, flies a drone over the farm. The pilot takes one or more high-resolution photograph capturing the sheep in real time. The images are then pulled into automated counting software, such as CountThings (https://www.CountThings. com), and a preliminary count is obtained. The auditor then uses a magnified digital image of the count to identify errors the software made in counting, where perhaps an oddly colored sheep is missed or two sheep close together are counted as one, or perhaps a sheep-like bush is counted. By using the drone technology, the process is far less messy and tedious. Further, the audit documentation is superior because photo records of the count exist and can be verified.

However, the advancement of technology does not take away the need for auditor skepticism and judgment. How does the auditor know the condition or health of the sheep in a drone photo? How does the auditor know that the boxes counted in a warehouse by

1AU-C 501- Audit Evidence- Specific Considerations for Selected Items

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a drone have the correct product in them? Are the 5,000,000 microchips counted in an instant salable and as described? Because of the importance of auditor judgment, no amount of technology can take away the need for professionally trained auditors, and if anything, the importance of high-quality judgment is more important now than ever. The process may just be less smelly and dusty, and fewer auditors will experience the joy of being a celebrity for a day, climbing up the side of a grain silo.

This chapter will begin with a description of a production cycle in a manufacturing environment because although nearly all auditing students have shopped at a retailer or have driven past a farm, many likely do not know the issues involved with producing goods. However, the chapter will focus on the significant accounts and relevant assertions for auditing inventory in a variety of industries.

INVENTORY MANAGEMENT: TYPICAL ACTIVITIES Many companies, including retailers such as Target, sell goods produced by other par- ties. In Chapter 8 you learned about the purchasing cycle, where companies purchase goods for both use in the business and for sale. There you learned about important con- trols surrounding the purchasing and handling of goods, as well as substantive tests that are performed in the purchasing process. Chapter 8 did not discuss how auditors obtain assurance regarding the goods held by the client at year-end, or how an auditor gains assurance related to the costing of goods produced by an entity. For any company with a material amount of inventory, auditors are concerned about the existence as well as the pricing of that inventory. For a retailer like Target, auditors focus on verifying the quantity of goods on hand, the company’s system for inventory cost flow assumptions, and whether all goods on hand are salable at an amount greater or equal to cost. However, many companies, such as Ford Motor Company, manufacture the goods that they sell. When auditing a manufacturer, whether it is a small entity producing specialty goods or one of the world’s largest automakers, it is paramount that an auditor understand all stages involved with converting raw materials into finished goods. If this process is not properly controlled, not only are financial statement misstatements likely, but also mis- management of inventory can quickly put a company out of business when companies either are not able to manufacture enough goods or are faced with large overstocks that are obsolete and overvalued.

The production cycle links the acquisition cycle, in which goods and services are pur- chased, to the revenue cycle, in which the inventory is sold (see Exhibit 9.1). These cycles, along with the payroll cycle, account for all additions and reductions of inventory items. Thus, the production cycle (Exhibit 9.2) is mostly concerned with accounting for inven- tory as it moves through the production stages from raw materials to work-in-process to finished goods and for accumulating accurate costs of the inventory items. Because the production cycle is critical for manufacturers, this chapter begins with a discussion of the typical activities for companies that produce the goods they sell.

LO 9-1 Describe the production cycle, including typical source documents.

EXHIBIT 9.1  Relationship of Business Cycles Acquisition

Cycle Revenue

Cycle Production

Cycle

Payroll, Administration, Financing, and General Accounting

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EXHIBIT 9.2  Production cycle

Bill of Materials

Production Plan

Inventory Planning

Inventory Plan

Start Here

Production Planning

Sales Forecast

Sales Forecast

Reconciliation (analysis)

Record Keeping

Custody

Authorization Determine Cost of Goods Sold

Cost of Goods Sold

Depreciation Schedule

Periodic Physical Count

Cost Accounting

Produce Goods and Services (physical quantity)

Acquisition Cycle

Purchase Labor, Materials, and Overhead

Payroll Cycle

Pay Wages

Revenue and Collection Cycle

Deliver to Customers

Orders Deliveries

Accounts/Records

Inventory Cost of Goods Sold

Inventory

(valuation)

Production Reports

Quality Control

Test Reports

Production Orders

Production Cost Analysis

3

2

1

Sales Forecasts ① Production activities start with a sales forecast, a marketing projection of product sales, based on past performance and marketing initiatives. Based on this forecast and other per- tinent factors (e.g., production setup costs, scheduled equipment maintenance, finished goods inventories, and raw material inventories), the production planner can determine both the type and the quantity of products that need to be produced to meet anticipated demand and can schedule the products in a production plan. The sales forecast is one of the most important documents in any organization. If it is incorrect and underestimates the company’s production requirements, hundreds of thousands of dollars of potential profits may be unattainable. However, if it is incorrect and overstates the product demand, millions of dollars of raw material and finished goods inventory may needlessly utilize corporate assets and warehouse space.

Production Planning ① The goal of production planning is to provide a schedule for manufacturing, called the production plan, so that quality products will be available at the appropriate time for the lowest cost. For example, production planners must balance the finished goods ware- housing costs associated with making large (high-quantity) production runs with the changeover costs of making several smaller (low-quantity) production runs. In addition, production planners must integrate corporate strategies such as long-range plans and just- in-time (JIT) inventory management. Refer to Exhibit 9.2 for the activities and account- ing involved in a production cycle. As you follow the exhibit, you can track the elements of a control system that are described in the following sections.

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The physical output of a production cycle is inventory (starting with raw materials, proceeding to work-in-process, and then moving through to finished goods). Exhibit 9.2 shows the connection of inventory to the revenue and collection cycle in terms of orders and deliveries. Most of the transactions in a production cycle are cost accounting alloca- tions, unit cost determinations, and standard cost calculations. These are internal trans- actions produced entirely within the company’s accounting system. Exhibit 9.2 also includes the elements of depreciation cost calculation, cost of goods sold determination, and production cost analysis as examples of these transactions.

The job of the production planner is one of the most critical in any manufacturing oper- ation. The production planner not only creates a production plan, but also must identify the total quantity of raw materials necessary for production based on the production plan and the bill of materials (a specification of the type and quantity of component materials required for the production). Once raw materials requirements (from the bill of materials) are known, the planner uses the raw material inventory status report to determine whether enough raw materials are in stock to complete production. If insufficient raw materials exist, additional materials must be purchased and, if required, the planner must send a purchase requisition to purchasing (which begins the expenditure cycle as discussed in Chapter 8). Purchase lead times must be factored into the production plan. The production planner must also be aware of labor requirements. If the production plan identifies a change in total production, human resources must be aware of the impact on the labor force.

Production ② Once the production plan has been finalized, it is generally shared with managers in the sales/ marketing department, production department, and possibly human resources who may be required to “sign off” as evidence of their approval of the plan. Managers may request adjust- ments to the schedule or may need to adjust personnel, maintenance schedules, even over- time, to ensure that production operates efficiently. As you can see, an error in the production plan may mean insufficient raw materials and personnel, excessive warehousing of finished goods, an oversupply of raw materials, unnecessary personnel, or insufficient finished goods to meet demand. All of these conditions represent real, substantial costs to the entity.

Inventory Control As the time for production nears, the production planner issues a production order to the appropriate production personnel including inventory control and production managers. Inventory control will receive a materials requisition, or materials transfer ticket, that autho- rizes inventory to release raw materials and supplies to production. These documents are the inventory record-keepers’ authorizations to update the raw materials inventory files by recording the reductions of the raw materials inventory.

Cost Accounting ③ When production is completed, production orders and the related records of materials and labor used are sent to the cost accounting department. Labor is reported by various means from time sheets to computerized clocks. Employees designate what job or prod- uct they worked on, or the labor is automatically assigned based on the department or machinery to which the employee is assigned. Because these accounting documents may come from the production workers, it may require an independent verification of hours worked from other sources (e.g., notifications of materials from the inventory custodian or labor costs assigned from the payroll department).

Cost accounting generally records finished goods at standard costs. Developing stan- dard costs is a difficult, time-consuming process, even for relatively simple products. All materials, supplies, labor, and overhead that go into the product must be measured based on the bill of materials and accumulated into the production cost. Differences between standard costs and actual costs are recorded in variance accounts and reviewed by super- visors. (Note: GAAP recognizes specific-item, first-in, first-out [FIFO], last-in, first- out [LIFO], and weighted-average costing but does not recognize standard costs per se.

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The auditor must ensure that standard costs are not materially different from the GAAP method that the client has adopted.)

The cost accounting department produces analyses of actual cost per unit, standard cost, and variances. Cost accounting also may determine the overhead allocation to production in general, to production orders, and to finished units. Depending on the design of the com- pany’s cost accounting system, these costs are used to value inventory and ultimately to determine the cost of goods sold. In addition, production reports are authorization for the finished goods inventory custodian to place the units in the finished goods inventory. The reports also authorize the inventory record-keepers to update the finished goods inventory.

It would be wrong to think of some elements of the production cycle as only applying to manufacturing companies. Clearly, Target has a sales forecast, and its product manag- ers (their equivalent of a production manager) need to determine what products are avail- able in stores and in the warehouses and compare that with the forecasted needs. Purchase requisitions are issued to buy additional product and have it available at the appropriate time. In a sense, production for a retailer may be viewed as the process of getting items from the warehouse to the store and into the appropriate retail space for sale.

REVIEW CHECKPOINTS 9.1 What functions are normally associated with the production cycle? 9.2 What inventory costing methods does GAAP recognize? 9.3 Describe a walkthrough of a production transaction from receiving production orders to making an

entry in the finished goods perpetual inventory records. What document copies would be collected? What controls noted? What duties separated?

9.4 How might an auditor use a client’s sales forecast for general familiarity with the production cycle or for evaluation of slow-moving inventory?

The cost accounting department at Pointed Publications Inc. routinely allocated overhead to book printing runs at the rate of 40 percent of materials and labor cost. The debit was made initially to the fin- ished goods (books) inventory, and the credit went to an “overhead allocated” account that was offset against other entries in the cost of goods sold calculation, which included all actual overhead incurred. During the year, the company produced 10 million books, to which

$40 million of overhead were allocated. The auditors noticed that actual overhead expenditures were $32 million and that 3 million books remained in the ending inventory. This finding resulted in the conclusion that inventory was overstated by $2.4 million, the cost of goods sold was understated by $2.4 million, and the income before taxes was overstated by 8.2 percent.

Overhead AllocationAUDITING INSIGHT

Overhead Allocation

  Company Accounting Proper Accounting

Books produced Books sold Labor and materials cost Overhead allocated Cost per book Cost of goods sold:  Labor and materials cost  Overhead allocated to books  Overhead incurred  Overhead credited to cost  Ending inventory Total cost of goods sold

10 million 7 million

$100 million $40 million

$14.00

$100 million 40 million 32 million

(40 million) (42 million) $ 90 million

10 million 7 million

$ 100 million $32 million (actual cost) $13.20

$ 100 million

32 million

(39.6 million) $92.4 million

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SIGNIFICANT ACCOUNTS AND RELEVANT ASSERTIONS

Obtain (or Retain)

Engagement

Engagement Planning Reporting

STAGES OF AN AUDIT

Risk Assessment

Audit Evidence

Exhibit 9.3 identifies the significant accounts and assertions in the audit of inventory. In this portion of the audit, the most significant risks usually relate to the existence and valuation of inventory. In addition, because whenever inventory is sold a cost for the inventory must be recognized, cost of goods sold also has significant risk. If management wants to inflate sales by creating fictitious sales or inflating sales amounts, there must be a corresponding debit. Expenses can be used for this purpose as explained in Chapter 8. However, inventory has also been a favorite place to hide fraud for many infamous frauds (e.g., Phar-Mor, Crazy Eddie’s).

Unethical managers might prefer to manipulate inventory instead of other expenses because of the double effect on the financial statements. When ending inventory is over- stated, assets are overstated and cost of goods sold is understated, thereby increasing both total assets and income. Analysts often look at a company’s profit margins to determine how well it is managing costs and to determine whether the company can maintain suf- ficient markup to cover other operating and nonoperating costs and be competitive.

Another reason that inventory is an inviting target for manipulation is the complexity and subjectivity involved in accounting for it. Because there are many large purchases of inventory, many fraudsters believe that fictitious or overstated transactions may be hard to catch or the audit of inventory can be controlled to the extent that such inflated inven- tory numbers can be obscured from the auditors. Further, even if the inventory account is correct, the manipulation of the cost by only a few cents on many items can result in a multimillion dollar misstatement. Therefore, the audit of inventory is especially impor- tant to ensure that the financial statements are not materially misstated.

Even a relatively simple inventory process can be manipulated and misstated. Many corporate frauds such as those at Crazy Eddie’s, Leslie Fay, and Health Management were concealed by creating nonexistent or overvalued inventory. Inventory is often the largest current asset on a company’s balance sheet, and it is likely to be a complex account. Imagine trying to value the cars at General Motors, the $17 billion of product held by Amazon.com, Inc., or the oil reserves at ExxonMobil. How about the $1 billion in live- stock listed as inventory by Tyson Foods? That’s a lot of animals to count and value! Even inventories of simple commodities present issues of measurement and valuation.

LO 9-2 Identify significant accounts and relevant assertions related to the audit of inventory.

EXHIBIT 9.3 Significant Accounts and Assertions in the Production Cycle

Significant Account Relevant Assertions

Inventory Existence Completeness Cutoff Valuation & allocation Rights Presentation & Disclosure

Cost of goods sold Completeness Accuracy

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Inventories of more complex items such as biochemicals or genetically modified crops can require the use of specialists by the auditors.

A number of problems can arise in accounting for inventory. Some inventories are very susceptible to theft. Others require complex cost build-ups (especially if they are valued at LIFO). GAAP require inventory to be stated at the lower of cost or net realizable value (NRV). Cost is the total price paid, including freight-in, or estimates of actual costs using LIFO, FIFO, or an average. Net realizable value is the selling price of the goods less all costs to complete and to sell the goods (e.g., sales commissions). Items should be added to inventory when the company has title to them and included in cost of goods sold when the related revenue is recognized.2 In addition, when a manufacturer has work- in-process inventory, this may be especially difficult because each item has different amounts of materials and labor incorporated into the product at the inventory date. These multiple and often subjective evaluations make inventory a high-risk area that is sus- ceptible to errors. Also, management can use inventory manipulation to overstate assets and income. Because of the multiple and complex risks for inventory, there are several relevant risks of material misstatement, as discussed in the next section.

2FASB, “Revenue Recognition,” ASC 606, May 2014.

REVIEW CHECKPOINTS 9.5 If the actual sales for the year are substantially lower than the sales forecasted at the beginning of

the year, what potential valuation problems could arise in the production cycle accounts? 9.6 The balance sheet of a company lists $25 million of inventory. What assertions is management

making regarding inventory?

RISK OF MATERIAL MISSTATEMENT When considering what could go wrong (WCGW) related to a client’s inventory, auditors consider seven primary concerns:

1. Items included in inventory were in inventory on the balance sheet date (existence and cutoff).

2. All inventory items have been included (completeness). 3. Inventory has been properly accounted for and properly valued using an acceptable

GAAP accounting method (valuation). 4. Items included in inventory were the property of the client (rights). 5. Proper presentation and disclosures have been provided for inventory (presentation

and disclosure). 6. Cost of goods sold includes all costs of the inventory items sold during the year

(completeness) 7. The amount of cost of goods sold has been properly accounted for using an acceptable

GAAP accounting method (accuracy).

Exhibit 9.4 summarizes the WCGW analysis for inventory. As previously discussed in this chapter, inventory is a significant account, with a

pervasive effect on the financial statements, and combined with its volume and its com- plexity, a misstatement may be probable if sufficient internal controls are not in place. In order for inventory to be properly disclosed, all items comprising inventory must be included and correctly valued. Consider the balance sheet and inventory footnote for Target Corporation’s 2018 fiscal year (February 2, 2019) shown in Exhibit 9.5.

LO 9-3 Discuss the risk of material misstatement in the audit of inventory.

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EXHIBIT 9.4 Assertions and What Could Go Wrong in the Audit of Inventory

Significant Account Relevant Assertions What Could Go Wrong?

Inventory Existence Items included in inventory records are not actual items in inventory.

Completeness Some items are not included in inventory.

Cutoff Items are included in inventory even when received in the subsequent period.

Valuation Inventory cost flow assumptions (e.g. FIFO) have been applied incorrectly Proper amounts direct materials, direct labor, and overhead are not allocated to produced inventory. Inventory is damaged or obsolete and has declined in value.

Rights Items held on consignment are included in inventory.

Presentation & Disclosure Inventory pledged as collateral is not disclosed. Footnote disclosures omit cost flow assumptions.

Cost of goods sold Completeness Labor or material may be omitted from production costs.

Accuracy Costs of direct material, labor, and overhead have not been properly calculated.

EXHIBIT 9.5 Excerpts from Target Corporation’s 10-K Panel A Consolidated Statements of Financial Position (millions, except footnotes)

  February 2, 2019 February 3, 2018

Assets   

Cash and cash equivalents $1,556 $2,643

Inventory 9,497 8,597

Other current assets 1,466 1,300

Total current assets 12,519 12,540

Property and equipment

Land 6,064 6,096

Buildings and improvements 29,240 28,131

Fixtures and equipment 5,912 5,623

Computer hardware and software 2,544 2,645

Construction-in-progress 460 440

Accumulated depreciation (18,687) (18,398)

Property and equipment, net 25,533 24,536

Operating lease assets 1,965 1,884

Other noncurrent assets 1,273 1,343

Total assets $41,290 $40,303

Continued

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Note that Target asserts that it has $9.5 billion in inventory, which represents 75 percent of its current assets and 23 percent of its total assets. Other than buildings and improve- ments, it is the largest single asset that Target owns. Further, consider the difficulties in establishing this number in its 1,844 stores and 40 distribution centers in the United States. Consider that if Target has 1,000 pairs of socks in each store and 10,000 in each warehouse and the cost was misstated by 10 cents, the balance sheet error would be more than $116,000. While this is not a material amount to an inventory of $9.5 billion, it illus- trates how a small error or misstatement can result in a large inventory valuation error.

An additional review of Target’s inventory footnote reveals several other issues. Note the second paragraph speaks of using a cost-to-retail method to value inventory and dis- cusses that some items have been marked down in value. Further, the third paragraph indicates that there are items that Target does not own and are paid for only after the mer- chandise is sold (items on consignment). Without good internal controls, a small error in the application of the cost estimation could produce a substantial inventory misstatement. Also, inventory on consignment might inappropriately end up as part of the inventory Tar- get asserts that it owns. Clearly, Target must take great care in establishing the value of its inventory in its entire system, and auditors must take care that the accumulation of inven- tory misstatements does not lead to a material misstatement in its financial statements.

Now let’s look at how an inventory misstatement might affect the overall financial statements. The following table provides numbers for 2018 for inventory, sales, cost of sales, earnings from continuing operations, and net income reported by Target in its February 2, 2019, 10-K report (all amounts in millions of dollars). While Target does an excellent job of preparing financial statements and we have no reason to suspect that the numbers presented are inaccurate in any way, for our purposes, let’s suppose that 5 percent of Target’s reported inventory is overstated, or $475 million. The third column shows how this hypothetical misstatement affects each of the accounts presented. Ignoring tax effects,

12. Inventory

The majority of our inventory is accounted for under the retail inventory accounting method (RIM) using the last-in, first-out (LIFO) method. Inventory is stated at the lower of LIFO cost or market. The cost of our inventory includes the amount we pay to our suppliers to acquire inventory, freight costs incurred in connection with the delivery of product to our distribution centers and stores, and import costs, reduced by vendor income and cash discounts. The majority of our distribution center operating costs, including compensation and benefits, are expensed in the period incurred. Inventory is also reduced for estimated losses related to shrink and markdowns. The LIFO provision is calculated based on inventory levels, markup rates, and internally measured retail price indices.

Under RIM, inventory cost and the resulting gross margins are calculated by applying a cost-to-retail ratio to the inventory retail value. RIM is an averaging method that has been widely used in the retail industry due to its practicality. The use of RIM will result in inventory being valued at the lower of cost or market because permanent markdowns are taken as a reduction of the retail value of inventory.

We routinely enter into arrangements with vendors whereby we do not purchase or pay for merchandise until the merchandise is ultimately sold to a guest. Under the vast majority of these arrangements, which represent less than 5 percent of consolidated sales, we record revenue and related costs gross. We concluded that we are the principal in these transactions for a number of reasons, most notably because we (1) control the overall economics of the transactions, including setting the sales price and realizing the majority of cash flows from the sale, (2) control the relationship with the customer, and (3) are responsible for fulfilling the promise to provide goods to the customer. Merchandise received under these arrangements is not included in Inventory in our Consolidated Statements of Financial Position because the purchase and sale of this inventory are virtually simultaneous.

Panel B Inventory Footnote

Source: Target 10-K, February 2, 2019.

EXHIBIT 9.5 Excerpts from Target Corporation’s 10-K (Concluded)

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this 5 percent inventory misstatement would result in a 19 percent overstatement of true net income. When auditors identify inventory as a pervasive error, they are referring to this cascading effect of the error—it affects many areas of the financial statements.

REVIEW CHECKPOINTS 9.7 What are the different types of cost included in cost of goods sold for a production operation? What

are the significant risks that would make this calculation inaccurate? 9.8 What makes the recording of inventory at its proper amount difficult on the financial statements? 9.9 Why do auditors consider inventory errors pervasive?

Account Actual Amount as

Reported for Target 2018 Actual if a 5% Inventory

Overstatement Error Exists

Inventory $  9,497     $   9,022  

Sales   74,433        74,433

Cost of sales   53,299       53,774

Earnings from continuing operations     2,930        2,455

Net income     2,937        2,462

INTERNAL CONTROL ACTIVITIES AND DESIGN EVALUATION In order to properly assess control risk, the auditor must understand the internal control system, assess the design of the controls, and assess whether the controls are in operation. Control risk assessment is important because it governs the nature, timing, and extent of substantive procedures that will be performed in the audit of inventory. For many retailers and wholesalers, the inventory balance consists of the costs of acquiring the inventory from third parties. However, for a manufacturer, the inventory account balances take into account that goods may be at multiple stages of the production cycle. Thus, multiple inventory account balances include

∙ Raw materials inventory. ∙ Work-in-process inventory. ∙ Finished goods inventory.

With respect to inventory valuation, this leads to significantly more risk in determining the cost basis of inventory. Controls surrounding the purchase of inventory by a retailer are similar to the controls for the purchase of any item, and were discussed in Chapter 8. Thus, this chapter focuses on the cost accounting function and its role in determining the cost valuation of manufactured finished goods, as well as controls surrounding inventory held in stock.

Entity-Level Controls It is important that auditors consider entity-level controls in all processes and proce- dures. In the production cycle, controls over access to the production facility, including inventory, are essential. The prevention of theft of inventory and equipment begins with a facility that requires escorts for visitors and ensures that only authorized personnel

LO 9-4 Identify important internal control activities present in a properly designed system to mitigate the risk of material misstatements for each relevant assertion in inventory management.

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have access to inventory and production areas. Furthermore, adequate security must be enforced when the facility is not in operation. Finally, production reports should be ade- quate to ensure that only authorized operations are performed and that performance sta- tistics are reviewed on a timely basis and anomalies are investigated promptly.

Control Considerations Control activities for proper separation of duties should be in place and operating. By referring to Exhibit 9.2, you can see that proper separation involves authorization (pro- duction planning, inventory planning, and purchase requisitions) by persons who do not have custody, record-keeping, cost accounting, or reconciliation duties. Custody of inven- tories (raw materials, work-in-process, and finished goods) is in the hands of persons who do not authorize the amount or timing of production or the purchase of materials and labor, perform the cost accounting record keeping, or prepare cost analyses (rec- onciliations). Persons who do not authorize production or have custody of assets in the production process perform cost accounting (a recording function). Combinations of two or more of the duties of authorization, custody, and accounting in one person, one office, or one computerized system could open the door for errors and frauds.

In addition, the internal control system should provide for detailed authorization, information processing, and management review control activities, for example

∙ Production orders should contain a list of materials and their quantities, and they should be approved by a production planner/scheduler.

∙ Material should not be issued to the production floor without an authorized material requisition.

∙ Material requisitions should be compared in the cost accounting department with the list of materials on the production orders, and the production operator and the materi- als inventory storekeeper should sign the materials requisitions.

∙ All material requisitions should be accounted for. Material requisitioned is used in production, is unusable (scrap), or excess material returned to raw material inventory.

∙ Documentation for material returned to raw material inventory should accompany the returned items with a copy going to inventory control for use in adjusting the perpetual raw material inventory.

∙ Production supervisors should sign (or review if the time is kept electronically) labor time records on jobs, and the cost accounting department should reconcile these cost amounts with the labor report from the payroll department.

∙ The production supervisor and finished goods inventory custodian should review pro- duction reports of finished units and then forward them to cost accounting.

∙ Inventory should be periodically counted with the counts agreed to perpetual inven- tory records.

These control activities track the raw materials and labor from the beginning of pro- duction to completion of the production process. With each internal transaction, the responsibility and accountability for assets are passed from one person or location to another.

Many entities have complex computer systems to manage production and materials flow. Even though the technology is complex, the basic management and control func- tions of ensuring the flow of labor and materials to production and the control of waste should be in place. Manual signatures, paper production orders, and paper requisitions often do not exist, but electronic equivalents should be in place.

Custody Supervisors and production workers have physical custody of materials and labor doc- uments (time cards, job tickets, etc.) while the production work is being performed. Authorized employees can requisition materials from the raw materials inventory, assign people to jobs, and control the pace of work. In a sense, they have custody of a “moving

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inventory.” The work-in-process (WIP) is literally “moving” and changing form in the process of being transformed from raw materials into finished goods.

Inventory warehouses and fixed asset locations should be under adequate physical security (storerooms, fences, locks, and the like). However, control over goods in process is more difficult than control over a warehouse of raw materials or finished goods where unauthorized individuals cannot gain access. Control over WIP can be exercised by hold- ing supervisors and workers accountable for the use of materials specified in the produc- tion orders, for the timely completion of production, and for the quality of the finished goods. This accountability can be achieved with effective cost accounting, cost analy- sis, performance reviews, and quality control testing. Accountability may be evident by ensuring that supervisors and management are analyzing the costs of production orders, comparing the costs to prior experience or to standard costs, and determining lower-of- cost-or-NRV valuations. When costs of material or labor, scrap rates for materials, or production numbers do not meet expectations, management should require a documented assessment by cost accounting or internal audit to determine the cause and corrective action required.

The Securities and Exchange Commission charged the Jacksonville, Florida-based retail chain Stein Mart Inc. with materially misstating its pre-tax income due to improper valuation of inventory subject to price discounts and for having inadequate internal accounting controls.

An SEC investigation found the retailer often offered its merchan- dise to customers at retail price reductions referred to as Perm POS markdowns and that merchandise subject to such a markdown never reverted back to its original retail price. Stein Mart reduced the value of inventory subject to these markdowns at the time the item was sold rather than immediately at the time the markdown was applied.

As a result, according to the SEC, Stein Mart materially misstated its pre-tax income in certain quarterly public filings with the SEC, includ- ing an overstatement of almost 30 percent in the first quarter of 2012.

“Inventory is one of the most significant assets for retail compa- nies, and as a result, it is critical that companies have effective internal accounting controls to ensure that inventory is valued properly,” said Michael Maloney, chief accountant of the SEC’s Enforcement Division, in a statement. “Stein Mart failed in this regard as its internal account- ing controls to ensure proper inventory valuations were inadequate in various ways.”

According to the SEC’s order instituting a settled administrative proceeding, Stein Mart’s internal accounting controls over Perm POS

markdowns were inadequate. For example, until at least the middle of 2011, the retailer’s decision to characterize a markdown as Perm POS resided solely with Stein Mart’s merchandising department, which did not understand the impact that Stein Mart’s markdowns could have on inventory valuation accounting, according to the SEC.

In the fall of 2012, Stein Mart raised its accounting treatment of Perm POS markdowns with its external auditor, and the external audi- tor informed Stein Mart that its accounting for Perm POS markdowns was not acceptable under GAAP. In May 2013, Stein Mart restated its financial results for the first quarter of 2012, all reporting periods in fiscal year 2011, and its annual reporting period in fiscal year 2010. According to the SEC’s order, Stein Mart also had inadequate internal accounting controls in the areas of software assets, credit card liabili- ties, and other inventory-related issues.

In agreeing to settle the charges without admitting or denying the SEC’s findings, Stein Mart consented to the SEC’s order imposing an $800,000 penalty and requiring the company to cease and desist from committing or causing any violations or any future violations of the reporting, books and records, and internal controls provisions of the federal securities laws. Source: Michael Cohn, “Stein Mart Settles with SEC for $800,000 on Inventory Valuation and Accounting Controls,” Accounting Today, September 22, 2015.

AUDITING INSIGHT

Internal Control Questionnaire Information about production cycle controls often is gathered initially by completing an internal control questionnaire (ICQ). A paper ICQ would rarely be completed, however a series of questions would typically be asked of management to enable the auditor to obtain an adequate understanding of the internal controls. An example of the types of questions that would be asked for control activities commonly found in the production cycle is included in Appendix Exhibit 9A.1. You can study this questionnaire for details of desir- able control activities. The ICQ is organized with headings that identify the important transaction assertions: occurrence, completeness, accuracy, cutoff, and classification.

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Exhibit 9.6 shows the significant accounts in the production cycle and the related important assertions, what could go wrong in the related assertions, and the control activ- ity that should be in place to mitigate the risk.

EXHIBIT 9.6 Internal Control Activities Relevant to the Audit of Inventory

Significant Account Relevant Assertions What Could Go Wrong? Internal Control Activity

Inventory Existence Items included in inventory records are not actual items in inventory.

Inventory areas should be secure.

Any transfer of inventory must be authorized.

Periodic physical inventory counts with reconciliation to records are performed.

Completeness Some items are not included in inventory.

Material requisitions are numbered sequentially.

Cutoff Items are included in inventory even when received in the subsequent period.

Receiving reports are prenumbered, used in sequence, and reconciled daily.

Valuation Inventory cost flow assumptions (e.g. FIFO) have been applied incorrectly

Inventory costing records are reviewed by management.

Proper amounts direct materials, direct labor, and overhead are not allocated to produced inventory.

Cost sheets are reviewed for all projects and production runs.

Inventory is damaged or obsolete and has declined in value.

Inventory items are reviewed periodically for usability.

Rights Items held on consignment are included in inventory.

A separate account number is used to track inventory on consignment.

Presentation & Disclosure Inventory pledged as collateral is not disclosed.

Disclosure checklist is completed prior to issuance of financial statements.

Footnote disclosures omit cost flow assumptions.

Management reviews all financial statement disclosures.

Cost of goods sold Completeness Labor or material may be omitted from production costs.

Cost sheets are reviewed for all projects and production runs for inclusion of relevant costs.

Bill of materials and direct labor requirements are approved  and used for cost calculations.

Accuracy Costs of direct material, labor, and overhead have not been properly calculated.

Job cost sheets are reviewed by management for accuracy.

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TESTING OF OPERATING EFFECTIVENESS OF INTERNAL CONTROL

Tests of Controls over Inventory Because inventory is a material and risky area for most entities that hold inventory for sale, auditors pay special attention to internal controls surrounding inventory. Exhibit 9.8 carries forward our example of relevant audit concerns and the control activities we would expect our clients to have in place and functioning appropriately with examples of tests of controls auditors may perform to gain assurance.

The tests of controls an auditor would perform are highly dependent on the type of company, as well as the type of inventory. Consider the risk that items included in the inventory records are not actually in inventory. For a manufacturing company, this risk may involve many potential hazards: loss during transfer from direct materials, scrap, theft, failure to record transfer, among other concerns. For this reason, authorization of materials transfers, use of transfer tickets or scanners for movement of materials, use of pre-numbered requisition forms, and appropriate documentation of scrap and waste are all important controls.

It should be clear that these control activities to prevent improper inclusion of inven- tory in the financial records are very different from the ones that are most relevant for a retail store such as Target or an automobile dealership. Retail stores focus on timely recording of transactions and reducing loss and theft. An auto dealer is far less concerned about a customer picking up an item and leaving the store, and a jeweler often protects its inventory in protective locked cases and may even limit access to their store.

The auditor is required to obtain an understanding of the controls for purpose of assessing control risk. For this reason, prior to performing tests of controls, an auditor has typically reviewed client control procedures and has an understanding of the process. If the auditor decides to perform tests of controls, this will often involve observing the cli- ent performing the procedures or inspecting documentation of the client performing the procedures, as shown in Exhibit 9.7. Reperformance of client control activities are rare in the audit of inventory, with the potential exception of performing tests of system controls within the inventory process. The listing of tests of controls provided in Exhibit 9.7 is clearly not even close to a comprehensive listing. An auditor needs to understand the cli- ent’s procedures and the general principles of internal control in order to gain appropriate assurance to support a reduction in control risk.

Tests of Controls in a Production Process The previous segment of this chapter focused on tests of controls that apply to a variety of entities with inventory, whether they purchase their inventory or produce it themselves. Some of the examples, such as costing of materials and labor, were specific to manufac- turers, whereas other controls, such as restricted access, were more general. Manufactur- ing entities require additional detailed control activities in place and operating to prevent, detect, and correct accounting errors during the production process. While production

LO 9-5 Give examples of tests of controls to test the operating effectiveness of internal controls in managing inventory.

REVIEW CHECKPOINTS 9.10 What features of the cost accounting system would be expected to prevent the omission of

recording materials used in production? 9.11 Describe how the functions of (a) authorization of production transactions, (b) recording of these

transactions, and (c) physical custody of inventories can be separated among the production, inventory, and cost accounting departments.

9.12 How does the production order record provide a control over the quantity of materials used in production?

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EXHIBIT 9.7 Tests of Controls Relevant to the Audit of Inventory

Significant Account Relevant Assertions What Could Go Wrong? Internal Control Activity Test of Control

Inventory Existence Items included in inventory records are not actual items in inventory.

Inventory areas should be secure.

Observe locked inventory areas and functioning cameras.

Any transfer of inventory must be authorized.

Inspect documentation of appropriate authorization of inventory transfers

Periodic physical inventory counts with reconciliation to records are performed.

Inspect documentation of periodic inventory accounts and reconciliation.

Completeness Some items are not included in inventory.

Material requisitions are numbered sequentially and reconciled.

Inspect requisition forms for numerical sequence and evidence of reconciliation.

Cutoff Items are included in inventory even when received in the subsequent period.

Receiving reports are prenumbered, used in sequence, and reconciled daily.

Inspect receiving reports for sequential numbering and reconciliation.

Valuation Inventory cost flow assumptions (e.g. FIFO) have been applied incorrectly

Inventory costing records are reviewed by management.

Inspect documentation of management review.

Proper amounts direct materials, direct labor, and overhead are not allocated to produced inventory.

Cost sheets are reviewed for all projects and production runs.

Inspect job cost sheets for evidence of managerial review.

Trace costs from cost sheets to supporting documentation.

Inventory is damaged or obsolete and has declined in value.

Inventory items are reviewed periodically for usability.

Inspect documentation of review procedures and observe evaluation.

Rights Items held on consignment are included in inventory.

A separate account number is used to track inventory on consignment.

Inspect documentation of procedures for consigned inventory and observe use of separate account numbers.

Presentation & Disclosure

Inventory pledged as collateral is not disclosed.

Disclosure checklist is completed prior to issuance of financial statements.

Inspect disclosure checklist for reasonableness.

Footnote disclosures omit cost flow assumptions.

Management reviews all financial statement disclosures.

Inspect documentation of management review of disclosure checklist.

Continued

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activities vary widely from one company to another, there are some specific controls that an auditor may evaluate. Observation of the physical controls over inventory may be of particular interest, especially if either raw materials or finished goods have significant value. Further, the auditor can observe the movement of inventory from raw materials to finished goods, specifically noting that proper authorization and documentation have been provided to the inventory custodian. The auditor should obtain evidence of proper separation of duties (custody of the inventory, inventory record-keeping, authorization for inventory movement) in the inventory area through observation. Documentation in the production and cost accounting areas should be inspected to determine that labor and material costs are properly recorded and allocated to the correct production run. Exhibit 9.8 puts controls in the perspective of production activity with examples of spe- cific WCGW concerns directly related to the production cycle and transaction assertions.

Auditors can perform tests of controls to determine whether company personnel are effectively performing control activities that are said to be in place and operating prop- erly. Exhibit 9.8 includes a selection of tests of controls for the accumulation of costs for WIP inventory. This is the stage of inventory that is in the production process. Upon completion, the accumulated costs become the value of the finished goods inventory. The illustrative procedures presume the existence of production cost reports that are updated as production takes place. Reports such as labor reports that assign labor cost to the job, material reports that charge raw materials to the production orders, and reports that pro- vide overhead allocation calculations. Some or all of these documents may be in the form of computerized records.

It is important for the auditor performing tests of controls in the production cycle to recognize that most of the company’s documentation is internal. The entity’s reporting system generates production reports, inventory reports, material and labor distribution reports, and other documents auditors rely on. The auditor must pay close attention to general and application controls over the production reporting system in order to have some assurance that reports can be relied on for testing.

EXHIBIT 9.7 Tests of Controls Relevant to the Audit of Inventory (Concluded)

Significant Account Relevant Assertions What Could Go Wrong? Internal Control Activity Test of Control

Cost of goods sold Completeness Labor or material may be omitted from production costs.

Cost sheets are reviewed for all projects and production runs for inclusion of relevant costs.

Inspect documentation of management review of cost sheets.

Bill of materials and direct labor requirements are approved  and used for cost calculations.

Inspect documentation of authorization of bill of materials and direct labor requirements.

Vouch from bill of materials and labor to job cost sheet for appropriate inclusion of relevant costs.

Accuracy Costs of direct material, labor, and overhead have not been properly calculated.

Job cost sheets are reviewed by management for accuracy.

Inspect documentation of management recalculation of job cost sheets.

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EXHIBIT 9.8 Additional Risks and Controls Specific to the Production Cycle

What Could Go Wrong? Controls Tests of Controls

Occurrence—Production and related events that have been recorded have not actually occurred.

• Cost accounting is separated from production, payroll, and inventory control.

• Material usage reports are reconciled with raw material stores’ issue slips, scrap reports, and documentation of unused material returned to inventory.

• Observe separation of cost accounting function from production, payroll, and inventory control.

• Inspect evidence of reconciliations.

Completeness—Some production documents have not been recorded.

• All documents are prenumbered and numerical sequence reviewed.

• Periodic count of raw materials and WIP inventory is compared to perpetual records.

• Open production cost reports are reconciled to the WIP inventory cost report.

• Receiving reports and material usage are posted to perpetual inventory records.

• Job cost sheets are posted weekly, and summary journal entries of work-in-process and work completed are prepared monthly.

• Inspect evidence of review of numerical sequence. Select a sample of documents and examine numerical sequence.

• Inspect evidence that inventory counts are compared to perpetual records.

• Inspect reconciliation of production cost reports to WIP inventory control report.

• Trace receiving reports to perpetual inventory. Trace materials used reports to production cost reports.

• Inspect journal entries and agree with approved cost sheets. Compare costs to standard cost listing.

Accuracy—Production information, including costs, has been improperly calculated and recorded.

• Labor usage reports are compared to job time tickets.

• Material usage and labor usage reports are prepared by floor supervisor and approved by production supervisor.

• Periodic count of inventory is compared to perpetual records.

• Receiving reports are posted to perpetual inventory on a timely basis.

• Inspect evidence of comparison by client. • Inspect evidence of approval of material and

labor usage reports. • Reconcile inventory counts with perpetual

records. • Trace dates on receiving reports to posting in

perpetual inventory records.

Cutoff—Production events have not been recorded in the correct accounting period.

• Receiving reports are posted to perpetual inventory in the proper period.

• Finished goods are recorded in the proper period.

• Production reports of material and labor are prepared weekly and transmitted to cost accounting.

• Vouch the dates of inventory records to receiving reports.

• Inspect production data and agree with finished goods inventory status reports.

• Inspect production reports and agree dates with dates in weekly journal entries.

Classification—Production material has been not been recorded in the proper accounts.

• Production supervisor is required to account for all material and labor as direct or indirect and to identify appropriate job classifications.

• Observe supervisor allocation. Test allocation. Examine supervisor signature.

Direction of Tests of Controls The tests of controls in Exhibit 9.8 are designed to test production accounting in two directions. One is the completeness direction, in which the auditors are interested in determining that all production that was started was recorded. Exhibit 9.9 shows that the sample for this direction is taken from the population of production orders found in the production-planning department. The procedures trace the cost accumulation forward to the production cost reports in the cost accounting department.

Testing the other direction relates to the occurrence of production. The auditors are interested in determining that items composing WIP and finished goods inventories recorded in the inventory accounts were produced. Exhibit 9.10 shows that the sample for this test is from the inventory accounts. This sample is vouched to the production

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reports (quantity and cost) recorded in the inventory accounts. Additional testing may include vouching from the production reports to the recorded material, labor, and payroll reports. Potential findings include errors in the accuracy of the recorded inventory cost. Of course, CAATs could be used to perform a 100 percent match that would accomplish both goals.

Summary: Control Risk Assessment The audit team should evaluate the evidence obtained from an understanding of the internal controls and from the tests of controls. The evaluation of control risk with the assessment of inherent risk provides the auditors an assessment of the risk of material misstatement. If the risk of material misstatement is relatively low, the substantive proce- dures on the account balances can be reduced. For example, if inventory observation test counts are performed on a date prior to the year-end, fewer counts would be made, and the inventory valuation procedures could be reduced in scope (i.e., smaller sample size). Furthermore, substantive analytical procedures could be used with more confidence in detecting material misstatements not otherwise evident in the accounting details.

On the other hand, if tests of controls reveal weaknesses and the risk of material mis- statement is higher, the substantive procedures need to be designed to lower detection risk in the inventory and cost of goods sold account balances. For example, a large num- ber of inventory production reports may be selected for valuation calculations, and the

EXHIBIT 9.9 Test of Production Cost Controls: Completeness Direction

Production Planning Department Cost Accounting

Production Orders

Bill of Materials Personnel Needs

Labor Reports Production Cost Reports

Issue Slips Materials Used Reports Production Cost Reports

Authorized

Sample Trace Trace

Ma tch

EXHIBIT 9.10 Test of Production Cost Controls: Occurrence Direction

Production Cost Accounting

Issue Slips Materials Used Reports

Materials Requisitions Bill of Materials

Ledger Inventory Accounts

Labor Reports

Overhead Analysis

Production Cost Reports

Recalculate

Vouch Materials Vouch

Labor

Vouch Overhead

Sample

Compare Materials

Compare Labor

Same Sample

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inventory observation may be scheduled nearer the year-end date with the audit team making a large number of test counts. Descriptions of significant deficiencies, control weaknesses, and inefficiencies may be incorporated in a letter to the client and must be communicated to the audit committee.

REVIEW CHECKPOINTS 9.13 What population of documents would an auditor examine to determine whether (a) all authorized

production was completed and placed in inventory or recorded as scrap and (b) finished goods inventory was actually produced and the costs were accounted for properly?

9.14 Why should receiving reports be prenumbered? What assertion would an auditor test using the receiving reports, and how would the auditor do this?

SUBSTANTIVE ANALYTICAL PROCEDURES AND TESTS OF DETAILS See Exhibit 9.11 for a continuation of the linking of assertions to sample risks and tests of controls, including a listing of primary substantive procedures used in an audit of inven- tory. When inventory is significant, GAAS requires auditors to be present to observe the client’s physical inventory count. After the inventory has been counted, the client summarizes the count by item number and then applies a chosen costing method to determine the total amount of inventory owned on that date, which is compared with the amount in the general ledger. For example, recall from earlier in the chapter that Target Corporation uses a retail inventory accounting method. This step is normally referred to as the compilation and pricing procedure, which the auditors also test. Differences between the inventory count and the per- petual records are adjusted through cost of goods sold. Cost of goods sold is primarily audited through the substantive tests of inventory, and errors in inventory generally result in errors in cost of goods sold, gross profit, and income. Thus, you should recognize that the substantive procedures listed in Exhibit 9.11 are testing both inventory and cost of goods sold.

LO 9-6 Give examples of substantive procedures in audits of inventory and relate them to assertions about significant account balances at the end of the period.

Significant Account

Relevant Assertions

What Could Go Wrong?

Internal Control Activity 

Test of Internal Control

Possible Substantive Analytical Procedures

Possible Substantive Tests of Detail

Inventory Existence Items included in inventory records are not actual items in inventory.

Inventory areas should be secure.

Observe locked inventory areas and functioning cameras.

Compare inventory turnover ratio to budget and previous periods.

Observe client’s physical inventory count.

Any transfer of inventory must be authorized.

Inspect documentation of appropriate authorization of inventory transfers

Compare gross profit percentage to budget and previous periods.

Confirm inventory held by others on consignment.

Periodic physical inventory counts with reconciliation to records are performed.

Inspect documentation of periodic inventory accounts and reconciliation.

Vouch items on inventory listing to inventory count tags.

EXHIBIT 9.11 Substantive Procedures in the Audit of Inventory

Continued

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Significant Account

Relevant Assertions

What Could Go Wrong?

Internal Control Activity 

Test of Internal Control

Possible Substantive Analytical Procedures

Possible Substantive Tests of Detail

Completeness Some items are not included in inventory.

Material requisitions are numbered sequentially and reconciled.

Inspect requisition forms for numerical sequence and evidence of reconciliation.

Observe client’s physical inventory count and ensure all items were counted.

Trace inventory test counts to inventory subsidiary accounts and control account.

Cutoff Items are included in inventory even when received in the subsequent period.

Receiving reports are prenumbered, used in sequence, and reconciled daily.

Inspect receiving reports for sequential numbering and reconciliation.

Perform purchase cutoff tests.

Valuation Inventory cost flow assumptions (e.g. FIFO) have been applied incorrectly

Inventory costing records are reviewed by management.

Inspect documentation of management review.

Compare average unit costs of inventory with prior periods and purchase records.

Test mathematical accuracy of management’s application of cost flow assumptions

Proper amounts direct materials, direct labor, and overhead are not allocated to produced inventory.

Cost sheets are reviewed for all projects and production runs.

Inspect job cost sheets for evidence of managerial review.

Trace inventory costs to standard costs and recalculate standard costs.

Trace costs from cost sheets to supporting documentation.

Inventory is damaged or obsolete and has declined in value.

Inventory items are reviewed periodically for usability.

Inspect documentation of review procedures and observe evaluation.

Compare inventory turnover ratio at the product level to previous periods or budget.

Inquire whether any inventory is obsolete or unsalable.

Perform lower-of- cost-or-NRV tests.

Rights Items held on consignment are included in inventory.

A separate account number is used to track inventory on consignment.

Inspect documentation of procedures for consigned inventory and observe use of separate account numbers.

Inquire of management whether any inventory is on consignment

EXHIBIT 9.11 Substantive Procedures in the Audit of Inventory (Concluded)

Continued

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Significant Account

Relevant Assertions

What Could Go Wrong?

Internal Control Activity 

Test of Internal Control

Possible Substantive Analytical Procedures

Possible Substantive Tests of Detail

Presentation & Disclosure

Inventory pledged as collateral is not disclosed.

Disclosure checklist is completed prior to issuance of financial statements.

Inspect disclosure checklist for reasonableness.

Inquire whether inventory has been pledged as collateral or security.

Perform bank and loan confirmations.

Inspect lending agreements and other contracts for the use of inventory as collateral.

Footnote disclosures omit cost flow assumptions.

Management reviews all financial statement disclosures.

Inspect documentation of management review of disclosure checklist.

Review inventory calculation for proper classification among raw materials, work-in- process and finished goods.

Complete disclosure checklist and evaluate disclosures for completeness and understandability.

Cost of goods sold

Completeness Labor or material may be omitted from production costs.

Cost sheets are reviewed for all projects and production runs for inclusion of relevant costs.

Inspect documentation of management review of cost sheets.

Compare unit costs of production with budgets or prior periods.

Trace labor costs from payroll records to production cost sheets.

Bill of materials and direct labor requirements are approved  and used for cost calculations.

Inspect documentation of authorization of bill of materials and direct labor requirements.

Compare actual production units to budgeted production units.

Vouch from bill of materials and labor to job cost sheet for appropriate inclusion of relevant costs.

Accuracy Costs of direct material, labor, and overhead have not been properly calculated.

Job cost sheets are reviewed by management for accuracy.

Inspect documentation of management recalculation of job cost sheets.

Recalculate standard costs.

EXHIBIT 9.11 Substantive Procedures in the Audit of Inventory (Concluded)

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Analytical Procedures Inventory is an excellent area for auditors to employ analytical procedures. The relation between trends in inventory prices and quantities and financial statement numbers is reason- ably predictable in the area of inventory, and therefore reasonably accurate expectations can be calculated. Inventory turnover, days’ sales in inventory, and simple trend analysis can indicate whether the client is able to sell the inventory or whether inventory is slow moving and in danger of becoming obsolete. In addition, an unexpected increase in raw material inventory may be a red flag indicating slowing sales and valuation issues, or perhaps it may be an indicator of expectations for increases in sales. Analytical procedures by themselves rarely diagnose a cause—but they can be valuable indicators of trends and potential misstate- ments. Increased scrap rates may be used to conceal theft of finished product at the end of the production process (prior to the transfer to finished goods inventory). The gross margin (gross profit) percentage reveals whether the client is able to price the inventory to earn an acceptable profit. Moreover, comparing current-year gross margin to that of prior years can uncover overstated or understated inventory accounting since inventory and cost of goods sold are inversely related. These ratios should be disaggregated to specific product lines or geographic regions to make them more meaningful. The results can be compared to the amounts budgeted, results in previous years, results of competitors, and industry averages.

Substantive Evidence in Management Reports Most entities produce timely reports that managers need for monitoring and controlling inventory. Auditors can use these reports as supporting evidence for assertions about raw materials inventories, work-in-process inventories, finished goods inventories, and cost of goods sold.

Sales Forecast Management’s sales forecast provides the basis for several aspects of business plan- ning, notably of production and inventory levels. Forecasts can be used in gaining an understanding of management’s plans for the year under audit, some of which will have already been completed when the audit work begins. Forecasts help auditors understand the nature and volume of production or purchase orders and management’s strategy and rationale for inventory levels. Forecasts for the following year can be used in valuing the inventory at lower of cost or NRV (e.g., identifying slow-moving and potentially obsolete inventory). Special care must be taken when using the forecast for the next year in valuing inventory because an overly optimistic forecast can lead to a failure to write down inven- tory, accelerate the depreciation of fixed assets, and account for more cost of goods sold.

If the auditors want to use the forecast for audit decisions, they should perform some work to obtain assurance about its reasonableness. For example, the auditors can inquire about how the forecast was prepared, what assumptions were made, and how the client ensures its accuracy. The auditors also can compare previous forecasts with actual results. In addition, some work on the mechanical accuracy of the forecast should be performed to avoid relying on faulty calculations. This work can usually be limited to overall tests for reasonableness.

The auditors were reviewing the inventory items that had not been sold for 30 days or more, considering the need to write some items down to market lower than cost. The sales manager showed them the SALY forecast that indicated continuing demand for the prod- ucts. The auditors agreed that the forecasts supported the prediction of future sales of products at prices that would cover the cost of the

slow-moving material items. Unfortunately, the auditors neglected to ask the meaning of SALY in the designation of the forecast and there- fore did not learn that it meant “same as last year.” It was not a fore- cast at all. The products did not sell at the prices expected, and the company experienced losses the following year that should have been charged to cost of goods sold earlier.

The SALY ForecastAUDITING INSIGHT

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Inventory Reports Companies can produce a wide variety of inventory reports useful to auditors in conduct- ing analytical procedures. These reports should include a list of the items in inventory and their costs and should agree with the inventory control account. Auditors can use this list (1) to scan for unusual conditions (e.g., negative item balances, overstocking, and valuation problems) and (2) as a population for sample selection for a physical inventory observation. Many of these analyses can be performed easily using IDEA or other data & analytic software.

Production Plans and Reports Based on the sales forecast, management should develop a plan for the amount and tim- ing of production in a manufacturing entity. The production plan provides general infor- mation to the auditors, but the production orders and inventory plan associated with the production plan are even more important. The production orders carry the information about requirements for raw materials, labor, and overhead, including the requisitions for purchase and use of materials and labor. These documents are the initial authorizations for control of the inventory and production.

Production reports record the completion of production quantities. When coupled with the related cost accounting reports, they are the company’s record of the cost of goods placed into the finished goods inventory. In most cases, auditors examine the cost reports in connection with determining the cost valuation of inventory and cost of goods sold.

Since the first production of financial reports for use by investors, man- agers have had incentives to present their financial position and results of operations in the most favorable manner possible. Because of the prevalence of inventory in organizations, desperate management often turn to inventory fraud to assist in achieving their financial goals. Consider the following historically large or unique inventory frauds:

• “Crazy Eddie” Antar overstated profits through an understatement of cost of goods sold. The company received inventory, but did not record it or the corresponding account payable in the books. How- ever, the inventory was present and counted, resulting in an over- statement of ending inventory in the company’s periodic inventory system, leading to materially understated cost of goods sold.

• Laribee Wire Manufacturing Company created fictitious inven- tory by regularly transferring raw materials between plants.  By recording the transfer in the receiving plant, but not recording the reduction in the shipping plant, the company materially overstated inventory through double-counting.

• Viken Keuylian was a leading dealer of Lamborghinis sold to the stars, including Kobe Bryant, Elton John, and many others.  Upon becom- ing more financially strapped, Keuylian began to make sales of the autos without reporting the sales to his floor manager. The already sold automobiles remained on the lot, and on the inventory count. What do these frauds have in common? An observant auditor

could have detected an increased risk through the use of substantive inventory analytical procedures. In all cases, the auditor would have noticed a difficult-to-explain increase in gross profit percentage, cou- pled with a decline in inventory turnover for the inventory class sub- ject to the fraud. With the increased availability of client data, auditors have the tools to perform inventory analytics at more detailed levels, and improve the precision of their risk assessments. Source: “Star Lambo Dealer Played Fast, Loose with Funds,” Automotive News, April 20, 2009; “White Collar Fraud:  Crazy Eddie Fraud” https:// whitecollarfraud.com/crazy-eddie/crazy-eddie-fraud/; “Inventory Manipulation: What You See Is Not Always What You Get”, https://www.abi.org/abi-journal/ inventory-manipulation-what-you-see-is-not-always-what-you-get.

The Value of Analytical ProceduresAUDITING INSIGHT

Physical Inventory Observation The auditing procedures for inventory and related cost of sales accounts frequently are extensive in an audit engagement. Remember, a material error or fraud in inventory has a pervasive effect on financial statements. Although analytical procedures may indicate inventory misstatements, the auditor’s best opportunity to detect inventory errors and frauds is during a physical inventory observation, an observation of the client’s physical inventory count taken by company personnel. Auditors observe the inventory taking and make test counts, but they seldom actually count the entire inventory.

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The auditor’s first task is to review the client’s inventory-taking instructions, which should include the following:

1. Names of client personnel responsible for the count. 2. Dates and times of inventory taking. 3. Names of client personnel who will participate in the inventory taking. 4. Instructions for recording accurate descriptions of inventory items, for counting and

double-counting, and for measuring physical quantities (such as counting by mea- sures of gallons, barrels, feet, dozens).

5. Instructions for making notes of obsolete or worn items. 6. Instructions for the use of tags, punched cards, count sheets, computers, or other

media devices and for their collection and control. 7. Plans for shutting down plant operations or for taking inventory after store closing

hours and plans for having goods in proper places (such as on store shelves instead of on the floor, or of raw materials in a warehouse rather than in transit to a job).

8. Plans for counting or controlling movement of goods in receiving and shipping areas if those operations are not shut down during the count.

9. Instructions for computer compilation of the count media (such as tags, count sheets) into final inventory lists or summaries.

10. Instructions for review and approval of the inventory count; supervisory personnel notations of obsolescence or other matters.

11. Instructions for making changes and corrections to count tickets.

These instructions characterize a well-planned counting operation. As the plan is car- ried out, the auditors should be present to hear the count instructions being given to the client’s count teams and to observe the instructions being followed. In addition, the audi- tor should make selected test counts and record these in the audit documentation.

Manual Physical Inventory Refer to Appendix Exhibit 9B.1 for an example of an audit plan for observing a physical inventory count. Note the requirement for obtaining tag numbers. It is critically important to know which tag numbers or count sheets were and were not used to prevent the client from simply adding inventory items by creating more tags at a later date. Also, note the cutoff procedures of examining shipping and receiving documents issued immediately before and after the count. The items that are included in the count must be the same as those recorded in the inventory records, and any items that have been sold or are not yet received must be excluded from the count and the records.

The auditors can perform dual-direction testing by (1) selecting inventory items from a perpetual inventory record, going to the location, and obtaining a test count, which

Apparently, quite a bit of money can be made from gourmet mush- rooms (no, not that kind). So much so that Gino Silva and Steven Perei, both employees with D’Artagnan, a mushroom distributor, set up their own company in direct competition with their employer.

Starting in December 2007, Silva and Perei made sales on behalf of their own company, Mediterra, and then stole D’Artagnan’s inven- tory to complete the sale. To conceal the inventory, Silva enlisted the help of D’Artagnan’s inventory control specialist to manipulate pur- chase order records and alter inventory records. This scheme was simple yet quite brilliant—by using their employer’s inventory for their

new company, top-line sales essentially equaled bottom-line profit. Why pay for something when someone else can foot the bill? The mushroom scheme lasted just over 12 months.

In April 2011, Silva pleaded guilty to interstate theft of property while on release pending sentencing in another federal criminal mat- ter. Silva was sentenced to 28 months in prison. Perei pleaded guilty in April 2010 to one count of selling and receiving stolen goods and was sentenced to two years of probation in June 2011. McCormack, Paul. “Payroll and Inventory Fraud – Are You Next?” Paul McCor- mack. http://mccormackwrites.com/tag/disgruntled-employees/.

Do You Want Mushrooms on That?AUDITING INSIGHT

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produces evidence for the existence balance assertion (vouching from the inventory record to the actual items in inventory), and (2) selecting inventory from locations on the warehouse floor, obtaining a test count, and tracing the count to the final inventory com- pilation, which produces evidence for the completeness balance assertion (tracing items from the inventory to the inventory records). If the company does not have perpetual records and a file to test for existence, the auditors must be careful to obtain a record of all counts and use it for the existence-direction tests. In addition to the test counts, the audi- tor should document whether: client personnel were following the inventory instructions, the tag or count sheet numbers used and unused, the last shipping and receiving reports issued before the inventory count, the condition of the inventory, any inventory on hand that the client does not own, and any unusual items noticed during the count.

Bar Codes and Computers in Physical Inventory Counts Most organizations are now using bar codes located on the product to improve the efficiency and effectiveness of monitoring and counting the physical inventory. Perhaps on a trip to the grocery store or department store you have seen an individual with a handheld device scanning the store shelves. This device (see Exhibit 9.12) is designed to scan the bar code located on the front of the shelf. That bar code records the product type, manufacturer, and size in the hand unit. Once the individual counts the number of units in inventory, the count can be entered and stored in the scanner by using the number pad located on the top of the scanner. When the counts are completed, the unit can be brought back to the physical inventory supervisor, who can download the data to the computer program being used to manage the physical inventory.

Although the use of scanners and computers greatly improves the accuracy (all product descriptions are identical) and efficiency (product descriptions and counts do not need to be written), there is still a need to follow the basic elements of a physical inventory count. For example, all items still should be counted twice. However, the computer can match first and second counts and, if they are identical, accept and record the count. If the counts are not identical, the item can be flagged for review by the physical inventory supervisor.

RFID Physical Inventory Many people driving in cities with toll roads and bridges now bypass the toll booths by using the technology of radio-frequency identification (RFID). Its devices send a signal to an RFID reader that identifies the automobile or truck as it travels and charges the driver’s account for the toll. This same technology is being used in some warehouses and stores around the world. As more and more products are tagged with RFID chips, most about the size of a nickel, companies will automatically scan each product as it enters or leaves the warehouse or store or count the inventory by using portable RFID readers. For example, Sam’s Club uses an electronic product code (EPC) system designed to track goods using RFID technology. When a case of products

EXHIBIT 9.12  Example of Inventory Bar Code Scanners

Paul Bradbury/Caiaimage/Getty Images

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tagged with RFID labels arrives in a warehouse, it is detected by readers on the door. A staff member can then use a handheld RFID reader to trace the case and process the product. If every product is tagged with individual RFID labels, inventory levels can be recorded automatically and out-of-stock situations reduced. Walmart has been using RFID technology for about a decade, resulting in numerous benefits—including more efficient inventory management.

Will this eliminate the need for a physical inventory? Probably not. But it will change the focus of the audit of the physical inventory. If the RFID reader is connected to a com- puter, a completely accurate count of the RFID signals can be made without the need for a second count. The major focus may be on sampling items to ensure the actual goods are contained in the shipping container, not just an empty container with only an RFID chip.

Radio-frequency identification (RFID) was up and running when the new 63,000-square-foot shoe department opened in Macy’s Herald Square (New York City) store. RFID, a technology that has been around for about 10 years, has become much more economical to apply to track merchandise. The first phase launched in August 2012 with 300,000 pairs of shoes for sale on any given day. RFID made it much easier to track such a large quantity of shoes and, importantly, made it possible to serve the customer faster and more efficiently.

Installing RFID in the shoe department is the first broad use of this technology by Macy’s. From shoes, RFID will be expanded into other departments next year. Merchandise that is basic, always in stock, and always in need of replenishment will follow. About one-third of the full replenishment assortment at Macy’s will be on RFID. As a result, mer- chandise in stock levels will rise, and customers will be happier. For example, shoes inventory will be monitored by size, width, and color, and eventually, polo shirts will be monitored by color and size. The cost of RFID technology and the chips on each garment have come

down dramatically in price, making it possible for Macy’s to take this first step.

Recently, Macy’s has implemented a new program that employs RFID to allow omnichannel fulfillment of consumer purchases, right down to its last available unit of in-store merchandise. The program, which Macy’s has named Pick to the Last Unit (P2LU), enables the retailer to list goods for sale online even when there is only one such item available at the store. In the past, inventory counts were simply not precise enough to ensure that a unit of a particular product was actually in stock and available for sale. However, Macy’s says it has proven that by using RFID technology to perform inventory counts, it can be certain of what it has available and can, therefore, put it up for sale.

Sources: “Macy’s Wins with Technology,” Forbes, www.forbes.com, July 7, 2012; Claire Swedberg, “Macy’s Launches Pick to the Last Unit Program for Omnichannel Sales,” RFID Journal, www.rfidjournal.com/articles/view?13990, January 26, 2016.

Using RFID in Inventory ManagementAUDITING INSIGHT

Advanced Technology in Inventory Counts As described in the opening chapter vignette, some firms and industries are beginning to use advanced technology, such as automated drones, to control and count physical inventories. Although this technology is promising, and frankly, fun to think about, the reality is that most inventory counts do not use drones or counting machines. The large majority of auditors and clients continue to count their inventory using traditional human-driven methods, although technology is almost always involved in some way through scanners or RFID chips. Further, and perhaps most importantly, nothing can replace due professional care and skepticism in the audit of inventory. Never rely on technology at the expense of carefully considering the reasonable- ness of the product you are counting. Does the item really seem to match the description given? Do you notice any dust building up on the boxes? Do some units appear different than others? What do sales records show about the movement of the inventory? Does the client maintain the same inventory item in multiple locations? Inventory affects nearly all aspects of the financial statements—a material misstatement in inventory is often consid- ered pervasive. Exercise due professional care and take your time to thoroughly under- stand your client’s business and processes and it will improve the quality of your audit.

Difficult Inventory Circumstances In the sections above, a standard inventory process was assumed. The following are some inventory issues that can lead to changes in the nature or timing of a standard audit pro- cedure and often present difficulties for the auditors.

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Physical Inventory Not on Year-End Date Clients usually count the inventory before or after the balance-sheet date. When the auditors are present to make their physical observation, they follow the procedures outlined for observation of the physical count. However, with an intervening period between the count date and the year-end, additional inventory roll-forward auditing procedures must be performed on transactions during that period. The inventory on the count date is reconciled to the year-end inventory by appro- priate addition or subtraction of the subsequent receiving and shipping transactions.

Cycle Inventory Counting Cycle counts are physical counts of selected inventory throughout the year (i.e., different parts of the inventory throughout the year). They are most appropriate when internal control over inventory is effective (i.e., a low level of control risk is present). Other companies use a statistical counting plan. In these cir- cumstances, the auditors must understand the cycle or sampling plan and evaluate its appropriateness. In this situation, the auditors are present for only some of the physical inventory counts. Only under unusual circumstances and as an “extended procedure” are auditors present every month (or more frequently) to observe all counts. Businesses that count inventory using cycle counts purport to have accurate perpetual records and carry out the counting as a means of testing the records and maintaining their accuracy.

When counts go on all year long, the auditors are present for only a few counts. Auditors should review annual inventory schedules and carefully select the inventories to observe. These observations may be performed during interim periods, but good inventory obser- vation procedures should always be followed. The auditors must be present during some counting operations to evaluate the counting plans and their execution. The same proce- dures enumerated for an annual count are used, test counts are made, and the audit team is responsible for making a determination concerning the accuracy of perpetual records.

Professional Inventory Teams Some clients with large numbers of operating facilities (e.g., retail store chains) may have a professional inventory team(s) or hire a professional inventory company. These teams go from one facility to another performing physical inventory counts all year long. In addition, these inventory companies may have their own standard inventory procedures, minimum qualification requirements, and substantial train- ing for inventory count supervisors and employees. These types of operations add an air of professionalism and expertise to the physical inventory count. Auditors should review inventory team qualifications, training requirements, and standard policies and procedures.

Auditors Not Present for Client’s Inventory Count This situation can arise on a first audit when the accounting firm is appointed after the beginning inventory already has been counted. Because the beginning inventory amount affects cost of goods sold, the auditors must disclaim an opinion on the income statement and may have substantial con- cerns with stockholders’ equity, the statement of cash flows, and additional items affected by net income if they are unable to perform alternative procedures. The auditor can uti- lize alternative procedures to provide sufficient, appropriate evidence that the beginning inventory number is not materially misstated. For example, the auditors must review the client’s plan for the already completed count as described earlier. Some test counts of current inventory should be made and traced to current records to determine the reliabil- ity of perpetual records. If the actual count was recent, intervening transaction activity might be reconciled back to the inventory count. The reconciliation of more than a few months’ transactions to unobserved beginning inventories could be very difficult. The auditors can employ analytical procedures using such interrelationships as sales activity, physical volume, price variation, standard costs, and gross profit margins for the decision about beginning inventory reasonableness. Nevertheless, much care must be exercised in “backing into” the audit of inventory previously taken.

Inventories Located Off the Client’s Premises The auditors must determine where and in what dollar amounts inventories are located off the client’s premises, in the custody of consignees, or in public warehouses. If amounts are material and if control activities are not exceptionally strong, the audit team may wish to visit these locations and conduct

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onsite test counts. However, if amounts are not material, if alternative evidence (such as periodic reports, cash receipts, receivables records, shipping records) is adequate, or if control risk is low, then direct confirmation with the custodian may be considered suf- ficient appropriate evidence of the existence of quantities.

After the observation is complete, auditors should have sufficient appropriate evidence of the following physical quantities and valuations:

∙ Goods in the perpetual records but not owned were excluded from the inventory compilation. ∙ Goods on hand were counted and included in the inventory compilation. ∙ Consignment (consigned-out) goods or goods stored in outside warehouses (goods

owned but not on hand) were included in the inventory compilation. ∙ Goods in transit (goods actually purchased and recorded but not received) were added

to the inventory count and included in the inventory compilation. ∙ Goods on hand that have been sold and by agreement are being held by the client were

excluded from the inventory compilation. ∙ Consignment (consigned-in) goods were excluded from the inventory compilation.

REVIEW CHECKPOINTS 9.15 What characteristics should be considered in reviewing a client’s inventory-taking instructions? 9.16 Explain dual-direction sampling in the context of inventory test counts. 9.17 Why is it important for auditors to obtain control information over inventory count sheets or tickets? 9.18 What inventory information should auditors document when performing an inventory count?

Inventory theft is known to cost retailers nearly $50 billion annually. What’s a company supposed to do about thieving customers and employees, especially as more and more businesses move to models with fewer front-end cashiers?

Some of the world’s largest retailers are moving towards artificial intelligence as a way to control inventory theft. Walmart has moved to a model where well over half of their transactions are completed without a cashier. A dishonest customer may think this makes stealing easy just transfer the item from the cart to a bag and pretend to scan it. Not so fast! Walmart uses “Missed Scan Detection,” an AI-based technology using cameras that detect any time a customer moves a product past the scanner without completing the sale. A nearby regis- ter attendant is notified instantly and can take action.

In an even more extreme example of the use of AI for inventory management, Amazon uses an entirely cashierless environment in its

off-line retail stores, Amazon Go. Amazon refers to the shopping expe- rience as “Just Walk Out.” Customers with the Amazon Go app simply walk into the store, take the items needed, and walk out. Using such techniques as computer vision, face recognition, and sensor fusion, the order is automatically charged to the customer’s Amazon account, and the customer can instantly see a receipt on the Go app. More importantly from an auditor’s perspective, inventory is maintained per- petually. Clearly, this type of technology adds an entirely new dimen- sion to assessing control risk and testing the operating effectiveness of internal controls, and also can lead to significant reductions in over- all risk in the inventory cycle.

Source: “Walmart is Using AI-Powered Cameras to Prevent Theft at Checkout Lanes,” The Verge, theverge.com, June 20, 2019; “What is Amazon Go, Where Is It, and How Does It Work?”, pocket-lint.com, February 18, 2019.

AI: The Next Frontier in Inventory ManagementAUDITING INSIGHT

Worthington Industries is a diversified metals processing company focused on steel processing and manufactured metal products. On December 3, 2008, Worthington announced that market weakness and decline in steel pricing have left it with inventories in excess of

demand with reduced market values. As a result, Worthington wrote down the value of its inventories by approximately $100 million. Source: “Worthington Industries Announces Inventory Write-Down and Declares Quarterly Dividend,” www.worthingtonIndustries.com, December 3, 2008.

Sometimes Things Aren’t Worth What They Were

AUDITING INSIGHT

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Inventory Counts —A Ripe Field for Fraud Although auditing standards do not expect the auditor to assume high fraud risk in inven- tory, as they do with revenue, there are nonetheless many examples of inventory frauds:

∙ Auditors were fooled as a result of taking a small sample for test counting, thus miss- ing important information.

∙ Entities included inventory they pretended to have ordered. ∙ Entities stacked inventory on pallets in such a manner that “empty spaces” were not

visible to auditors, resulting in overstatements of inventory. ∙ Auditors permitted company officials to follow them and note their counts. Then the

managers falsified counts for inventory the auditors did not count. ∙ Shipments between plants (transfers) were reported as inventory at both plant locations. ∙ Auditors spotted a barrel whose contents management had valued at thousands of dol-

lars, but it was filled with sawdust. The auditors required management to exclude the value from the inventory, but it never occurred to them that they had found just one instance in an intentional and pervasive overstatement fraud.

∙ Auditors observed inventory at five store locations and told the management in advance of the specific stores. Management took care not to make fraudulent entries in these 5 stores but, instead, made fraudulent adjustments in many of the other 236 stores.

∙ After counting an inventory of computer chips, the auditors received a call from the client’s controller: “Just hours after you left the plant, 2,500 chips arrived in a ship- ment in transit.” The auditors included them in inventory but never checked to see whether the chips were actually received.3

Accounting Firm Tips To help detect inventory fraud, Grant Thornton, a large national accounting firm, advises its audit personnel:

∙ Focus test counts on high-value items and sample lower-value items. Test count a suf- ficient dollar amount of the inventory.

∙ If all locations will not be observed, do not follow an easily predictable pattern. Advise client personnel as late as possible of the locations to be visited.

∙ Be skeptical of large and unusual test count differences or of client personnel making notes or displaying particular interest in procedures and test counts.

∙ Be alert for inventory not used for some time; stored in unusual locations; or showing signs of damage, obsolescence, or excess quantities.

Pricing and Compilation The physical observation procedures are designed to audit for existence and completeness (physical quantities). The pricing and compilation tests examine valuation (recalculation of appropriate FIFO, LIFO, or other pricing at cost, and lower of cost or NRV, and write- down of obsolete or worn inventory).

The compilation and pricing stage starts by listing all inventory items counted. The auditor foots4 the list and tests the mathematical accuracy by multiplying the quantities and the price to get the total value for each item. Test counts taken by the auditor during the physical count are traced to the list, and other items from the list are vouched back to inventory count tags. The unit price is vouched to the vendor invoices for the purchase price for raw materials and to standard cost for in-process and finished goods. Many of these tests can be performed automatically using CAATs.

Lower-of-cost-or-NRV testing is an important step toward the valuation assertion. NRV can be obtained by examining the client’s catalog and actual sales in the subsequent

3Examples cited in this list have been taken from The Wall Street Journal. 4Foots is an accounting term meaning to add up a column.

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period and reviewing the costs associated with product sales. Items that are slow moving or obsolete can be spotted during the inventory observation if they demonstrate evidence of unsalability (e.g., old inventory tags, dust, and rust). Appendix Exhibit 9B.2 illustrates an audit plan for inventory pricing and compilation tests.

Presentation and Disclosure Assertions When the auditor is satisfied that controls have been examined and transactions and bal- ances are fairly presented according to GAAP, the job is not over. The aspects of pro- duction, especially inventory, require many disclosures. The components of inventory (raw materials, work-in-process, finished goods), inventory valuation method, lower of cost or NRV, and allocation of fixed costs are only a few of the essential items with spe- cific presentation and disclosure requirements. These disclosures must ensure that the presentation and disclosure assertions of occurrence, rights and obligations, complete- ness, classification and understandability, and accuracy and valuation are all met. See Exhibit  9.13 for excerpts from the footnote contained in Boeing Corporation’s 2018 financial statements.

REVIEW CHECKPOINTS 9.19 Why is it important to obtain shipping and receiving cutoff information during the inventory

observation? 9.20 What procedures do auditors employ to audit inventory when the physical inventory is taken on a

cycle basis or on a statistical plan but never a complete count on a single date? 9.21 What could be happening when a client’s managers take notes of auditors’ test counts while an

inventory is being counted? 9.22 What analytical procedures might reveal obsolete or slow-moving inventory?

EXHIBIT 9.13 Excerpts from Inventory Footnote in Boeing Aircraft 2018 Annual Report

Disclosure Assertion Excerpt from Boeing Footnote

Completeness Inventoried costs on commercial aircraft programs and long-term contracts include direct engineering, production and tooling and other non-recurring costs, and applicable overhead, which includes fringe benefits, production related indirect and plant management salaries and plant services, not in excess of estimated net realizable value.*

Classification of items included in inventory costs

To the extent a material amount of such costs are related to an abnormal event or are fixed costs not appropriately attributable to our programs or contracts, they are expensed in the current period rather than inventoried. Inventoried costs include amounts relating to programs and contracts with long-term production cycles, a portion of which is not expected to be realized within one year. Included in inventory for federal government contracts is an allocation of allowable costs related to manufacturing process reengineering.*

Accuracy and valuation of inventoried parts

We review our commercial spare parts and general stock materials quarterly to identify impaired inventory, including excess or obsolete inventory, based on historical sales trends, expected production usage, and the size and age of the aircraft fleet using the part. Impaired inventories are charged to Cost of products in the period the impairment occurs.

Included in inventory for commercial aircraft programs are amounts paid or credited in cash, or other consideration to certain airline customers, that are referred to as early issue sales consideration.

Presentation Early issue sales consideration is recognized as a reduction to revenue when the delivery of the aircraft under contract occurs.

*These items are one single paragraph in the annual report. It has been separated for illustrative purposes.

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AUDIT RISK MODEL APPLIED Now that the control and inherent risk elements for the production cycle and some of the important substantive procedures have been presented, let’s examine how an auditor might apply the audit risk model for the account balance assertion of existence. First, we show a table relating levels of detection risk to the extent of substantive procedures; note that the level of detection risk influences the nature (use of analytical procedures), tim- ing (year-end counts versus interim counts versus cycle counts), and extent (number of inventory purchases vouched) of substantive tests. Then we provide an example of how they might be employed in practice. It is important to note that similar examples could be provided for the remaining material financial statement assertions related to inventory.

LO 9-7 Apply your knowledge to perform audit procedures in the audit of inventory and evaluate the findings of your tests.

Extent of Substantive Inventory Procedures for Balance Assertion of Existence

Low detection risk

Observe physical inventory count at year-end. Take substantial number of test counts and use large sample for vouching inventory purchases. Perform analytical procedures during planning and at audit completion.

Moderate detection risk

Observe inventory count at interim date. Test roll-forward to year-end. Use moderate vouching of purchases. Perform analytical procedures during planning and at audit completion.

High detection risk

Rely heavily on analytical procedures. Observe cycle counts of inventory. Rely on roll- forward procedures with minimal testing.

World Electronics LLC Martin Phelps has been assigned as audit manager for World Electronics LLC, a medium-size publicly held manufacturer of semiconductors used in the computer indus- try. It has four manufacturing facilities located in Lexington, Kentucky; Dublin, Ireland; Barcelona, Spain; and Bangkok, Thailand. World uses just-in-time inventory manage- ment at all plants so that when a plant receives a customer order, it electronically for- wards a purchase order for the materials to vendors. The company takes cycle counts of its inventory so it will not disrupt production. When World receives goods, the receiving clerk enters the receipt into the system, which automatically updates the perpetual inven- tory. Likewise, as semiconductors are completed, they are scanned and automatically moved from in-process to finished goods. The computerized controls were reviewed and tested by the audit firm’s computer audit specialist, who noted no exceptions. Therefore, Phelps has set control risk as low. Control risk also has been set as low in the acquisition cycle and the revenue cycle.

The company is a leader in the industry, and management has a very good reputation. The semiconductor industry is experiencing strong growth, and the company is consis- tently profitable. There have been only minor audit adjustments in previous years, and the company has moved quickly to correct the cause of the adjustments. Consequently, Phelps also has set inherent risk as low. Therefore, considering these factors and the assessment of control risk, the risk of material misstatement is assessed as low and detec- tion risk has been set as high. As a result, Phelps can select a sample of the cycle counts to observe on a surprise basis. He can record limited test counts and rely on limited testing of the computer records that roll forward the perpetual inventory until year-end. Because risk of material misstatement is low in the acquisition cycle, Phelps can limit vouching of invoices to test the prices of raw materials. Finally, Phelps can rely heavily on analytical procedures, particularly gross margin percentages, to ensure that no serious errors or frauds have occurred. The combination of a low risk of material misstatement and a high detection risk combine to give Phelps an acceptably low audit risk.

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Fraud Case: Extended Audit Procedures (AS 2301) The case refers to the Phar-Mor incident discussed at the beginning of this chapter. “The Problem” section reiterates the “inside story,” which auditors seldom know before they perform the audit procedures. The second part of the case under the heading “Audit Approach” tells a structured story about the audit objective, controls, tests of controls, substantive procedures, and discovery summary. At the end of the chapter, some similar discussion cases are presented, and you can prepare the audit approach to test your ability to design audit procedures for the detection of errors and frauds.

Case 9.1

We Will Not be Undersold!5

PROBLEM Mickey Monus, the CEO of Phar-Mor, stated on many occasions that he would “not let Walmart undersell Phar-Mor.” To that end, Phar-Mor would actually sell many products at a loss resulting in corporate net losses. Phar-Mor dumped these losses in a “bucket account” and spread them over the individual stores by increasing inventory amounts. When company personnel found out which stores the auditors would be visiting for inventory observation, they simply moved goods from the stores that were not visited to make up for shortages. Phar-Mor used an outside service for inven- tory counting, but after receiving the results, Phar-Mor personnel would inflate the amounts during the pricing and compilation process. In some cases, the compilations were altered after the auditors tested them. When Phar-Mor rolled forward the inventory from the count date, the inventory showed large increases right at year-end. These increases were due to the “blow-out” entries allocating the losses in the bucket account to stores’ inventory. One entry was as high as $139 million. Finally, Phar-Mor did not have perpetual records but used the retail inventory method instead. Employees used distorted margin percentages to increase the estimated cost of the inventory on hand.

Phar-Mor issued fictitious invoices for purchases, made fictitious journal entries to increase inventory and decrease cost of sales, recognized purchases but failed to record the liabilities, and overcounted the merchandise.

The fraud lasted over a 10-year period, resulting in a financial statement fraud of more than $1 billion.

AUDIT APPROACH The primary control should have been an environment that discouraged false accounting. However, this clearly was not the case. Other controls that should have prevented or detected these misstate- ments include a review of nonstandard journal entries, comparison of inventory records to actual periodic counts, and management analysis of gross margins and cash flows. Senior management can easily override any controls. Doing so requires only employees who can be bribed, threatened, or intimidated into going along.

How does one test the control environment? In the client acceptance/continuation stage of plan- ning, the auditors should obtain evidence about management’s reputation for integrity. In this case, many vendors were complaining because they were “squeezed” by Phar-Mor to provide rebates and promotion allowances, and some were threatening to cut the company off for nonpayment of bills. Many employees, including the controller, were very concerned about the company’s prac- tices and might have been persuaded to come clean had the auditors approached the audit with skepticism. However, because the client’s chief financial officer was a former partner of the audit firm, the auditors appeared to lack skepticism.

It is not practical to observe inventory at all stores. However, because the auditors had identified inventory valuation as a high-risk area, they probably should have visited more than four stores! Moreover, the actual stores that the auditors visited for inventory observation should have been kept secret until the day of the count and randomized from one year to the next.

5Additional data taken from D. Cottrell and S. Glover, “Finding Auditors Liable for Fraud: What the Jury Heard in the Phar-Mor Case,” CPA Journal, July 1997, pp. 14–21.

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The auditors performed only a reasonableness test of the margins used in the retail method. They selected a sample of items in a “haphazard” method that turned out not to be representative. When the sample margins differed from the company’s margins, the auditors explained the differ- ence away without expanding their sample. In vouching the costs of inventory, the auditors should have been alert to phony documentation. Finally, large nonstandard journal entries at the end of the year should have been thoroughly scrutinized.

DISCOVERY SUMMARY When a travel agent noticed that a bill for the World Basketball League (WBL), a league started by Monus, was paid with a Phar-Mor check, she asked a neighbor, who was a major shareholder, why Phar-Mor would pay the WBL’s expenses. The neighbor phoned a board member, who initiated the investigation that uncovered the fraud.

REVIEW CHECKPOINTS 9.23 What steps should auditors take if the client has multiple locations being counted? 9.24 What is an inventory roll-forward? What roll-forward tests should be performed?

Audits of inventory vary greatly from client to client. An audit of a retailer’s inventory is almost completely different from an audit of a manufacturer, yet the same auditing standards apply.

Audits of companies who purchase their inventory are characterized by strong external evidence regarding the timing and cost of inventory acquisition. An audit of the revenue cycle provides substantial evidence surrounding the sales of the inventory.

The production cycle for manufacturers, on the other hand, is characterized by having mostly internal documentation as evidence and having relatively little external documen- tary evidence; therefore, the systems that produce these documents must be evaluated to ensure the validity of the information.

Companies reduce control risk by having a suitable separation of authorization, cus- tody, recording, and periodic reconciliation duties within the inventory cycle. Error- checking procedures, including analyzing production orders, purchase orders, sales orders, and finished production cost reports, are important for the proper determination of inventory values and proper valuation of cost of goods sold. Otherwise, many things

Summary

INVENTORY TESTING Significant issues in inventory occur when amounts in the physical inventory do not match the amounts in the accounting records. Audi- tors are aware of the beginning inventory for the year, (the audited value for ending inventory form the previous year) and using computer software can calculate inventory received from receiving reports and inventory used from production reports. Using these numbers, the auditor can obtain an approximation of inventory that should be in this year’s ending inventory, as follows:

Beginning inventory + inventory purchases – inventory usage = ending inventory.

If we adjust the ending inventory for scrap, the number is even more accurate.

The recorded ending inventory and the inventory account should not be materially misstated from the preceding calculation. Major dis- crepancies should be investigated and may be the result of poor record keeping or theft of inventory. Further, audit software like IDEA can com- pare physical counts with actual inventory. The use of such a program is extremely important when inventory includes tens of thousands of items. (Note: A typical Walmart store has approximately 140,000 SKUs.)

Further, inventory valuation is critical to reaching an audit conclu- sion about inventory, and audit software can assist the auditor in iden- tifying unusual and potentially obsolete inventory items.

At the end of this chapter, you can perform testing related to the valuation assertion in Exercise 9.69, and tests related to inventory summarization in Exercises 9.70–9.73.

Using IDEA in the AuditAUDITING INSIGHT

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could go wrong, ranging from overvaluing the inventory to understating costs of produc- tion by deferring costs that should be expensed.

Cost accounting is a central feature of a production cycle for manufacturers. The illus- trative case in the chapter tells the stories of financial reporting manipulations and the audit procedures that will detect them. The physical inventory observation audit work was discussed because actual contact with inventories provides auditors direct eyewitness evidence of important tangible assets.

Many frauds have been hidden in the inventory accounts. Therefore, the auditors should pay attention to the inventory balance assertions of existence and valuation and alloca- tion. The audit of inventory requires professional judgment, professional skepticism, and due professional care. The following Auditing Insight presents deficiencies noted in the PCAOB inspection reports of some of the largest audit firms regarding audits of this cycle.

• The Firm failed to perform sufficient procedures related to inven- tory, as follows – • A significant portion of the issuer’s inventory was located in

one warehouse. The Firm selected for testing a control over the existence of this inventory. The control required that 80 percent of the inventory storage locations at this warehouse be counted at least once a year. The Firm failed to evaluate whether this control was designed to appropriately address the risk related to the existence of inventory. Specifically, the Firm did not evaluate whether this control, which required that only 80 percent of the inventory storage locations be counted, could effectively prevent or detect material misstatement of the inventory located in this warehouse.

• The Firm designed certain of its substantive procedures – including the sample size used in those procedures – based on a level of control reliance that was not supported due to the deficiency in the Firm’s testing of the control that is discussed above. As a result, the sample size the Firm used to test the existence of this inventory was too small to provide sufficient evidence.

• To determine the allowance for excess and obsolete inven- tory for one of its components, the issuer applied a different reserve percentage to each of the categories within its two types of inventory. The Firm failed to perform sufficient testing of this allowance. Specifically –

• For both types of inventory, the Firm failed to test the com- pleteness of the inventory included in each of the catego- ries used in the calculation of the allowance.

• For one type of inventory, the Firm failed to evaluate the reasonableness of the reserve percentages that the issuer applied to the categories in determining the allowance.

In this audit of an issuer in the health care industry sector, the Firm failed to obtain sufficient appropriate audit evidence to support its audit opinion on the effectiveness of ICFR: • The Firm’s procedures related to controls over the existence of the

majority of the issuer’s inventory were insufficient. The Firm identi-

fied and tested one control that consisted of a review of the issu- er’s reconciliation of its cycle-count results to the inventory system and its investigation of variances for individual items. This control was not designed to address the sufficiency of the inventory items counted, the frequency of the counts, and the aggregate devia- tions identified in the counts, and the Firm failed to identify and test any other controls that did so. The Firm failed to perform sufficient procedures related to the

valuation of inventory. Specifically • The Firm selected for testing a control that included the prepa-

ration and review of the issuer’s excess and obsolete inventory reserve analysis. The Firm failed to sufficiently test this control, as its procedures were limited to (1) inquiring of the preparer of the reserve analysis, (2) verifying that the preparer had documented general explanations for certain inventory items, and (3) inspect- ing evidence indicating that a review had occurred. The Firm failed to evaluate the nature of the review activities the control owners performed to evaluate the reasonableness of this inven- tory reserve. In addition, the Firm failed to identify and test any controls over the accuracy of certain spreadsheets used in the operation of this control.

• The Firm selected for testing an automated control over the allo- cation of costs to finished goods inventory that consisted of the system’s calculation of the value of this inventory using standard costs from the inventory-management system. The Firm’s proce- dures to test this control consisted of inquiring of management and selecting one item that was sold during the year to determine that the correct amount was relieved from inventory and recorded to cost of goods sold. The Firm, however, failed to test whether this automated control would correctly apply standard costs to fin- ished goods inventory.

• The Firm’s substantive procedures to test inventory were insuffi- cient in the following respects – • The Firm failed to test the quantities included in the bills-of

materials that were used to value the work-in-process and finished goods inventory items that it selected for testing at year end.

Deficiencies from PCAOB Inspection Reports in Audits of Inventory

AUDITING INSIGHT

(continued)

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• The Firm’s procedures to evaluate the reasonableness of the excess and obsolete inventory reserve included testing the issuer’s reserve analysis. The Firm, however, failed to test the accuracy of certain spreadsheets that the issuer used in this analysis.

• For certain inventory that the issuer identified as potentially excess or obsolete, the Firm failed to sufficiently evaluate the reasonableness of management’s conclusions that no inventory reserve or write-off was required, as its procedures were limited to reading management’s explanations, without obtaining corroboration of those explanations.

• The Firm failed in the following respects to obtain sufficient appro- priate audit evidence to support its audit opinions on the financial statements and on the effectiveness of ICFR. The issuer’s inventory

located at its distribution centers was subject to daily cycle counts. The Firm selected for testing five controls that consisted of the (1) performance of daily cycle counts; (2) review of the inventory adjustment report, which listed differences that resulted from the daily cycle counts; (3) monthly review of the inventory variance report, which listed unrecorded differences; (4) monthly review of inventory writeoffs that were proposed as a result of the operation of the third control; and (5) monthly reconciliation of the inven- tory perpetual records to the general ledger. The Firm’s testing of these controls was insufficient.

Sources: 2017 PCAOB Inspection Report BDO USA, LLP (June 20, 2019); 2017 PCAOB Inspection of Deloitte & Touche LLP (December 20, 2018); 2017 PCAOB Inspection Report of KPMG LLP (January 24, 2019); 2017 PCAOB Inspection of PricewaterhouseCoopers (February 28, 2019).

(concluded)AUDITING INSIGHT

bill of materials: A list of raw materials and supplies used to build a product that is used to develop standard costs, 393 consignment goods: The goods that are given by one party, the consignor, to another party, the consignee, to sell; however, the consignee retains title until the goods are sold, 417 cycle counts: A method of physically counting different areas of inventory throughout the year, 416 inventory roll-forward: An accounting process from date of physical inventory count to the end of the period; includes additions for purchases and production and reductions for sales, scrap, and so on, 416 material requisition (materials transfer ticket): A form used to obtain raw materials and supplies from inventory custodian, 393 net realizable value (NRV): The selling price less costs to sell (e.g., sales commissions), 396 overhead allocation: An accounting procedure used to assign indirect costs to various products, 394 physical inventory count: The client’s procedure for determining actual amount of inventory on hand, 412 physical inventory observation: The auditor’s procedures during client’s physical inventory count; includes observing inventory procedures and performing test counts on selected inventory items, 412 pricing and compilation: The procedure for translating units counted in the physical inventory count to amounts recorded in the accounting records, including gains or losses for shortages or overages; involves mathematically accumulating counts and applying standard costs, 418 production order: A document that communicates to production personnel the specific product, product quantity, and date a product is to be produced, 393 production plan: A schedule of goods to be produced for a period based on sales forecasts, 392 raw material inventory status report: A periodic report (usually daily or weekly) that includes a list of all raw materials and the inventoried quantity of each material, 393 sales forecast: A report, usually prepared by marketing, predicting future sales of product, 392 standard costs: The estimates of cost to produce a product; used for transferring products between departments and to finished goods and to record cost of goods sold; compared to actual costs to obtain variances, 393

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Multiple-Choice Questions for Practice and Review

All applicable Exercises and Problems are available with Connect.

9.25 Which cycle is not directly linked to the production cycle? a. Acquisition and expenditure cycle. b. Payroll cycle. c. Revenue and collection cycle. d. Finance and investment cycle.

9.26 To determine the client’s planned amount and timing of production of a product, the auditor reviews the a. Sales forecast. b. Inventory reports. c. Production plan. d. Purchases journal.

9.27 An auditor reviews job cost sheets to test which transaction assertion? a. Occurrence b. Completeness c. Accuracy

d. Classification

9.28 Which of the following is an internal control weakness for a company whose inventory of supplies consists of a large number of individual items? a. Supplies of relatively little value are expensed when purchased. b. The cycle basis is used for physical counts. c. The warehouse manager is responsible for maintenance of perpetual inventory records. d. Perpetual inventory records are maintained only for items of significant value.

9.29 To make a year-to-year comparison of inventory turnover most meaningful, the auditor per- forms the analysis a. For the company as a whole. b. By division. c. By product. d. All of the above.

9.30 Which of the following procedures would best prevent or detect the theft of valuable items from an inventory that consists of hundreds of different items selling for $1 to $10 and a few items selling for hundreds of dollars? a. Maintain a perpetual inventory of only the more valuable items with frequent periodic

verification of the accuracy of the perpetual inventory record. b. Have an independent accounting firm prepare an internal control report on the effective-

ness of the controls over inventory. c. Have separate warehouse space for the more valuable items with frequent periodic physi-

cal counts and comparison to perpetual inventory records. d. Require a manager’s signature for the removal of any inventory item with a value of more

than $50. 9.31 An auditor usually traces the details of the test counts made during the observation of physi-

cal inventory counts to a final inventory compilation. This audit procedure is undertaken to provide evidence that items physically present and observed by the auditor at the time of the physical inventory count are a. Owned by the client. b. Not obsolete. c. Physically present at the time of the preparation of the final inventory schedule. d. Included in the final inventory schedule.

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9.32 A retailer’s physical count of inventory was higher than that shown by the perpetual records. Which of the following could explain the difference? a. Inventory items had been counted, but the tags placed on the items had not been taken off

and added to the inventory accumulation sheets. b. Credit memos for several items returned by customers had not been recorded. c. No journal entry had been made on the retailer’s books for several items returned to its suppliers. d. An item purchased FOB shipping point had not arrived at the date of the inventory count

and had not been reflected in the perpetual records. (AICPA adapted)

9.33 From the auditors’ point of view, inventory counts are more acceptable prior to the year-end when a. Internal control is weak. b. Accurate perpetual inventory records are maintained. c. Inventory is slow moving. d. Significant amounts of inventory are held on a consignment basis.

9.34 Which of the following internal control activities most likely addresses the completeness assertion for inventory? a. The work-in-process account is periodically reconciled with subsidiary inventory records. b. Employees responsible for custody of finished goods do not perform the receiving function. c. Receiving reports are prenumbered, and the numbering sequence is checked periodically. d. There is a separation of duties between the payroll department and inventory accounting

personnel. 9.35 When auditing inventories, an auditor would least likely verify that

a. All inventory owned by the client is on hand at the time of the count. b. The client has used proper inventory pricing. c. The financial statement presentation of inventories is appropriate. d. Damaged goods and obsolete items have been properly accounted for.

(AICPA adapted) 9.36 A client maintains perpetual inventory records in quantities and in dollars. If the assessed

control risk is high, an auditor would probably a. Apply gross profit tests to ascertain the reasonableness of the physical counts. b. Increase the extent of tests of controls relevant to the inventory cycle. c. Request the client to schedule the physical inventory count at the end of the year. d. Insist that the client perform physical counts of inventory items several times during the year.

(AICPA adapted) 9.37 An auditor selected items for test counts while observing a client’s physical inventory. The

auditor then traced the test counts to the client’s inventory listing. This procedure most likely obtained evidence concerning management’s balance assertion of a. Rights and obligations. b. Completeness. c. Existence. d. Valuation and allocation.

(AICPA adapted) 9.38 Which of the following auditing procedures probably would provide the most reliable evi-

dence concerning the entity’s assertion of rights and obligations related to inventories? a. Trace test counts noted during the entity’s physical count to the entity’s summarization of

quantities. b. Inspect agreements to determine whether any inventory is pledged as collateral or subject

to any liens. c. Select the last few shipping documents used before the physical count and determine

whether the shipments were recorded as sales. d. Inspect the open purchase order file for significant commitments that should be consid-

ered for disclosure. (AICPA adapted)

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9.39 An auditor most likely would analyze inventory turnover rates to obtain evidence concerning management’s balance assertions about a. Existence. b. Rights and obligations. c. Completeness. d. Valuation and allocation.

9.40 An auditor would vouch inventory on the inventory status report to the vendor’s invoice to obtain evidence concerning management’s balance assertions about a. Existence. b. Rights and obligations. c. Completeness. d. Valuation.

9.41 When evaluating inventory controls, an auditor would be least likely to a. Inspect documents. b. Make inquiries. c. Observe procedures. d. Consider policy and procedure manuals.

9.42 When testing a company’s cost accounting system, the auditor uses procedures that are pri- marily designed to determine that a. Quantities on hand have been computed based on acceptable cost accounting techniques

that reasonably approximate actual quantities on hand. b. Physical inventories agree substantially with book inventories. c. The system is in accordance with generally accepted accounting principles and is func-

tioning as planned. d. Costs have been properly assigned to finished goods, work-in-process, and cost of goods

sold. 9.43 The auditor tests the quantity of materials charged to work-in-process by vouching these

quantities to a. Cost ledgers. b. Perpetual inventory records. c. Receiving reports. d. Material requisitions.

9.44 Your client counts inventory three months before the end of the fiscal year because controls over inventory are excellent. Which procedure is not necessary for the roll-forward? a. Check that shipping documents for the last three months agree with perpetual records. b. Trace receiving reports for the last three months to perpetual records. c. Compare gross margin percentages for the last three months. d. Request the client to recount inventory at the end of the year.

9.45 An auditor is examining a nonpublic company’s inventory procurement system and has decided to perform tests of controls. Under which of the following conditions do GAAS require tests of controls be performed by an auditor? a. Significant weaknesses were found in the company’s internal control. b. The auditor hopes to reduce the amount of work to be done in assessing inherent risk. c. The auditor believes that testing the controls could lead to a reduction in overall audit

time and cost. d. Tests of controls are always performed when the auditor begins to assess control risk.

9.46 Which of the following management assertions is an auditor most likely testing if the audit objective states that all inventory on hand is reflected in the ending inventory balance? a. The entity has rights to the inventory. b. Inventory is properly valued. c. Inventory is properly presented in the financial statements. d. Inventory is complete.

(AICPA adapted)

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9.47 A portion of a client’s inventory is in public warehouses. Evidence of the existence of this merchandise can most efficiently be acquired through which of the following methods? a. Observation b. Confirmation c. Calculation d. Inspection

(AICPA adapted) 9.48 The purpose of tracing a sample of inventory tags to a client’s computerized listing of inven-

tory items is to determine whether the inventory items a. Represented by tags were included on the listing. b. Included on the listing were properly counted. c. Represented by tags were reduced to the lower of cost or market. d. Included in the listing were properly valued.

9.49 Which of the following results of analytical procedures would most likely indicate possible unrecorded inventory? a. Current ratio of 3:1 as compared to 5:1 for the prior period. b. Inventory turnover of 3.25 during the current year compared to 3.75 during the prior year. c. Inventory balance increase of 10% during the current period. d. Accounts payable turnover of 6 as compared with 8 for the prior period.

9.50 An auditor is testing internal controls in the manufacturing of a client’s inventory. Which of the following audit procedures, if used, should be combined with other audit procedures when testing the operating effectiveness of controls? a. Observation b. Inspection of documents c. Inquiry d. Reperformance

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All applicable Exercises and Problems are available with Connect.

Exercises and Problems 9.51 Internal Control Questionnaire Items: Possible Error or Fraud Due to Weakness. Refer

to the internal control questionnaire for the production cycle (Appendix Exhibit 9A.1) and assume that the answer to each question is “no.” Prepare a table matching questions to errors or frauds that could occur because of the absence of the control. Your column headings should be as follows:

Question Possible Error or Fraud Due to Weakness

9.52 Tests of Controls Related to Controls and Assertions. Each of the following tests of controls could be performed during the audit of the controls in the production cycle.

Required: For each procedure, identify (a) the internal control activity (strength) being tested and (b) the assertion(s) being addressed. 1. Balance and reconcile detailed production cost sheets to the work-in-process inventory

control account. 2. Scan closed production cost sheets for missing numbers in the sequence. 3. Vouch a sample of open and closed production cost sheet entries to (a) labor reports and

(b) issue forms and materials used reports. 4. Locate the material issue forms and determine whether they are (a) prenumbered, (b)

kept in a secure location, and (c) available to unauthorized persons. 5. Select several summary journal entries in the work-in-process inventory and (a) vouch

them to weekly labor and material reports and to production cost sheets and (b) trace them to the control account.

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6. Select a sample of the material issue forms in the production department file. Examine them for a. Issue date and materials used report date. b. Production order number. c. Floor supervisor’s signature or initials. d. Name and number of material. e. Raw material stores clerk’s signature or initials. f. Material requisition in raw material stores file, noting the date of requisition.

7. Determine by inquiry and inspection whether cost clerks review dates on reports of units completed for accounting in the proper period.

9.53 Cost Accounting Tests of Controls. The diagram that follows describes several cost accounting tests of controls. It shows the direction of the tests, leading from samples of cost accounting analyses, management reports, and the general ledger to blank squares.

Required: For each blank square in the diagram, write a cost accounting test of controls procedure and describe the evidence it can produce. (Hint: Refer to Exhibits 9.4 and 9.6.)

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Sample

Sample

Clock Cards

Cost Accounting Analyses

Management Reports

General LedgerPayrolls

Vouch Time

Trace

TraceReconcile

Vouch to Supporting Analyses

Sample

Diagram of Cost Accounting Tests of Controls

9.54 Inventory Count Observation: Planning and Substantive Procedures. Sammy Smith is the partner in charge of the audit of Blue Distributing Corporation, a wholesaler that owns one warehouse containing 80 percent of its inventory. Smith is reviewing the audit docu- mentation that was prepared to support the firm’s opinion on Blue’s financial statements and wants to be certain that essential audit procedures are well documented.

Required: a. What evidence should Smith expect to find indicating that the observation of the client’s

physical count of inventory was well planned and that assistants were properly supervised? b. What substantive procedures should Smith find in the audit documentation of manage-

ment’s balance assertions about existence and completeness of inventory quantities at the end of the year? (Refer to Appendix 9B for the audit plan’s procedures.)

(AICPA adapted) 9.55 Sales/Inventory Cutoff. Your client took a complete physical inventory count under your

observation as of December 15 and adjusted the inventory control account (perpetual inven- tory method) to agree with the physical inventory. After considering the count adjustments as of December 15 and after reviewing the transactions recorded from December 16 to Decem- ber 31, you are almost ready to accept the inventory balance as fairly stated. However, your review of the sales cutoff as of December 15 and December 31 disclosed the following items not previously considered:

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Sales Date

Cost Price Shipped Billed Credited to Inventory Control

$28,400 $36,900 12/14 12/16 12/16

39,100 50,200 12/10 12/19 12/10

18,900 21,300 1/2 12/31 12/31

Required: What adjusting journal entries, if any, would you make for each of these items? Explain why each adjustment is necessary.

(AICPA adapted) 9.56 Purchasing Cutoff. When tracing using the cutoff information from the December 31

inventory count of Thermo-Tempur Mattresses, you note the following information:

Receiving Report Number Date Received Total Cost

12/28 $12,433.61

1180 12/28 8,923.34

1181 12/29 15,448.22

1182 12/31 14,109.33

1183 12/31 11,482.57

1184 1/2 17,852.56

1185 1/3 8,753.95

The purchases list shows that the following items were recorded in December.

Receiving Report Number Date Received Total Cost

1179 12/28 $12,433.61

12/28 8,923.34

1181 12/29 15,448.22

1182 12/31 14,109.33

1184 1/2 17,852.56

The documentation indicates that the last receiving report included in the inventory count was Receiving Report 1182. Receiving Reports 1183 and 1184 were for goods received on the company’s truck but not unloaded. Receiving report 1185 was for goods received on January 3.

Required: Prepare a correcting journal entry assuming that Thermo-Tempur uses (a) a periodic inven- tory system and (b) a perpetual inventory system that was updated for the inventory count.

9.57 Statistical Sampling Used to Estimate Inventory. ACE Corporation does not conduct a complete annual physical count of purchased parts and supplies in its principal warehouse but uses statistical sampling to estimate the year-end inventory. ACE maintains a perpetual inventory record of parts and supplies. Management believes that statistical sampling is highly effective in determining inventory values and is sufficiently reliable, making a physi- cal count of each item of inventory unnecessary.

Required: a. List at least 10 normal audit procedures that should be performed to verify physical quan-

tities whenever a client conducts a periodic physical count of all or part of its inventory. (See Appendix Exhibit 9B.1 for procedures.)

b. Identify the audit procedures you should use that change or are in addition to normal required audit procedures [in addition to those listed in your solution to part (a)] when a client utilizes statistical sampling to determine inventory value and does not conduct a 100 percent annual physical count of inventory items.

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9.58 Inventory Procedures Using Computer-Assisted Audit Techniques (CAATs). You are conducting an audit of the financial statements of a wholesale cosmetics distributor with an inventory consisting of thousands of individual items. The distributor keeps its inventory in its own distribution center and in two public warehouses. A perpetual inventory computer database is maintained on a computer disk. The database is updated at the end of each busi- ness day. Each record of the perpetual inventory database contains the following data: Item number. Location of item. Description of item. Quantity on hand. Cost per item. Date of last purchase. Date of last sale. Quantity sold during year.

You are planning to observe the distributor’s physical count of inventories as of a given date. The client will provide a computer file of the preceding items taken from its database as of the date of the physical count. Your firm has a computer audit plan that will be ideal for analyzing the inventory records.

Required: List the basic inventory auditing procedures and, for each, describe how the use of CAATs and the computerized perpetual inventory database might be helpful to the auditor in perform- ing such auditing procedures. (See Appendix 9B for substantive procedures for inventory.)

Organize your answer as follows:

Basic Inventory Auditing Procedures How CAATs and Copy of the Inventory Data File Might Be Helpful

Conduct an observation of the company’s physical count.

Determine which items are to be test counted by selecting a random sample of a representative number of items from the inventory file as of the date of the physical count.

(AICPA adapted) 9.59 CAATs Application: Inventory. Your client, Boos & Becker Inc., is a medium-size manu-

facturer of products for the leisure-time activities market (camping equipment, scuba gear, bows and arrows, and the like). During the past year, a computer system was installed, and inventory records of finished goods and parts were converted to computerized processing. Each record of the inventory master file contains the following information: Item or part number. Description. Size. Quantity on hand. Cost per unit. Total value of inventory on hand at cost. Date of last sale or usage. Quantity used or sold this year. Reorder point (quantity). Economic order quantity. Code number of major vendor or code number of secondary vendor.

In preparation for year-end inventory, the client has two identical sets of preprinted inven- tory cards prepared from the master file. One set is for the client’s inventory counts, and the other is for your use to make audit test counts. The following information has been included on the preprinted cards: Item or part number. Description. Size. Unit of measure code.

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In taking the year-end count, the client’s personnel will write the actual counted quantity on the face of each card. When all counts are complete, the counted quantity will be pro- cessed against the master file, and quantity-on-hand figures will be adjusted to reflect the actual count. A computer list will be prepared to show any missing inventory count cards and all quantity adjustments of more than $100 in value. Client personnel will investigate these items and will make all required adjustments. When adjustments have been completed, the final year-end balances will be computed and posted to the general ledger.

Your firm has available an audit software package that will run on the client’s computer and can process both cards and disk master files.

Required: a. In general, and without regard to the preceding facts, discuss the nature of CAATs and

list the various audit uses of such packages. b. List and describe at least five ways CAATs can be used to assist in all aspects of the audit

of the inventory of Boos & Becker Inc. (For example, CAATs can be used to read the inventory master file and list items and parts with a high unit cost or total value. Such items can be included in the test counts to increase the dollar coverage of the audit verifi- cation.) (Hint: Think of the normal audit procedures in gathering evidence on inventory when the client makes a periodic count; then think of how these could help in this par- ticular client situation.)

(AICPA adapted) 9.60 Inventory Evidence and Long-Term Purchase Contracts. During the audit of Mason

Company Inc. for the calendar year 2014, you noted that the company produces aluminum cans at the rate of about 40 million units annually. On the plant tour, you noticed a large stockpile of raw aluminum in storage. Your inventory observation and pricing procedures showed this stockpile to be the raw materials inventory of 400 tons valued at $240,000 (LIFO cost). Inquiry with the production chief yielded the information that 400 tons was about a four-month supply of raw materials.

Suppose you learn that Mason had executed a firm long-term purchase contract with All Purpose Aluminum Company to purchase raw materials on the following schedule:

Delivery Date Quantity Total Price

January 30, 2013   500 $300,000

June 30, 2013   700 420,000

December 30, 2013 1,000 500,000

Because of recent economic conditions, principally a decline in the demand for raw alu- minum and a consequent oversupply, the price stood at 20 cents per pound as of January 15, 2015. Commodities experts predict that this low price will prevail for 12 to 15 months or until there is a general economic recovery.

Required: a. Describe the procedures you would employ to gather evidence about this contract (includ-

ing its initial discovery). b. What facts recited in the problem would you have to discover for yourself in an audit? c. Discuss the effect this contract has on the financial statements.

9.61 Tracing the Inventory Count. You have been assigned to trace the results of the observa- tion of Brightware China’s physical inventory count to its pricing and compilation. You note the following conditions. 1. The last inventory tag documented by Mark Hulse, the auditor who observed the inventory,

was 1732, but you notice a number of items with count ticket numbers higher than 1732. You contact the client’s controller, Marcia Vines, who tells you the client found a storage room full of a new product that Brightware had just produced and added it to the inventory.

2. The count tickets recorded by Hulse agree to the inventory list, but some of the other count tickets you select are substantially different from it. Vines tells you these are input errors and she will have them corrected.

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3. Hulse described several boxes of goods as being dusty and even broken. They are included in the inventory at cost. Vines’s explanation is that china never “goes bad” and the goods themselves were not broken.

Required: a. Prepare an audit plan for tracing the information from the inventory count to the

compilation. b. What might have caused the conditions you found? What effect might they have on the

financial statements? c. What steps will you take to follow up on Vines’s explanations?

9.62 FIFO Inventory Pricing. You are auditing Martha’s Prison Clothes Inc. as of December 31, 2014. The inventory for orange jumpsuits shows 1,263 suits at $782 for a total of $987,666. When you look at the invoices for the jumpsuits, you see the following:

Inventory Number Date Quantity Unit Price Total

12732 11/22/13 1,000 $765 $765,000

12844 12/03/13 800   777 621,600

12905 12/28/13 600   782 469,200

Required: a. Determine the adjusting entry, if any, for the cost of inventory at December 31, 2014. b. Would your answer to part (a) be different if you saw an invoice dated January 9, 2015,

for 500 suits at $750?

Instructions for Problems 9.61, 9.62, and 9.63 The cases in Problems 9.61, 9.62, and 9.63 are similar to the one in the chapter. They give the problem and the amount. Your assignment is to write the audit approach portion of the case organized around these sections: Objective. Express the objective in terms of the facts supposedly asserted in the financial records, accounts, and statements. Control. Write a brief explanation of desirable controls, missing controls, and especially the types of deviations that might arise from the situation described in the case. Tests of controls. Write some procedures for obtaining evidence about controls, especially procedures that could discover control deviations. If there are no controls to test, there are no procedures to perform; go to the next section. A procedure should instruct someone about the source(s) of evidence to tap and the work to do. Audit of balance. Write some procedures for obtaining evidence about the balance assertions of existence, rights and obligations, completeness, valuation, and accuracy identified in your objective section. Discovery summary. Write a short statement about the discovery you expect to accomplish with your procedures. Inventory and deferred cost overstatement. Follow the preceding instructions. Write the audit approach section following the cases in the chapter.

9.63 Toying around with the Numbers. Mattel Inc., a manufacturer of toys, failed to write off obsolete inventory, thereby overstating inventory and improperly deferred tooling costs, both of which understated cost of goods sold and overstated income.

“Excess” inventory was identified by comparing types of toys (wheels, general toys, dolls, and games), parts, and raw materials with the forecasted sales or usage; lower-of-cost- or-market (LCM) determinations then were made to calculate the obsolescence write-off. Obsolescence was expected and the target for the year was $700,000. The first comparison computer run showed $21 million “excess” inventory! The company “adjusted” the forecast by increasing the quantities of expected sales for many toy lines. (Forty percent of items had forecasted sales more than their actual recent sales.) Another “adjustment” was to fore- cast toy closeout sales not at reduced prices but at regular prices. In addition, certain parts were labeled “interchangeable” without the normal reference to a new toy product. These adjustments to the forecast reduced the excess inventory exposed to LCM valuation and

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write-off. The cost of setting up machines, preparing dies, and other preparations for manu- facture are tooling costs. They benefit the lifetime run of the toy manufactured. The com- pany capitalized them as prepaid expenses and amortized them in the ratio of current-year sales to expected product lifetime sales (much like a natural resource depletion calculation). To lower the amortization cost, the company transferred unamortized tooling costs from toys with low forecasted sales to ones with high forecasted sales. This caused the year’s amortiza- tion ratio to be lower, the calculated cost write-off lower, and the cost of goods sold lower than it should have been.

The computerized forecast runs of expected usage of interchangeable parts provided a space for a reference to the code number of the new toy where the part would be used. Some of these references contained the code number of the part itself, not a new toy. In other busi- ness cases, the forecast of toy sales and parts usage contained the quantity on hand, not a forecast number.

In the tooling cost detailed records, unamortized cost was classified by lines of toys (similar to classifying asset cost by asset name or description). Unamortized balances were carried forward to the next year. The company changed the classifications shown at the prior year-end to other toy lines that had no balances or different balances. In other words, the bal- ances of unamortized cost at the end of the prior year did not match the beginning balances of the current year except for the total prepaid expense amount.

For lack of obsolescence write-offs, inventory was overstated at $4 million. The company recorded a $700,000 obsolescence write-off. It should have been about $4.7 million, as later determined. The tooling cost manipulations overstated the prepaid expense by $3.6 million.

The company reported net income (after taxes) of $12.1 million in the year before the manipulations took place. If pretax income were in the $20 to $28 million range in the year of the misstatements, the obsolescence and tooling misstatements alone amounted to about 32 percent income overstatement.

9.64 No Defense for These Charges. Follow the instructions preceding Problem 9.61. Write the audit approach section following the case in the chapter.

SueCan Corporation manufactured electronic and other equipment for private customers and government defense contracts. It deferred costs under the heading of defense contract claims for reimbursement and deferred tooling labor costs, thus overstating assets, understat- ing cost of goods sold, and overstating income.

Near the end of the year, the company used a journal entry to remove $110,000 from cost of goods sold and defer it as deferred tooling cost. This $110,000 was purported to be labor cost associated with preparing tools and dies for large production runs.

The company opened a receivables account for “cost overrun reimbursement receivable” as a claim for reimbursement on defense contracts ($378,000).

The company altered the labor time records for the tooling costs in an effort to provide substantiating documentation. Company employees prepared new work orders numbered in the series used late in the fiscal year and attached labor time records dated much earlier in the year. The production orders originally charged with the labor cost were left completed but with no labor charges!

The claim for reimbursement on defense contracts did not have documentation specifi- cally identifying the labor costs as being related to the contract. There were no work orders. (Auditors know that Defense Department auditors insist on documentation and justification before approving such a claim.)

SueCan reported net income of about $442,000 for the year, an overstatement of approxi- mately 60 percent.

9.65 Chips Ahoy. Follow the instructions preceding Problem 9.61. Write the audit approach sec- tion following the cases in the chapter.

The following is an excerpt from an article, “Memory Chip Trader Gets 14 Years for Bank Fraud,” The Straits Times (Singapore), February 13, 2009:

Through most of the 1990s, entrepreneur Kelvin Ang Ah Peng rode the crest of a wave as his company traded in memory chips and recycled used ones for sale at a good price. His story, which follows the ebb and flow of the integrated circuit (IC) chip business, started at EC–Asia International (ECI) in 1993. Computer chips were expensive, so his business did well. A major earthquake in Taiwan in 1999 totaled the computer chip factories there. Production halted and the market price of computer chips soared even higher. The bubble

LO 9-7

LO 9-7

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burst the following year, when the Taiwan factories recovered and several computer chip businesses folded. In 2001, as ECI struggled to keep afloat, Ang started abusing its credit facilities. Between that year and early 2007, he bought and sold worthless memory chips and created fake orders and invoices to receive payment from banks.

He was charged in October 2008 on 687 charges involving US$290 million; last month, he pleaded guilty to 30 charges—28 for cheating and 2 for money laundering and falsify- ing revenues in ECI’s initial public offering (IPO) prospectus. Deputy Public Prosecutor David Chew Siong Tai said that, to secure credit in the absence of incoming orders, Ang fashioned an elaborate scheme with the help of Hong Kong firms. He got ECI’s partners to issue the necessary trade documents and to circulate computer chips and money between Hong Kong and Singapore. Chips were actually shipped in these sham transactions as if they were bona fide trades. In reality these were worthless, defective chips due for scrapping by ECI. In November 2006 when asked about ECI’s unusually large inventory in Hong Kong and the huge debts owed by the firm’s Hong Kong “customers,” Ang confessed to an ECI subsidiary’s director that 90 percent of the inventory did not exist and that its billings were all faked.

Yesterday, Ang, 44, was jailed for 14 years for having swindled banks of US$23 million (US$35 million) and laundering these proceeds through Hong Kong. The Australian-listed ECI is now being liquidated, and Ang was declared bankrupt last year.

9.66 Detection of Errors and Fraud. For each of the following independent events, indicate the (1) effect of the error or fraud on the financial statements and (2) what auditing procedures could have detected the misstatement resulting from error or fraud.

a. The physical inventory count of J. Payne Enterprises, which has a December 31 year-end, was conducted on August 31 without incident. In September, the perpetual inventory was not reduced for the cost of sales.

b. Holmes Drug Stores counted its inventory on December 31, which is its fiscal year-end. The auditors observed the count at 20 of Holmes’s 86 locations. The company falsified the inventory at 20 of the locations not visited by the auditors by including fictitious goods in the counts.

c. Pope Automotive inadvertently included in its inventory automobiles that it was holding on consignment for other dealers.

d. Peffer Electronics Inc. overstated its inventory by pricing wiring at $200 per hundred feet instead of $200 per thousand feet.

e. Goldman Sporting Goods counted boxes of baseballs as having one dozen baseballs per box when they had only six per box.

9.67 Identifying Obsolete Inventory and Proposing Provisions For this exercise, your client, BrightIDEAs Inc., has provided you with a listing of inven- tory on hand as of the end of the year. You have been assigned the task of performing pro- cedures to identify unusual or potentially obsolete inventory items and propose a valuation allowance.

Required: a. Import the client’s database of inventory and reconcile it to the general ledger (pp. 193–202

of the IDEA Workbook). b. Use data extraction techniques to identify client-identified obsolete inventory items in

the client’s inventory listing or items showing negative amounts or quantities (pp. 203– 206 of the IDEA Workbook).

c. Calculate inventory usage ratios to identify inventory items not flagged by the client that may nonetheless be obsolete. (pp. 206–213 of the IDEA Workbook).

d. Use your calculations from the above steps to estimate a provision for obsolete inventory. (pp. 214–218 of the IDEA Workbook).

e. Do you consider the difference between what the client proposed and your proposed pro- vision to be a material difference?

Required Data available on Connect ∙ Inventory 2015.asc

LO 9-7

LO 9-7

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Applying IDEA to the Production Cycle—Elm Manufacturing Company Exercises 9.64–9.66 require the application of IDEA in the production cycle audit in summa- rizing client data and recalculating inventory balances using client records. Elm Manufactur- ing Company (ELM) is a small manufacturer of backpacks located in Rochelle, Illinois. You have access to ELM’s electronic records on Connect. The appropriate files for these exercises are the Sales 2017 4th Q data set, the Purchases 2017-4th Q data set, the Inventory Count data set, the Ending Inventory Balances 2017-3rd Q data set, the Finished Goods Production 2017-4th Q data set, the Production Bill of Raw Materials data set, and the Combined Mate- rials and Supplies Vendor Price List data set. You will also require the 2017 ELM Production Cycle Supplementary Information document. Detailed information about ELM, instructions for accessing data sets, and a data directory for data sets can be found on Connect.

9.68 Inventory Fraud and Detection Issues You are auditing the financial statements of Holly’s Happenin’ Hula Hoops Club (4H Club). Unbeknownst to you as the auditor, there is a fraud being committed related to the inventory account. For the fraud described below, specifically list a) the assertion about the inventory account that is violated, b) a control procedure the client should have had in place that could have potentially prevented the fraud, and c) an audit procedure that you would likely per- form during the audit of inventory that would detect the fraud.

Each month, an employee in the receiving department submits a fictitious receiving report to accounting. A few days later, he sends the 4H Club an invoice for the quantity of goods ordered from a small company he owns and operates. The invoice is always paid when the accounts payable clerk matches the receiving report with the vendor’s invoice.

Required: i. Inventory Assertion Violated: ii. Control procedure to prevent: iii. Audit procedure to detect:

9.69 Substantive Testing of Inventory Variances An auditor observed Bizarre Costume Shop’s physical inventory count on the last day of the client’s fiscal year, October 31, 2020. In addition to being somewhat disturbed by the costumes, the auditors identified several variances in the test counts relative to the client’s recorded inventory. Through inquiry, YBBD obtained explanations from the client’s management.

Required: For each variance listed and client response, select the audit response the auditor would most likely make from the list of possible responses. Each response may be used once, more than once, or not at all. Write only the letter of the response in the space provided.

Possible audit responses: a. Inspect supporting documents and agree quantities received to purchase order. b. Inspect supporting purchase documents for proper shipping terms and receiving informa-

tion to verify exclusion from inventory count. c. Inspect supporting purchase documents for proper shipping terms and receiving informa-

tion to verify inclusion in inventory count. d. Inspect supporting sale and shipment documentation for proper shipping terms for exclu-

sion in inventory count. e. Inspect supporting sale and shipment documentation for proper shipping terms for inclu-

sion in inventory count. f. Request that client make appropriate correction to record additional inventory. g. Request that client make appropriate correction to reduce inventory.

LO 9-2, 9.4, 9.6

LO 9-6

Test Count number

Inventory Item Recorded Inventory Quantity

Auditor’s Test Count

Variance Client Explanation Auditor Response (letter)

1 SpiderHorse 175 125 (50) Inventory in transit shipped f.o.b. shipping point; received 11/2/2020

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2 Unibrow Man 850 715 (135) Inventory sold to customer f.o.b. destination; not received by customer until 11/2/2020

3 Werewolf WonderWoman

200 225 25 Sale recorded based on customer request to hold items. Customer has not paid or picked items up yet.

4 Hairy Potter 455 500 45 Inventory received 10/30/2020; vendor shipment receipt not recorded.

5 Rainbow Unicorn

650 550 (100) Inventory was separated for an 11/1/2020 sale; held on dock for customer pickup.

9.70 Summarizing Direct Materials Production Costs Using IDEA. ELM reports that the following is the total cost for each product:

Product Direct material Direct Labor Overhead* Total Cost

SP001 $ 5.91 $ 1.99 $ 0.16 $ 8.06

HB005 $ 13.40 $ 4.96 $ 0.40 $ 18.76

CB008 $ 56.39 $ 8.11 $ 0.65 $ 65.15 *Overhead is allocated at 8% of direct labor costs (rounded)

Required: Assume that the cost of Direct Labor and Overhead has been separately verified. Use the Bill of Materials and the Materials Unit Cost sheet to recalculate the Direct Materials cost per unit for the three products. Do you find any differences in calculated materials costs?

9.71 Summarizing Finished Goods Quantities Using IDEA You have been assigned the task of recalculating the client’s Finished Goods ending inven- tory quantity based on sales and manufacturing records and comparing it to the year-end inventory count. You may assume there is no Work-in-Process inventory as of year-end.

Required: a. Perform an inventory roll-forward and calculate the total year end quantity for each of the

three items in Finished Goods inventory (Hints: Beginning Balance + Finished Goods Manufactured – Sales = Ending Balance. Don’t forget that you should only consider sales that have shipped during the quarter and that the company sells products in cases of 12. You may assume there were no shipments of outstanding orders from prior quarters.).

b. Compare the ending inventory balances from part a. to the quantity based on the year-end inventory count. Are there any significant discrepancies between the calculated ending inventory and the inventory counts?

c. What are some of the reasons that could cause these discrepancies? How would you resolve these issues?

d. What would you propose as the final inventory quantity?

LO 9-7

LO 9-7

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9.72 Summarizing Raw Materials Quantities Using IDEA You have been assigned the task of recalculating the client’s Raw Materials ending inven- tory quantity based on purchase and manufacturing records and comparing it to the year-end inventory count. You may assume there is no Work-in-Process inventory as of year-end.

Required: a. Calculate the total year end quantity for Raw Materials Inventory (Hint: Beginning

Balance + Purchases – Used in Production = Ending Balance. Don’t forget that you should only include purchases that have been received in calculating purchases. Column “TYPE” in 3rd q inventory database will be helpful for extracting relevant records.)

b. Are there any significant discrepancies between the calculated ending inventory and the inventory counts? Identify possible reasons for such discrepancies.

c. How would you proceed to resolve these issues? d. What would you propose as the final raw materials inventory quantity?

9.73 Testing Supplies Inventory and Expense Using IDEA You have been assigned the task of testing the client’s Supplies Expense based on purchase records and the year-end inventory count. ELM’s unaudited Trial Balance shows a recorded amount of $33,650 for Supplies Expense during the 4th quarter. Per the client, Supplies Expense consists of the all supplies indirectly used in the factory, but which do not get included in the cost of the manufacturing process. These products are all inventory units beginning with E, Q, or J. Assume that the cost of supplies remained constant throughout the quarter.

Required: a. Using the information given about beginning balances, purchases, ending counts, and the

vendor price list, recalculate Supplies Expense. For the purposes of this exercise, ignore any taxes or shipping charges and base costs solely on the price list.

b. Does ELM’s recorded Supplies Expense appear reasonable? Would the auditor perform any further detail testing on Supplies Expense? Explain your reasoning.

LO 9-7

LO 9-7

Apollo Shoes Inventory Audit You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Water- shed and have been assigned to the engagement team of a new audit client, Apollo Shoes Inc. You have been asked to perform substantive procedures related to the audit of inven- tory. As part of your audit you will evaluate documents such as inventory observation memos, count sheets, and purchase invoices. Detailed instructions, as well as the working papers and supporting documents, can be found in Connect.

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APPENDIX EXHIBIT 9A.1 Production Cycle

Occurrence 1. Is cost accounting separate from production, payroll, and inventory control? 2. Is access to blank production order forms restricted to authorized persons? 3. Is access to blank bills of materials and labor needs forms restricted to authorized persons? 4. Is access to blank material requisition forms restricted to authorized persons? 5. Are production orders prepared by authorized persons? 6. Are bills of materials and labor needs prepared by authorized persons? 7. Are material usage reports compared to raw material stores issue forms? 8. Are labor usage reports compared to job time tickets? 9. Are material requisitions and job time tickets reviewed by the production supervisor after the floor

supervisor prepares them? 10. Are the weekly direct labor and materials used reports reviewed by the production supervisor after

preparation by the floor supervisor? Completeness 1. Are production orders prenumbered and the numerical sequence checked for missing documents? 2. Are bills of materials and labor needs forms prenumbered and the numerical sequence checked for

missing documents? 3. Are material requisitions and job time tickets prenumbered and the numerical sequence checked for

missing documents? 4. Are inventory issue forms prenumbered and the numerical sequence checked for missing

documents? 5. Is accounting notified of terms on purchase agreements? 6. Is accounting notified of orders received on consignment? Accuracy 1. Are differences between inventory issue forms and materials used reports recorded and reported to

the cost accounting supervisor? 2. Are differences between job time tickets and the labor report recorded and reported to the cost

accounting supervisor? 3. Are standard costs used? If so, are they reviewed and revised periodically? 4. Are reports for materials issued to production reconciled with finished goods reports? Cutoff 1. Does the accounting manual give instructions to date cost entries on the date of use? 2. Does an accounting supervisor review monthly, quarterly, and year-end cost accruals? Classification 1. Are summary entries reviewed and approved by the cost accounting supervisor? 2. Does the accounting manual give instructions for proper classification of cost accounting

transactions?

Yes/No Comment

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Internal Control Questionnaires

Appendix 9A

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APPENDIX EXHIBIT 9A.2 Inventory Transaction Processing

Yes/No Comment

Occurrence 1. Are perpetual inventory records kept for raw materials? Supplies? Work-in-process? Finished goods? 2. Is merchandise or materials held on consignment (not the property of the company) physically

segregated from goods owned by the company? 3. Are additions to inventory quantity records made only on receipt of a receiving report copy? 4. Do inventory custodians notify inventory record keepers of reductions of inventory? Completeness 1. Are reductions of inventory record quantities made only on receipt of inventory issuance documents? 2. Do inventory custodians notify the records department of additions to inventory? 3. Are separate records maintained for consignment inventory? Accuracy

1. Are perpetual records reconciled to general ledger control accounts? 2. Do the perpetual records show both quantities and prices? 3. Are inventory records maintained by someone other than the inventory stores custodian? 4. Are the inventory records compared to physical counts? 5. Are production reports of material and labor prepared weekly and transmitted to cost accounting? 6. Are job cost sheets posted weekly and summary journal entries of work-in-process and work

completed prepared monthly? 7. Are job cost sheet entries reviewed by a person independent of the preparer? 8. If standard costs have been used for inventory pricing, have they been reviewed for reasonableness

and current applicability? 9. Is there a periodic review for overstocked, slow-moving, or obsolete inventory? Have any adjustments

been made during the year? 10. Are periodic counts of physical inventory made to correct errors in the individual perpetual records? Cutoff 1. Does the accounting manual give instructions to record inventory additions on the date of the

receiving report? 2. Does the accounting manual give instructions to record inventory issues on the issuance date? Classification 1. Are perpetual inventory records kept in dollars periodically reconciled to general ledger control

accounts?

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Audit Plans

Appendix 9B

APPENDIX EXHIBIT 9B.1

DUNDER-MIFFLIN, INC Audit Plan for Physical Inventory Observation

December 31, 2017

Performed by Ref.

1. Obtain client’s inventory-counting instructions and review for completeness. 2. Tour facility before the inventory count looking for out-of-the-way items, obsolete items, and patterns of

inventory flow. 3. Observe client personnel taking inventory counts for compliance with instructions. 4. Test count a selection of items throughout the facility, and record a sample of your test counts. Note

description, stage of completion, counting unit, and condition. 5. Obtain and record tag numbers used and ensure all tag numbers are accounted for. 6. Select sample of used tags and trace them to the items on the floor. 7. Record the last five receiving reports and last five shipping documents and the numbers of next five unused

items in sequence. Vouch the recorded items to inventory count to determine that the item was appropriately included (or excluded) from the inventory count.

8. Tour facilities to ensure all items have been counted.

APPENDIX EXHIBIT 9B.2

DUNDER-MIFFLIN, INC Audit Plan for Inventory Observation and Cost of Goods Sold

December 31, 2017

Performed by Ref.

Inventory 1. Obtain client’s inventory list, recalculate, and check it against the general ledger. 2. Trace test counts from inventory observation to the final inventory compilation. 3. Select a sample of inventory items.

a. Vouch unit prices to vendors’ invoices or other cost records. b. Recalculate the inventory valuation for sampled items.

4. Scan the inventory compilation for items added from sources other than the physical count and items that appear to be large round numbers or systematic fictitious additions.

5. Recalculate the extensions and footings of the final inventory compilation for mathematical accuracy. Reconcile the total to the adjusted trial balance.

6. For selected inventory items and categories, determine the replacement cost and the applicability of lower-of-cost-or-NRV valuation.

7. Inspect inventory for evidence of obsolete or damaged goods. Trace identified obsolete or damaged goods to inventory records for write-down.

8. Inquire about obsolete, damaged, slow-moving, and overstocked inventory. 9. Scan the perpetual records for slow-moving items.

10. During the physical observation, be alert to notice damaged or scrap inventory. 11. Compare the list of obsolete, slow-moving, damaged, or unsalable inventory from last-year’s audit to the

current inventory compilation. 12. At year-end, identify the numbers of the last shipping and receiving documents for the year. Compare

these to the sales, inventory/cost of sales, and accounts payable entries for proper cutoff. 13. Read bank confirmations, debt agreements, and minutes of the board and make inquiries about pledge or

assignment of inventory to secure debt. 14. Inquire about inventory held by third parties on consignment and inventory on hand on consignment from

vendors.

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DUNDER-MIFFLIN, INC Audit Plan for Inventory Observation and Cost of Goods Sold

December 31, 2017

Performed by Ref.

15. Confirm or inspect inventories held in public warehouses. 16. Recalculate the amount of intercompany profit to be eliminated in consolidation. 17. Obtain management representations concerning pledging of inventory as collateral, intercompany sales,

and other related-party transactions. Cost of Sales 1. Select a sample of recorded cost of sales entries and vouch to supporting documentation. 2. Select a sample of basic transaction documents (such as sales invoices, production reports) and determine

whether the related cost of goods sold was figured and recorded properly. 3. Review the accounting costing method used by the client (such as FIFO, LIFO, standard cost) for proper

application. 4. Compute the gross margin rate and compare to prior years. 5. Compute the ratio of cost elements (such as labor, material) to total cost of goods sold and compare this

ratio to that for prior years.

APPENDIX EXHIBIT 9B.2 (concluded)

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LEARNING OBJECTIVES The finance and investment cycle consists of planning for capital requirements and raising the required money by borrowing, selling stock, and entering into acquisitions and joint ventures. The finance part of the cycle involves obtaining money through stock or debt issues. The investment portion of the cycle encompasses using the funds for investments in property, plant, and equipment (covered in the acquisition and expenditure cycle in Chapter 8); marketable securities; joint ventures and partnerships; and subsidiaries. The transactions discussed in this chapter generally involve large dollar amounts and occur relatively infrequently. They can involve complex accounting issues and generally

receive significant attention from management, the board of directors, and the auditors. The audit approach often differs significantly compared with auditing the operating cycle.

Your objectives are to be able to:

LO 10-1 Describe the finance and investment cycle, including typical source documents.

LO 10-2 Identify significant accounts and relevant assertions related to the finance and investment cycle.

LO 10-3 Discuss the risk of material misstatement in the finance and investment cycle, with a specific focus on improper valuation and disclosure.

LO 10-4 Identify important internal control activities present in a properly designed system to

Daniel Webster, American statesman, lawyer, and orator (1782–1852)

Credit has done a thousand times more to enrich mankind than all the

goldmines in the world. It has exalted labor, stimulated manufacture,

and pushed commerce over every sea.

Finance and Investment Cycle

C H A P T E R 1 0

Professional Standards References

Topic AU-C/ISA Section

PCAOB Reference

Audit Evidence—Specific Consideration for Selected Items 501

External Confirmations 505 AS 2310

Analytical Procedures 520 AS 2305

Auditing Accounting Estimates, including Fair Value Measurements

540 AS 2501

Related Parties 550 AS 2410

Using the Work of an Audit Specialist 620 AS 1210

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mitigate the risk of material misstatements for each relevant assertion in the finance and investment cycle.

LO 10-5 Give examples of tests of controls to test the operating effectiveness of internal controls in the finance and investment cycle.

LO 10-6 Give examples of substantive procedures in the finance and investment cycle and relate them to assertions about significant account balances at the end of the period.

LO 10-7 Apply your knowledge to perform audit pro- cedures in the finance and investment cycle and evaluate the findings of your tests.

INTRODUCTION On August 15, 2019, Harry Markopolos, a fraud investigator best known as the whistle- blower in Bernie Madoff’s $65 billion Ponzi scheme, issued a 175-page report accusing General Electric (GE) of committing a $38 billion fraud in its financial statements. GE stock plummeted by nearly $8 billion. Nearly all of Markopolos’s accusations involved accounting for estimates, many involving reserves for long-term insurance contracts. Markopolos referred to “discovery of an Enronesque business approach that has left GE on the verge of insolvency.” GE’s executives responded immediately that Markopolos was wrong, putting their money on their company—investing heavily in the declining stock. Surely, KPMG, the auditors for GE, took notice of the accusations because valu- ation of financial assets and liabilities is an area ripe with risk. Perhaps by the time you read this, it will be more clear whether GE did anything wrong. However, the immediate reactions by the executives and stock markets demonstrated two clear points relevant to auditors: (1) Accounting for estimates and fair values are often material and risky, (2) No one wants to hear their name and a comparison to Enron in the same sentence.

Enron used hundreds of off-the-book arrangements known as special-purpose entities (SPEs) ostensibly to create joint ventures for new businesses such as energy trading and on-demand movies. (The company created so many SPEs that officers named them after Star Wars characters [Chewco and Jedi], animals [raptors and bobcats], and even officers’ children.) In fact, however, they were used to enrich company officers and hide more than $1 billion of debt from the company’s creditors, investors, and auditors. Rather than vehi- cles to fund expansion into new innovative markets, the SPEs essentially hid the problems facing the company. Many of the SPEs were financed by pledges of Enron stock as col- lateral, and their viability depended on the company’s stock price. When the company’s stock started to fall, the SPEs collapsed. When the firm’s stock price dropped from $80 to less than $1 in less than a year, millions of investors suffered losses, and thousands of current and former company employees had their retirement plans wiped out. The restate- ment of the company’s financial statements totaled $586 million. Although Andersen’s obstruction of justice conviction for shredding Enron audit documentation was later over- turned by the U.S. Supreme Court, the 86,000-employee accounting firm had been ruined.

Enron appeared to be a spectacular, greatly successful business; therefore, the audit failure captured the attention of the country, and when you hear the name you prob- ably immediately think “failure.” However, hidden behind all of the headlines was the enormous difficulty the auditors faced in unraveling Enron’s complex financing arrange- ments. Enron management had paid millions of dollars to Wall Street firms to design the SPEs so that they could be kept off the balance sheet. Early knowledge of the extent of Enron’s deception might have caused its auditors to insist on consolidating the SPEs on Enron’s books and, thereby, might have saved Andersen.

It is very likely KPMG already considered the issues brought up in the GE Markopo- los report. Perhaps the auditors collected sufficient, appropriate evidence to support the GAAP valuation presented in the financial statements. Because of the inherent uncer- tainty and measurement error in estimates of this type, it may be very hard to tell ex-post.

However, these two examples illustrate the potential size and complexity of trans- actions in the finance and investment cycle. Transactions in this cycle are much less frequent than in the other cycles; however, they tend to be large and complex. Thus, the

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focus of control activities is on the authorization of transactions and making sure that the client has competent accounting personnel who can understand the transactions and related accounting standards. Further, because management is so closely involved in these transactions, it is critical that the audit committee, the board of directors, and often third parties are involved to maintain control over management. In addition, many assets in this cycle, such as leases, hedges, and investments, are difficult to value. Use of profes- sional judgment in determining the fair market value (FMV) of these items is difficult and inherently risky for the auditor. Auditors must examine with professional skepticism all aspects of the transactions in the finance and investment cycle, but the focus of substan- tive procedures is gaining an understanding of the significant transactions, verifying the amounts and calculations, determining FMV on certain assets, and ensuring proper pre- sentation and disclosure. Finance and investment cycle transactions have become a lead- ing cause of recent financial statement restatements, and many of these issues have led to the creation of both new auditing standards on auditing fair values and new accounting standards on derivative securities, leases, and insurance contracts. Some of the largest financing and investment cycle restatements are described in Exhibit 10.1.

EXHIBIT 10.1 Finance and Investment Shenanigans

Company Cause of Misstatement Amount

Bernard Madoff Investments

Extensive Ponzi scheme used to defraud thousands of investors, including individuals, charities, and pension funds.

$65.0 billion

Lehman Brothers The company overstated fair values, and also created improper “repo” transactions, which enabled them to keep debt off the books and appear financially stronger than competition.

$50+ billion

Freddie Mac The mortgage lending giant used improper accounting techniques and financial transactions structured to push unwanted earnings into the future and hide gains senior management thought would make the entity appear too volatile.

$4.5 billion

AIG The insurance giant hid deferred compensation that some executives received through an investment entity, Starr International Co., with long ties to AIG. AIG disclosed the amounts in prior filings but did not run the cost through its financial statements, as it now admits it should have. In addition, the company had problems with accounting for investments by AIG’s subsidiaries in synthetic-fuel production facilities. These facilities wrongly booked tax credits from the investments as net investment income or other revenue when it should have used them to reduce tax expenses and accounted for syndication transactions from low-cost housing as sales, boosting net income by $209 million over five years.

$2.7 billion

El Paso The energy company used improper hedges of anticipated natural gas production. $2.4 billion

Tyco Most of the substantive accounting changes centered on $50.6 million in pretax credits that it took to reverse merger reserves set up in prior periods but never used. The SEC said the reserves either should never have been set up or should have been reversed earlier. Additionally, a subsidiary, ADT, improperly carried canceled alarm accounts on its books. Other issues were included in the final total.

$1.15 billion

Goodyear Tire Company

The company changed the way it accounted for income taxes and the costs of retirees’ health and life insurance benefits.

$1.03 billion

General Electric The company misapplied a rule on how to account for certain derivative deals. $460 million

Millennium Chemicals

The company changed the accounting treatment on a five-year agreement for its requirements for gold used for production of acetyls that should have been accounted for as a secured financing lease rather than as an operating lease, underestimated the obligation due to its largest domestic pension plan, and understated deferred taxes.

$400 million

Xerox Over a period of years, several senior managers in Mexico collaborated to circumvent Xerox’s accounting policies and administrative procedures. The restatement related to uncollectible long- term receivables; a failure to record liabilities for amounts due to concessionaires; and, to a lesser extent, for contracts that did not fully meet the requirements to be recorded as sales-type leases.

$207 million

Continued

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FINANCE AND INVESTMENT CYCLE: TYPICAL ACTIVITIES The finance and investment cycle contains a large number of accounts and records rang- ing across tangible (e.g., property, plant, and equipment [PP&E], investment securities) and intangible assets (e.g., goodwill, patents), long-term liabilities, deferred credits, stockholders’ equity, gains and losses, expenses, and income taxes. See Exhibit 10.2 for a list of the major accounts and records. These include some of the more complicated topics in accounting: equity method accounting for investments, consolidation account- ing, goodwill, income taxes, and derivatives, to name a few. The purpose of this chapter is to focus on the auditing issues associated with each of these accounting topics, not to explain how to account for these balances and transactions. Further, we will focus on the more general characteristics of assets, liabilities, and equity accounts in this cycle.

You may recall that an entity’s operations and accounting records consist of rou- tine transactions, nonroutine transactions, and accounting estimates. Auditors typically

LO 10-1 Describe the finance and investment cycle, including typical source documents.

Company Cause of Misstatement Amount

Gap Inc. The popular clothier used improper lease accounting related to accounting for rent holidays and tenant allowances.

$200 million

Nikko Cordial The company falsified information on the timing of a derivative deal. $119 million

Provident Financial Group

Auto leases were reported off the company’s balance sheet as sale and leasebacks of operating leases, but after a review, the company determined that none of the transactions should have been recorded that way. Instead, they should have been recorded as financing leases with all assets and liabilities appearing on the company’s balance sheet.

$114.7 million

Start Here

Cash Flow Forecast

Capital Budget

Acquisition and Expenditure Cycle

Purchase Resources: Inventory, Expenses, Equipment

Production and Payroll Cycle

Convert Resources into Products and Services

Revenue and Collection Cycle

Deliver Goods and Services, Bill Customers, Collect

3

2

1

Invest Excess Funds Financial Planning

Sell Stock or Borrow Money

Relations with Financial Institutions and Public Securities Markets

Accounts/Records

Capital Stock Paid-in Capital Dividends Bonds, Notes Payable Interest Expense Income Tax Expense, Deferred Taxes Financial Instruments SEC Securities Registration

Mergers and Acquisitions

Accounts/Records

Consolidations Goodwill Intangibles Deferred Charges

Accounts/Records

Marketable Securities Long-Term Investments Joint Ventures Advances to Subsidiaries Equity Method Investments Gains and Losses Deferred Gains and Losses Property, Plant, and Equipment

EXHIBIT 10.2 Finance and Investment Cycle

EXHIBIT 10.1 Finance and Investment Shenanigans (Concluded)

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approach audits of routine transactions with a reliance approach—evaluate internal con- trols and rely on the operation of controls found to be in place. In contrast, audits of nonroutine transactions generally take a substantive approach. In the large majority of audits that do not require an audit of internal controls, auditors may do very few tests of controls related to nonroutine transactions and rely on substantive tests. Similarly, audi- tors apply a more substantive approach with accounting estimates. Because the financing and investment cycle generally involves large, infrequent, significant transactions—often with some degree of estimation—auditors usually employ more substantive testing pro- cedures in this cycle and rely less on tests of controls.

Exhibit 10.2 is an illustration of the finance and investment cycle, which interacts with all of the other cycles. Its major functions are financial planning; raising capital; and entering into mergers, acquisitions, and other investments. As you follow the exhibit, you can use the numbers to track the elements of internal control described in the following sections.

Financing the Entity through Debt and Stockholder Equity Transactions in debt and stockholder equity are normally few in number but large in mon- etary amount, and with a high level of management involvement. The highest levels of corporate governance authorize and execute these transactions. The control-related duties and responsibilities reflect this high-level attention.

Financial Planning 1 The purpose of financial planning is to ensure that the entity has enough cash to operate the business. Entities can fund capital needs through their operations, but any additional needs must be fulfilled through financing activities. Financial planning starts with the cash flow forecast by the chief financial officer (CFO). This forecast informs the board of directors and management of the business plans, the prospects for cash inflows, and the needs for cash outflows. The cash flow forecast usually is integrated with the capital budget, which contains the plans for asset purchases and business acquisitions. A capital budget approved by the board of directors constitutes the authorization for major capital asset acquisitions (acquisition cycle) and investments. Cash flow planning and capital budgeting are important controls over major management decisions.

Raising Capital 2 The board of directors usually authorizes sales of capital stock and debt financing trans- actions. All directors must sign registration documents for public securities offerings. However, authority normally is delegated to the CFO or treasurer to complete other sig- nificant transactions (e.g., periodic renewals of notes payable and other ordinary types of significant financing transactions without specific board approval of each transaction). Auditors should expect to find the authorizing signatures of the CEO, CFO, treasurer, chair of the board of directors, and perhaps other high-ranking officers on financing documents. Because financing transactions are typically authorized and executed by top management and directors, it is much more difficult to rely on segregation of duties to ensure that these transactions flow properly through the accounting system using only internal employees. As a result, most entities rely on external parties to process debt and equity transactions involving multiple investors.

Company bonds and stocks are normally handled by an intermediary called a transfer agent, generally a bank or trust company. The transfer agent tracks securities’ owners for payment of interest or dividends. The certificate records are kept by a registrar who updates the records based on information from the transfer agent. Often, the registrar and transfer agent are the same company.

In the past, many financing transactions have been off the balance sheet. Companies entered into obligations and commitments that did not require entries in the accounting system. Examples of transactions that did not necessitate reporting on the balance sheet

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include operating leases and endorsements on discounted notes or on other companies’ obligations, letters of credit, guarantees, repurchase or remarketing agreements, commit- ments to purchase at fixed prices, commitments to sell at fixed prices, and certain kinds of stock options. As noted previously, the Enron debacle was a case of using SPEs to keep certain large transactions off the company’s balance sheet. Off-balance-sheet transactions often cause problems in financial reporting and disclosure. Although new accounting standards will reduce the number of off-balance-sheet transactions (e.g., new rules make it harder to create SPEs and have mandated more disclosure), auditors must still be aware of their existence and ensure their proper use and adequate disclosure. Because of the complexity of the transactions, often the most difficult task for the auditor is discovery and understanding of the transactions.

Record Keeping for Long-Term Liabilities The accounting department and the CFO or controller maintain records of notes and bonds payable. The record-keeping procedures should be similar to those used to account for vendor accounts payable: comparing payment notices from lenders to the accounting records, monitoring due dates, setting up interest in vouchers for payment, and making accruals for unpaid interest on financial reporting dates. If the company has only a few bonds and notes outstanding, it usually does not keep subsidiary records of them. All information is in the general ledger accounts. However, many large companies, especially in industries such as utilities, have large numbers of bonds and notes and may keep con- trol and subsidiary accounts as is done for accounts payable. Exhibit 10.3 shows selected debentures of Consolidated Edison Inc. as disclosed in its 2018 financial statements. With 45 debentures totaling $15.5 billion as of the end of 2018, record keeping and audit- ing records represent a formidable task. But add to this eight additional tax-exempt items, and the total debt exceeds $18 billion. Also, when all or parts of the notes become due within the next year, the CFO and controller must have the necessary information for properly classifying current and long-term amounts. As shown in Exhibit 10.3, long-term debt accounts for over half of Consolidated Edison Inc.’s total capitalization, making this a significant audit issue.

EXHIBIT 10.3 Consolidated Edison Inc. 2018 Financial Statements

Consolidated Edison, Inc. Consolidated Statement of Capitalization

LONG-TERM DEBT (Millions of Dollars) At December 31,

Maturity Interest Rate Series 2018 2017

DEBENTURES:

2019 6.65 2009B 475 475

2020 4.45 2010A 350 350

2024 3.30 2014B 250 250

2033 5.875 2003A 175 175

2033 5.10 2003C 200 200

2034 5.70 2004B 200 200

2035 5.30 2005A 350 350

2035 5.25 2005B 125 125

2036 5.85 2006A 400 400

2036 6.20 2006B 400 400

Continued

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Consolidated Edison, Inc. Consolidated Statement of Capitalization

LONG-TERM DEBT (Millions of Dollars) At December 31,

Maturity Interest Rate Series 2018 2017

2036 5.70 2006E 250 250

2037 6.30 2007A 525 525

2038 6.75 2008B 600 600

2039 5.50 2009C 600 600

2040 5.70 2010B 350 350

2042 4.20 2012A 400 400

2043 3.95 2013A 700 700

2044 4.45 2014A 850 850

2045 4.50 2015A 650 —   

2054 4.625 2014C 750 750

25 Additional Debentures* Various 6,900 5,910

TOTAL DEBENTURES 15,500 13,860

TAX-EXEMPT DEBT—Notes issued to New York State Energy Research and Development Authority for Facilities Revenue Bonds*:

5 Other Bonds with 2017 Balance

Various Various - 736 

2036 1.74 2010A 225   225 

2039 1.75 2004C 99  99 

2039 1.71 2005A 126  126 

TOTAL TAX-EXEMPT DEBT 450  1,086 

TOTAL PROJECT DEBT 2,076  915 

Unamortized debt expense (152) (113)

Unamortized debt discount   (33)  (29)

TOTAL 18,145  16,029 

Less: Long-term debt due within one year 650  1,298 

TOTAL LONG-TERM DEBT 17,495  14,731 

TOTAL CAPITALIZATION $34,221  $30,149 

*Excluded for brevity. These debentures are listed in the Consolidated Edison Annual Report. *Rates are to be reset weekly or by auction held every 35 days; December 31, 2018 rates shown. The accompanying notes are an integral part of these financial statements.

Another class of credit balances for which the functions of authorization, custody, and reconciliation are not easy to describe are the “calculated liabilities and credits”: lease obligations, deferred income taxes, pension and postretirement benefit liabilities, and foreign currency translation gains and losses, to name a few. These are accounting trans- actions calculated according to accounting rules using basic data from company plans and operations. Management usually has considerable discretion in structuring leases,

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tax strategies, pension plan and employee benefit terms, foreign holdings, and the like. These accounting calculations often involve significant accounting estimates made by management. Company accountants try to capture the economic reality of these calcu- lated liabilities by following generally accepted accounting principles, which are often complex and difficult to understand. Auditors need to discuss these transactions at length and ensure that the fundamental economic and business assumptions underlying signifi- cant transactions are reasonable.

Periodic Reconciliation Most public entities use registrars and transfer agents to issue certificates and track stock ownership. Reports can be obtained from registrars and transfer agents to verify that the company’s record of the number of shares outstanding agrees with the registrar’s num- ber. (Without this reconciliation, counterfeit shares handled by the transfer agent and recorded by the registrar might go unnoticed.) A trustee having duties and responsibilities similar to those of registrars and transfer agents can handle ownership of bonds. Confir- mations and reports from bond trustees can be used to reconcile the trustee’s records to the company’s records.

Some small, especially closely held, corporations may issue stock certificates them- selves. These companies utilize a stock certificate book to issue certificates as authorized by the board of directors. A responsible independent person should periodically inspect the stock certificate book to determine whether all certificates are recorded and in the possession of bona fide owners. If necessary, officials in very small companies can con- firm the ownership of shares with the holders of record.

Investing Transactions: Investments and Intangibles 3 Company investments can take many shapes. Management invests company resources through the purchase or lease of PP&E, which was discussed in Chapter 8. Investments in intangible assets may be in the form of purchased assets (e.g., patents, trademarks) or accounting allocations (e.g., goodwill, deferred charges). Finally, a company can have a variety of types of investments in marketable securities. The following sections are phrased in the context of a manufacturing or service company; however, financial insti- tutions (banks, thrifts), investment companies (mutual funds, small business investment companies), and insurance companies have more elaborate systems for managing their investments and intangibles.

Authorization Those in the entity charged with governance (e.g., board of directors or investment commit- tee) should approve all investment policies. It is not unusual to find board or executive com- mittee approval required for major investment transactions. However, auditors should expect to find a great deal of variation across companies about the nature and amount of transac- tions that must have specific high-level approval. It is imperative that auditors understand the approval process and vouch major acquisitions to the appropriate documented approval.

The chief financial officer of Travum County invested several million dollars of county funds with a California-based investment money manager. Soon thereafter, news stories of the money manager’s expensive personal lifestyle and questionable handling of clients’ funds began to circulate, indicating that clients could lose much of their investments. At the same time, news stories about the county

treasurer’s own credit card spending habits were published locally, indicating that she had obtained a personal credit card by using the county’s name. Although no county funds were lost and no improper credit card bills were paid, the county commissioners temporarily sus- pended the treasurer’s authority to choose investment vehicles for county funds.

Authorization: Here Today, Gone Tomorrow AUDITING INSIGHT

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Custody Negotiable certificates such as stocks and bonds may be kept in a brokerage account. Other negotiable certificates (such as titles to real estate) may be in the actual possession of the client. If the company keeps them, they should be in a safe or a bank safe deposit box. Only high-ranking officers (e.g., CFO, CEO, president, and chairman of the board) should have access, which should require two people (dual control) to access these documents. This may require two signatures to access a safe deposit box or ensure that no one person knows the complete combination to the safe. When it is not possible for one person to access a safe, cabinet, or drawer, as in two locks and no one has both keys, or no one knows the entire com- bination, a strict form of dual custody, known as joint custody, is implemented as a control.

Patents, trademarks, copyrights, and similar legal intangible rights can be evidenced in legal documents and contracts. These seldom are negotiable, and they usually are kept in ordinary company files. However, these intangible assets are highly valued, and entities make every effort to protect these assets as indicated in the following Auditing Insight.

The University of Texas at Austin has trademark rights over the “longhorn” symbol and a particular school color (burnt orange). The university actively prohibits businesses from using these symbols without permission. For example, a local cleaning business and a trash-hauling business were informed that they must cease and desist using the longhorn head logo on their buildings, signs, and trucks. The businesses complied by repainting and finding other ways to promote their business.

The Coalition to Advance the Protection of Sports Logos (CAPS), whose members are colleges and the professional leagues (NFL, NBA, MLB, and NHL), uses a national network of investigators to scour flea markets, customs ports, and parking lots on game days to ferret out unlicensed T-shirts, caps, and other gear. Since 1993, CAPS, work- ing with local law enforcement, has seized more than 9 million illegal products valued at more than $329 million.

Source: “Stopping Knockoffs an Elusive Goal for Flyers,” The Philadelphia Inquirer, May 15, 2008, p. C01.

Don’t Use Our Logo AUDITING INSIGHT

Record Keeping for Investments Unauthorized transactions can be a major risk for investments and intangibles. The board of directors or other responsible officials should authorize large transactions. These authorizations provide the approval for initializing the purchase of the investment. The procedures for purchase of investments varies greatly depending on the type of invest- ment involved. For example, in a more manual system, the voucher system previously described in Chapter 8 may be used. The authorization from the board provides the pur- chasing department the go-ahead to acquire the assets and the accounting department the approval to prepare the voucher and the check. The treasurer or CFO signs the check to purchase the investment. Alternatively, many investment transactions are performed elec- tronically. For these transactions, multifactor authentication, transaction limits, and other automated controls become critical.

The record keeping for many types of investments and intangibles can be compli- cated. The complications arise not so much from the original recording of transactions, but from the maintenance of the accounts over time. This is where complex accounting standards for marketable securities, equity method accounting, consolidations, goodwill, intangibles’ amortization and valuation, depreciation, deferred charges, deferred taxes, pension and postretirement benefit liabilities, and various financial instruments enter the picture. High-level accountants who prepare financial statements are involved with the accounting rules and the management estimates required to account for such investments and intangibles. Management plans and estimates of future events and interpretations of the accounting standards often become elements of the accounting maintenance of these balances. These decisions are ripe areas for overstatement of assets, understatement of liabilities, and understatement of expenses.

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Periodic Reconciliation Investment accounts may be overstated by recording marketable securities that the entity does not own (this represents a violation of the rights assertion). When a brokerage firm holds the securities, the inspection is accomplished with a written confirmation, which is the most typical situation. However, when a company physically holds marketable securi- ties in its possession, a reconciliation performed through inspection and count of nego- tiable securities certificates is a critical control. This reconciliation is similar to a physical inventory count consisting of an inspection of certificates on hand and comparison with the information recorded in the accounts.

A securities count is not a mere handling of bits of paper. A securities count should include a record of the name of the company represented by the certificate, the interest rate for bonds, the dividend rate for preferred stocks, the due date for bonds, the serial numbers on the certificates (known as the CUSIP number), the number of stock shares or face amount of bonds, and notes on the name of the owner shown on the face of the cer- tificate or on the endorsements on the back (should be the client company). Companies should perform this reconciliation reasonably often and not wait for an annual visit by the independent auditors. A securities count in a financial institution that holds thousands of shares in multibillion-dollar asset accounts is a major undertaking. A surprise count by the auditors may be done during the interim testing. As with other assets, the auditor should insist that client personnel are present during the entire count.

REVIEW CHECKPOINTS 10.1 Who is normally responsible for the authorization of investment activities? Why is the authoriza-

tion normally performed at this level? 10.2 What constitutes the authorization for notes payable? What documentary evidence could auditors

examine to confirm this authorization? 10.3 What documents would a company need to correctly account for its investment securities, and

what information would they obtain from these documents? 10.4 Describe the activities a company should perform to ensure the accuracy of an investment listing

of marketable securities.

SIGNIFICANT ACCOUNTS AND RELEVANT ASSERTIONS Exhibit 10.4 identifies significant accounts and assertions in the finance and invest- ment cycle. It is nearly impossible to describe a “typical” finance and investment cycle. Depending on the company and the industry, audit clients may be nearly entirely equity financed or largely debt financed. In addition, some companies have simple investment activities consisting of purchasing plant assets and occasionally investing excess cash in highly liquid securities with publicly available valuations. The type of investment can have a huge influence on the effort required by the auditor. For example, Micro- soft Corporation reports approximately $122 billion of investment securities in its 2018 annual report. However, the large majority of these securities are government debentures that are relatively simple to audit because of their short-term nature and publicly available valuations. However, Microsoft also reports approximately $45 billion of equity method investments and intangible assets—much more difficult to audit, as we will discuss later when addressing audits of estimates, including fair value measurements. Thus, although Exhibit 10.4 simply lists “Investments” as a significant account, the type of investment has a huge effect on the most relevant assertions and the amount of work done. In subse- quent sections of this chapter, we will discuss how the activities within the accounts can vary and how the auditor approaches these varying risks.

LO 10-2 Identify significant accounts and relevant assertions related to the finance and investment cycle.

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EXHIBIT 10.4

Significant Account Relevant Assertions

Investments Existence/occurrence Completeness Valuation Presentation and disclosure

Long-Term Debt Existence/occurrence Completeness Valuation Presentation and disclosure

Capital Stock Completeness Presentation and disclosure

Retained Earnings Completeness

Mergers and acquisitions are very common ways for companies to invest their assets and grow their businesses. Some companies compete via acquisition. As a result, investments often represent a significant activity for large companies. Verizon, the giant telecommunications company, announced on July 25, 2016, its intent to purchase Yahoo! for $4.8 billion in an effort to compete with Google and Facebook for advertising revenue. With this purchase, Verizon will acquire not only the tangible assets and liabilities of Yahoo!, but also intangible assets—some which can be specifically identified—as well as goodwill. The valuation and distinction between specifically identifiable intangi- ble assets and goodwill is critical from an audit perspective. Specifically

identifiable assets are amortized, but under ASC 350, goodwill is only subject to impairment tests. Although Yahoo! is a very large and well- known company, it is only the fourth-largest acquisition made by Veri- zon in the past 10 years. Verizon has also purchased Verizon Wireless ($130.1 billion), Alltel ($28.1 billion), and MCI ($10.3 billion), in addi- tion to AOL ($4.3 billion) and many other companies. The Verizon Wireless acquisition was the largest acquisition ever when it occurred in 2013. As discussed later in this chapter, the valuation of assets in acquisitions can represent a significant risk of material misstatement.

Source: Dealogic.

It’s Just a Small Purchase . . . AUDITING INSIGHT

RISK OF MATERIAL MISSTATEMENT As previously mentioned, the transactions in the financing and investing cycle do not occur in most firms on a daily, or even weekly, basis and are often for large amounts. Therefore, there is a premium on ensuring that transactions are properly authorized. In addition, there is significant risk and professional judgment in determining the fair mar- ket value (FMV) of certain assets, and accounting standards require significant detailed disclosure regarding the FMV of these items. Therefore, presentation and disclosure have increased risk in the finance and investment cycle. Refer to Exhibit 10.5 for a summary of some of the things that can go wrong in a typical corporation that lead to a risk of mate- rial misstatement in the finance and investment cycle.

A quick analysis of Exhibit 10.5 shows that many of the common problems in the finance and investment cycle involve failure to record and disclose transactions and fail- ure to appropriately adjust asset valuations for either changes in fair value on marketable securities or impairments. These problems can occur for a variety of reasons: (1) com- plex transactions make the accounting and disclosure rules difficult; (2) the infrequent transactions do not lend themselves to routine control procedures, making errors and omissions more frequent; and (3) because of higher amounts of estimation and judgment, top management may intentionally misstate financial statements. In this section, we will discuss some of the more difficult issues that can occur in the finance and investment cycle from a perspective of why there is a higher risk of material misstatement.

LO 10-3 Discuss the risk of material misstatement in the finance and investment cycle, with a specific focus on improper valuation and disclosure.

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EXHIBIT 10.5

Significant Account Relevant Assertions What Could Go Wrong?

Investments Existence/occurrence Management may sell company-owned securities for their own benefit.

Investment securities held by the entity may be stolen.

Management may record fictitious interest income.

Completeness Investment transactions from the current period may be recorded in the subsequent period.

Valuation Management fails to mark marketable equity securities to fair market value.

Equity method investments are not accurately adjusted for investee income and dividends.

Impairments to investment securities are not properly recorded.

Presentation and disclosure Management fails to appropriately account for derivative transactions that do not qualify for hedge treatment.

Available for Sale Debt securities are misclassified as Held to Maturity.

Long-Term Debt Existence/occurrence Fully paid notes are not properly removed from schedule of long-term debt.

Completeness Management fails to record capital lease obligations.

Valuation Amortization of long-term debt is calculated incorrectly.

Presentation and disclosure Management fails to reclassify current portions of long-term debt.

Management fails to disclose future minimum required debt payments.

Violations of restrictive loan covenants are not properly disclosed.

Capital Stock Completeness Some issued stock is not recorded.

Treasury stock repurchases are not recorded.

Presentation and disclosure Exercises of stock options are not allocated correctly between capital stock accounts.

Retained Earnings Completeness Declared dividends are not recorded.

Prior-period error corrections are not recorded appropriately.

Complex Transactions In the past, clients have worked with investment bankers to create investing and financ- ing transactions that are structured to get around GAAP rules. Management may want to keep risky ventures off the financial statements to make the company look better. The  Enron  example from earlier in the chapter is one example of this. However, many transactions are complex, and even ones that reach the balance sheet can be challenging.

For some companies, off-balance-sheet risk exposure can significantly influence the amount of risk present. For example, an important risk measure for banks is the Basel III Supplementary Leverage ratio. This ratio measures the core strength of a bank from a regulatory perspective by comparing the amount of tier 1 capital, primarily com- mon stock and retained earnings, to the bank’s total leverage expo- sure, which measures both the on- and off-balance-sheet assets of a bank. A higher ratio indicates less risk from a regulatory perspective. Because of the importance of the ratio to regulators, a key user of the financial statements, auditors must pay close attention not only

to the on-balance-sheet assets, but also the off-balance-sheet assets of a bank. These off-balance-sheet exposures can be complex con- tracts such as derivatives, cancelable commitments, and guarantees. For the year ended December 31, 2018, Citigroup, one of the larg- est multinational financial institutions, reported off-balance-sheet risk exposures related to guarantees of $451 billion. To put this number in perspective, Citigroup’s off-balance-sheet guarantee exposures are equal to more than 2 percent of the 2018 U.S. GDP!

Source: Citigroup Form 10-K, December 31, 2018.

Don’t Just Look at the Balance Sheet AUDITING INSIGHT

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For example, complex instruments that contain characteristics of both debt and equity can be difficult to classify and value the components. Merger and acquisition transactions also have large amounts of estimation, which can lead to large differences in judgments. These transactions are usually complex, are difficult to audit, and can be used as vehicles to hide fraud—all of which lead to higher risks of material misstatement.

Fair Market Value Judgment, as defined by KPMG, is “the process of reaching a decision or drawing a con- clusion where there are a number of possible alternative solutions.”1 Judgment is made in an environment of uncertainty and risk. As the uncertainty and risk increase, the need for greater skepticism and increased experience or expertise is required to ensure that sound audit judgment is applied.

The investment cycle covers a number of difficult-to-value assets such as

∙ Investments in debt and equity securities or unique assets. ∙ Derivative instruments. ∙ Certain financial instruments. ∙ Intangible assets, including goodwill. ∙ Loans and other receivables that are possibly impaired. ∙ Pension and other postretirement assets and liabilities.

Each of these and other assets and liabilities require the auditor to exercise profes- sional judgment in an area of high risk. Management will value most of these assets using assumptions they have made about the financial markets, commodity prices, and short- and long-term economic activity. The auditor will evaluate the assumptions that manage- ment has made regarding all assets for which FMV is a concern, but even the most diligent audit cannot remove the inherent risk of the changing economic and financial markets that affect the FMV of these assets and liabilities, leading to high risk of material misstatement.

1KPMG, “Evaluating Professional Judgment in Auditing and Accounting,” www.scribd.com/doc/105344428/KPMG-monograph.

Estimate calculations in the investment area very often involve complex, level 3 fair value estimates. Level 3 fair value estimates involve unobservable variables, such as expected growth rates or discount rates. A recent study on estimation uncertainty within pub- lic companies revealed that, often, very small changes in underlying assumptions, well within a margin for error, could lead to changes in valuation estimates many times materiality levels. Consider the example of a company acquiring another company. After consider- ing tangible assets, the purchasing company has $3 billion to allocate between corporate trademarks, which are limited life intangibles and must be amortized, and goodwill, which is not subject to amortization.

Assume the trademark has 10 or more years of useful life remaining. It is likely that a .5 percent change in the assumed discount range may lead to a fluctuation in the estimated value of the trademark many times materiality. Because a company may have the incentive to recognize more goodwill (because it is not amortized), the auditor must be vigilant in evaluating whether the discount rate used in the fair value estimate is overstated, which would reduce the computed FV of the trademark.

Source: B. E. Christensen, S. M. Glover, and D. A. Wood, “Extreme Estimation Uncertainty in Fair Value Estimates: Implications for Audit Assurance,” Audit- ing: A Journal of Practice & Theory 31, no. 1 (2012): 127–146.

Small Changes in Assumptions, Huge Changes in Estimates

AUDITING INSIGHT

Related-Party Transactions Related-party transactions occur frequently in companies. For example, Caterpillar Inc. has a division that builds construction equipment and has a division that builds engines. Because engines are sold from the engine division to the construction division and because the corporation’s management could influence the nature of these transactions, such a sale qualifies as a related-party transaction. The issue for the auditor is determin- ing that the engine division sold engines to the construction division under the same

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terms as sales made by the engine division to outside customers. In other words, these sales should be the equivalent of an arm’s-length transaction.

Many of the examples of fraud in this chapter occurred through related-party transac- tions. ASC 850 provides the definition for related parties and the appropriate disclosure and accounting. Essentially, a related party is one that can exert significant influence over another party. Related parties are frequently used in fraudulent activity because they can conceal activities that the auditors would normally be aware of if the activity occurred between unre- lated parties. AU-C 240, “Consideration of Fraud in a Financial Statement Audit,” specifi- cally lists significant transactions with related parties not in the ordinary course of business as risk factors relating to fraudulent financial reporting. According to AS 2410, the objec- tive of the auditor is “to obtain sufficient appropriate audit evidence to determine whether related parties and relationships and transactions with related parties have been properly identified, accounted for, and disclosed in the financial statements” (AS 2410.02).

Lease Accounting A company can make an investment by purchasing property, plant, or equipment. These transactions were discussed in the acquisition and expense cycle in Chapter 8. Often, compa- nies do not want to purchase assets because of cash considerations or the flexibility in chang- ing assets as the business changes. Leases may offer businesses a better cash flow situation or the ability to easily terminate or modify an asset. However, the accounting for leases is more complex than a direct purchase of an asset. Historically, the classification of leases as either operating or capitalized was based on a series of assumptions that could be easily manipu- lated by management (as discussed in ASC 840). For example, if the present value of lease payments is 90 percent or more of the property’s value, the lease is capitalized; if it is only 89.9 percent of the value, the lease is classified as operating and is not reported as a liability on the balance sheet. This ability to structure lease transactions produced less transparent information and allowed certain leases not to be capitalized. The SEC estimated that as of 2005, SEC registrants alone had $1.25 trillion of off-balance-sheet operating lease commit- ments.2 To improve financial reporting about lease transactions, on February 25, 2016, the FASB issued ASU No. 2016-02 (Topic 842). According to the new standard, all leases greater than 12 months must be recognized as assets with their matching liabilities. In addition, the standard increased the quantity of disclosures required for leasing transactions. Thus, although the new standard reduced the ability of management to structure lease transactions, in many ways it increased the risk to the auditor by requiring all leases to be accounted for using imputed present value estimations. The new standard was effective for public com- panies beginning with fiscal year 2019 and for nonpublic companies for fiscal year 2020. However, many companies adopted the standard early. For example, Microsoft reports nearly $6.7 billion of operating lease right-of-use assets in their June 30, 2018, balance sheet. Previ- ously, these operating lease assets would not have been shown on the balance sheet.

Loan Covenants To protect themselves, banks usually insert clauses in loan agreements intended to keep the borrower’s financial position at a level that will ensure repayment of the loan. These loan covenants may restrict payment of dividends, additional borrowings, or use of assets for col- lateral on other debt. They often require the borrower to maintain certain ratio levels (e.g., a current ratio of no less than 2:1). If borrowers violate these restrictions, the debt can be called (payment demanded) immediately. If the borrower cannot pay the debt when called, the lender can force the borrower into bankruptcy. Auditors must check to see that their clients are not in violation of their loan covenants. An additional risk is that companies’ managements will misstate their other accounts to meet the covenant requirements. A loan covenant violation can also trigger other difficult decisions for the auditor. For example, if a company is in violation of a loan covenant and has not reached a resolution with the lender, this will often trigger an assessment of substantial doubt related to going-concern uncertainty. This assessment may lead to a modification of the standard auditor’s report.

22005 SEC report on off-balance-sheet activities.

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Impairments When auditing large investment balances and purchase-related intangible assets, audi- tors must be aware of the risk of material misstatement related to the valuation assertion. GAAP require that impairments to asset values should normally be taken as losses when they occur. Valuing investments and determining possible impairment of related goodwill is very complex. Moreover, companies have been accused of taking a “big bath,” which means writing off assets and building up reserves to reduce expenses in future years. This is more likely to happen when a company is experiencing a bad year or when it hires a new CEO (like a football coach going 1–11 his first year and blaming it on his predeces- sor’s players). Thus, auditors must always consider whether assets are overstated due to a possible impairment or whether impairment write-offs have been delayed, both of which can lead to material misstatements.

Presentation and Disclosure As previously mentioned, failure to appropriately disclose complex transactions and estimates can lead to confusion and the inability for both auditors and investors to under- stand exactly what a company is doing. For that reason, presentation and disclosure assertions take on added importance in the finance and investment cycle. In Exhibit 10.5, we listed several examples of potential hazards facing auditors. With investment securi- ties, classification of marketable securities and derivative instruments are critical. The classification of a security as trading or available for sale affects whether changes in value influence net income. Even more critically, marketable debt security investments classified as held-to-maturity are not subject to mark-to-market accounting on the face of the financial statements. Similarly, the classification of a derivative instrument as a hedge influences the presentation and characterization of fluctuations in value. On the financing side, disclosures related to pensions, leases, and stock options are complex and extensive, and the completeness and accuracy of the disclosures represent high risks of material misstatement. The SEC takes disclosure very seriously, and the following Audit- ing Insight represents just one example where lack of disclosure was considered to be a material omission.

According to the SEC, five former San Diego city officials knew that the city had been intentionally underfunding its pension obligations so that it could increase pension benefits but defer the costs. They were aware that the city would face severe difficulty funding its future pension and retiree health care obligations unless new revenues were obtained, pension and health care benefits were reduced, or city ser- vices were cut. They specifically knew that the city’s unfunded liability to its pension plan was projected to dramatically increase from $284 million at the beginning of fiscal year 2002 to an estimated $2 billion by 2009 and that the city’s liability for retiree health care was another estimated $1.1 billion. But the officials failed to disclose these and other material facts to rating agencies or to investors in bond-offering documents and continuing disclosures.

Specifically, the SEC alleges that the city manager signed the clos- ing letter for one of the bond offerings, falsely certifying that it was accurate and did not contain misleading statements. The city audi- tor and comptroller signed letters falsely representing that the city’s audited financial statements included in the securities offerings were accurate. The deputy city manager of finance regularly reviewed and revised the false and misleading disclosure documents and signed the

closing letter for two of the five bond offerings. She falsely certified that the disclosures were accurate and did not contain misleading statements, and she reviewed and made presentations to the rating agencies. The assistant auditor and comptroller reviewed the city’s financial statements that contained some of the false and misleading disclosures, and the city treasurer participated in drafting the city’s false and misleading disclosures. Additionally, the city treasurer and the assistant auditor and comptroller both knew that in 2003, the rating agencies had concerns about the city’s growing pension obli- gations and that those obligations could negatively affect the city’s credit rating. Nevertheless, they withheld material facts from the rat- ing agencies.

In October 2010, four of the accused officials agreed to pay a total of $80,000 to settle the fraud charges with the Securities and Exchange Commission. Regulators have pointed to this case as an indication that they intend to pursue individuals engaged in perceived abuses in the $2.8 billion municipal bond market.

Source: “SEC Charges Five Former San Diego Officials with Securities Fraud,” SEC Press Release 2008-57, April 7, 2008; N. Bullock, “Ex-San Diego Officials Fined in Fraud Case,” www.ft.com, October 28, 2010.

Not Disclosing Information Can Hurt AUDITING INSIGHT

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INTERNAL CONTROL ACTIVITIES AND DESIGN EVALUATION In the finance and investment cycle, auditors look for control activities such as authoriza- tion, appropriate custody, record keeping, and periodic reconciliation. They especially look for information about the level of management that is involved in these functions. Tests of controls generally begin with inquiries and observations related to these features. Inspection of documents, primarily looking for proper authorizations, and a walkthrough of controls over the determination of the fair value of assets should also be performed.

Because finance and investment transactions are often individually material, each trans- action usually is audited using substantive procedures. Auditors do not normally exam- ine samples of significant transactions for tests of controls as they do in the other cycles because reliance on controls does not normally reduce the extent of substantive procedures on finance and investment cycle accounts. However, lack of controls can lead to perfor- mance of significant extended procedures. Of particular importance are the entitywide con- trols that restrict access to systems, documents, and assets—many of which are key in the performance of investment cycle activities. Establishing appropriate procedures, includ- ing adequate controls, for determining the fair market value of investments, derivatives, hedges, and other investment instruments is imperative in accessing the overall control structure for any company that maintains a material amount of such instruments. Of course, for public companies in which the auditors must issue a report on the effectiveness of con- trols over the financial reporting process, evaluation of controls over these transactions is essential. However, for the majority of nonpublic clients, tests of controls may be limited to entity level in the finance and investment cycle. Exhibit 10.6 outlines some of the primary control considerations in the finance and investment cycle that entities use to mitigate risk.

LO 10-4 Identify important internal control activities present in a properly designed system to mitigate the risk of material misstatements for each relevant assertion in the finance and investment cycle.

EXHIBIT 10.6

Significant Account Relevant Assertions What Could Go Wrong? Internal Control Activity (Mitigate Risk)

Investments Existence/occurrence Management may sell company- owned securities for their own benefit.

Broker transaction confirmations should be periodically reviewed by the investment committee of the board of directors (BOD).

Investment purchases and sales should be approved by the BOD.

Investment securities held by the entity may be stolen.

Securities should be held in lockboxes, and responsibility for custody should be separated from responsibility for record keeping.

Management may record fictitious interest income.

The investment committee of the BOD should regularly compare investment performance to expectations.

Completeness Investment transactions from the current period may be recorded in the subsequent period.

The responsibility for authorization of purchases of securities should be separated from recording purchases in the securities ledger.

Valuation Management fails to mark marketable equity securities to fair market value.

Qualified staff is responsible for end- of-period fair value estimates.

(continued)

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Significant Account Relevant Assertions What Could Go Wrong? Internal Control Activity (Mitigate Risk)

Equity method investments are not accurately adjusted for investee income and dividends.

Ensure accurate financial statements for investees are obtained on a timely basis.

Impairments to investment securities are not properly recorded.

Management reviews investment securities for evidence of other than temporary declines in value.

Separate the duty of investment acquisition from the duty of investment valuation.

Presentation and disclosure Management fails to appropriately account for derivative transactions that do not qualify for hedge treatment.

Properly trained employees supervise the estimation process for derivative securities.

Available for Sale Debt securities are misclassified as Held to Maturity.

Ensure the investment committee of the BOD has a written policy on investment classification.

Long-Term Debt Existence/occurrence Fully paid notes are not properly removed from schedule of long- term debt.

The BOD authorizes all issuances of long-term notes and bonds.

Completeness Management fails to record capital lease obligations.

Separate the duties of authorization of lease agreements from accounting for lease agreements.

Valuation Amortization of long-term debt is calculated incorrectly.

Hire qualified personnel and review their work.

Presentation and disclosure Management fails to reclassify current portions of long-term debt.

Ensure active oversight by independent financial experts from the audit committee.

Management fails to disclose future minimum required debt payments.

Ensure active oversight by independent financial experts from the audit committee.

Violations of restrictive loan covenants are not properly disclosed.

Ensure active oversight by independent financial experts from the audit committee.

Capital Stock Completeness Some issued stock is not recorded.

Management regularly obtains register of issued stock from third- party registrar and compares with recorded capital stock.

Treasury stock repurchases are not recorded.

Require authorization of BOD for treasury stock repurchases.

Presentation and disclosure Exercises of stock options are not allocated correctly between capital stock accounts.

Hire qualified accounting staff and review their work.

Retained Earnings Completeness Declared dividends are not recorded.

Management should periodically review equity accounts.

Prior-period error corrections are not recorded appropriately.

Hire qualified personnel and review their work.

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Control Considerations Control activities for suitable handling of responsibilities should be in place and operat- ing. By referring to the discussion accompanying Exhibit 10.2, you may notice that these responsibilities are primarily in the hands of senior management officials. You also can surmise that different companies may have widely different policies and activities.

It is difficult to have a strict separation of functional responsibilities when the principal officers of a company authorize, execute, and control finance and investment activities. It is not realistic to have the CEO authorize investments but not have access to stockholder records, securities certificates, and the like. Real separation of duties can be found in middle management and lower ranks, but it is difficult to create and enforce among upper managers.

Because of this control problem, a company should have compensating control activi- ties. A compensating control is a control activity used because a specific standard control activity is not in place. The compensating control reduces the risk due to the missing control. For example, the board of directors may authorize the purchase of an investment and delegate the execution of investment purchases to the CFO. The CFO would call the company’s broker to execute the authorized transaction. Because the CFO is authorized to instruct the broker to buy and sell securities, the CFO is in a position to sell company securities for personal use. A compensating control might be an agreement with the bro- ker to mail transaction confirmations to other company personnel or to use electronic transfer directly into the company’s account for all proceeds from the sale of investments. In the area of finance and investment, the compensating control feature often involves two or more persons in each area of important functional responsibility.

If involvement by multiple persons is not specified, an oversight or review can be substituted. For example, the board of directors can authorize the purchase of securities or the creation of a partnership. The CFO or CEO can carry out the transactions, have custody of certificates and agreements, manage the partnership or the portfolio of securi- ties, oversee the record keeping, and make the decisions about valuations and accounting (authorizing the journal entries). These are normal management activities, and they com- bine several responsibilities. The compensating control can exist in the form of periodic reports to the board of directors, oversight by the investment committee of the board, and internal audit involvement in making a periodic reconciliation of securities certificates in a portfolio with the amounts and descriptions recorded in the accounts.

Auditors considering the design of internal controls in the finance and investment cycle typically perform a walkthrough, which involves starting with an inquiry of management about how the processes are completed. For example, the auditor may ask management who initiates an investment transaction, how the transaction is approved, and how the transaction is executed. The auditor may then inspect and document a sample investment transaction to obtain a clear understanding of the design of the controls put into action. Based on the understanding, the auditor will then often discuss the resulting flowchart or narrative with management and document a preliminary risk assessment related to the purchase or sale of an investment transaction. A similar process can be repeated for other significant accounts and assertions within the finance and investment cycle.

TESTS OF OPERATING EFFECTIVENESS OF INTERNAL CONTROL

Following an assessment of the design effectiveness of internal controls in the finance and investment cycle, the auditor may consider testing the operating effectiveness of internal control. Of course, recall that auditors performing an integrated audit must always test the operating effectiveness of internal controls. Exhibit 10.7 outlines some of the tests of controls that an auditor may perform in the finance and investment cycle. A scan of the exhibit likely shows you that tests of controls in this cycle are very different from the ones

LO 10-5 Give examples of tests of controls to verify the operating effectiveness of internal controls in the finance and investment cycle.

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EXHIBIT 10.7

Significant Account

Relevant Assertions What Could Go Wrong?

Internal Control Activity (Mitigate Risk) Test of Internal Control

Investments Existence/ occurrence

Management may sell company-owned securities for their own benefit.

Broker transaction confirmations should be periodically reviewed by the investment committee of the board of directors (BOD).

Inspect documents for evidence of periodic board review of purchase transactions.

Investment purchases and sales should be approved by the BOD.

Review BOD minutes for evidence of authorization of investment purchases.

Investment securities held by the entity may be stolen.

Securities should be held in lockboxes, and responsibility for custody should be separated from responsibility for record keeping.

Inquire about proper segregation of duties and about lockbox security procedures.

Management may overstate current-period interest income.

The investment committee of the BOD should regularly compare investment performance to expectations.

Inspect documents for evidence of periodic board review of investment performance.

Completeness Investment transactions from the current period may be recorded in the subsequent period.

The responsibility for authorization of purchases of securities should be separated from recording purchases in the securities ledger.

Inquire about proper segregation of duties.

Valuation Management fails to mark marketable equity securities to fair market value.

Qualified staff is responsible for end-of-period fair value estimates.

Inquire about the estimation process, and observe evidence that process is being followed.

Equity method investments are not accurately adjusted for investee income.

Ensure accurate financial statements for investees are obtained on a timely basis.

Inquire about the process of obtaining investee financial statement information, and inspect evidence of timeliness.

Impairments to investment securities are not properly recorded.

Management reviews investment securities for evidence of other than temporary declines in value.

Inspect documentation for evidence of management review of investment valuation.

Separate the duty of investment acquisition from the duty of investment valuation.

Inquire of personnel about impairment process, and observe separation of duties.

Presentation and disclosure

Management fails to appropriately account for derivative transactions that do not qualify for hedge treatment.

Properly trained employees supervise the estimation process for derivative securities.

Inquire about the client’s policies and procedures for determining hedge treatment of derivative securities.

Available for Sale Debt securities are misclassified as Held to Maturity.

Ensure the investment committee of the BOD has a written policy on investment classification.

Review entity’s investment classification policy.

(continued)

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Significant Account

Relevant Assertions What Could Go Wrong?

Internal Control Activity (Mitigate Risk) Test of Internal Control

Long-Term Debt Existence/ occurrence

Fully paid notes are not properly removed from schedule of long-term debt.

The BOD authorizes all issuances of long-term notes and bonds.

Inspect BOD meeting minutes for evidence of approval of debt.

Completeness Management fails to record capital lease obligations.

Separate the duties of authorization of lease agreements from accounting for lease agreements.

Inquire of personnel about lease contracting process, and observe separation of duties.

Valuation Amortization of long-term debt is calculated incorrectly.

Hire qualified personnel and review their work.

Inspect documents for evidence of management review of debt schedules.

Presentation and disclosure

Management fails to reclassify current portions of long-term debt.

Ensure active oversight by independent financial experts from the audit committee.

Obtain minutes of audit committee meetings, and inspect for evidence of appropriate oversight.

Management fails to disclose future minimum required debt payments.

Ensure active oversight by independent financial experts from the audit committee.

Obtain minutes of audit committee meetings, and inspect for evidence of appropriate oversight.

Violations of restrictive loan covenants are not properly disclosed.

Ensure active oversight by independent financial experts from the audit committee.

Obtain minutes of audit committee meetings, and inspect for evidence of appropriate oversight.

Capital Stock Completeness Some issued stock is not recorded.

Management regularly obtains register of issued stock from third-party registrar and compares with recorded capital stock.

Inspect documents for evidence that management periodically reviews stock registers.

Treasury stock repurchases are not recorded.

Require authorization of board of directors for treasury stock repurchases.

Inspect BOD meeting minutes for evidence of approval of treasury stock repurchases.

Presentation and disclosure

Exercises of stock options are not allocated correctly between capital stock accounts.

Hire qualified accounting staff and review their work.

Inquire about hiring process, and inspect evidence of management review of capital stock transactions.

Retained Earnings

Completeness Declared dividends are not recorded.

Management should periodically review equity accounts.

Inquire of management about process for ensuring accuracy and completeness of equity accounts.

Prior-period error corrections are not recorded appropriately.

Hire qualified accounting staff and review their work.

Inquire about hiring process, and inspect evidence of management review of error corrections.

EXHIBIT 10.7 (Continued)

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covered in the other cycle chapters. Auditors do not typically vouch or trace transactions as control tests in this cycle. The primary reason is that there are often so few transac- tions, and they are likely material, so the auditor tests the transactions as substantive tests, not tests of controls for the purpose of assessing control risk. In fact, tests of controls in the finance and investment cycle primarily deal with determining whether there is suf- ficient board oversight in practice, proper authorization and review of transactions, and sufficient documentation of finance and investment policies. In this section, you will learn about some of the more difficult evaluations auditors must make in assessing con- trol risk in the finance and investment cycle. First, you will learn about tests of controls surrounding accounting estimates and then about tests of controls surrounding authoriza- tion, record keeping, and custody.

Control over Accounting Estimates An accounting estimate is a measurement or recognition in the financial statements of (or a decision to not recognize) an account, disclosure, transaction, or event that gener- ally involves subjective assumptions and measurement uncertainty (AS 2501.02). Esti- mates often are included in basic financial statements because the measurement of some amount is uncertain, perhaps depending on the outcome of future events, or relevant data cannot be accumulated on a timely, cost-effective basis. Some examples of accounting estimates in the finance and investment cycle include the following:

∙ Plant and equipment depreciation. Useful lives, salvage values. ∙ Financial instruments. Valuation of securities, including fair values assigned to debt

and equity securities; classification into held-to-maturity, available-for-sale, and trad- ing securities investment portfolios; probability of a correlated hedge; sales of securi- ties with puts and calls; investment model assumptions; and impairments. The issue of valuation may be especially difficult if the investment was received in a noncash trans- action and is not readily marketable. Appraisals, financial modeling, or other methods may be necessary to estimate the investment’s value.

∙ Accruals. Compensation in stock option plans, actuarial assumptions in pension costs. ∙ Leases. Initial direct costs, useful lives, and residual values; rate of interest implicit in

the lease. ∙ Rates. Imputed interest rates on long-term receivables and payables. ∙ Other. Losses and net realizable value on segment disposal and business restructuring,

fair values in nonmonetary exchanges, and impairment of goodwill.

A client’s management is responsible for making estimates and should have processes and controls designed to reduce the likelihood of material misstatements in them. Spe- cific relevant aspects of such controls include the following:

∙ Management communication of the need for proper accounting estimates. ∙ Accumulation of relevant, sufficient, and reliable data for estimates. ∙ Preparation of estimates by qualified personnel. ∙ Adequate review and approval by appropriate levels of authority. ∙ Comparison of prior estimates with subsequent results to assess the reliability of the

process used to develop estimates. ∙ Consideration by management of whether particular accounting estimates are consis-

tent with the company’s operational plans.

Although accounting estimates are primarily tested substantively, the quality of the client’s internal controls affects the nature of the substantive tests. We will discuss this later in the chapter. Auditors’ tests of controls over the estimation process include mak- ing inquiries and observations. Inquiries would include such questions as: Who prepares estimates? When are they prepared? What data are used? Who reviews and approves the estimates? Have prior estimates been compared with subsequent actual events?

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The auditor also will assess the involvement of the audit committee of the board of direc- tors in evaluating the estimation process. If the audit committee is more heavily involved in risk assessment and process evaluation, control risk may be reduced for relevant assertions in the finance and investment cycle. Observations in tests of controls over accounting estimates include study of data documentation, study of comparisons of prior estimates with subsequent actual experience, and study of intercompany correspondence concerning estimates and operational plans. The audit of a valuation estimate starts with the tests of controls, many of which have a bearing on the quality of the estimation pro- cess and of the estimate itself.

A large television manufacturer decided to extend its 90-day warranty on labor to one year. Because the company had no experience with such an extended warranty, it devised a complex formula to take into account the increased likelihood of repair and the associated cost.

While going through the pages and pages of calculations with the war- ranty accountant to obtain an understanding, the auditor noticed that one fraction used in the calculation was inverted. The error resulted in a $20 million understatement of the warranty reserve.

OOPS! AUDITING INSIGHT

Authorization Most of the transactions in the financing and investing cycle involve large amounts of cash or other assets. Therefore, authorization is a critical issue when examining these transactions. The issuance, sale, or purchase of company stock and bonds, the obtaining of large bank loans, and the purchase or sale of large assets generally are discussed at the highest levels of the organization. Auditors must review minutes of the board of directors meetings, finance committee meetings, or other appropriate committee meetings for the authorization of significant transactions, including dividends, treasury stock repurchases, issuance of stock options, and acquisitions, among many others. In addition, the authori- zation for the purchase of large assets may reside in the capital budget, which should have been approved by senior management and the board. Absent tangible evidence of the authorization of significant transactions, the auditor should make inquiries at the highest levels to ensure that these major transactions have been approved.

Record Keeping Transactions that occur on a daily basis are usually recorded in a journal designed espe- cially for those transactions (e.g., sales journals, purchase journals, payroll journals). Usually, the transactions in this cycle occur infrequently and are recorded in the general journal. In addition, because the transactions are infrequent, vary greatly in type, and are for large dollar amounts, controls over the proper recording of the transaction must be implemented. The competency of the individuals making these journal entries and the review and reconciliation of the general ledger are essential controls that the auditor should test. Assessing the competency of client employees can be difficult but should begin with inquiry of management regarding the qualifications of employees responsible for record keeping in the finance and investment cycle. Auditors will also often evalu- ate the hiring process of employees in an audit of the company’s human resources and payroll accounts. The auditor also can use evidence obtained from prior audits as an indication of the competency/lack thereof of a company’s employees. For this reason, employee turnover is deemed a significant risk factor when considering controls over complex transactions.

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Custody In large companies, custody of stock certificate books is not a significant management problem because of the use of registrars and transfer agents. Small companies often keep their own stockholder records. A stock certificate book looks like a checkbook. It has perforated stubs for recording the number of shares, the owner’s name and other identifi- cation, and the date of issue. Actual unissued share certificates are attached to the stubs, like blank checks in a checkbook. The company should have a record of certificates that are outstanding in the possession of owners. Custody of the stock certificate book is important because the unissued certificates are like money or collateral. If improperly removed, they can be sold to buyers who think they are genuinely issued or can be used as collateral with unsuspecting lenders. Auditors should test controls surrounding the physical security of stock certificate books and should test the process for issuance of stock certificates.

Lenders have custody of debt instruments (e.g., leases, bonds, and notes payable). However, when a company repurchases its bonds or pays off its debt, the debt instruments are returned to the company. These documents could be misused by improperly reselling them to unsuspecting investors. Auditors should inspect documentation indicating the extinguishment of debt and should inspect returned bonds or notes for appropriate can- cellation or evidence of destruction.

Something strange must have happened on the way to the dump. Hundreds of long-term bonds were redeemed early and presented to Citibank in New York, which acted as the agent for the issues. Many of the bonds still had not reached the maturity date marked on them. Citibank sent about $1 billion of the canceled U.S. corporate bonds to a landfill dump in New Jersey, but some of them turned up at banks in Europe and the United States. Although the bonds are worthless, they

still might look genuine to a layperson or even to some bankers. The FBI traced the canceled bonds to a defunct company in New Jersey that had a contract to destroy the bonds. (Note: Companies obtain a destruction certificate when bonds and stock certificates are canceled. The certificates obtained by Citibank apparently were fraudulent.)

Source: Securities Exchange Act Release No. 31612, December 17, 1992, www.sec.gov/news/digest/1992/dig121792.pdf.

A New Meaning for “Recycling” AUDITING INSIGHT

Summary: Control Risk Assessment From the preceding discussion, you can tell that tests of controls take a variety of forms: inquiries, observations, inspection of documentation, comparisons with related data, and detail audits of some significant transactions. However, because of the nature of finance and investment transactions (i.e., few in number and high in dollar amount), auditors often focus on substantive tests rather than tests of controls. For example, a company may have only 10 significant security investment transactions during the year. The most efficient use of audit time may be to review all 10 significant transactions for all relevant assertions. Conversely, some companies may have numerous debt-financing transactions and a more detailed evaluation of control risk may be pertinent, including the selection of a sample of significant transactions for control risk assessment evidence.

See Appendix 10A for internal control questionnaires for the finance and investment cycle. They illustrate typical questions about the assertions. These inquiries give auditors insights into the client’s specifications for review and approval of major investing and financing transactions, the system of accounting for them, and the provision for error- checking review activities.

The audit team should evaluate the evidence obtained from an understanding of the design of internal control and from tests of the operating effectiveness of controls.

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These tests can take many forms because management systems for finance and invest- ment accounts can vary a great deal among clients. The involvement of senior officials in a relatively small number of high-dollar transactions makes control risk assessment a process tailored specifically to the company’s situation. Some companies enter into complicated financing and investment transactions while others keep to the simple transactions.

Many companies, particularly companies that have significant inter- national and online businesses, are beginning to accept payments in bitcoin, a digital asset and payment system first introduced by Satoshi Nakamoto in 2008. As of 2019, hundreds of thousands of merchants were accepting bitcoins as payment, including large corporations such as Microsoft, Expedia, Wikipedia, and Overstock. Bitcoin transactions are peer-to-peer and do not require an intermediary, thus reducing transaction costs considerably. In addition, bitcoin transac- tions are permanently recorded in blockchain, a distributed database of transactions that cannot be tampered with or revised. Blockchain technology has the potential to lead to better electronic audit trails, but with it comes potential issues. As EY tweeted, “With blockchain what comes first, opportunity or threat?” However, from an auditing standpoint, bitcoins present potential issues both for valuation and for controls. Because they are not a currency, they are not treated as cash. Unlike investment securities, however, bitcoins are not

backed by any asset. Further, they are maintained in digital wallets, and anyone with access to the wallet can immediately steal the bit- coins. As a result, bitcoins are treated under GAAP as an intangible asset, although there is no formal standard currently and some com- panies attempt to claim them as mark-to-market investments. Thus, existence, valuation, classification, and rights and obligations of bit- coins represent significant risks of material misstatement, and tests of controls must be performed on clients with material bitcoin assets or transactions. Further, verifying rights to bitcoin is challenging and often requires the client to execute a small bitcoin transaction from a digital wallet to demonstrate they control the private key, and hence own the bitcoin.

Sources: A. Cuthbertson, “Bitcoin Now Accepted by 100,000 Merchants Worldwide,” International Business Times February 4, 2015; EY, “Implementing Blockchains and Distributed Infrastructure,” 2016; https://twitter.com/EYnews/ status/747468816641200128.

Blockwhat?AUDITING INSIGHT

REVIEW CHECKPOINTS 10.5 What is a compensating control? Give some examples for finance and investment cycle accounts. 10.6 What are some of the specific relevant aspects of management’s control over the estimation pro-

cess? What are some inquiries auditors can make? 10.7 What are some specific transactions that an auditor would expect to be approved by the board

of directors? How would it affect the audit if these transactions were not required to be approved by the board?

10.8 What documentation should an auditor inspect when a client has paid off a bank note? How could an employee defraud the company if the bank note has no indication of being paid?

SUBSTANTIVE ANALYTICAL PROCEDURES AND TESTS OF DETAILS

As discussed earlier, the finance and investment cycle is primarily audited with a substan- tive approach. When the auditor uses a reliance approach in the operating cycle, reductions in control risk enable the use of less detailed substantive testing. For example, an audi- tor may choose to use analytical procedures to assess the reasonableness of certain cur- rent liabilities without testing the transactions or balances in detail. However, because the finance and investment cycle consists of infrequent and significant transactions, the auditor relies less on tests of controls and more on direct substantive tests of details. This section addresses the typical types of substantive tests an auditor uses to obtain sufficient, appropri- ate evidence in the finance and investment cycle. As in previous chapters, the section con- cludes with some cases illustrating errors and frauds to describe useful audit approaches.

LO 10-6 Give examples of substantive procedures in the finance and investment cycle and relate them to assertions about significant account balances at the end of the period.

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Exhibit 10.8 completes the audit approach for the finance and investment cycle. In the exhibit, substantive analytical procedures and substantive tests of details that are often  used to obtain evidence about significant accounts and relevant assertions are presented.

EXHIBIT 10.8

Significant Account

Relevant Assertions

What Could Go Wrong?

Internal Control Activity (Mitigate Risk)

Test of Internal Control

Possible Substantive Analytical Procedures

Possible Substantive Tests of Details

Investments Existence/ occurrence

Management may sell company-owned securities for their own benefit.

Broker transaction confirmations should be periodically reviewed by the investment committee of the board of directors (BOD).

Inspect documents for evidence of periodic board review of purchase transactions.

Confirm investments with brokerage.

Investment purchases and sales should be approved by the BOD.

Review BOD minutes for evidence of authorization of investment purchases.

Vouch purchases and sales of securities to broker’s advices.

Investment securities held by the entity may be stolen.

Securities should be held in lockboxes, and responsibility for custody should be separated from responsibility for record keeping.

Inquire about proper segregation of duties and about lockbox security procedures.

Physically inspect all investment securities held by entity.

Management may overstate current-period interest income.

The investment committee of the BOD should regularly compare investment performance to expectations.

Inspect documents for evidence of periodic board review of investment performance.

Recalculate interest income on debt securities based on principal balances and interest rates.

Vouch recorded interest income to cash receipts journal and premium/discount amortization.

Completeness Investment transactions from the current period may be recorded in the subsequent period.

The responsibility for authorization of purchases of securities should be separated from recording purchases in the securities ledger.

Inquire about proper segregation of duties.

Compare current-year investment account balances with expected balances based on prior-year balances and current- year operating and financing activities.

Scan cash disbursements ledger for large purchases surrounding year-end.

Valuation Management fails to mark marketable equity securities to fair market value.

Qualified staff is responsible for end- of-period fair value estimates.

Inquire about the estimation process, and observe evidence that process is being followed.

Inspect client budgets, and compare with actual investment returns.

Vouch market values of marketable investment securities to The Wall Street Journal.

(Continued)

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Significant Account

Relevant Assertions

What Could Go Wrong?

Internal Control Activity (Mitigate Risk)

Test of Internal Control

Possible Substantive Analytical Procedures

Possible Substantive Tests of Details

Equity method investments are not accurately adjusted for investee income.

Ensure accurate financial statements for investees are obtained on a timely basis.

Inquire about the process of obtaining investee financial statement information, and inspect evidence of timeliness.

Obtain financial statements of investments accounted for by the equity method, and recalculate recorded amounts.

Impairments to investment securities are not properly recorded.

Ensure management reviews investment securities for evidence of other than temporary declines in value.

Inspect documentation for evidence of management review of investment valuation.

Test the company’s process used to develop the impairment estimate.

Separate the duty of investment acquisition from the duty of investment valuation.

Inquire of personnel about impairment process, and observe separation of duties.

Presentation and disclosure

Management fails to appropriately account for derivative transactions that do not qualify for hedge treatment.

Properly trained employees supervise the estimation process for derivative securities.

Inquire about the client’s policies and procedures for determining hedge treatment of derivative securities.

Inspect documentation supporting client classification of derivative securities.

Available for Sale Debt securities are misclassified as Held to Maturity.

The investment committee of the BOD has a written policy on investment classification.

Review entity’s investment classification policy.

Obtain representations from management regarding intent of debt investments.

Long-Term Debt

Existence/ occurrence

Fully paid notes are not properly removed from schedule of long-term debt.

The BOD authorizes all issuances of long-term notes and bonds.

Inspect BOD meeting minutes for evidence of approval of debt.

Compare expected debt balances to actual debt balances based on understanding of client’s financing needs and prior-year balances.

Confirm long-term debt with debtors, including terms and interest rates.

EXHIBIT 10.8 (Continued)

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Significant Account

Relevant Assertions

What Could Go Wrong?

Internal Control Activity (Mitigate Risk)

Test of Internal Control

Possible Substantive Analytical Procedures

Possible Substantive Tests of Details

Completeness Management fails to record capital lease obligations.

Separate the duties of authorization of lease agreements from accounting for lease agreements.

Inquire of personnel about lease contracting process, and observe separation of duties.

Inspect lease agreements, and evaluate appropriate accounting treatment.

Valuation Amortization of long-term debt is calculated incorrectly.

Hire qualified personnel and review their work.

Inspect documents for evidence of management review of debt schedules.

Obtain debt amortization schedules, and recalculate balances.

Presentation and disclosure

Management fails to reclassify current portions of long-term debt.

Ensure active oversight by independent financial experts from the audit committee.

Obtain minutes of audit committee meetings, and inspect for evidence of appropriate oversight.

Inspect schedule of long-term debt, and evaluate appropriate classification of debt.

Management fails to disclose future minimum required debt payments.

Ensure active oversight by independent financial experts from the audit committee.

Obtain minutes of audit committee meetings, and inspect for evidence of appropriate oversight.

Complete disclosure checklist, and agree footnote disclosures to debt instruments.

Violations of restrictive loan covenants are not properly disclosed.

Ensure active oversight by independent financial experts from the audit committee.

Obtain minutes of audit committee meetings, and inspect for evidence of appropriate oversight.

Inspect debt agreements, and recalculate ratios for compliance with debt covenants.

Capital Stock

Completeness Some issued stock is not recorded.

Management regularly obtains register of issued stock from third- party registrar and compares with recorded capital stock.

Inspect documents for evidence that management periodically reviews stock registers.

Compare current- year capital stock accounts with expectations based on review of board minutes and prior- year balances.

Confirm capital stock with third- party registrar.

Inspect cash receipts ledger for presence of equity transactions surrounding year- end.

EXHIBIT 10.8 (Continued)

(Continued)

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Significant Account

Relevant Assertions

What Could Go Wrong?

Internal Control Activity (Mitigate Risk)

Test of Internal Control

Possible Substantive Analytical Procedures

Possible Substantive Tests of Details

Treasury stock repurchases are not recorded.

Require authorization of BOD for treasury stock repurchases.

Inspect BOD meeting minutes for evidence of approval of treasury stock repurchases.

Inspect schedule of treasury stock repurchases, and trace to general ledger.

Presentation and disclosure

Exercises of stock options are not allocated correctly between capital stock accounts.

Hire qualified accounting staff and review their work.

Inquire about hiring process, and inspect evidence of management review of capital stock transactions.

Inspect BOD minutes for approval of stock options.

Obtain schedule of stock options, and test for accuracy. Trace to capital stock ledger and general ledger.

Retained Earnings

Completeness Declared dividends are not recorded.

Management should periodically review equity accounts.

Inquire of management about process for ensuring accuracy and completeness of equity accounts.

Inspect BOD minutes for evidence of dividend declarations, and trace to general ledger.

Prior-period error corrections are not recorded appropriately.

Hire qualified accounting staff and review their work.

Inquire about hiring process, and inspect evidence of management review of error corrections.

Trace schedule of known prior period adjustments to retained earnings.

EXHIBIT 10.8 (Continued)

In general, substantive procedures on finance and investment accounts are extensive. Nevertheless, control deficiencies and unusual or complicated transactions can cause auditors to adjust the nature and timing of audit procedures. For example, if separation of duties is lacking in the execution of investment transactions, the auditor may move most testing of investment securities and related accounts to year-end. Complicated financial instruments, pension plans, exotic equity securities, related-party transactions, and non- monetary exchanges of investment assets call for procedures designed to find evidence of errors and frauds in the finance and investment accounts.

As shown in Exhibit 10.8, the auditor’s primary concerns surrounding typical market- able investment securities mostly involve the existence of the securities and the valua- tion of the securities. For this reason, auditors typically rely on either positive external

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confirmation with a broker or direct physical examination of security certificates to ensure the existence of the investments, and they verify ownership through confirma- tion or inspection to determine that the client is listed as the owner. Similarly, the audi- tor relies on vouching the reported market value of securities to a public source such as The Wall Street Journal. Auditors also evaluate disclosures and recalculate both real- ized and unrealized gains and losses on marketable investment securities, as well as consider the reasonableness of management’s classification of the securities within the relevant financial accounting standard. However, companies can have a wide variety of investments and relationships with affiliates. Investment accounting may be on the market value method, cost method, equity method, or full consolidation, depending on the nature, size, and influence represented by the investment. Consolidations usually create problems of accounting for the fair value of acquired assets and the related good- will. Auditors must identify the appropriate accounting method for each investment and ensure that investments are properly valued. The next section discusses some of the more complex issues auditors may face in auditing investment securities. The section con- cludes with two specific valuation and classification issues: auditing fair value measure- ments and derivative securities.

Trouble Spots in Audits of Investments and Intangibles To some, it might appear that the audit of investments and intangibles presented in this chapter is straightforward. After all, in many instances, we have stated that the auditor can test most, if not all, of the significant transactions in these areas; finding documentation for authorization is the key control. Some of the complex issues in the audit of investments and intangibles follow:

∙ Valuation of investments at cost or market or impairment that is other than temporary. ∙ Determination of significant influence relationship for equity method investments. ∙ Impairment of goodwill. ∙ Capitalization and continuing valuation of intangibles and deferred charges. ∙ Propriety, effectiveness, and risk disclosure of derivative securities used as hedges

of exposure to changes in fair value (fair value hedge), variability in cash flows (cash flow hedge), or fluctuations in foreign currency.

∙ Determination of the fair value of derivatives and securities, including valuation mod- els and the reasonableness of key assumptions.

∙ Realistic distinctions of research, feasibility, and production milestones for capitaliza- tion of software development costs.

∙ Adequate disclosure of restrictions, pledges, or liens related to investment assets.

Investment costs should be vouched to brokers’ confirmations, monthly statements, or other documentary evidence of cost. At the same time, the amounts of investment sales should be traced to gain or loss accounts, and the amounts of sales prices and pro- ceeds should be vouched to the brokers’ statements and the cash receipts journal. Audi- tors should determine what method of cost-out assignment was used (i.e., FIFO, specific identification, or average cost) and whether it is consistent with prior-years’ transactions.

Market valuation of securities is required for securities classified in trading portfolios and available-for-sale portfolios. Although management may assert that an investment valuation is not impaired, subsequent sale at a loss before the end of audit fieldwork will indicate otherwise. Auditors should review significant investment transactions sub- sequent to the balance-sheet date for this kind of evidence about value impairment.

Classification of marketable securities is another management judgment that audi- tors must evaluate. If management classifies securities as trading securities, net income includes unrealized gains. When the market is doing well, these gains can provide sig- nificant additions to the bottom line. When the market is down, management can classify the securities as available for sale, which removes the losses from net income. How- ever, management is required to make transfers between trading and available-for-sale

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securities at fair value, thus the auditor must verify consistent classification of securi- ties. Similar management judgments can move securities from noncurrent to current, thus affecting current ratios. Auditors must use their professional judgment to ensure that management is basing its classifications on sound business judgments, not their financial statement effect. However, there is often little tangible evidence in support of manage- ment responses to these audit inquiries. By consulting quoted market values for securi- ties, auditors can calculate market values and determine whether investments should be written down in value. If quoted market values are not available, financial statements related to investments must be obtained and analyzed for evidence of basic value. If such financial statements are unaudited, they provide extremely weak evidence.

Income amounts can be verified by consulting published or online dividend records for quotations of dividends actually declared and paid during a period (e.g., Moody’s and Standard & Poor’s dividend records). Because auditors know the holding period of securities, dividend income can be calculated and compared to the amount in the account. Any difference could indicate a cutoff error, misclassification, defalcation, or failure to record a dividend receivable. In a similar manner, application of interest rates to bond or note investments produces a calculated interest income figure (considering amortization of premium or discount if applicable).

Inquiries should deal with the nature of investments and the reasons for holding them, especially derivative securities used for hedging activities. The classification affects the accounting treatment of market values and the unrealized gains and losses on investments. Due to the complexity of ASC 815, “Derivatives and Hedging,” auditors may need special skills or knowledge to understand clients’ hedging transactions, to ensure that effective controls are in place to monitor them, and to audit the significant transactions.

When equity method accounting is used for investments, auditors need to obtain financial statements of the investee company. These should be audited statements. The inability to obtain financial statements from a closely held investee could indicate that the client investor does not have the significant controlling influence required by APB Opinion No. 18. When available, these statements are used as the basis for recalculating the amount of the client’s share of income to recognize in the accounts. In addition, these statements can be used to audit the disclosure of investees’ assets, liabilities, and income presented in footnotes, a disclosure recommended when investments accounted for by the equity method are material.

Auditing Accounting Estimates, including Fair Value Measurements As described in the earlier discussion of internal controls in the finance and investment cycle, an accounting estimate generally involves subjectivity and measurement uncertainty. Because of the subjectivity involved in the calculation of an estimate, the auditor is espe- cially concerned about management bias in the process. This potential for bias, and the inherent measurement uncertainty, often leads to the auditor assessing the risk of material misstatement at an elevated level for accounting estimates. Although the auditor considers and tests the client’s internal controls over accounting estimates, AS 2301, “The Auditor’s Responses to the Risks of Material Misstatement,” requires that as the risk of material mis- statement increases, the evidence from substantive procedures should also increase.

When performing substantive procedures to test accounting estimates, AS 2501, “Auditing Accounting Estimates” provide the auditor with three approaches to choose from, including a combination of any of the three:

1. Test the company’s process used to develop the accounting estimate. 2. Develop an independent expectation for comparison to the company’s estimate. 3. Evaluate audit evidence from events or transactions occurring after the measurement

date related to the accounting estimate for comparison to the company’s estimate. 

Although developing an independent expectation would potentially lead to the most unbiased testing of accounting estimates, auditors most commonly test the

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company’s  process.3 Researchers have documented that when choosing this approach, auditors sometimes fail to sufficiently test the underlying data, missing inconsistencies among assumptions and other internal and external data. As a result, it is critical that auditors exercise professional skepticism and make high quality professional judgments in audits of complex accounting estimates. A key part of this exercise of professional judgment is a required brainstorming discussion among key engagement personnel about how the financial statements could be manipulated through management bias in account- ing estimates in significant accounts and disclosures.4 This discussion is including during the auditor’s brainstorming about the potential for fraud in the financial statements.

Two areas of significant measurement uncertainty that are critical to the audit of the finance and investment cycle are audits of fair value estimates and derivative securities. GAAP pronouncements increasingly require the use of fair value for measurement of trans- actions and disclosure amounts. In addition, recent FASB pronouncements have required more stringent determination and more complete disclosures for investments, derivatives, and other assets and liabilities that are measured at fair value on a recurring basis. A fair value hierarchy has been established at three different levels as explained in Exhibit 10.9.

Disclosure is required not only as to the level for assets and liabilities, but also as to specific information if an item is moved between levels. For level 3 assets and liabilities, a reconciliation of the beginning and ending balances is required. These additional dis- closure requirements increase the risk for assets and liabilities measured at fair value.

As part of performing substantive procedures for auditing fair value accounting esti- mates, auditors follow the same standards for any accounting estimate. Specifically, an auditor should determine whether (1) the valuation principles are acceptable under the financial reporting framework, (2) the valuation principles are consistently applied, (3) the valuation principles are supported by the underlying documentation, and (4) the method of estimation and the significant assumptions are properly disclosed according to GAAP.

As with other estimates, management has primary responsibility for determining fair value in accordance with GAAP. Observable market-based values are generally preferred (level 1). However, if market prices are not readily available, clients should incorporate assumptions that would have been used by the marketplace (level 2). If information about the assumptions is not readily available, management can use their own assumptions. Thus, auditors first must determine whether a market-based value is available; if not, they must evaluate whether clients’ assumptions would have been used by the marketplace or there are data contrary to what the client used—very murky waters, indeed. The auditor must take considerable care when auditing fair value calculations for level 3. These cal- culations use a considerable amount of judgment and estimates resulting in an increased risk of improper valuation. Appendix Exhibit 10B.1 provides an example of an audit plan for the fair market value of assets and liabilities.

Derivative instruments are those that take their value from another asset or index. For example, an option to buy Disney stock is a derivative instrument. Interest rate swaps,

EXHIBIT 10.9 Fair Market Value Measurement Hierarchy

The Financial Accounting Standards Board (FASB) and International Accounting Standards Board (IASB) have established a three-level hierarchy in dealing with the problem of fair values that do not result from market prices:

Level 1: Fair values are derived from quoted market prices for identical assets or liabilities from an active market to which an entity has immediate access.

Level 2: Market prices are available for similar (as opposed to identical) assets or liabilities.

Level 3: If values for levels 1 or 2 are not available, fair value is estimated using valuation techniques.

3GRIFFITH, E. E.; J. S. HAMMERSLEY; AND K. KADOUS. “Audits of Complex Estimates as Verification of Management Numbers: How Institutional Pressures Shape Practice.” Contemporary Accounting Research, 2015. 4AS 2201: An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements

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options, futures contracts, and foreign currency options are also derivatives. Derivatives can be used as hedging instruments to protect companies from uncertainties in the market- place. For example, a clothing manufacturer could buy futures contracts on cotton to lock the price of its main raw material so that it can predict the future cost of goods sold. Like- wise, companies selling overseas use currency futures to lock in the exchange rate for their sales. Accounting for derivatives is extremely complex, and new ones are constantly being developed. There are even derivatives to protect against bad weather!

Depending on why a company engages in derivative activities, the company may have only a few derivatives (e.g., foreign currency hedges to protect a few large contracts where foreign currency is the method of payment) or a large number of derivatives (commodity options to protect the company from price swings in essential raw materials). In the latter case, the auditor may need to focus on control activities and adjust the substantive testing based on the control risk assessment. When derivative activity is characterized by few significant transactions, the auditor likely focuses on the transaction authorization and performs substantive tests on most or all of the significant transactions. Auditors must ensure that derivatives are recorded at their fair market value at the balance-sheet date

In 2008, Lehman Brothers was the fourth largest investment bank in the United States. The company, originally founded in 1850, had boomed in the mid-2000s with the acquisition of five large mortgage lenders, several making loans to borrowers with poor credit or no doc- umentation requests. The risky strategy led to record profits, including $4.2 billion net income in 2007. Even though housing defaults were on the rise, Lehman’s CFO indicated that the risks posed to Lehman were minimal and would have little impact on the firm’s earnings.

However, Lehman’s estimates of the valuation of its portfolio of mortgage-backed securities (MBSs) proved to be based on default assumptions that were not nearly conservative enough, and as the housing market crashed, so did Lehman’s ability to generate cash flow from loan repayments and, in turn, its stock price, losing more than $46 billion of market value.

When Lehman Brothers filed for bankruptcy on September 15, 2008, it was the largest bankruptcy in history with $619 billion of debt, blowing away the bankruptcies of previous widely covered col- lapses of Enron and WorldCom.

Ernst & Young, Lehman Brothers’ auditor, was quickly hit with civil fraud cases claiming that it stood by watching while Lehman used shady accounting gimmicks to hide its problems. Ernst & Young vigorously

defended the accusations claiming that, “Lehman’s audited financial statements clearly portrayed Lehman as a highly leveraged entity oper- ating in a risky and volatile industry.” However, institutional investors questioned the audit work performed and asked specifically whether the firm had misrepresented Lehman’s financial condition, “artificially inflating the value of its securities.” Perhaps because of the high costs of defending lawsuits, Ernst & Young settled two separate lawsuits in 2013 and 2015 for $99 million with investors and $10 million with the state of New York without admitting to any flaws in the audits.

The Lehman Brothers failure demonstrates how fair values of investment securities can be difficult, or maybe impossible, to audit in some situations. It is important to note that the valuations used by Lehman were based on the same assumptions used at many other large investment bankers who failed concurrently with Lehman Broth- ers. This again demonstrates the importance of maintaining a skepti- cal attitude in all aspects of the audit.

Source: G. McCool, “Ernst & Young Accused of Hiding Lehman Troubles,” Reuters, December 21, 2010; A. Harris, “Ernst & Young Settles Lehman Inves- tor Lawsuit for $99 Million,” Accounting Today, December 2, 2013; C. Smythe Bloomburg, “Ernst & Young Will Pay $10 Million to End N.Y. Lehman Suit,” Accounting Today, April 15, 2015.

Impossible to Audit? AUDITING INSIGHT

J.M. Smucker Company, the maker of Smucker’s jams and Jif peanut butter, saw a strong first quarter on higher volumes in its key brands and expects the momentum to continue into the second quarter, helped by its hedging activities taken in response to increasing cof- fee prices. The company said it has protected itself against exposure to coffee price fluctuations for the second quarter very well. Indeed, Smucker, whose coffee brands include Folgers and Dunkin’ Donuts,

said the coffee segment, which accounts for about 38 percent of its revenue, surpassed its expectations with a 7 percent increase in sales for the quarter, but the margin took a beating due to higher green coffee costs. Coffee futures had rallied about 40 percent since the beginning of March.

Source: “JM Smucker Sees Strong Q2 on Coffee Price Hedging,” Reuters, August 20, 2010.

Trimming the Hedge? AUDITING INSIGHT

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and should review derivative activities after the balance-sheet date in a search for unre- corded derivatives. Because of the risk of misclassifying derivative securities, auditors must also test management’s evaluation of the successfulness of the hedges.

An illustrative audit plan of substantive procedures for investments and related accounts is presented in Appendix Exhibit 10B.2. Part B of this audit plan covers portfo- lio classification, fair value determination, and evidence about impairment.

REVIEW CHECKPOINTS 10.9 What are some of the important assertions found in investment accounts? 10.10 What are some of the typical areas of concern to auditors involving investment accounts? 10.11 How can confirmations be used in auditing investments in stocks? 10.12 How can auditors gain assurance about estimates in the investment cycle?

Long-Term Liabilities and Related Accounts Exhibit 10.8 also presents substantive procedures for audits of long-term debt. The pri- mary audit concerns with the verification of long-term liabilities is that all of them are recorded, that the interest expense is properly paid or accrued, and that they are classified and disclosed appropriately. Therefore, the balance-sheet assertions of completeness and presentation and disclosure are paramount. Alertness to the possibility of unrecorded liabilities during the performance of procedures in other areas frequently uncovers liabili- ties that have not been recorded. For example, when PP&E are acquired during the year under audit, auditors should inquire about the source of funds to finance the new assets. Auditors also should be alert for large cash disbursements and maintenance expenses for upgrades of electrical, plumbing, and air-conditioning systems. Often, all of these are indicators of the purchase and installation of equipment.

When auditing long-term liabilities, auditors usually obtain independent written con- firmations for notes and bonds payable. In the case of notes payable to banks, the stan- dard bank confirmation may be used and should include a request to list any banking relationships not listed on the confirmation request. The amount and terms of bonds pay- able, mortgages payable, and other formal debt instruments can be verified by reading the bond indenture, the written agreement with the bondholders, and confirmed by requests to bondholders or the bond trustee. The confirmation request should include questions not only of amount, interest rate, and due date, but also of collateral, restrictive cove- nants, and other items of agreement between lender and borrower. Confirmation requests should be sent to lenders with whom the company has done business in the recent past, even if no liability balance is shown at the confirmation date. Such extra coverage is a part of the search for unrecorded liabilities. An illustration of typical audit documentation for auditing long-term debt and interest expense is in Exhibit 10.10. Note that the interest expense consists of additions to the accrual account as well as amortization of premiums or discounts on long-term debt. An illustrative audit plan of substantive procedures for notes payable and long-term debt is in Appendix Exhibit 10B.3.

Confirmation and inquiry procedures may be used to obtain responses on a class of items loosely termed off-balance-sheet information. Within this category are terms of loan agreements, leases, endorsements, guarantees, and insurance policies (whether issued by a client insurance company or owned by the client). Among these items is the difficult-to-define set of commitments and contingencies that often pose evidence- gathering problems. See Exhibit 10.11 for some common types of commitments.

Footnote disclosure should be considered for the types of commitments shown in Exhibit 10.11. Some of them can be estimated and valued and, thus, can be recorded in  the accounts and shown in the financial statements themselves (such as losses on fixed -price purchase commitments and losses on fixed-price sales commitments).

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EXHIBIT 10.11 Off-Balance-Sheet Commitments

DUNDER-MIFFLIN INC. Long-Term Debt, Accrued Interest Payable, and Interest Expense

For Year Ended 12/31/2020 Prepared by Client

Long-Term Debt Accrued Interest Payable

Date Due Balance

12/31/2019 Additions Amortization/

Payments Balance

12/31/2020 Balance

12/31/2016 Interest Expense Payments

Balance 12/31/2017

5.25% senior subordinated debt

6/30/23 $2,500,000 PY               0 $250,000 v $2,250,000 CF/

   TB $66,750 $    131,437 C $143,750

v $54,437 CF

4% note payable— Bank One

9/30/16               0 $500,000u                   0 $   500,000 CF/

   TB $ 5,000 $        20,000 C

$  20,000 v $    5,000

CF

Premium on long-term debt $  354,128

PY               0 $  18,266 C $   335,862 CF/ TB

$   18,266 C

$71,750 F PY

$169,703 F/TB

$163,750 F

$59,437 CF F/TB

Prepared by RJR 3/10/2018

Reviewed by DHS 3/12/2018

EXHIBIT 10.10 Audit Documentation—Long-Term Debt and Interest Expense

Type of Commitment Typical Audit Procedures

Repurchase or remarketing agreements Vouching of contracts, confirmation by customer, and inquiry of client management

Commitments to purchase at fixed prices Vouching of open purchase orders, inquiry of purchasing personnel, and confirmation by supplier

Commitments to sell at fixed prices Vouching of sales contracts, inquiry of sales personnel, and confirmation by customer

Guaranteed obligations of unconsolidated subsidiaries

Vouching of contracts, confirmation with debtors, and inquiry of client management

Loan commitments (as in a savings and loan association)

Vouching of open commitment file, inquiry of loan officers

Lease commitments Vouching of lease agreement, confirmation with lessor or lessee

Interest expense generally is related item by item to interest-bearing liabilities. Based on the evidence of long-term liability transactions (including those that have been retired dur- ing the year), the related interest expense amounts can be recalculated. The amount of debt, the interest rate, and the time period are used to determine whether the interest expense and accrued interest are properly recorded. Interest expense also may be estimated by the analytical procedure of multiplying average debt outstanding by the average interest rate.

Stockholders’ Equity: Substantive Procedures Stockholders’ equity transactions usually are well documented in the minutes of the meetings of the board of directors, proxy statements, and securities offering registration statements. For publicly traded companies, stock transactions usually require a filing with the SEC (e.g., an offering of stock to raise capital). Transaction authorization can be vouched to these documents, and the cash proceeds can be traced to the bank accounts. Capital stock may be subject to confirmation when independent registrars and transfer agents are employed.

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Such agents are responsible for knowing the number of shares authorized and issued and for keeping lists of stockholders’ names. The basic information about capital stock—such as number of shares, classes of stock, preferred dividend rates, conversion terms, dividend payments, shares held in the company name, expiration dates, and terms of warrants and stock dividends and splits—can be confirmed with the independent agents. The audit team’s own inspection and reading of stock certificates, charter authorizations, directors’ minutes, and registration statements can corroborate many of these items. However, when the client company does not use independent agents, most audit evidence is gathered by inspecting and vouching stock record documents (such as certificate book stubs). When circumstances call for extended procedures, information on outstanding stock in very small corporations having only a few stockholders may be confirmed directly with the holders.

Auditing Stock-Based Compensation Plans ASC 718 requires that employee stock-based compensation must be recorded using a fair value–based method at the date the award is granted and must be credited to paid-in- capital and expensed over the compensation period. The definition of fair value account- ing in ASC 718 is different from the general definition of fair value in ASC 820 and often requires the application of complex option pricing models. As a result, auditing stock- based compensation can be a risky area. There are many types of employee stock-based compensation, and some, such as employee stock options, require appropriate allocation between common stock and paid-in-capital accounts upon exercise.

When auditing employee share options, auditors must follow the standards for auditing accounting estimates as discussed earlier. However, because employee share options are complex financial instruments, and no market value is available, companies typically use option-pricing models, which have assumptions that can be difficult to evaluate. Some of these assumptions include a stock price volatility rate and a risk-free interest rate that are assumed to be constant. In auditing employee share option plans, auditors focus on valuation of the options as well as presentation and disclosure of the options. The audi- tor should obtain copies of any employee stock-based compensation plans and vouch to approval by the board of directors. In addition, auditors should test the accounting for the valuation estimates and recalculate compensation expense. The PCAOB has specifically addressed auditing of employee share options and focuses on auditors’ understanding of the process used by management for valuing and accounting for share options.5

With the exception of stock-based compensation plans, audits of stockholders’ equity are considered to be low risk. See Appendix Exhibit 10B.4 for an illustrative audit plan of substantive procedures for stockholders’ equity.

5PCAOB. Staff Questions and Answers, Auditing the Fair Value of Share Options Granted to Employees, October 17, 2006.

REVIEW CHECKPOINTS 10.13 What are some of the important assertions found in stockholders’ equity account balances and

disclosures? 10.14 What are some of the important assertions found in the long-term liability accounts? 10.15 How can confirmations be used in auditing (a) stockholder capital accounts and (b) notes and

bonds payable? 10.16 What information about capital stock could be confirmed with outside parties? How could the

auditors corroborate this information? 10.17 Define and give examples of off-balance-sheet information. Why should auditors be concerned

with such items? 10.18 If a company does not monitor notes payable for due dates and interest payment dates in rela-

tion to financial statement dates, what misstatements can appear in the financial statements?

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FRAUD CASES: EXTENDED AUDIT PROCEDURES These cases first set the stage with a story about an accounting error or fraud. The prob- lem section of each case gives you the “inside story,” which auditors seldom know before they perform this audit work. The second part of the case is the audit approach, which tells a structured story about the audit objective, desirable controls, test of control activi- ties, and audit of balance procedures. The third part wraps up the case with a discovery summary. You will have an opportunity to develop your own audit approach for similar cases in Exercises 10-60 through 10-62 at the end of this chapter.

Case 10.1

Unregistered Sale of Securities

PROBLEM A.T. Bliss & Company (Bliss) salespeople contacted potential investors and sold limited partner- ship interests in the company. The setup deal called for these limited partnerships to purchase solar hot-water heating systems for residential and commercial use from Bliss. All partnerships entered into arrangements to lease the equipment to Nationwide Corporation, which then rented the equipment to end users. The limited partnerships were, in effect, financing conduits for obtain- ing investors’ money to pay for Bliss’s equipment. The investors depended on Nationwide’s busi- ness success and ability to pay under the lease terms for their return of capital and profit.

Bliss published false and misleading financial statements, which used a non-GAAP revenue recognition method and failed to disclose cost of goods sold. Bliss overstated Nationwide’s record of equipment installation and failed to disclose that Nationwide had little cash flow from end users (resulting from rent-free periods and other inducements). Bliss knew—and failed to disclose to prospective investors—the fact that numerous previous investors had filed petitions with the U.S. tax court to contest the disallowance by the IRS of all their tax credits and benefits claimed in con- nection with their investments in Bliss’s tax-sheltered equipment lease partnerships.

All of the money put up by the limited partnership investors was at risk but was not disclosed to investors.

AUDIT APPROACH Management should employ experts—attorneys, underwriters, and accountants—who can deter- mine whether securities and investment contract sales require registration. Auditors should learn the business backgrounds and securities industry expertise of the client’s senior managers. They should study the minutes of board of directors meetings for authorization of the fund-raising method, obtain and study opinions rendered by attorneys and underwriters about the legality of the fund-raising methods, and inquire about management’s interaction with the SEC in any presale clearance. (The SEC gives advice about the necessity for registration.)

Auditors should study the offering documents and literature used in the sale of securities to determine whether financial information is being used properly. In this case, the close relationship with Nation- wide and the experience of earlier partnerships give reasons for extended procedures to obtain evidence about the representations concerning Nationwide’s business success (in this case, lack of success).

DISCOVERY SUMMARY The auditors gave unmodified reports on Bliss’s materially misstated financial statements. The auditors apparently did not question the legality of the sales of the limited partnership interests as a means of raising capital. They apparently did not perform procedures to verify representations made in offering literature reflecting Bliss or Nationwide finances. Two partners in the audit firm were enjoined because of violations of the securities laws. The partners resigned from practice before the SEC and were ordered not to perform any attest services for companies making filings with the SEC. According to SEC Litigation Release 10274, AAER 20, and AAER 21, they later were expelled from the AICPA as reported in The CPA Letter, for failure to cooperate with the Professional Ethics Division in its investigation of alleged professional ethics violations.

LO 10-7 Apply your knowledge to perform audit procedures in the revenue cycle and evaluate the findings of your tests.

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Case 10.2

Off-Balance-Sheet Inventory Financing

PROBLEM Verity Distillery Company’s president incorporated the Veritas Corporation, making him and two other Verity officers the sole stockholders. The president arranged to sell $40 million of Verity’s inventory of whiskey in the aging process to Veritas, showing no gain or loss on the transaction. The officers negotiated a 36-month loan with a major bank to get the money Veritas used for the purchase, pledging the inventory as collateral. Verity pledged to repurchase the inventory for $54.4 million, which amounted to the original $40 million plus 12 percent interest for three years.

The contract of sale was in the files, specifying the name of the purchasing company, the $40 million amount, and the cash consideration. Nothing mentioned the relationship of Veritas to the officers. Nothing mentioned the repurchase obligation. However, the sale amount was unusu- ally large for a company the size of Verity.

The $40 million amount was 40 percent of the normal inventory. Veritas’s cash balance increased 50 percent. The current asset total was not changed, but the inventory ratios (e.g., inven- tory turnover, days’ sales in inventory) and quick ratio were materially altered. Long-term liabili- ties were understated by not recording the liability. The ploy was actually a secured loan with inventory pledged as collateral, but this reality was neither recorded nor disclosed. The total effect would be to keep debt off the books, to avoid recording interest expense, and later to record inven- tory at a higher cost. Subsequent sale of the whiskey at market prices would not affect the ultimate income results, but the unrecorded interest expense would be buried in the cost of goods sold. The net income in the first year when the “sale” was made was not changed, but the normal relationship of gross margin to sales was distorted by the zero-profit transaction.

Before Transaction ($ in millions)

Recorded Transaction ($ in millions)

Pro Forma $ in millions)

Assets $530 $530 $570 

Liabilities $390 $390 $430

Stockholder equity $140 $140 $140

Debt/equity ratio   2.79 2.79 3.07

AUDIT APPROACH The relevant control in this case would rest with the integrity and accounting knowledge of the senior officials who arranged the transaction. Remember, competent individuals in key positions is an element of the control environment at the entity level. Authorization in the board minutes might detail the arrangements, but, if the officials wanted to hide it from the auditors, they also would suppress the telltale information in the board minutes.

Inquiries should be made about large and unusual financing transactions. This might not elicit a response because the event is a sales transaction according to Veritas. Other audit work on controls in the revenue and collection cycle might reveal the large sale. Fortunately, this one sticks out as a large one.

Analytical procedures to compare monthly or seasonal sales probably will identify the sale as large and unusual. This identification should lead to an examination of the sales contract. Audi- tors should discuss the business purpose of the transaction with knowledgeable officials. If being this close to discovery does not result in an admission of the loan and repurchase arrangement, the auditors nevertheless should investigate further. Even if the “customer” names were not a give- away, a quick inquiry of the corporation records office at the secretary of state will show the names of the officers, and the auditors will know the related-party nature of the deal. A request for the financial statements of Veritas should, therefore, be made.

DISCOVERY SUMMARY The auditors found the related-party relationship between the officers and Veritas. Confronted, the president admitted the attempt to make the cash position and the debt/equity ratio look better than they were. The financial statements were adjusted to reflect the pro forma set of figures shown earlier.

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Case 10.3

Go for the Gold

PROBLEM In 2009, Alta Gold Company was a public shell corporation that was purchased for $1,000 by the Blues brothers. Operating under the corporate names of Silver King and Pacific Gold, the brothers purchased numerous mining claims in auctions conducted by the U.S. Department of the Interior. They invested a total of $40,000 in 300 claims. Silver King sold limited partnership interests in its 175 Nevada silver claims to local investors, raising $20 million to begin mining production. Pacific Gold then traded its 125 Montana gold mining claims for all of the Silver King assets and partnership interests, valuing the silver claims at $20 million. (Silver King valued the gold claims received at $20 million as the fair value in the exchange.) The brothers then put $3 million obtained from dividends into Alta Gold and, with the aid of a bank loan, purchased half of the Silver King gold claims for $18 million. The Blues brothers then obtained another bank loan of $38 million to merge the remainder of Silver King’s assets and all of Pacific Gold’s mining claims by purchase. They paid off the limited partners. At the end of 2009, Alta Gold had cash of $16 million, mining assets valued at $58 million, and liabilities on bank loans of $53 million.

Alta Gold had in its files the partnership-offering documents, receipts, and other papers show- ing partners’ investment of $20 million in the Silver King limited partnerships. The company also had Pacific Gold and Silver King contracts for the exchange of mining claims. The $20 million value of the exchange was justified in light of the limited partners’ investments.

Appraisals in the files showed one appraiser’s report that there was no basis for valuing the exchange of Silver King claims other than the price limited partner investors had been willing to pay. The second appraiser reported a probable value of $20 million for the exchange based on proved production elsewhere, but no geological data on the actual claims had been obtained. The $18 million paid by Alta to Silver King also had similar appraisal reports.

The transactions occurred over a period of 10 months. The Blues brothers had $37 million of cash in Silver King and Pacific Gold as well as the $16 million in Alta (all of which was the gullible bank’s money, which the bank had loaned to Alta with the mining claims and produc- tion as security). The mining claims that had cost $40,000 were now in Alta’s balance sheet at $58 million, the $37 million was about to flee, and the bank was about to be left holding the bag containing 300 mining claim papers.

AUDIT APPROACH Alta Gold, Pacific Gold, and Silver King had no internal controls. The Blues brothers engineered all transactions and hired friendly appraisers. The only control that might have been effective was at the bank in a more diligent loan process.

The most likely control would have been the engagement of competent, independent apprais- ers. Because the auditors need to use (or try to use) the appraisers’ reports, the procedures involve investigating the reputation, engagement terms, experience, and independence of the apprais- ers. The auditors can use local business references, local financial institutions that keep lists of approved appraisers, membership directories of the professional appraisal associations, and inter- views with the appraisers themselves (AU-C 620).

The procedures for auditing the asset values include analyses of each of the transactions through all of the complications, including obtaining knowledge of the owners and managers of the several companies and the identities of the limited partner investors. If the Blues brothers did not disclose their connection with the other companies (and perhaps with the limited partners), the auditors need to inquire at the secretary of state’s offices where Pacific Gold and Silver King are incor- porated and try to discover the identities of the players in this flip game. Numerous complicated premerger transactions in small corporations and shells often signal manipulated valuations.

Loan applications and supporting papers should be examined to determine the representations Alta made in connection with obtaining the bank loans. These papers may reveal some contradic- tory or exaggerated information.

Ownership of the mining claims might be confirmed with the Department of Interior auction- eers or be found in the local county deed records (spread all over Nevada and Montana).

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DISCOVERY SUMMARY The inexperienced audit staff was unable to unravel the Byzantine exchanges and never ques- tioned the relation of Alta Gold to Silver King and Pacific Gold. They never discovered the Blues brothers’ involvement in the other side of the exchange, purchase, and merger transactions. They accepted the appraisers’ reports because they had never worked with appraisers before and thought all appraisers were competent and independent. The bank lost $37 million. The Blues brothers changed their names.

Case 10.4

No Treasure in This Treasure Planet6

PROBLEM In 2002, Disney had to take a last-minute write-down of motion picture production costs for the movie Treasure Planet. The set-in-space version of Robert Louis Stevenson’s Treasure Island cost $140 million to make, but opening five-day revenues were only $16.7 million, compared to rela- tively successful Lilo & Stitch, which grossed $35.3 million in its first weekend.

Revenue forecasts are based on many factors, including facts and assumptions about number of theaters, ticket prices, receipt-sharing agreements, domestic and foreign reviews, and moviegoer tastes. Several publications track the box-office records of movies. You can find them in newspa- per entertainment sections and in industry trade publications. Of course, the production companies themselves are the major source of the information. However, company records also show the rev- enue realized from each movie. Revenue forecasts can be checked against actual experience, and the company’s history of forecasting accuracy can be determined by comparing actual to forecast over many films and many years.

The write-down in 2002 was $74 million.

AUDIT APPROACH Revenue forecasts should be prepared in a controlled process that documents the facts and under- lying assumptions built into the forecast. Forecasts should break down the revenue estimate by years, and the accounting system should produce comparable actual revenue data so that forecast accuracy can be assessed after the fact. Forecast revisions should be prepared in as much detail and documentation as original forecasts.

The general procedures and methods used by personnel responsible for revenue forecasts should be studied (inquiries and review of documentation), including their sources of information, both internal and external. Procedures for review of mechanical aspects (arithmetic) should be tested. Select a sample of finished forecasts and recalculate the final estimate.

Specific procedures for forecast revision also should be studied in the same manner. A review of the accuracy of forecasts for other movies with hindsight on actual revenues helps in a circum- stantial way, but past accuracy on different film experiences does not directly influence the fore- casts on a new, unique product.

The audit of motion picture development costs concentrates on the content of the forecast itself. The preparation of forecasts used in the impairment calculation should be studied to distinguish underlying reasonable expectations from hypothetical assumptions. A hypothetical assumption is a statement of a condition that is not necessarily expected to occur but nonetheless is used to prepare an estimate. For example, a hypothetical assumption is like an “if-then” statement: “If Treasure Planet sells 15 million tickets in the first 12 months of release, then domestic revenue and product sales will be $40 million, and foreign revenue can eventually reach $10 million.” Auditors need to assess the reasonableness of the basic 15-million-ticket assumption. It helps to have some early actual data from the film’s release in hand before the financial statements need to be finished and distributed. For actual data, auditors should review industry publications and pay special attention to competing films and critics’ reviews (yes, movie reviews!).

6F. Ahrens, “Is Disney Losing Its Boy Appeal?” The Washington Post, December 19, 2002.

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DISCOVERY SUMMARY The company was too optimistic in its revenue forecasts, and management did not weigh unfa- vorable actual/forecast history comparisons heavily enough. Apparently, management let itself be convinced that the movie was comparable to recent animated hits from other studios such as Shrek and A Bug’s Life. One of the possible problems was the long development time—17 years from conception. The audit of forecasts and estimates used in accounting determinations is very dif- ficult, especially when company personnel have incentives to hype the numbers, seemingly with conviction about the artistic and commercial merit of their productions. The high production costs finally came home to roost in big write-offs when the film was released.

REVIEW CHECKPOINTS 10.19 What unfortunate lesson did the auditors learn from the situation in the Unregistered Sale of

Securities case? What should auditors do when a violation of U.S. securities laws is suspected? 10.20 How could auditors have discovered the off-balance-sheet financing described in the

Off-Balance-Sheet Inventory Financing case? 10.21 What effect can related-party transactions have in some cases of asset valuation? (Refer to the

Go for the Gold case.) 10.22 How should an audit team assess the reasonableness of a film studio’s estimate of film

revenues? (Refer to the No Treasure in This Treasure Planet case.)

• In this audit of an issuer in the financials industry sector, the Firm failed to, in the following respects, obtain sufficient appropriate audit evidence to support its audit opinion on the effectiveness of ICFR – The Firm’s procedures to test controls over the valuation of

a significant portion of the issuer’s investment portfolio were insuffi- cient. This portion consisted of investments either that were catego- rized as level 3 within the hierarchy set forth in Financial Accounting Standards Board (“FASB”) Accounting Standards Codification

PCAOB Inspections and the Finance and Investment Cycle

AUDITING INSIGHT

Summary The finance and investment cycle contains a wide variety of accounts: Capital Stock, Dividends, Long-Term Debt, Interest Expense, Income Tax Expense and Deferred Taxes, financial instruments, marketable securities, equity method investments, related gains and losses, consolidated subsidiaries, goodwill, and other intangibles. These accounts involve some of the most technically complex accounting standards. They create many of the difficult judgments for financial reporting.

Senior officials generally authorize these transactions and maintain control of them in these accounts. Therefore, internal control is centered on the integrity and accounting knowledge of these officials. The procedural controls over details of transactions are not very effective because senior managers can override them and order their own desired accounting presentations. As a consequence, auditors’ work on the assessment of con- trol risk is directed toward the senior managers and the board of directors, focusing on authorization and design of finance and investment activities. Because of the threat of management override and the high dollar value of many of these transactions, auditors ensure the occurrence and valuation of transactions as well as the existence and valuation of year-end balances. Many accounts consist of relatively few high-dollar transactions; therefore, the auditor often relies on substantive testing of most, if not all, of the transac- tions that occurred during the audit period. See the following Auditing Insight for some deficiencies the PCAOB noted in its inspections of the registered public accounting firms regarding audits of this cycle.

(continued)

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Key Terms

(“ASC”) Topic 820, “Fair Value Measurement,” or the value of which had a significant effect on certain income statement accounts.

• The Firm failed to perform sufficient substantive procedures to test the discounted cash-flow forecasts that the issuer used to deter- mine the fair value of its business for purposes of its annual goodwill impairment analysis. Specifically: The Firm’s procedures to evaluate the reasonableness of the revenue-growth assumptions underly- ing the discounted cash-flow forecasts consisted of (1) inquiring of management, which included obtaining an understanding of the status of the regulatory approvals for certain of the issuer’s prod- ucts; (2) comparing forecasted revenue for three products for the first year of the forecast period to actual revenue for that period and noting that the actual revenue for two of the products was sig- nificantly less than the forecast; and (3) reading a sample of sales contracts for one product. These procedures were insufficient. . .

• During the year, the issuer acquired a business, and it used cash- flow forecasts to determine the fair value of certain acquired intangible assets. The Firm selected for testing a control over the accounting for business combinations that included a review of the reasonableness of the assumptions used in the cash-flow forecasts. The Firm’s procedures to test this aspect of the control consisted of inquiring of management and inspecting emails for evidence of review and approval. The Firm failed to evaluate the nature of the review procedures performed by the control owner, including the criteria used to identify matters for follow up and the resolution of those matters.

Source: 2017 PCAOB Inspection of Ernst & Young LLP; 2017 PCAOB Inspec- tion of PricewaterhouseCoopers LLP; 2017 PCAOB Inspection of Deloitte & Touche LLP

accounting estimate: A measurement or recognition in the financial statements of (or a decision to not recognize) an account, disclosure, transaction, or event that generally involves subjective assumptions and measurement uncertainty, 463 capital budget: A listing of the proposed expenditures for property, plant, and equipment or other capital items for a period of time (usually annually). The capital budget is submitted to senior management with corporate governance responsibilities for approval; is often a part of the annual budget, 447 compensating control: A control activity instituted by a company to offset the risk imposed by a weakness in another activity, 460 derivative instrument: A financial instrument whose value is based on an index or value of another financial instrument, 473 dual control: Having two people perform a task (e.g., open the mail) as a control over the process, 451 hedging instrument: An investment made to reduce the risk of adverse price movements in a security or future transaction by taking an offsetting position in a related security such as an option or a short sale, 474 indenture: A written agreement between the issuers of bonds and the bondholders, usually specifying interest rate, maturity date, convertibility, and other terms, 475 joint custody: The safeguarding of assets by placing them in a secured area that requires two people to access (e.g., a cabinet with two locks to which no individual has both keys), 451 loan covenant: A provision in a loan agreement that requires the borrower to undertake or refrain from specified actions and to maintain specified financial levels and ratios, 456 registrar: A financial institution appointed to record issue and ownership of company securities, 447 related party: A relationship between two businesses that have a personal or other association that might destroy the self-interest of one of the parties to an extent that one of them might be prevented from fully pursuing its own separate interests, 456 special purpose entity (SPE): A partnership formed by a company to pursue particular lines of business, often used to keep risky enterprises off the company’s books. QSPE (qualified special purpose entity) is the newer term used by the FASB, 444 stock certificate book: A book (similar to a checkbook) with prenumbered stock certificates. These certificates are issued to investors with the custodian of the book recording the number of shares, the owner’s name, the date of issue, and other identification information; basically used only by small companies that are not traded publicly, 465 transfer agent: A bank or other company employed by a corporation to maintain shareholder records, including purchases, sales, and account balances, 447 trustee: Agent of a bond issuer who handles the administrative aspects of a loan and ensures that the borrower complies with the terms of the bond indenture, 450

(concluded) AUDITING INSIGHT

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Multiple-Choice Questions for Practice and Review

All applicable Exercises and Problems are available with Connect.

10.23 Which of the following approaches is most suitable for auditing the finance and investment cycle?

a. Perform extensive tests of controls and limit substantive procedures to analytical procedures. b. Ignore internal controls and perform extensive substantive procedures. c. Gain an understanding of internal controls and perform extensive substantive procedures. d. Ignore internal controls and limit substantive procedures to analytical procedures.

10.24 Loan covenants are used for which of the following reasons? a. To protect the lender from the borrower’s substantially weakening financial position. b. To protect the borrower from the lender’s calling the loan early. c. To protect the auditors from false information by the borrower. d. To protect shareholders from management taking on too much debt.

10.25 A related party is a person or entity that a. Has a family tie to a management member. b. Does business with the company. c. Can exert significant influence over or be influenced by the company. d. Is a member of the company’s management team or board of directors.

10.26 Jones was engaged to examine the financial statements of Gamma Corporation for the year ended June 30. Having completed an examination of the investment securities, which of the following is the best method of verifying the accuracy of recorded dividend income?

a. Tracing recorded dividend income to cash receipts records and validated deposit slips. b. Performing analytical procedures and statistical sampling. c. Comparing recorded dividends with amounts appearing on federal information Form 1099. d. Comparing recorded dividends with a standard financial reporting service’s record of

dividends. 10.27 When the client holds a large amount of negotiable securities, auditors need to plan to

guard against a. Unauthorized negotiation of the securities before they are counted. b. Unrecorded sales of securities after they are counted. c. Substitution of securities already counted for other securities that should be on hand but

are not. d. Substitution of authentic securities with counterfeit securities.

10.28 Which of the following internal control activities would most likely justify reducing the assessment of the risks of material misstatement for long-term notes payable?

a. The use of prenumbered purchase orders to prevent unrecorded notes. b. All direct borrowings on notes payable are authorized by the board of directors. c. Any use of assets for collateral on long-term notes payable are analyzed for criticality to

operations. d. Proceeds from long-term notes payable are included in regular review of budgets to

ensure adequacy of cash flow availability. 10.29 Which of the following assertions is most likely to have the highest risk of material mis-

statement for the goodwill account? a. Existence b. Completeness c. Valuation d. Rights & Obligations

10.30 In connection with the audit of an issue of long-term bonds payable, the audit team should a. Determine whether bondholders are persons other than owners, directors, or officers of

the company issuing the bond.

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b. Calculate the effective interest rate to see whether it is substantially the same as the rates charged for similar issues.

c. Decide whether the bond issue was made without violating state or local laws or regulations. d. Ascertain that the client has obtained the opinion of counsel on the legality of the issue.

10.31 Which of the following is the most important audit consideration when examining the stockholders’ equity section of a client’s balance sheet?

a. Changes in the capital stock account are verified by an independent stock transfer agent. b. Stock dividends and stock splits during the year under audit were approved by the

stockholders. c. Stock dividends are capitalized at par or stated value on the dividend declaration date. d. Entries in the capital stock account can be traced to resolutions in the minutes of meet-

ings of the board of directors. 10.32 If the auditors discover that the carrying amount of a client’s investments is overstated

because of a loss in value that is other than a temporary decline in market value, they should insist that

a. The approximate market value of the investments be shown in parentheses on the face of the balance sheet.

b. The investments be classified as long term for balance-sheet purposes with full disclo- sure in the footnotes.

c. The loss in value be recognized in the financial statements. d. The equity section of the balance sheet separately show a charge equal to the amount of

the loss. 10.33 The primary reason for preparing a reconciliation between interest-bearing obligations out-

standing during the year and interest expense in the financial statements is to a. Evaluate internal control over securities. b. Determine the validity of prepaid interest expense. c. Ascertain the reasonableness of imputed interest. d. Detect unrecorded liabilities.

10.34 The auditors should insist that a representative of the client be present during the inspection and count of securities to

a. Lend authority to the auditors’ directives. b. Detect forged securities. c. Coordinate the return of all securities to proper locations. d. Acknowledge the receipt of securities returned.

10.35 When independent stock transfer agents are not employed and the corporation issues its own stock and maintains stock records, canceled stock certificates should

a. Be defaced to prevent reissuance and attached to their corresponding stubs. b. Not be defaced but be segregated from other stock certificates and retained in a canceled

certificates file. c. Be destroyed to prevent fraudulent reissuance. d. Be defaced and sent to the secretary of state.

10.36 When a client company does not maintain its own capital stock records, the auditors should obtain written confirmation from the transfer agent and registrar concerning

a. Restrictions on the payment of dividends. b. The number of shares issued and outstanding. c. Guarantees of preferred stock liquidation value. d. The number of shares subject to agreements to repurchase.

(AICPA adapted) 10.37 All corporate capital stock transactions should ultimately be traced to the

a. Minutes of the meetings of the board of directors. b. Cash receipts journal. c. Cash disbursements journal. d. Numbered stock certificates.

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10.38 An audit plan for the examination of the retained earnings account should include a step that requires verification of the (choose two steps)

a. Market value used to charge retained earnings to account for a 2-for-1 stock split. b. Approval of the adjustment to the beginning balance as a result of a write-down of

account receivables. c. Authorization for both cash and stock dividends declared and paid. d. Gain or loss resulting from disposition of treasury shares.

10.39 When an entity uses a trust company as custodian of its marketable securities, the possibil- ity of concealing fraud most likely would be reduced if the

a. Trust company has no direct contact with the entity employees responsible for maintain- ing investment accounting records.

b. Securities are registered in the name of the trust company rather than the entity itself. c. Interest and dividend checks are mailed directly to an entity employee who is authorized

to sell securities. d. The trust company places the securities in a bank safe deposit vault under the custo-

dian’s exclusive control. (AICPA adapted)

10.40 An audit team would most likely verify the interest earned on bond investments by a. Vouching the receipt and deposit of interest checks. b. Confirming the bond interest rate with the issuer of the bonds. c. Recomputing the interest earned on the basis of face amount, interest rate, and period held. d. Testing internal controls relevant to cash receipts.

(AICPA adapted) 10.41 A client has a large and active investment portfolio that is kept in a bank safe deposit box.

If the auditors are unable to count securities at the balance sheet date, they most likely will a. Request the bank to confirm to the auditors the contents of the safe deposit box at the

balance-sheet date. b. Examine supporting evidence for transactions occurring during the year. c. Count the securities at a subsequent date and confirm with the bank whether securities

were added or removed since the balance-sheet date. d. Request the client to have the bank seal the safe deposit box until the auditors can count

the securities at a subsequent date. (AICPA adapted)

10.42 An audit team testing long-term investments would ordinarily use analytical procedures to ascertain the reasonableness of the

a. Existence of unrealized gains or losses. b. Completeness of recorded investment income. c. Classification as available-for-sale or trading securities. d. Valuation of trading securities.

(AICPA adapted) 10.43 In auditing for unrecorded long-term bonds payable, an audit team most likely will

a. Perform analytical procedures on the bond premium and discount accounts. b. Examine documentation of assets purchased with bond proceeds for liens. c. Compare interest expense with the bond payable amount for reasonableness. d. Confirm the existence of individual bondholders at year-end.

(AICPA adapted) 10.44 An audit plan to examine long-term debt most likely would include steps that require

a. Comparing the carrying amount of held-to-maturity securities with their year-end mar- ket values.

b. Correlating interest expense recorded for the period with outstanding debt. c. Verifying the existence of the holders of the debt by direct confirmation. d. Inspecting the accounts payable subsidiary ledger for unrecorded long-term debt.

(AICPA adapted)

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10.45 Which of the following questions would auditors most likely include on an internal control questionnaire for notes payable?

a. Are assets that collateralize notes payable critically needed for the entity’s continued existence?

b. Are two or more authorized signatures required on checks that repay notes payable? c. Are the proceeds from notes payable used to purchase noncurrent assets? d. Are direct borrowings on notes payable authorized by the board of directors?

(AICPA adapted) 10.46 An audit team’s purpose in reviewing the documentation concerning the renewal of a note

payable shortly after the balance-sheet date most likely is to obtain evidence concerning management’s assertions about

a. Existence. b. Valuation. c. Completeness. d. Classification.

(AICPA adapted) 10.47 Which of the following audit procedures would not likely be performed for audits of

investments? a. Read board of directors’ minutes for authorization of investment strategies. b. Confirm investments with registrar. c. Confirm investments with broker or trustee. d. Compare valuation to published market prices.

10.48 Which of the following audit procedures would not likely be performed for audits of share- holders’ equity?

a. Read board of directors’ minutes for authorization of equity transactions. b. Confirm outstanding common and preferred stock with stock registrar. c. Compare valuation of stock to published market prices. d. Obtain management representation about number of shares issued and outstanding.

10.49 ABC Company has 100 shares of IBM stock that it holds as an investment. The stock was purchased three years ago and has been in the client’s safe deposit box along with other investment securities. During an inspection of securities held by the client, the auditor noted the 100 shares of IBM stock had a different CUSIP number than the number listed when purchased and the number verified during the previous audit. Which of the following would be the auditor’s main concern about this discovery?

a. The certificates in the safe deposit box were forgeries. b. There had been unauthorized buying and selling of investment securities. c. The securities may be misclassified on the balance sheet. d. ABC Company no longer owns the securities.

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All applicable questions are available with Connect. Exercises and Problems

10.50 Internal Control Questionnaire for Equity Investments. Cassandra Corporation, a man- ufacturing company, periodically invests large sums in marketable equity securities. The investment committee of the board of directors established the investment policy. The trea- surer is responsible for carrying out the investment committee’s directives. All securities are stored in a bank safe deposit vault. Your internal control questionnaire with respect to Cassandra’s investments in equity securities contains the following three questions: 1. Is investment policy established by the investment committee of the board of directors? 2. Is the treasurer solely responsible for carrying out the investment committee’s directive? 3. Are all securities stored in a bank safe deposit vault?

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Required: In addition to these three questions, what questions should your internal control question-

naire include with respect to the company’s investment in marketable equity securities? (Hint: Prepare questions to cover management’s transaction assertions of occurrence, completeness, cutoff, accuracy, classification.)

(AICPA adapted) 10.51 Investment Securities. You are engaged in the audit of the financial statements of Bass

Corporation for the year ended December 31 and you are about to begin an audit of the investment securities. Bass’s records indicate that the company owns various bearer bonds as well as 25 percent of the outstanding common stock of Commercial Industrial Inc. All securities in Bass’s portfolio are actively traded in a broad market. You are satisfied with evidence that supports the presumption of significant influence over Commercial Industrial Inc. The various securities are at two locations as follows:

1. Recently acquired securities are in the company’s safe in the custody of the treasurer. 2. All other securities are in the company’s bank safe deposit box.

Required: a. Assuming that the internal controls over securities are satisfactory, what are the objec-

tives (specific assertions) for the audit of the held-to-maturity securities? b. What audit procedures should you undertake with respect to obtaining audit evidence for

the existence and cost valuation of Bass’s securities in the held-to-maturity classification? c. What audit procedures should you undertake with respect to obtaining audit evidence

against Bass’s investment in Commercial Industrial Inc.? d. What audit procedures should you undertake with respect to obtaining audit evidence

about the classification of held-to-maturity securities in the Bass portfolio? (Hint: Review the audit plan in Appendix Exhibit 10B.1.)

e. Suppose that the held-to-maturity portfolio (excluding the investment in Commercial Industrial Inc.) is carried at cost in the amount of $3,450,000. What audit procedures should you undertake with respect to obtaining audit evidence about the fair market value of this portfolio?

f. Suppose that the auditors determine that the held-to-maturity portfolio (excluding the investment in Commercial Industrial Inc.) has an aggregate fair market value of $2,970,000. What audit procedures should they undertake with respect to obtaining audit evidence regarding a value impairment that might be “other than temporary”? (Hint: Review the audit plan in Appendix Exhibit 10B.1.)

(AICPA adapted) 10.52 Lease Accounting. Union Pacific Corp. opened its new 19-story, $260 million headquar-

ters in Omaha, Nebraska. The railroad operator is the owner of the city’s largest build- ing, the Union Pacific Center. Under an initial operating lease, Union Pacific guaranteed 89.9 percent of all construction costs through the building’s completion date. After completing the building, the company signed a new operating lease, which guarantees 85 percent of the building’s costs. Both were “synthetic” leases, which allow the company to take income tax deductions for interest and depreciation while maintaining complete operational control (Jonathan Weil, “Open Secrets: How Leases Play a Shadowy Role in Accounting,” The Wall Street Journal, September 22, 2004).

Required: a. Explain why Union Pacific would want to structure the lease to be an operating lease. b. What audit evidence would you require for testing the appropriate accounting for this lease?

10.53 Securities Examination and Count. You are in charge of the audit of the financial state- ments of Demot Corporation for the year ended December 31. The corporation has a policy of investing its surplus funds in marketable securities. Its stock and bond certificates are kept in a safe deposit box in a local bank. Only the president and the treasurer of the corpo- ration have access to the box.

You were unable to obtain access to the safe deposit box on December 31 because neither the president nor the treasurer was available. Arrangements were made for your assistant to accompany the treasurer to the bank on January 11 to examine the securities. Your assistant should be able to inspect all securities on hand in an hour. Your assistant has never exam- ined securities in the safe deposit box and requires instructions.

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Required: a. List the instructions that you should give to your assistant regarding the examination of

the stock and bond certificates kept in the safe deposit box. Include in your instructions the details of the securities to be examined and the reasons for examining these details.

b. After returning from the bank, your assistant reports that the treasurer had entered the box on January 4 to remove an old photograph of the corporation’s original building. The photograph was loaned to the local chamber of commerce for display purposes. List the additional audit procedures that are required because of the treasurer’s action.

(AICPA adapted) 10.54 Audit Objectives and Procedures for Investments. In the audit of investment securities,

auditors develop specific audit assertions related to the investments. They then design spe- cific substantive procedures to obtain evidence about each of these assertions. Following is a selection of investment securities assertions:

1. Investments are properly described and classified in the financial statements. 2. Recorded investments represent investments actually owned at the balance-sheet date. 3. Investments are properly valued at the balance-sheet date.

Required: For each of these assertions, select the following audit procedure that is best suited for the audit

plan. Select only one procedure for each assertion. A procedure may be selected once or not at all. a. Trace opening balances in the general ledger to prior-year audit documentation. b. Determine whether employees who are authorized to sell investments have access to cash. c. Examine supporting documents for a sample of investment transactions to verify that

prenumbered documents are used. d. Determine whether any other-than-temporary impairments in the carrying value of

investments have been properly recorded. e. Verify that transfers from the trading portfolio to the held-to-maturity investment portfo-

lio have been properly recorded. f. Obtain positive confirmations as of the balance sheet date of investments held by inde-

pendent custodians. g. Trace investment transactions to minutes of the board of directors meetings to determine

that transactions were properly authorized. (AICPA adapted)

10.55 Intangibles. Sorenson Manufacturing Corporation was incorporated on January 3, 2019. The corporation’s financial statements for its first year’s operations were not examined by a CPA. You have been engaged to audit the financial statements for the year ended December 31, 2017, and your work is substantially completed. A partial trial balance of the company’s accounts follows:

SORENSON MANUFACTURING CORPORATION Trial Balance

At December 31, 2020

Debit Credit

Cash $11,000 Accounts receivable 42,500  Allowance for doubtful accounts $500 Inventories 38,500 Machinery 75,000 Equipment 29,000 Accumulated depreciation 10,000 Patents 85,000 Leasehold improvements 26,000 Prepaid expenses 10,500 Organization expenses 29,000 Goodwill 24,000 Licensing Agreement No. 1*  50,000 Licensing Agreement No. 2* 49,000

*An intangible asset representing the right to use a patent.

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The following information relates to accounts that may yet require adjustment: 1. Patents for Sorenson’s manufacturing process were purchased January 2, 2020, at a cost

of $68,000. An additional $17,000 was spent in December 2019 to improve machinery covered by the patents and charged to the Patents account. The patents had a remaining legal term of 17 years.

2. On January 3, 2017, Sorenson purchased two licensing agreements; at that time they were believed to have unlimited useful lives. The balance in the Licensing Agreement No. 1 account included its purchase price of $48,000 and $2,000 in acquisition expenses. Licens- ing Agreement No. 2 also was purchased on January 3, 2019, for $50,000, but it has been reduced by a credit of $1,000 for the advance collection of revenue from the agreement.

3. In December 2019, an explosion caused a permanent 60 percent reduction in the expected revenue-producing value of Licensing Agreement No. 1 and, in January 2020, a flood caused additional damage, which rendered the agreement worthless.

4. A study of Licensing Agreement No. 2 made by Sorenson in January 2020 revealed that its estimated remaining life expectancy was only 10 years as of January 1, 2020.

5. The balance in the Goodwill account includes $24,000 paid December 30, 2019, for an advertising program, which it is estimated will assist in increasing Sorenson’s sales over a period of four years following the disbursement.

6. The Leasehold Improvement account includes (a) the $15,000 cost of improvements with a total estimated useful life of 12 years, which Sorenson, as tenant, made to leased prem- ises in January 2019; (b) movable assembly-line equipment costing $8,500, which was installed in the leased premises in December 2020; and (c) real estate taxes of $2,500 paid by Sorenson, which, under the terms of the lease, should have been paid by the land- lord. Sorenson paid its rent in full during 2020. A 10-year nonrenewable lease was signed January 3, 2019, for the leased building that Sorenson used in manufacturing operations.

7. The balance in the Organization Expenses account includes preoperating costs incurred during the organizational period.

Required: For each of the items 1–7

a. Prepare adjusting entries as necessary. b. Identify the substantive audit procedures you would perform to test the transactions.

(AICPA adapted) 10.56 Loan Covenants. A loan covenant is a condition requiring the borrower to comply with the

terms of a loan agreement. If the borrower does not act in accordance with the covenants, the loan can be considered in default and the lender has the right to demand payment (usually in full).

Required: a. Why do banks add covenants to loan agreements? b. The following is a list of common loan covenants. For each covenant, indicate what the

bank is trying to accomplish by requiring it. (1) Maintain hazard insurance/content insurance. (2) Maintain key-person life insurance. (3) Make all payments of taxes/fees/licenses. (4) Provide financial information on borrower and guarantor. (5) Maintain a certain level in key financial ratios such as (a) Minimum quick and current ratios (liquidity). (b) Minimum return on assets and return on equity (profitability). (c) Minimum equity and minimum working capital. (d) Maximum debt to worth (leverage). (6) Make no change of management or merger without prior approval. (7) Obtain no more loans without prior approval. (8) Make no dividends/withdrawals or limited dividend withdrawals. c. For each item 1–7, indicate where the auditor would be most likely to find evidence of

the company’s adherence with the covenant. d. Why is it important for an auditor to review the covenants and review documents related

to each item listed in part (b)?

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10.57 Long-Term Financing Agreement. You have been engaged to audit the financial state- ments of Broadwall Corporation for the year ended December 31, 2020. During the year, Broadwall obtained a long-term loan from a local bank pursuant to a financing agreement, which provided the following:

1. The loan is to be secured by the company’s inventory and accounts receivable. 2. The company is to maintain a debt:equity ratio not to exceed 2:1. 3. The company is not to pay dividends without permission from the bank. 4. Monthly installment payments are to commence July 1, 2020. In addition, during the

year, the company also borrowed, on a short-term basis, substantial amounts just prior to the year-end from the president of the company.

Required: a. For the purposes of your audit of the Broadwall Corporation’s financial statements, what

procedures should you employ in examining the described loans? Do not discuss inter- nal control.

b. What are the financial statement disclosures that you should expect to find with respect to the loan from the president?

10.58 Bond Indenture Covenants. The following covenants are extracted from the indenture of a bond issue. The indenture provides that failure to comply with its terms in any respect automatically advances the due date of the loan to the date of noncompliance (the stated date is 20 years hence). Give any audit steps or reporting requirements you believe should be taken or recognized in connection with each of the following:

1. “The debtor company shall endeavor to maintain a working capital ratio of 2:1 at all times and, in any fiscal year following a failure to maintain said ratio, the company shall restrict compensation of officers to a total of $500,000. Officers for this purpose shall include the board chair, president, all vice presidents, secretary, and treasurer.”

2. “The debtor company shall keep all property that is security for this debt insured against loss by fire to the extent of 100 percent of its actual value. Policies of insurance compris- ing this protection shall be filed with the trustee.”

3. “The debtor company shall pay all taxes legally assessed against property that is secu- rity for this debt within the time provided by law for payment without penalty and shall deposit receipted tax bills or equally acceptable evidence of payment of same with the trustee.”

(AICPA adapted) 10.59 Common Stock and Treasury Stock: Substantive Audit Procedures. You are the

continuing auditor of Sussex Inc. and are beginning the audit of the common stock and treasury stock accounts. You have decided to design substantive procedures with reliance on internal controls.

Sussex has no-par, no-stated-value common stock and acts as its own registrar and trans- fer agent. During the past year, Sussex both issued and reacquired shares of its own com- mon stock, some of which the company still owned at year-end. Additional common stock transactions occurred among the shareholders during the year.

Common stock transactions can be traced to individual shareholders’ accounts in a sub- sidiary ledger and to a stock certificate book. The company has not paid any cash or stock dividends. There are no other classes of stock, stock rights, warrants, or option plans.

Required: What substantive procedures should you apply in examining the common stock and trea-

sury stock accounts? Organize your answer as a list of audit procedures organized by the financial statement assertions. (See Appendix Exhibit 10B.4 for examples of substantive procedures for stockholders’ equity.)

(AICPA adapted) 10.60 Stockholders’ Equity. You are a CPA engaged in an audit of the financial statements of

Pate Corporation for the year ended December 31. The financial statements and records of Pate Corporation have not been audited by a CPA in prior years. The stockholders’ equity section of Pate Corporation’s balance sheet at December 31 follows:

Pate Corporation was founded in 1985. The corporation has 10 stockholders and serves as its own registrar and transfer agent. No capital stock subscription contracts are in effect.

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Required: a. Prepare the detailed audit plan for the examination of the three accounts composing the

stockholders’ equity section of Pate Corporation’s balance sheet. Organize the audit plan under broad financial statement assertions. (Do not include in the audit plan the audit of the results of the current-year operations.)

b. After every other figure on the balance sheet has been audited, it might appear that the retained earnings figure is a balancing figure and requires no further audit work. Why do auditors audit retained earnings as they do the other figures on the balance sheet? Discuss.

(AICPA adapted) 10.61 Intercompany and Interpersonal Investment Relations. You have been engaged to audit

the financial statements of Hardy Hardware Distributors Inc., as of December 31. In your review of the corporate nonfinancial records, you have found that Hardy Hardware owns 15 percent of the outstanding voting common stock of Hardy Products Corporation. Upon further investigation, you learn that Hardy Products Corporation manufactures a line of hardware goods, 90 percent of which is sold to Hardy Hardware.

James L. Hardy, president of Hardy Hardware, has supplied you objective evidence that he personally owns 30 percent of the Hardy Products voting stock and the remaining 70  percent is owned by Juana Hardy Lewis, his sister and president of Hardy Products. Hardy also owns 20 percent of the voting common stock of Hardy Hardware Distributors, another 20 percent is held by an estate of which Hardy and Lewis are beneficiaries, and the remaining 60 percent is publicly held. The stock is listed on the American Stock Exchange.

Hardy Hardware consistently has reported operating profits higher than the industry aver- age. Hardy Products Corporation, however, has a net return on sales of only 1 percent. The Hardy Products investment always has been reported at cost, and no dividends have been paid by the company. During the course of your conversations with the Hardy siblings, you learn that you were appointed as auditor because they had a heated disagreement with the former auditors over the issues of accounting for the Hardy Products investment and the prices at which goods have been sold to Hardy Hardware.

Required: Discuss the following: a. Identify the issues in this situation as they relate to (1) conflicts of interest and (2) con-

trolling influences among individuals and corporations. b. Should the investment in Hardy Products Corporation be accounted for using the equity

method? c. What evidence should the auditor seek with regard to the prices paid by Hardy Hardware

for products purchased from Hardy Products Corporation? d. What information would you consider necessary for adequate disclosure in the financial

statements of Hardy Hardware Distributors?

Instructions for Discussion Cases 10.62–10.64 These cases are designed to be similar to the ones in the chapter. They give the problem, and your assignment is to write the audit approach portion of the case organized around these sections:

∙ Objectives. Express the objective in terms of the facts supposedly asserted in financial records, accounts, and statements.

∙ Control. Write a brief explanation of control considerations, especially the kinds of manipulations that could arise from the situation described in the case.

∙ Tests of controls. Write some procedures for getting evidence about existing controls, especially procedures that could discover management manipulations. If there are no con- trols to test, there are no procedures to perform; go on then to the next section. A proce- dure should instruct someone about the source(s) of evidence to tap and the work to do.

∙ Audit of balance. Write some procedures for getting evidence about the existence, com- pleteness, valuation, rights, and disclosure assertions identified in your objectives section.

∙ Discovery summary. Write a short statement about the discovery you expect to accom- plish with your procedures.

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10.62 Related-Party Transaction “Goodwill.” Write the audit approach section like the cases in the chapter.

Hide the Loss under the Goodwill Gulwest Industries, a public company, decided to discontinue its unprofitable line of busi-

ness of manufacturing sporting ammunition. Gulwest had capitalized the startup cost of the business, and with its discontinuance, the $7 million deferred cost should have been writ- ten off. Instead, Gulwest formed a new corporation, Amron, and transferred the sporting ammunition assets (including the $7 million deferred cost) to it in exchange for all Amron stock. In the Gulwest accounts, the Amron investment was carried at $12.4 million, which was the book value of the assets transferred (including the $7 million deferred cost).

Gulwest and a different public company (Big Industrial) created another company (Big- Shot Ammunition). Gulwest transferred all Amron assets to BigShot in exchange for (1) common and preferred stock of Big Industrial valued at $2 million and (2) a note from BigShot in the amount of $3.4 million. Big Industrial thus acquired 100 percent of the stock of BigShot. Gulwest management reasoned that it had “given” Amron stock val- ued at $12.4  million to receive stock and notes valued at $5.4 million, so the difference must  be  goodwill. Thus, the Gulwest accounts carried amounts for Big Industrial Stock ($2 million), BigShot’s note receivable ($3.4 million), and Goodwill ($7 million).

Gulwest directors included in the minutes of board meetings an analysis of the sporting ammunition business’s lack of profitability. The minutes showed approval of a plan to dis- pose of the business, but they did not use the words discontinue the business. The minutes also showed approval of the creation of Amron, the deal with Big Industrial, the formation of BigShot, and the acceptance of Big’s stock and BigShot’s note in connection with the final exchange and merger.

10.63 Related-Party Transaction Valuation. Follow the instructions preceding the case in prob- lem 10.62. Write the audit approach section like the cases in the chapter.

In Plane View Whiz Corporation owned 160,000 shares of Wing Company stock, carried on the books

as an investment in the amount of $6,250,000. Whiz bought a used airplane from Wing, giving in exchange (1) $480,000 cash and (2) the 160,000 Wing shares. Even though the quoted market value of the Wing stock was $2,520,000, Whiz valued the airplane received at $3,750,000, indicating a stock valuation of $3,270,000. Thus, Whiz recognized a loss on disposition of the Wing stock in the amount of $2,980,000.

Whiz justified the airplane valuation with another transaction. On the same day it was purchased, Whiz sold the airplane to the Mexican subsidiary of one of its subsidiary com- panies (two layers down, but Whiz owned 100 percent of the first subsidiary, which in turn owned 100 percent of the Mexican subsidiary). The Mexican subsidiary paid Whiz with US$25,000 cash and a promissory note for US$3,725,000 (market rate of interest).

The transaction was within the authority of the chief executive officer, and company pol- icy did not require a separate approval by the board of directors. A contract of sale and cor- respondence with Wing detailing the terms of the transaction were in the files. Likewise, a contract of sale to the Mexican subsidiary, a copy of the deposit slip, and a memorandum of the promissory note were on file. The note itself was kept in the company vault. None of the Wing papers cited a specific price for the airplane.

Whiz overvalued the Wing stock and justified it with a related-party transaction with its own subsidiary company. The loss on the disposition of the Wing stock was understated by $750,000.

10.64 Lack of Controls over Investments. Follow the instructions preceding the case in problem 10.62. Write the audit approach section like the cases in the chapter.

Rogue Trader In February 1989, 22-year-old Nicholas Leeson joined Barings Investment Bank. In 1993,

he began trading on behalf of the Barings group as a “proprietary trader” on the Singapore International Monetary Exchange (SIMEX). By 1995, he had wiped out the 233-year-old bank, which had counted Queen Elizabeth as a client. He left behind liabilities totaling $1.3 billion. As a proprietary trader, Leeson was to arbitrage or take advantage of differ- ences between the prices quoted for identical contracts on SIMEX and on other exchanges. This was supposed to be achieved by entering into matching purchase and sale contracts

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simultaneously to capture favorable price differences. Unfortunately, Leeson entered into very large contracts that were not matched with offsetting contracts, exposing the bank to enormous potential losses from even small market movements. These trades were hidden in a separate account: 88888. Transactions were transferred from other Barings accounts into account 88888 to artificially generate a profit for the other accounts.

During the period, Barings was reorganizing and Leeson reported to local managers in Singapore and product managers in London. Neither set of managers checked Leeson’s activities. An internal audit report had criticized the reporting structure, but its recommen- dations were never implemented. Funds to finance Leeson’s trades were requested from him to ostensibly fund client positions and were recorded as receivables from clients. The credit control group never reviewed the creditworthiness of the clients because they said they were never informed of the remittances.

Leeson’s managers accepted reports of his profitability with admiration. They did not question the unusually large profits from his trading that would have been unlikely from an arbitrage operation.

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Internal Control Questionnaires

Appendix 10A

EXHIBIT 10A.1 Internal Control Questionnaire: Investments

Yes/No Comments

Environment  1. Does the board of directors authorize investment strategies?  2. Are investment structures based on legitimate business goals?  3. Are trading guidelines and limits established by company policy?  4. Are derivatives used for legitimate company objectives?  5. Are brokerage relationships reviewed for potential conflicts of interests?  6.  Are personnel recording investments competent and appropriately trained to

ensure the accuracy and appropriateness of journal entries? Existence/Occurrence  7. Are brokerage statements reconciled to the general ledger monthly? Completeness  8. Are company traders monitored in their discussions with brokers? Valuation  9. Does accounting review all significant transactions? 10.  Are purchases and sales of investments listed on brokerage statements compared

to changes in the investment account? 11.  Are purchases and sales of investments listed on brokerage statements compared

to receipts and disbursements? 12.  Are changes in investments accounted for on the equity method monitored and

recorded in the financial statements? 13. Are accounting personnel trained in standards for hedge accounting? Cutoff 14.  Are purchases and sales of investments listed on brokerage statements compared to

changes in the investment account to ensure they were recorded in the proper period? Presentation and disclosure 15. Are investment classifications based on legitimate management intentions? 16. Are disclosures reviewed by senior management?

EXHIBIT 10A.2 Internal Control Questionnaire: Notes Payable

Yes/No Comments

Environment  1. Are notes payable records kept by someone who cannot sign notes or checks?  2.  Are direct borrowings on notes payable authorized by the directors? By the

treasurer or by the chief financial officer?  3. Are two or more authorized signatures required on notes? Existence/Occurrence  4. Are paid notes canceled, stamped PAID, and filed? Completeness  5.  Is all borrowing authorized by the directors checked to determine whether all

notes payable are recorded? Valuation  6. Are loan documents forwarded to accounting for review?  7. Are bank due notices compared with records of unpaid liabilities?  8.  Is the subsidiary ledger of notes payable periodically reconciled with the general

ledger control account(s)? Are interest payments and accruals monitored for due dates and financial statement dates?

Cutoff  9. Are new notes recorded in the appropriate period? Presentation and disclosure 10.  Is sufficient information available in the accounts to enable financial statement

preparers to classify current and long-term debt properly?

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APPENDIX 10B

Substantive Audit Plans

EXHIBIT 10B.1

DUNDER-MIFFLIN INC. Audit Plan for Fair Market Value of Assets and Liabilities December 31, 2020

Performed By Ref.

A. Review Details of Management’s Valuation Approach 1. Assess the completeness of management assumptions (i.e., whether management has considered all

relevant issues). 2. Determine the reasonableness of significant assumptions, including whether these assumptions reflect a. The general economic environment. b. The specific industry’s economic and regulatory environment. c. Other market information. d. Assumptions made in prior periods. e. Past experience with the entity. f. The potential variability in the amount and timing of cash flows and related effect on the discount rate. g. Results of other audit procedures. 3. Obtain data used in reaching these assumptions including a. Recency of data. b. Source of data. c. Consistency of data (i.e., assumptions used in one calculation are consistent with assumptions used in

other calculations). 4. Reperform computations. 5. Trace data to source documents for accuracy. 6. Identify possible bias or misapplication of assumptions. B.  Reperform the Valuation Process to Provide an Auditor’s Estimate of the Value Estimate and Compare

That Value to Management’s Estimate C. Review Transactions That Have Occurred since Year-End That Provide Evidence 1. Determine whether the assumptions underlying management’s valuation supports (or refutes) that valuation. 2. Review the valuation itself. D.  Document All Management Assumptions and Audit Procedures Used to Substantiate Those Assumptions

DUNDER-MIFFLIN INC. Audit Plan for Investments and Related Accounts

December 31, 2020

Performed By Ref.

A. Investments and Related Accounts 1. Obtain a schedule of all investments, including purchase and disposition information for the period. Reconcile

with investment accounts in the general ledger. 2. Inspect or confirm with a trustee or broker the name, number, identification, interest rate, and face amount (if

applicable) of securities held as investments. 3. Vouch the cost of recorded investments to brokers’ reports, contracts, canceled checks, and other supporting

documentation. 4. Vouch recorded sales to brokers’ reports and bank deposit slips and recalculate gain or loss on disposition. 5. Recalculate interest income and verify dividend income from a dividend-reporting service (such as Moody’s or

Standard & Poor’s annual dividend record). 6. Obtain market values of investments and determine whether any write-down or write-off is necessary. Scan

transactions soon after the client’s year-end to see whether any investments were sold at a loss. Recalculate the unrealized gains and losses required for fair value securities accounting.

(continued)

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DUNDER-MIFFLIN INC. Audit Plan for Investments and Related Accounts

December 31, 2017

Performed By Ref.

7. Read loan agreements and minutes of the board of directors and inquire of management about pledges of investments as security for loans.

8. Obtain audited financial statements of joint ventures, investee companies (equity method of accounting), subsidiary companies, and other entities in which an investment interest is held. Evaluate indications of significant controlling influence. Inspect documents for proper balance sheet classification and conformity with accounting principles.

9. Obtain management representations concerning pledge of investment assets as collateral. B. Investments in Debt and Equity Securities 1. Review the proper classification of securities in the categories of held-to-maturity, available-for-sale, and

trading securities. a. Inquire about management’s intent regarding classifications. b. Inspect written records of investment strategies. c. Inspect documentation for investment activities and transactions. d. Review instructions to portfolio managers. e. Inspect minutes of the investment committee of the board of directors. 2. Review whether facts support management’s intent to hold securities to maturity. a. Inquire of management concerning the company’s financial position, working capital requirements, results

of operations, debt agreements, guarantees, and applicable laws and regulations. b. Inspect documentation and review for compliance with working capital requirements, debt agreements,

guarantees, and applicable laws and regulations. c. Inspect the company’s cash flow forecasts. d. Obtain management representations confirming proper classification with regard to intent and ability. 3. Review the value of debt and equity securities by performing the following: a. Obtain published market quotations. b. Obtain market prices from broker-dealers who are market makers in particular securities. c. Obtain valuations from expert specialists. d. Inspect documentation and review proprietary market valuation models for reasonableness and evaluate

the data and assumptions in them are appropriate. 4. Review whether value impairments are “other than temporary,” considering evidence of the following: a. Fair market is materially below cost. b. The value decline is due to specific adverse conditions. c. The value decline is industry or geographically specific. d. Management does not have both the intent and the ability to hold the security long enough for a

reasonable hope of value recovery. e. The fair value decline has existed for a long time. f. A debt security has been downgraded by a rating agency. g. The financial condition of the issuer has deteriorated. h. Dividends of interest payments have been reduced or eliminated.

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DUNDER-MIFFLIN INC. Audit Plan for Notes Payable and Long-Term Debt

December 31, 2020

Performed By Ref.

1. Obtain a schedule of notes payable and other long-term debt (including capitalized lease obligations) showing beginning balances, new notes/ issuances, repayment, and ending balances. Trace to general ledger accounts.

2. Confirm liabilities with creditor: amount, interest rate, due date, collateral, and other terms. Some of these confirmations may be standard bank confirmations.

3. Review the standard bank confirmation for evidence of assets pledged as collateral and for unrecorded obligations.

4. Review loan agreements for terms and conditions that need to be disclosed and for pledge of assets as collateral.

5. Recalculate the portion of long-term debt classified as a current liability and trace to the trial balance.

6. Inspect lease agreements for indications of need to capitalize leases. Recalculate the capital and operating lease amounts for required disclosures.

7. Recalculate interest expense on debts and trace to the interest expense and accrued interest accounts.

8. Obtain written representations from management concerning notes payable, collateral agreements, and restrictive covenants.

EXHIBIT 10B.3

DUNDER-MIFFLIN INC. Audit Plan for Stockholders’ Equity

December 31, 2020

Performed By Ref.

1. Obtain an analysis of stockholders’ equity transactions. Trace additions and reductions to the general ledger.

a. Vouch additions to directors’ minutes and cash receipts. b. Vouch reductions to directors’ minutes and other supporting documents. 2. Read the directors’ minutes for stockholders’ equity authorization. Trace to

entries in the accounts. Review related disclosures for completeness and accuracy.

3. Confirm outstanding common and preferred stock with stock registrar. 4. Vouch stock option and profit-sharing plan disclosures to contracts and plan

documents. 5. Vouch treasury stock transactions to cash receipts and cash disbursement

records and to directors’ authorization. Inspect treasury stock certificates. 6. When the company keeps its own stock records: a.  Inspect the stock record stubs for certificate numbers and number of

shares. b. Inspect the unissued certificates. 7. Obtain management representations about the number of shares issued and

outstanding.

EXHIBIT 10B.4

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LEARNING OBJECTIVES This chapter discusses the completion of the audit examination and identifies major events and auditors’ responsibilities in the completion stage of the audit.

Your objectives are to be able to:

LO 11-1 Identify major activities performed by auditors in completing the substantive procedures following the date of the financial statements.

LO 11-2 Understand the role of attorney letters in evaluating litigation, claims, and assessments.

LO 11-3 Explain why auditors obtain written representations and identify the key components of written representations.

LO 11-4 Identify the final steps in the completion of an audit.

LO 11-5 Understand auditors’ responsibility for subsequent events and subsequently discovered facts.

LO 11-6 Identify important activities and communica- tions following the completion of the audit and audit report release date.

“Yogi” Berra, former American Major League Baseball catcher, coach, and manager

It ain’t over till it’s over.

Completing the Audit

C H A P T E R 1 1

Professional Standards References

Topic AU-C/ISA Section AS Section

Quality Control for an Audit Engagement 220 1220

Communication with Those Charged with Governance 260 1301

Communicating Internal Control-Related Matters Identified in an Audit 265 1305

Evaluation of Misstatements 450 2810

Inquiry of a Client’s Lawyer 501 2505

Analytical Procedures 520 2305

Accounting Estimates 540 2501

Subsequent Events and Subsequently Discovered Facts 560 2801, 2905

Going Concern 570 2415

Written Representations 580 2805

Omitted Procedures 585 2901

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INTRODUCTION1 Canadian pharmaceutical giant Valeant appeared to be on top of the world. The hedge fund darling experienced significant growth through the acquisition of other pharmaceu- tical companies and their portfolios of prescription drugs. Valeant would then raise the prices for those drugs it thought were underpriced.

Everything came to a screeching halt for Valeant in early 2016. First, just after the company’s December 31, 2015 year-end, the company announced that CEO Michael Pearson was taking an indefinite leave of absence for health reasons. At the same time, public outrage over price increases (some as high as 525 percent) for commonly used pre- scription drugs brought unwanted congressional attention to the company’s operations. Questions also began to circulate about the company’s revenue recognition practices, especially those involving drug distributor Philidor; critics alleged that Philidor coerced insurers to pay reimbursements for Valeant’s drugs over cheaper alternatives.

Under current rules, large public companies are required to file audited financial statements with the SEC within 60 days of their fiscal year-ends. This deadline requires auditors to complete their work within a relatively short time period and ensure that all important matters are addressed and promptly resolved with clients. Failing to file its Form 10-K on time with the SEC raised concerns as to whether Valeant would be able to meet its debt covenants with its lenders; violating its debt covenants might force the company into bankruptcy.

With all of these issues facing its client, Valeant’s auditor, PwC, was faced with a dilemma. With the SEC filing deadline looming, should the public accounting firm issue its audit report on time to allow Valeant to meet the deadline or delay until more informa- tion was available to address remaining concerns? In this chapter, we discuss the many issues an engagement team faces when wrapping up an audit. Although the Valeant case is obviously unusual, it illustrates that the completion of an audit is not necessarily a straightforward, “check-the-boxes” activity.

Thus far in this text, we have discussed auditors’ use of the audit risk model to limit exposure to audit risk, auditors’ tests of controls to determine the operating effectiveness of internal control and to assess control risk (and the risk of material misstatement), and audi- tors’ substantive procedures to determine the fairness of the account balances and classes of transactions. At this point, it seems as though little work remains to be done! Although the audit is concluding, the potential for audit failure is at its highest. Consider just a few of the questions that Valeant’s auditors may have been asking as the audit was concluding:

∙ Have year-end misstatements that significantly affect the financial statements been identified?

∙ What events that occurred after the date of the financial statements could have affected the current-year financial statements?

∙ What potential exposure does the client have for pending litigation? ∙ Has the client provided all relevant information to auditors during the engagement? ∙ What matters need to be discussed with the individuals charged with governance of

the client (normally, the audit committee)?

Valeant finally filed its Form 10-K in late April, two months after the SEC filing dead- line, but the company was able to get debt covenant waivers from its lenders. An internal investigation, however, found a material weakness in internal control over financial reporting that allowed the company to prematurely recognize revenue of almost $60 million in sales to Philidor. The company’s stock price, once trading at more than $250 per share, was trading in the low $30s by June 2016. Three years and a name change later, the former Valeant, now Bausch Health, still has not recovered. In April 2019, Bausch was trading in the mid $20s.

1Much of the background in this section is drawn from “Valeant Could Have Trouble Getting Clean Opinion from Auditor,” CFO Journal, March 21, 2016.

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As shown in the following Auditing Insight, the completion of the audit involves sig- nificant auditor judgment and attention. The Public Company Accounting Oversight Board (PCAOB) identified these matters during its annual inspections for audits con- ducted by the Big Four firms (Deloitte, Ernst & Young [EY], KPMG, and PwC). In this excerpt, “the firm” refers to one of these firms.

Beginning of Year

January 1, 2020

Interim testing Test of controls Substantive procedures

Completing substantive procedures Attorneys’ letters Written representations Going-concern assessment Adjusting journal entries Audit documentation review Subsequent events

Subsequently discovered facts

Subsequently discovered facts Omitted audit procedures Management letter Communications with those charged with governance

Year-End Date (date of the

financial statements) December 31, 2020

Date of the Auditor’s Report

(audit completion date) February 15, 2021

Audit Report Release Date

February 17, 2021

• The Firm identified known errors that it concluded did not warrant further investigation, discussion, or adjustment to the financial statements. Some of these errors were left in the audit documen- tation without final disposition, despite the fact that they exceeded the Firm’s posting threshold.

• The Firm’s analytical procedures for testing operating expenses did not appropriately set a threshold for investigation of significant differences between the recorded balance and the firm’s expecta- tions; further, the Firm did not document its corroboration of man- agement’s explanations for significant differences between the recorded balance and the Firm’s expectations.

• While the Firm tested certain revenue transactions that occurred during the first seven months of the year, it failed to perform roll- forward procedures for the remaining five months of the year or otherwise adequately test revenues at year-end.

• While the Firm obtained responses to attorneys’ letters, the responses did not include an evaluation from the attorneys regard- ing the probability of an unfavorable outcome and the Firm failed to perform additional procedures to evaluate the contingency.

• Firms did not sufficiently test or challenge management’s fore- casts, views, or representations that constituted critical support for amounts recorded in the financial statements.

• Deficiencies raised questions about the sufficiency, rigor, and effec- tiveness of the review of audit documentation, including engage- ment quality review. In some of these instances, the amount of time committed to an engagement quality review did not appear suffi- cient, given the difficulty and complexity of the engagement.

• The Firm did not sufficiently evaluate if certain identified and uncor- rected misstatements associated with one group of accounts were material, individually or combined, and also failed to sufficiently evalu- ate all relevant quantitative and qualitative factors of materiality.

• The Firm failed to evaluate the reasonableness of management’s conclusions to record no inventory reserve or write-off related to potentially excess or obsolete inventory. The firms procedures were limited to reading management explanations, with no cor- roboration of such explanations.

All four of the firms performed additional auditing procedures in response to PCAOB inspection findings; in all but one instance, the additional procedures did not affect the firms’ conclusions, the client’s financial statements, or the firms’ reports on the financial statements. In the one exception, the firm’s failure to identify departures from GAAP resulted in the client restating its financial statements.

Sources: 2005-2017 PCAOB Inspection of Deloitte, EY, KPMG, and PwC. All reports can be found on the PCAOB website.

PCAOB Inspections and Completing the Audit AUDITING INSIGHT

AUDIT TIMELINE This chapter discusses the completion (or wrap-up) of the audit. During this time, many important issues arise, and many other issues that have served as the focus of the audi- tors’ work need to be documented. To provide an overview of the general time frame of the audit and the potential emergence of issues and matters for the auditors’ consider- ation, consider the following broad timeline:

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The preceding timeline suggests four important periods, beginning with the period under audit. Auditors often do a significant amount of tests of controls and substantive procedures prior to year-end to “spread” the audit work over a more extended period. This interim testing occurs between the beginning of the year (January 1, 2020) and the year-end date under audit (December 31, 2020), also referred to as the date of the financial statements.

The second period of interest begins on the date of the financial statements (December 31, 2020) and runs through the completion of the audit (February 15, 2021). Although a significant amount of audit evidence is typically gathered prior to the date of the financial statements, auditors will continue to perform other procedures and gather evidence following this date. At some point, auditors will have gathered sufficient, appropriate evidence on which to base their reports on the financial statements and internal control over financial reporting; this includes the review of audit documentation, preparation of the financial statements and related disclosures, and management’s assertion that they take responsibility for the financial statements and disclosures. We refer to this as the date of the auditor’s report, which is the date auditors use for their reports on the client’s financial statements and internal control over financial reporting. (This date is also referred to as the audit completion date and, in our example, would be February 15, 2021.) Recall that the auditor’s report on the entity’s financial statements covers all events that occur up to this date, and, as a result, auditors need to continue to be alert for developments affecting the client.

In some instances, auditors become aware of a development affecting the client after the date of the auditor’s report (in our example, February 15, 2021) but prior to the audit report release date (date on which auditors allow the client to use the auditor’s reports in conjunc- tion with the financial statements, in our example, February 17, 2021).2 This is the third period of interest to the auditor. Although this period normally is fairly short, events occur- ring between the date of the auditor’s report and audit report release date present significant challenges to auditors—they are no longer actively obtaining audit evidence—however, their reports have yet to be issued. The auditors’ dilemma is simple: how to report on the new development without increasing the responsibility for other (unknown) developments. As discussed later in this chapter, auditors may consider dual dating the report on the finan- cial statements to limit responsibility to specifically identified developments.

Finally, some issues can come to auditors’ attention after the audit report release date and the issuance of the client’s financial statements (in our example, February 17, 2021); this is the fourth period of interest.3 Although Form 10-K and auditor’s reports have been released, information may come to the auditor’s attention that could cause the auditor to take steps to ensure that third parties do not inappropriately rely on auditors’ reports that are no longer reliable. In addition, following the audit report release date, auditors make other communications to the client and individuals charged with governance based on observations during the audit examination.

This chapter focuses on a number of the topics addressed in the preceding timeline. Regarding auditors’ responsibility for various matters, it is important to consider the tim- ing of these topics in the timeline discussed.

2These reports include opinions on the financial statements and the effectiveness of internal control over financial reporting. As noted in Chapter 12, both auditors’ reports are dated on the audit completion date and included with the 10-K filed with the U.S. Securities and Exchange Commission (SEC). 3Larger public entities must file annual reports with the SEC within 60 days after the date of the financial statements. Thus, audit fieldwork must be completed and auditors’ reports for these companies must be dated earlier than 60 days after the date of the financial statements.

REVIEW CHECKPOINT 11.1 Identify four primary periods in an audit examination and the tasks and activities that occur in each.

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PROCEDURES PERFORMED DURING FIELDWORK Completing Substantive Procedures Roll-Forward Procedures From earlier chapters, you know that auditors often test account balances at an interim point for efficiency reasons. For example, if relevant internal controls are effective, accounts receivable can be confirmed at November 30 for a December 31 year-end client. Similarly, although most inventory observations occur near year-end, they actually can be performed at an earlier time. In such cases, auditors use roll-forward procedures to roll the conclusions forward to the year-end date under audit. Common roll-forward procedures include examining material account transactions that occur between the interim testing date and the date of the financial statements.

Analytical Procedures and Review of Accounts  Throughout the text, we have discussed the use of analytical procedures, which allow audi- tors to evaluate financial information by studying relationships among both financial and nonfinancial data. Professional standards state that analytical procedures can be used throughout the audit:

1. During planning to assist auditors in planning the nature, timing, and extent of other auditing procedures (required).

2. As part of substantive testing, to obtain audit evidence about particular assertions related to account balances or classes of transactions (optional).

3. Near the end of the audit as an overall review of the financial information to assess the conclusions reached and evaluate the overall financial statement presentation (required).

This latter use of analytical procedures is of interest to auditors in completing the audit. In this use, auditors review the financial statements and footnotes to the financial statements to evaluate (1) the adequacy of evidence gathered in response to unexpected account balances or relationships among account balances identified during the audit and (2) unusual or unexpected account balances or relationships among account balances that were not previously identified in other parts of the audit. In this way, analytical proce- dures near the end of the audit act as a final “catch all.” If there are unusual or unexpected balances not previously identified, it is not too late to investigate them before the audit report is issued!

In addition to the preceding, auditors should be alert for “miscellaneous,” “other,” and “clearing” accounts classified as revenues or expenses, particularly when they result from adjustments made at the end of the year or quarter. These items can be identified by scanning accounts for large and unusual entries. In many cases, these items reflect adjustments made to meet analysts’ earnings expectations (known as earnings management) and should be more appropriately classified as deferred items, assets, liabilities, contra-assets, or contra-liabilities. If items of this nature are identified, auditors should examine related documentation and inquire of the client to verify that classification as a revenue or expense is appropriate.

Review of Accounting Estimates  Chapters 6 through 10 discuss auditing procedures performed in the examination of various cycles. As noted in these chapters, the entity’s account balances and finan- cial statements are affected by many significant estimates that must be made by management. For example, Best Buy (a retailer of consumer electronics, home office

LO 11-1 Identify major activities performed by auditors in completing the substantive procedures following the date of the financial statements.

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products, entertainment software, appliances, and related services) identifies the following as some of the critical accounting estimates necessary in preparing its financial statements:

∙ Future markdown and loss reserves for valuing its inventories. ∙ Future cash flows from long-lived assets for evaluating potential impairment. ∙ Sales returns for recognizing net revenues. ∙ Allowance for doubtful accounts for determining the balance of accounts receivable. ∙ Potential benefits earned by customers under loyalty programs for accruing potential

liabilities related to those programs. ∙ Gift card usage for determining revenue earned from the sale of gift cards.

Because estimates, by their very nature, reflect uncertainty and future outcomes, auditors cannot “audit,” “corroborate,” or “verify” accounting estimates. However, auditors should consider whether estimates are reasonable in the circumstances. For example, it is not likely that assigning computer equipment a 20-year useful life for purposes of depreciation would be considered reasonable. Although the reasonableness of accounting estimates is assessed to some extent on an account-by-account basis throughout the audit, auditors will evaluate management’s process for developing estimates as well as the overall reasonableness of management’s estimates near the end of the audit. With respect to reasonableness, auditors should ensure that estimates are consistent with one another, historical data, and industry data. In addition, auditors should consider how events occurring after the date of the financial statements may affect the reasonableness of accounting estimates. For example, a significant economic downturn may suggest that previous estimates related to uncollectible accounts are insufficient and a higher percentage of uncollectible accounts should be estimated. In a sense, this overall review of the reasonableness of accounting estimates is similar in nature and purpose to the role of analytical procedures conducted near the end of the audit.

REVIEW CHECKPOINTS 11.2 What are roll-forward procedures? Provide some examples. 11.3 How are analytical procedures used near the end of the audit? 11.4 What additional issues are involved with miscellaneous, other, and clearing accounts? 11.5 What are auditors’ responsibilities with respect to accounting estimates made by management?

Attorney Letters For financial statements to be presented according to an applicable financial report- ing framework (such as GAAP), all material contingencies (contingent gains or losses) must be properly accounted for and disclosed in the financial statements. According to Accounting Standards Codification 450 (ASC 450), a contingency is

an existing condition, situation, or set of circumstances involving uncertainty as to possible gain or loss to an enterprise that will ultimately be resolved when one or more future events occur or fail to occur.

Examples of contingent liabilities include potential payments related to warranties for products and services sold by the entity, income taxes in disputes with the Internal Revenue Service, and guarantees of debt on behalf of another party. With respect to contingencies, auditors should ensure that (1) all contingencies have been appropri- ately identified and (2) any client disclosure of contingencies reflects the most current

LO 11-2 Understand the role of attorney letters in evaluating litigation, claims, and assessments.

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information and all recent developments, both favorable and unfavorable to the client. These contingencies are normally evaluated as part of the audit of the related account balances and classes of transactions and have been discussed in previous chapters of this text.

A contingent liability that requires special consideration by auditors is the uncertain outcome of litigation, claims, and assessments pending against the entity. From the audi- tors’ standpoint, two important issues relating to pending litigation, claims, and assess- ments are ensuring that all pending litigation, claims, and assessments (1) have been disclosed to auditors and (2) are properly presented and disclosed in the client’s financial statements. Because the client’s attorneys are most familiar with the existence and clas- sification of pending litigation, claims, and assessments, they play a very important role in auditors’ evaluation of these matters.

Auditors should inquire of management and discuss potential litigation, claims, and assessments. Once this inquiry has identified litigation, claims, and assessments, auditors perform the following procedures:

∙ Obtain from management a description and evaluation of litigation, claims, and assessments.

∙ Examine documents in the client’s possession concerning litigation, claims, and assessments, including correspondence and invoices from attorneys.

∙ Obtain assurance from management that it has disclosed all material unasserted claims the attorney has advised them are likely to be litigated.

∙ Read minutes of meetings of stockholders, directors, and appropriate committees. ∙ Read contracts, loan agreements, leases, and correspondence from taxing or other gov-

ernmental agencies. ∙ Obtain information concerning guarantees from bank confirmations. ∙ Review the legal expense account, cash disbursements records, and invoices related to

legal services.

The client’s responsibility is to respond to auditors’ inquiries and provide auditors with a description and evaluation of litigation, claims, and assessments. When auditors assess a risk of material misstatement from pending litigation, claims, and assessments, they will request that the client send an attorney letter (or letter of inquiry) to all attorneys who worked for the client during the period under audit. It is important to note that the client should make this request because it informs the attorney that the client is waiving the attorney-client privilege and is authorizing the attorney to provide information to auditors. The attorney letter should contain the following information (prepared from the client’s perspective):

∙ A list of pending or threatened litigation, claims, or assessments. ∙ A description of each item, including the nature of the case and management responses

or intended responses to the case. ∙ An evaluation of the likelihood of an unfavorable outcome. ∙ An estimate of the range of potential loss.

Review the following diagram for the flow of correspondence related to the attor- ney letter. The process begins when auditors request the client to prepare a letter to its attorney(s) (step 1). In step 2, the attorney receives the letter mailed by the auditor asking the attorney to respond to the letter (step 3). The attorney’s response should be provided directly to auditors for purposes of control and should explain any matters noted in the attorney letter in which the attorney’s view differs from the information in the letter. For example, the client may indicate that the likelihood of an unfavorable outcome is “remote,” but the attorney may believe that it is higher than “remote.” In addition, the attorney may inform auditors of pending litigation, claims, or assessments not included in the attorney letter.

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The general roles of the client, auditors, and attorney(s) in this process are summa- rized in Exhibit 11.1.

Unasserted claims raise additional issues for attorney letters. An unasserted claim rep- resents that no formal lawsuit or claim has been filed or threatened on behalf of others but that circumstances such as a catastrophe, accident, or other physical occurrence could result in a suit or claim being filed in the future. Because unasserted claims have not been filed, the issue of client disclosure of these matters to auditors is less clear. Attorneys should encourage their clients to disclose this information to auditors when the assertion of a claim is at least probable. However, the American Bar Association’s guidelines to attorneys do not require them to disclose unasserted claims to auditors unless the client specifically lists them in the attorney letter. Thus, auditors must rely on the attorney to inform the client (not the auditors) if an unasserted claim must be disclosed. The attorney letter explicitly asks that this understanding be communicated to the client’s auditors through the attorney’s response.

Auditors Request Client to Prepare Letter to Attorney(s)

Attorney Letter (with attorney response)

Auditors

Attorney

Client

Attorney Letter

2

1

3

Sent by Auditors

Party Responsibilities

Auditors • Inquire of client regarding the existence of litigation, claims, and assessments. • Perform various procedures regarding litigation, claims, and assessments. • Initiate request to the client for attorney letter. • Mail attorney letter prepared by client.

Client • Respond to auditors’ inquiries regarding litigation, claims, and assessments. • Provide auditors a list, description, and evaluation of litigation, claims, and assessments. • Prepare letter to attorney (attorney letter) that includes information related to litigation,

claims, and assessments.

Attorney • Respond to auditors regarding client’s description of litigation, claims, and assessments contained in the attorney letter.

EXHIBIT 11.1  Role of Various Parties in Audit of Litigation, Claims, and Assessments

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Written Representations Under section 302 of the Sarbanes–Oxley Act of 2002, all 10-Q and 10-K filings with the SEC are required to include certifications from the chief executive officer and chief financial officer related to the fairness of the financial statements and effectiveness of the internal control over financial reporting. However, these are only some representations that the client makes. As noted in previous chapters, an important source of audit evi- dence is inquiries of client personnel. Many of the responses to these inquiries are very important. To the extent that additional evidence is obtainable through other procedures, auditors should corroborate these representations.

Professional standards require that auditors obtain written representations (also known as management representations or client representations) to confirm certain matters and support other evidence obtained during the audit. The representations take the form of a letter on the client’s letterhead addressed to auditors and signed by responsible offi- cers of the client (normally the chief executive officer [CEO], chief financial officer [CFO], and other appropriate officers). The letter is dated as of the date of the auditor’s reports, which is when the audit is completed (in fact, the audit is not complete until the auditors’ receipt of assertions from management regarding its responsibility for the fairness of the financial statements and related disclosures through written representations). Thus, written representations cover events and representations running beyond the date of the financial statements up to this date.

It is important to note that written representations are not substitutes for corroborat- ing evidence obtained by applying other substantive procedures. That is, auditors can- not substitute client inquiry (and representations regarding that inquiry) for substantive procedures. For example, the representation that “management told us that the inventory costing method was FIFO and adequate allowance for obsolescence was provided” is not a good excuse for failing to obtain the evidence from the records and other sources.

LO 11-3 Explain why auditors obtain written representations, and identify the key components of written representations.

In early May 2019, Volkswagen announced that they had set aside 5.5 billion euros in their quarterly financial statements (approximately $6.16 billion US dollars at the time) for contingent liabilities related to a US diesel emissions cheating scandal that was uncovered four years earlier.

In 2015, the Environmental Protection Agency announced that several Volkswagen models sold in the US were equipped with software that would detect when emissions were being tested and change the performance accordingly to improve the emission testing results. Including the first quarter earnings announcement of 2019,

the overall cost of the diesel cheating scandal to Volkswagon had thus far amounted to 30 billion euros. That’s just over $33.5 billion US dollars!

Source: Edward Taylor, “Volkswagen sets aside 5.5 billion euros in contingent liabilities for diesel scandal,” Reuters Business News, May 2, 2019, https://www .reuters.com/article/us-volkswagen-results-q1-liabilities/volkswagen-sets-aside- 5-5-billion-euros-in-contingent-liabilities-for-diesel-scandal-idUSKCN1S81BH ?feedType=Rss&feedName=businessNews&utm_source=feedburner&utm_ medium=feed&utm_campaign=Feed%3A+reuters%2FbusinessNews+%28B usiness+News%29; Russle Hotten, “Volkswagen: The scandal explained,” BBC News, December 10, 2015, https://www.bbc.com/news/business-34324772

Costly Contingencies for Volkswagen AUDITING INSIGHT

REVIEW CHECKPOINTS 11.6 What are the responsibilities of (a) client management, (b) auditors, and (c) the client’s attorneys

with respect to obtaining evidence regarding litigation, claims, and assessments? 11.7 What is the typical content of attorney letters? 11.8 In addition to obtaining responses to attorney letters, what other procedures can be used to

gather audit evidence regarding litigation, claims, and assessments?

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However, in some cases, written representations are the only available evidence about important matters of management intent. For example, the following representations (written by the client’s management) provide auditors important audit evidence regarding presentation and disclosure matters:

∙ “We will discontinue the parachute manufacturing business, wind down the opera- tions, and sell the remaining assets” (classification of the parachute manufacturing business as a discontinued operation).

∙ “We will exercise our option to refinance the maturing debt on a long-term basis” (classification of the maturing debt as long-term debt).

Within the letter, management representations are organized into three sections that discuss:

1. The entity’s financial statements, including

∙ Management’s responsibilities for the financial statements and internal control over financial reporting.

∙ The appropriate disclosure, presentation, and reasonableness of certain items (accounting estimates, related parties, subsequent events, and litigation and claims).

∙ A statement that uncorrected misstatements are immaterial to the financial state- ments taken as a whole.

2. Types and completeness of information provided to the auditors, both in general and related to sensitive areas (fraud, noncompliance with laws and regulations, litigation, and related-party transactions).

3. Representations made related to internal control over financial reporting (for audits of public entities).

Although representations should be limited to matters that are material, professional standards note that materiality guidelines do not apply for representations not related to amounts included in the financial statements (such as management’s responsibility for the financial statements) or for management’s acknowledgement regarding its responsibility for designing, implementing, and maintaining internal control to prevent and detect fraud.

Clearly, written representations provide an important part of auditors’ overall ability to support the opinion on the financial statements. As a result, management’s refusal to fur- nish representations constitutes a scope limitation, which typically results in a withdrawal from the engagement or a disclaimer of an opinion. However, contingent upon the nature of the representations not obtained or the reasons for refusal, auditors can opt to qualify the opinion. Regardless, auditors should be very skeptical of any situation in which the client’s management refuses to furnish representations.

In addition to those discussed, auditors may obtain representations related to specific transactions or activities, particularly if they have a material effect on the companies’ financial statements.

In an address made in September 2016, Andrew Ceresney, the direc- tor of the Division of Enforcement at the Securities and Exchange Commission (SEC) at the time, highlighted enforcement actions that showed a “variety of professional failures” on the part of the auditor, including a lack of due professional care and professional skepticism. One particular area of weakness he noted was auditors’ “failure to exercise sufficient professional skepticism in evaluating management representations.” Mr. Ceresney referenced two separate audit failures due, in part, to auditor over reliance on management representations

and the failure to gather sufficient appropriate evidence related. As a result, two engagement partners and one senior manager were charged for their respective roles in the audit failures and subse- quently suspended from working on SEC engagements .

Source: Andrew Ceresney, “The SEC Enforcement Division’s Focus on Auditors and Auditing,” Keynote Address: American Law Institute Conference on Accountants’ Liability 2016: Confronting Enforcement and Litigation Risks, September 22, 2016, https://www.sec.gov/news/speech/ceresney- enforcement-focus-on-auditors-and-auditing.html

Can You Trust Management Representations? AUDITING INSIGHT

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Ability to Continue as a Going Concern As auditors gather evidence throughout the engagement, they may encounter information that raises questions as to the client’s ability to continue as a going concern, such as

∙ Negative trends, including recurring operating losses, working capital deficiencies, and negative cash flow from operations.

∙ Indications of financial difficulties, including default on loans, denial of trade credit from suppliers, restructuring of debts, or dividends in arrears.

∙ Internal matters, including work stoppages or substantial dependence on the success of a particular project or activity.

∙ External matters, including legal proceedings; loss of a key franchise, license, or pat- ent; or loss of a major customer or supplier.

Auditors are not expected to design and perform procedures solely for the purpose of identifying conditions that indicate going-concern uncertainties. However, procedures performed during the normal course of the audit might reveal such situations. For exam- ple, performing analytical procedures may reveal deteriorating profitability and cash flows, which may indicate the client’s inability to continue as a going concern. Also, communications received from client attorneys (discussed earlier in this chapter) might reveal litigation that could significantly threaten the client’s ability to continue to exist.

Auditors are required to consider whether any evidence that comes to their attention during the examination provides “substantial doubt” about the client’s ability to continue as a going concern for a reasonable period of time. The “reasonable period of time” should be consistent with the period of evaluation for management’s own going-concern assessment as required by the applicable financial reporting framework. Auditors are also required to ask management about events or conditions beyond the period of evalua- tion that may affect the entity’s ability to continue as a going concern. Beyond inqui- ries, auditors are not required to perform additional procedures during the completion stages designed to assess going-concern status. However, they are required to consider evidence obtained and accumulated throughout the audit and make an overall evaluation as to whether substantial doubt exists with respect to the ability of the client to continue as a going concern.

If the auditors’ evaluation suggests going-concern uncertainties, auditors should obtain information about management’s plans to mitigate the effect of these factors and assess the likelihood that these plans can be effectively implemented. For example, cli- ents may have the ability to delay or reduce expenditures, restructure existing debt on more favorable terms, or access additional sources of financing. If so, and these actions would allow the client to continue in operations, auditors may conclude that the likeli- hood of going-concern uncertainties is low. In this instance, auditors would likely con- clude that substantial doubt about going concern does not exist and no further financial statement disclosures or audit report modifications would be necessary. The auditor may,

LO 11-4 Identify the final steps in the completion of an audit.

REVIEW CHECKPOINTS  11.9 What are the major categories of information contained in written representations? 11.10 If the entity is subject to PCAOB requirements regarding communication about control deficien-

cies (AS 1305), what written representations should auditors obtain from the client with respect to internal control over financial reporting?

  11.11 Why are written representation and attorney letters obtained near the end of the evidence- gathering process and dated on the date of the auditor’s report?

11.12 How should auditors respond if the client refuses to furnish written representations?

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however, decide to include an emphasis of a matter paragraph in the audit report (also called a “close-call” situation) to highlight liquidity issues.

In contrast, if after this evaluation auditors still believe that substantial doubt exists about the client’s ability to continue as a going concern, they should ensure that man- agement has appropriately used the going-concern basis of accounting when preparing the financial statements and modify their opinion on the client’s financial statements. Depending upon the severity of the going-concern uncertainty, an unmodified opinion with an emphasis of a matter paragraph for the going concern or disclaimer of opinion may be issued; the specific report modifications for going-concern uncertainties are dis- cussed in Chapter 12.

In all cases, audit documentation should include information related to the (1) condi- tions or events that suggested going-concern uncertainties, (2) management’s plans to mitigate going-concern uncertainties and the audit procedures performed to evaluate management’s plans, and (3) the auditors’ conclusion as to whether substantial doubt exists about the client’s ability to continue as a going concern and whether the audit report needs to be modified to reflect that substantial doubt.

In April 2018, MoviePass’s auditors indicated substantial doubt for MoviePass’s ability to remain a going concern. MoviePass offers a service where subscribers are able to see a set number of movies for a monthly fee. At one point, MoviePass was offering subscribers one movie ticket per day for a $9.95 monthly fee! The financial woes facing MoviePass may be the result of two very different issues. First, MoviePass was paying full price for movie tickets to most theaters, which was a strategy that was leading to losses. Secondly, MoviePass was struggling (and continues to struggle) to rein in fraud among their subscribers. Subscribers have shared

their MoviePass cards with friends and family, used MoviePass to gain rewards points at the theaters, and even purchased multiple tickets with the MoviePass app and subsequently resold them at a higher price.

Sources: Brent Lang, “MoviePass Auditor Raises ‘Substantial Doubt’ About Subscription Business,” Variety, April 18, 2018, https://variety.com/2018/film/ news/moviepass-mitch-lowe-1202756923/; Andrew Gruttadaro, “Do We Want to Be in Business?” The Strange, Never-Ending Saga of MoviePass,” The Ringer, February 6, 2019, https://www.theringer.com/movies/2019/2/6/18212482/ moviepass-mitch-lowe-khalid-itum-interview-2019

MoviePass Going Concerns AUDITING INSIGHT

REVIEW CHECKPOINTS 11.13 What responsibility do auditors have for evaluating a client’s ability to continue as a going

concern? 11.14 What factors may indicate that substantial doubt exists about the client’s ability to continue as a

going concern? 11.15 What actions should auditors take if evidence suggests that substantial doubt exists about the cli-

ent’s ability to continue as a going concern?

Adjusting Entries and Financial Statement Disclosure The financial statements, including the accompanying footnotes, are the responsibility of the client’s management. Thus, although auditors could detect some misstatements in the financial statements during the examination, it is the client’s responsibility to adjust the financial statements. Even when the failure to adjust the financial statements would result in materially misstated financial statements, it is the client’s decision as to whether to accept auditors’ proposed adjustments.

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Exhibit 11.2 is a summary worksheet (“score sheet”) showing the effect of proposed adjusting journal entries. In this example, three potential adjustments were noted during the audit: (1) recording payments on account to vendors made prior to year-end, (2) reversing sales entries that were incorrectly recorded in the current year, and (3) recording items discovered during the auditors’ search for unrecorded liabilities. In addition, a fourth adjustment reflects the income tax effects of these adjustments (if recorded by the client). These adjustments are considered to be proposed to

Income Statement Balance Sheet

Increase (Decrease) Net Income

Increase (Decrease)

Assets

Increase (Decrease) Liabilities

Increase (Decrease)

Equity

(1) Unrecorded cash disbursements

Accounts payable ($42,000)

Cash ($42,000)

(2) Improper sales cutoff

Sales ($13,000) ($13,000)

Inventory 7,800

Cost of goods sold 7,800 7,800

Accounts receivable (13,000)

(3) Unrecorded liabilities

Utilities expense (700) (700)

Commissions expense (3,000) (3,000)

Wage expense (2,500) (2,500)

Accounts payable 700

Accrued expenses payable 5,500

Net effect before taxes ($11,400) ($47,200) ($35,800) ($11,400)

(4) Reduction in income taxes ($11,400 × 0.35)

Income tax expense 3,990 3,990

Income taxes payable (3,990)

Current-year effects ($7,410) ($47,200) ($39,790) ($7,410)

Uncorrected misstatements from prior audits

($18,000) ($18,000)

Cumulative effect of uncorrected misstatements

($25,410) ($25,410)

Conclusion: Uncorrected misstatements from previous audits had a net debit effect of $18,000 on the income statement (decrease in net income) and a net credit effect on the balance sheet (decrease in net assets, or equity). When considered with the $7,410 effect noted in the current year, the cumulative uncorrected misstatements ($25,410) are less than performance materiality ($100,000). As a result, no adjustment to the financial statements is considered necessary.

EXHIBIT 11.2  Proposed Adjusting Journal Entries (Score Sheet)

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indicate the responsibility of management for the financial statements. This summary indicates how the proposed adjustments would affect the financial statements and helps auditors decide which adjustments must be made to support an unmodified opinion on the financial statements and which adjustments may be waived (or not corrected). An uncorrected misstatement is a misstatement that the auditors have identified and accumulated during the audit that the client has not corrected (or adjusted), often because of materiality or cost/benefit considerations.

As shown in Exhibit 11.2, the misstatements have a current-year $7,410 debit (decrease) effect on net income and a $7,410 credit (decrease) effect on net assets. In addition, note that $18,000 of uncorrected misstatements was identified in previous audits. If performance materiality were established at $100,000, auditors could decide not to require adjustment of these misstatements because doing so would not result in materially misstated financial statements. However, Staff Accounting Bulletin No. 99 notes that auditors and clients should not simply decline to adjust “apparently” immate- rial misstatements without giving consideration to a number of other factors (such as the effect of adjusting the misstatement on debt covenants).

An important issue with respect to the auditors’ adjustment recommendation is whether a number of uncorrected misstatements in previous years will accumulate over time to have a material effect on an entity’s financial statements in a future year. For example, if performance materiality is $100,000 and an entity fails to accrue a $25,000 liability for unused sick pay (which will not be paid until employees retire) each year for four years, this matter will not have a material effect on the income statement in any individual year. However, assuming this obligation has not been paid, at least in part, by the end of year 4, the cumulative effect on the entity’s balance sheet would become material ($100,000).

Auditors may use either of two methods to evaluate the materiality of uncorrected misstatements. The rollover method considers only the current-period income effect(s); when using the rollover method as in the example shown in Exhibit 11.2, auditors would consider the misstatement to be $7,410. In contrast, the iron curtain method considers the aggregate effect of the misstatements on the entity’s balance sheet; when using the iron curtain method, auditors would consider the misstatement to be $25,410 (the $7,410 of current-year adjustments and the $18,000 of uncorrected prior-year adjustments). Audi- tors are required by the Securities and Exchange Commission’s Staff Accounting Bul- letin No. 108 to evaluate misstatements using both methods and propose an adjustment if either method indicates that the misstatement is material. Because neither the amount of the current-year uncorrected misstatement in Exhibit 11.2 ($7,410) nor the cumula- tive effect of uncorrected misstatements ($25,410) exceeds performance materiality of $100,000, the auditors would conclude that the financial statements are not materially misstated (see conclusion in Exhibit 11.2). Although auditors could recommend the cli- ent adjust its financial statements for all known adjustments, no adjustment is required in this situation.

Auditors are required to communicate all misstatements detected during the audit to the client’s audit committee (or other individuals charged with governance). These should be communicated regardless of whether they have a material effect on the finan- cial statements. A report issued by the PCAOB noted that a common deficiency observed by inspection teams was the failure of audit teams to accumulate all uncorrected mis- statements and communicate these to the audit committee.4 Auditors’ identification of material misstatements is normally considered to be a “strong indicator” of a material weakness in internal control over financial reporting even if these misstatements are ulti- mately adjusted by the client.

4Report on the PCAOB’s 2004, 2005, 2006, and 2007 Inspections of Domestic Annually Inspected Firms, PCAOB Release No. 2008-008, December 5, 2008.

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Audit Documentation Review During fieldwork, the audit supervisor—and sometimes the audit manager—reviews the audit documentation soon after the audit staff completes it. The general purpose of this review is to ensure that all appropriate steps in the audit plan were performed, the refer- encing among audit documentation is clear, and the explanations contained in the audit documentation are understandable. In general, the supervisor is attempting to determine that the work was performed with due care and that, if necessary, the work can be reper- formed or verified by another party. A common outcome of this review is a set of “review notes” prepared by the audit supervisor that are to be completed or addressed by the audit staff; these notes address the procedures performed, the referencing among audit docu- mentation, and the appropriateness of the audit staff member’s conclusions based upon the procedures performed. This review process provides evidence of compliance with the performance principle, which requires proper planning and supervision.

A significant amount of academic research has evaluated the process through which auditors and clients “negotiate” with respect to adjust- ments identified during the audit examination. These studies demon- strate that this process is prevalent; Gibbins and his associates found that 67 percent of audit partners entered into some level of negotia- tion with more than one-half of their clients and that all partners have negotiated with at least one client.a Some interesting conclusions in these studies include

• While approximately one-third of surveyed chief financial officers (CFOs) and audit partners indicated they “won” the negotiation (34 percent for CFOs and 32 percent for auditors), both groups indicated that negotiations resulted in a compromise (26 percent for CFOs and 41 percent for auditors) or a new solution generated during the negotiation (17 percent for CFOs and 16 percent for auditors)b Each group was asked to recall an auditor–client negotiation and was not necessarily considering the same negotiation.

• Factors considered as important by CFOs in the outcome of the negotiation include accounting and disclosure standards, the prior relationship with the audit partner, the organization’s (client’s) accounting expertise, and the audit firm’s accounting expertise; auditors primarily considered accounting and disclosure stan- dards and the audit firm’s accounting expertise as important in influencing the outcome of the negotiation.c

• The (income-decreasing) adjustments proposed by auditors are smaller in cases in which the magnitude of the audit difference is higher and when the client has previously conceded with respect to an audit issue.d

• Auditors are less influenced by management’s need to meet or beat analysts’ expectations when negotiating misstatements in a post Sarbanes-Oxley environment than in prior.e

• Experimental evidence indicates that negotiations with manage- ment are less contentious and management is more accommodat- ing when negotiating with a newly rotated audit partner.f

Sources : a M. Gibbins, S. Salterio, and A. Webb, “Evidence about Auditor-Client Management Negotiation Concerning Client’s Financial Reporting,” Journal of Accounting Research, December 2001, pp. 535–563. b M. Gibbins, S. McCracken, and S. Salterio, “Negotiations over Accounting Issues: The Congruency of Audit Partner and Chief Financial Officer Recalls,” Auditing: A Journal of Practice & Theory, Supplement 2005, pp. 171–193. c Ibid. d R.C. Hatfield, R.W. Houston, C.M. Stefaniak, and S. Usrey, “The Effect of Mag- nitude of Audit Differences and Prior Client Concessions on Negotiations of Pro- posed Adjustments,” The Accounting Review, September 2010, pp. 1647–1668. e H. Brown-Liburd, J. Cohen, and G. Trompeter, “Effects of Earnings Forecasts and Heightened Professional Skepticism on the Outcomes of Client-Auditor Negotiation,” Journal of Business Ethics, August 2013, pp. 311–325. f R. Schmidt and B. Cross, “The Effects of Auditor Rotation on Client Management’s Negotiation Strategies,” Managerial Auditing Journal, 2014, pp. 110–130.

Academic Insights into Auditor Negotiations AUDITING INSIGHT

REVIEW CHECKPOINTS 11.16 Why are adjusting entries and note disclosures labeled “proposed”? 11.17 What is an uncorrected misstatement? What is the auditors’ responsibility for communicating mis-

statements detected during the audit? 11.18 Identify the two methods of evaluating the performance materiality of uncorrected misstate-

ments. What are the requirements of Staff Accounting Bulletin No. 108 for evaluating the perfor- mance materiality of these misstatements?

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When this initial review has been completed, the audit manager and audit partner review the audit documentation. This review focuses more on the overall scope of the audit and whether the overall conclusions in the audit documentation are sufficient to provide support for the opinion on the financial statements.

Current GAAS require the audit documentation to be reviewed by an additional per- son (normally, a partner or equivalent with the firm) who has not been involved with the audit (known as an engagement quality reviewer). This review focuses on the significant judgments made by the engagement team and the conclusions reached by the engagement team in preparing the auditor’s report. AS 1220 notes that this engagement quality review (formally known as a second-partner review or concurring-partner review) is under- taken to ensure that the quality of audit work and reporting is in keeping with the public accounting firm’s quality standards. In addition, the engagement quality review provides a very-high-level review of whether the evidence obtained during the audit is sufficient to support the opinion on the client’s financial statements. The use of electronic audit documentation and the accompanying search capabilities has enhanced the efficiency and effectiveness of audit documentation review. Audit documentation review provides a number of benefits to the firm, including these:

∙ Because audit documentation is the primary evidence of the audit procedures per- formed and conclusions reached by auditors, the review ensures that the audit is con- ducted in accordance with GAAS.

∙ Audit documentation review provides the firm an opportunity to evaluate the overall quality of the firm’s audit practices as a method of quality control.

∙ Audit documentation review often serves as an important component of the training and evaluation of audit staff members.

∙ Audit documentation review allows the firm to adhere to the performance prin- ciple, which requires that auditors adequately plan the work and properly supervise any assistants.

REVIEW CHECKPOINTS 11.19 Describe the audit documentation review process in a public accounting firm. 11.20 What is an engagement quality review? 11.21 What are some of the benefits of audit documentation review to a public accounting firm?

SUBSEQUENT EVENTS AND SUBSEQUENTLY DISCOVERED FACTS

What is the auditors’ responsibility for events occurring after the date of the financial statements but before the audit report is released? In early 2008, after the company’s fiscal-year end, real estate investments held by UBS (a global financial services firm) declined in value by 19 billion Swiss francs (US $16 billion). On one hand, because this decline in value occurred after December 31, 2007 (the date of UBS’s financial state- ments), it did not affect the financial position or results of operations as of December 31, 2007. However, it would clearly be misleading for UBS to fail to disclose this decline in market value if it occurred and was known prior to the issuance of its financial state- ments. As a result, auditors not only should evaluate the fairness of the entity’s financial statements based on facts and circumstances that exist as of the date of the financial statements but also should consider the impact of events occurring after the date of the financial statements.

LO 11-5 Understand auditors’ responsibility for subsequent events and subsequently discovered facts.

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Subsequent Events Events occurring between the date of the financial statements and the date of the audi- tor’s report are referred to as subsequent events. The auditors’ primary objective with respect to subsequent events is to ensure that any material events that affect the fairness of the client’s financial statements and disclosures are properly identified and disclosed in the client’s financial statements. Professional standards (specifically AU-C 560) iden- tifies the following two types of subsequent events:

∙ Events that provide additional evidence of conditions that existed at the date of the financial statements (for example, the deteriorating financial condition of the cli- ent’s customer that had a large accounts receivable balance at the date of the financial statements).

∙ Events that provide evidence of conditions that arose following the date of the finan- cial statements (for example, a major acquisition occurring after the date of the finan- cial statements).

Examples of subsequent event disclosures from recent SEC filings are shown in the accompanying Auditing Insight.

The following are examples of subsequent events disclosed by com- panies in their footnotes to the financial statements:

• In February 2019, Ford Motor Company disclosed that it commit- ted to a plan to exit the commercial heavy truck business in South America. Related to this plan, Ford disclosed expected charges of $460 million to be recorded in the 2019 financial statements.

• In February 2019, Walmart announced dividends declared of $2.08 per share to be paid out in 4 quarterly installments over the next fiscal year.

• In January 2019, pharmaceutical company Bristol Myers Squibb (BMS) entered into a merger agreement to acquire

Celgene. The disclosure references the agreement terms, in which Celgene shareholders would receive one share of BMS stock and $50 in cash for each share of Celegene stock. Based on stock prices on the closest trading day after the merger announcement, the total cost was expected to be approximately $74 billion.

• In February 2019, Harley-Davidson issued $550 million of medium-term notes maturing in Febraury 2022 and paying annual interest of 4.05%.

Sources: Ford Motor Company, Walmart, Bristol Myers Squibb, and Harley- Davidson Inc. 10-K filings.

The Real World of Subsequent Events AUDITING INSIGHT

Auditors may learn of subsequent events through audit procedures performed in obtaining evidence related to account balances or classes of transactions. For example, the deterioration of a customer’s financial condition may be identified through accounts receivable confirmations obtained after the date of the financial statements. Other pro- cedures performed during the completion stage of the audit (such as attorney letters and written representations) may provide auditors information about the existence of sub- sequent events. Professional standards identify the following procedures that should be specifically performed to identify the existence of material subsequent events:

∙ Obtain an understanding of procedures management performed to identify material subsequent events.

∙ Inquire of management and those charged with governance as to the existence of sub- sequent events. (This inquiry should subsequently be corroborated through written representations.)

∙ Read minutes of meetings of owners, management, or those charged with governance held after the date of the financial statements.

∙ Review the entity’s latest interim financial statements, if applicable.

When material subsequent events are identified, auditors are required to ensure that the financial statement disclosure of these events reflects all current information and is

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according to GAAP. This might require adjustment to the financial statements to reflect new information (for conditions existing at the date of the financial statements) or disclo- sure of the information in the financial statements or footnotes accompanying the finan- cial statements (for conditions that arose after the date of the financial statements).

Subsequently Discovered Facts In the preceding discussion, we assumed that auditors identified material subsequent events prior to the date of the auditor’s report. This assumption is noteworthy because the auditors are still conducting fieldwork and can obtain evidence regarding the appropriate presentation and disclosure of the subsequent events. However, in some situations, audi- tors learn of events or facts following the date of the auditor’s report. The dilemma for auditors in these situations is that the fieldwork is complete and, in some cases, the finan- cial statements and auditor’s report may have been issued. Facts that become known to auditors after the date of the auditor’s report that, had they been known at that time, may have caused the auditors to revise their report, are known as subsequently discovered facts.

The auditors’ response to subsequently discovered facts depends on when the facts are identified. In some circumstances, auditors could learn of these facts after the date of the auditor’s report but prior to the audit report release date. The issue this raises for the auditors is that auditing procedures have been performed only through the date of the audi- tor’s report, yet the facts are discovered prior to the release of the financial statements and auditor’s report. As a result, the financial statements, or auditor’s report, or both could still be revised prior to issuance. If these facts require revision of the financial statements or footnote disclosures, auditors should perform additional procedures and evaluate the appro- priateness of the disclosure of these events. One option would be to do so and change the date on the auditor’s report to reflect the new (later) date. However, a disadvantage of this approach is that the auditors’ responsibility for all events is now extended to this later date.

When facts are discovered following the date of the auditor’s report but prior to the audit report release date, auditors normally choose to dual date the report (that is, to give it two dates). For example, KPMG completed the fieldwork for the 2018 audit of Papa Johns International on March 8, 2019. Following the end of fieldwork date, a material weakness in internal controls over financial reporting was discovered. Therefore the date used by KPMG in the 2018 auditor’s report of Papa Johns was as follows:

March 8, 2019, except for the restatement as to the effectiveness of internal control over financial reporting for the material weaknesses related to variable interest entity and con- solidation matters, as to which the date is May 7, 2019.

As this report dating noted, KPMG has taken full responsibility for all material sub- sequent events through March 8, 2019, except for the material weakness in internal con- trols. KPMG has responsibility for this event through May 7, 2019. While not the case in the KPMG example above, often times the report dating will refer to a financial statement note where more information about the dual dated event can be found.

Dual dating serves two important functions. First, it provides a way to modify the financial statements and disclosures for information discovered by auditors after the date of the auditor’s report. This gives financial statement users the most complete and cur- rent set of information about the entity. Second, it limits auditors’ liability for events after the date of the auditor’s report to the event(s) specifically identified in the report date. In some cases (particularly if facts become known immediately before a filing deadline), auditors may choose not to evaluate the effect of subsequently discovered facts on the financial statements. For example, in January 2011, American International Group (AIG) disclosed the impact of the recapitalization of AIG through the distribution of 92.2 percent of its outstanding shares of common stock to the U.S. Department of the Treasury. This event was disclosed in the footnotes to AIG’s financial statements and was marked as “unaudited.”

Alternatively, auditors may learn of facts following the issuance of the financial statements and auditor’s report. Obviously, this situation presents additional challenges

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because the financial statements and auditor’s report have already been issued to finan- cial statement users. If these facts would result in either the revision of the auditor’s report or the financial statements and individuals continuing to rely on these financial statements, the client should take the following actions:

1. Notify individuals known to be relying on the financial statements or likely to rely on the financial statements that (a) the financial statements should not be relied upon and (b) revised financial statements and a new auditor’s report will be issued.

2. Issue revised financial statements as soon as practicable with appropriate disclosure of the matter related to the subsequently discovered facts.

In the event that management refuses to take either of these actions, auditors should notify management, regulatory agencies, or any individuals known to be relying on the financial state- ments that the auditor’s report cannot be relied upon. If auditors determine that the subsequently discovered facts would require revision to the financial statements, the nature of the matter and effect on the financial statements should also be included in the auditor’s notification.

The audit timeline and actions for subsequent events and subsequently discovered facts follow:

For Fortune 100 companies in 2019, the average lag between the date of the financial statements and the date of the auditor’s report for the most recent fiscal year is 48.6 days and from the date of the audi- tor’s report to the filing of the 10-K with the SEC is 0.14 days. Interest- ingly, 91.4 percent of the Fortune 100 companies file their 10-K with the SEC on the same date as the date of the auditor’s report. Clearly,

the length of the period between the date of the auditor’s report and the audit report release date is quite short for the largest companies; this same period is 0.15 days for the Fortune 500 companies.

Source: Drawn from Wharton Research Data Services Audit Analytics database.

How Long Does It Take? AUDITING INSIGHT

Perform procedures related to subsequent events Adjust financial statements or disclose subsequent events

Perform procedures related to subsequently discovered facts Adjust financial statements or disclose subsequently discovered facts Extend date of the auditor’s report or dual date auditor’s report on financial statements

Request client to take action to reduce reliance on financial statements and auditor’s report and reissue financial statements If client refuses to take above actions, notify client, regulatory agencies, and users that auditor’s report is not to be relied upon

Year-End Date (December 31, 2020)

Date of the Auditor’s Report (audit completion date)

(February 15, 2021)

Audit Report Release Date (February 17, 2021)

On May 2, 2019, Kraft Heinz filed a Form 8-K with the Securities and Exchange Commission indicating that its previously issued financial statements for fiscal 2017 and 2016 (including interim financial state- ments) should no longer be relied upon because of certain accounting errors and irregularities in those financial statements.

Source: Kraft Heinz Form 8-K, May 2, 2019. In January 2016, KPMG announced the withdrawal of almost

10 years of audit opinions on the U.S. Commodity Futures Trading Commission (CFTC) due to alleged violations of GAAP. KPMG alleged

the CFTC understated liabilities in 2015 by $194 million and in 2014 by $212 million, the equivalent of more than 75% of the CFTC’s annual budget. In total, KPMG asked the CFTC to remove audit opinions from fiscal years 2005-2008 and years 2010 – 2014 from the CFTC website.

Source: Matthew Heller, “KPMG Withdraws Audit Opinions on Regulator,” CFO.com, January 21, 2016, (http://www.cfo.com/auditing/2016/01/kpmg- withdraws-audit-opinions-regulator/); Sarah N. Lynch and Lisa Lambert, “Exclusive: KPMG withdraws audit opinions on CFTC over accounting error - documents,” Reuters, January 19, 2016, (https://www.reuters.com/article/ us-usa-cftc-accounting-exclusive-idUSKCN0UY05Q)

Don’t Rely? AUDITING INSIGHT

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RESPONSIBILITIES FOLLOWING THE AUDIT REPORT RELEASE DATE

Omitted Procedures Although auditors have no responsibility to continue to review their work after the audit report release date, auditor’s reports and audit documentation may be subjected to a PCAOB inspection, external peer review, or the firm’s own internal inspec- tion program as part of its system of quality control. Section 104 of Sarbanes–Oxley requires inspections to be conducted annually by the PCAOB (if the firm provides services for more than 100 public audit clients) or every three years (if the firm pro- vides services for 100 or fewer public audit clients). These inspections could reveal situations in which an audit was not performed in accordance with generally accepted auditing standards. In particular, auditors could have failed to perform necessary audit procedures prior to the audit report release date. This situation is referred to as omitted procedures.

Professional standards provide guidance for such situations. If (1) the omitted procedures are important in supporting the auditor’s opinion and (2) individuals are currently relying on the client’s financial statements (and auditor’s reports), auditor’s should perform the omitted procedure or alternative procedure(s), if practicable. Assuming that the procedures allow auditors to support the previously expressed opinion, no further action is necessary. However, if they do not, auditors should formally withdraw the original report, issue revised reports, and inform persons currently relying on the financial statements.

Communications with Individuals Charged with Governance  During the engagement, matters can arise that are of such importance that they must be communicated with “individuals charged with governance.” Individuals charged with governance are the person(s) responsible for overseeing the client’s financial reporting process, including the internal control over financial reporting. Although this phrase can include the client’s management and full board of directors, for public entities it is typi- cally the audit committee of the board of directors. Audit committees are required for registrants under Sarbanes–Oxley and must be composed of only independent directors. Audit committees are an important element in the governance process because they are directly responsible for the appointment, compensation, and oversight of auditors and the audit examination.

Sections 204 and 404 of Sarbanes–Oxley both address required communications between auditors and the client’s audit committee. Professional standards require auditors

LO 11-6 Identify important activities and communications following the completion of the audit and audit report release date.

REVIEW CHECKPOINTS 11.22 What is a subsequent event? 11.23 What procedures do auditors perform to identify subsequent events? 11.24 Identify the two types of subsequent events. How should information about these events be

reflected in the financial statements? 11.25 What are subsequently discovered facts? 11.26 What are auditors’ responsibilities for subsequently discovered facts if these are identified (a)

prior to the audit report release date and (b) following the audit report release date? 11.27 What is the purpose of dual dating the auditor’s report?

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to communicate (in writing) all significant internal control deficiencies and material weaknesses to the client and individuals charged with governance. For public entities, the communication must be made prior to the audit report release date. For nonpublic entities, it is preferable to provide this communication prior to the audit report release date, but it should be made no later than 60 days following the audit report release date. Although auditors may decide to communicate significant deficiencies and material weaknesses to the client as they are discovered during the audit, if the client has not corrected (or remediated) these deficiencies or weaknesses, they must be communicated again in writing near the end of the audit.

For nonpublic entities, auditors’ communication would acknowledge that the pur- pose of the audit is to express an opinion on the financial statements, not on internal control over financial reporting; furthermore, the communication would explicitly state that auditors are not expressing an opinion on internal control over financial report- ing. For public entities subject to the reporting requirements of Sarbanes–Oxley, this communication would parallel the form and content of the auditor’s report on internal control over financial reporting, which expresses an opinion on internal control over financial reporting.

In addition to internal control deficiencies, professional standards require auditors to communicate various other matters to the client. As with internal control communica- tions, auditors ordinarily make these communications with individuals charged with gov- ernance after the audit; however, if the matters are particularly significant, they should be communicated during the audit. These communications may be made either orally or in writing (however, because of the important nature of these matters, one would anticipate that they be made in writing).

Auditors should communicate the following information to individuals charged with governance:

∙ Auditors’ responsibility under generally accepted auditing standards. ∙ An overview of the planned scope and timing of the audit. ∙ Auditors’ judgment about the quality of the client’s critical accounting policies,

accounting estimates, and financial statement disclosures. ∙ Any significant difficulties encountered during the audit. ∙ Any uncorrected misstatements identified during the audit other than those auditors

believe to be trivial and a request to correct the misstatements. ∙ Any disagreements with management. ∙ Material, corrected misstatements that were brought to the attention of management. ∙ Representations requested from the client’s management. ∙ Any management consultations with other auditors or any contentious matters about

which the auditor consulted outside the engagement team that may be relevant to the oversight of the financial reporting process.

∙ Any significant issues arising from the audit that were discussed with management. ∙ The auditor’s understanding of the business rationale for significant unusual

transactions. ∙ Other findings or issues that are significant and relevant to individuals charged with

governance.

Auditors also should determine that individuals charged with governance have received copies of written communications regarding material issues between auditors and man- agement such as engagement letters, written representations, and reports on deficiencies in internal control over financial reporting. Because of its important role, auditors com- municate frequently with the audit committee throughout the engagement. However, as the accompanying Auditing Insight reveals, such communication does not ensure that all relevant issues will be handled appropriately.

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Management Letter During the engagement (particularly the study and evaluation of the client’s internal control, assessment of the risk of material misstatement, and evaluation of the effectiveness of internal control over financial reporting), auditors note matters that can be made as recommendations to the client. These recommendations may allow the client to improve the efficiency and effectiveness of their operations. Near the end of the audit, these matters are summarized in a letter (commonly referred to as the management letter) that is delivered to and discussed with the client. Management letters are not required by generally accepted auditing standards but are considered an important method of adding value to clients beyond that provided by the audit examination. In this spirit, some firms encourage consulting and tax professionals to participate in preparing the management letter.

Management letters are a service provided as a by-product of the audit. The manage- ment letter is an excellent opportunity to develop rapport with the client and to make the client aware of other business services offered by the public accounting firm.

Summary of Audit Communications This text has mentioned many types of formal communications. Because you are learn- ing the final procedures to complete the audit, this is a good place to summarize these various communications. See Exhibit 11.3 for a summary of audit correspondence other than auditor’s reports on the financial statements (discussed in Chapter 12) and internal control over financial reporting (discussed in Chapter 5).

EXHIBIT 11.3 Audit Communications

Type From To Timing Reference Method Engagement letter Auditors Client Before engagement AU-C 210; AS 1301 Written

Acceptance letter (signed copy of engagement letter)

Client Auditors Before engagement AU-C 210;AS 1301 Written

Attorney letter response Attorney Auditors Near date of the auditor’s reports AU-C 501;AS 2505 Written

Written representations Client Auditors Date of the auditor’s reports (audit completion date)

AU-C 580;AS 2805 Written

Internal control deficiencies

Auditors Individuals charged with governance (audit committee)

Prior to audit report release date (for public entities) or within 60 days of audit report release date (for large nonpublic entities)

AU-C 265; AS 1305 Written

Communications with individuals charged with governance

Auditors Individuals charged with governance (audit committee)

After audit AU-C 260; AS 1301 Oral or written

Management letter Auditors Client After audit None Oral or written

Based on interviews with auditors, an academic study by Cohen et al. provided the following insights into auditors’ meetings with client audit committees:

• The frequency of meetings has increased from two to three times per year prior to Sarbanes–Oxley to more than six times per year.

• The most frequent issues discussed in audit committee meetings relate to accounting/auditing issues encountered in the engagement,

the audit plan, the results of the audit, and other mandated disclosures (discussed in this section).

• A relatively small percentage of auditors (52 percent) indicated that audit committees played an important role in resolving audi- tor disputes with management.

Source: J. Cohen, G. Krishnamoorthy, and A. Wright, “Corporate Governance in the Post-Sarbanes–Oxley Era: Auditors’ Experiences,” Contemporary Accounting Research, (Fall 2010), pp. 751–786.

Meetings with Audit Committees? AUDITING INSIGHT

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This chapter began by identifying four major periods during an audit: (1) prior to the date of the financial statements, (2) between the date of the financial statements and the date of the auditor’s report, (3) between the date of the auditor’s report and the audit report release date, and (4) following the audit report release date. As various matters are discussed, it is important to determine the time period in which auditors identify issues because this will affect auditors’ responsibility for these matters.

Within the context of the four periods, the chapter discussed several aspects of completing an audit. These events include (1) completing substantive procedures, (2) obtaining responses to attorney letters, (3) obtaining written representations, (4) evaluating the entity’s ability to continue as a going concern, (5) summarizing proposed adjustments to the financial statements, (6) reviewing audit documentation, (7) considering the effects of subsequent events and subsequently discovered facts, (8) evaluating omitted audit procedures identified following the audit examination, and (9) providing communications near the end of the audit. The purpose of these proce- dures is to enable auditors to issue and support opinions on financial statements and internal control over financial reporting.

Summary

REVIEW CHECKPOINTS 11.28 What steps should auditors take if, after the audit report release date, they discover that an

important audit procedure was omitted? 11.29 Identify information that auditors are required to communicate to individuals charged with gover-

nance of the client. 11.30 What is a management letter? Are management letters required by generally accepted auditing

standards?

Key Terms analytical procedures: Procedures that allow auditors to evaluate financial information by studying relationships among both financial and nonfinancial data. When used near the end of the audit, analytical procedures allow auditors to assess the conclusions reached during the audit and evaluate the overall financial statement presentation, 503 attorney letter: A communication prepared by the client but sent by the auditors to the client’s attorneys that details all pending litigation, claims, and assessments against the client and that requests the attorneys to comment on these matters directly to the client’s auditors, 505 audit report release date: The date on which auditors allow the client to use their reports in conjunction with the financial statements; also the date on which the client’s financial statements are issued, 502 contingency: An existing condition, situation, or set of circumstances involving uncertainty as to possible gain or loss to an enterprise that will ultimately be resolved when one or more future events occur or fail to occur, 504 date of the auditor’s report: The date on which auditors have gathered sufficient appropriate evidence on which to base their opinions on the financial statements and internal control over financial reporting; the date that will be used for auditors’ reports on the client’s financial statements and internal control over financial reporting, 502 date of the financial statements: The year-end date of the latest period covered by the client’s financial statements, 502 dual date: The use of two dates in the auditor’s report to limit the responsibility beyond the date of the auditor’s report to a specific subsequent event identified in the report, 516 engagement quality review: A review of audit documentation by an additional person (normally, a partner or equivalent with the firm who has not been involved with the audit) to ensure that the quality of the audit work and reporting is consistent with the quality standards of the public accounting firm, 514

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individual(s) charged with governance: The person(s) responsible for overseeing the client’s financial reporting process, including the internal control over financial reporting; individuals charged with governance may include the client’s management and full board of directors, but typically refers to public entities’ audit committee of the board of directors, 518 iron curtain method: The process used when evaluating the effect of uncorrected misstatements that considers the aggregate effect of current and prior misstatements in the entity’s balance sheet, 512 management letter: A communication that provides a summary of auditors’ recommendations resulting from the audit engagement that allows the client to improve the effectiveness and efficiency of its operations, 520 omitted procedures: The inadvertent failure of auditors to perform necessary audit procedures prior to the audit report release date, 518 roll-forward procedure(s): The procedure(s) performed by auditors to extend the conclusions from an interim date to the date of the financial statements, 503 rollover method: The process used when evaluating the effect of uncorrected misstatements that considers only the current-period income effect(s) of the potential adjustment, 512 subsequent events: Events occurring between the date of the financial statements and the date of the auditor’s report, 515 subsequently discovered fact: Information that becomes known to auditors after the date of their report that, had it been known at that time, may have caused the auditors to revise their report, 516 unasserted claim: A representation that no formal lawsuit or assertion has been filed or threatened on behalf of others against the audit client but that circumstances such as a catastrophe, accident, or other physical occurrence could result in a suit or assertion being filed in the future, 506 uncorrected misstatement: A misstatement that the auditor identified and accumulated during the audit that has not been corrected (or adjusted) by the client, 512 written representation: A written assertion provided by management to auditors related to the entity’s financial statements, the information provided to the auditors, and management’s internal control over financial reporting to confirm certain matters and support other evidence obtained during the audit, 507

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Multiple-Choice Questions for Practice and Review

11.31 Which of the following best describes the role of analytical procedures near the end of the audit engagement?

a. To identify possible deficiencies in the client’s internal control over financial reporting.

b. To identify accounts that appear to be misstated with the intention of planning the nature, timing, and extent of other substantive procedures.

c. To gather evidence to support one or more assertion(s) related to the account balance or class of transactions.

d. To provide an overall review of the financial information and assessment of the ade- quacy of evidence gathered during the audit engagement.

11.32 A major objective of written representations is to a. Shift responsibility for financial statements from the management to auditors. b. Provide a substitute source of audit evidence for substantive procedures that auditors

would otherwise perform. c. Provide management an opportunity to make assertions about the quantity and valuation

of the physical inventory. d. Impress on management its ultimate responsibility for the financial statements and

disclosures.

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11.33 Which of these substantive procedures is not used to obtain evidence about contingencies? a. Scanning expense accounts for credit entries. b. Obtaining a letter from the client’s attorney. c. Reading the minutes of the board of directors’ meetings. d. Examining terms of sale in sales contracts.

11.34 Subsequent knowledge of which of the following would cause the entity to adjust its December 31 financial statements?

a. Sale of an issue of new stock for $500,000 on January 30. b. Settlement of a damage lawsuit for a customer’s injury sustained February 15 for

$10,000. c. Settlement of litigation in February for $100,000 that had been estimated at $12,000 in

the December 31 financial statements. d. Storm damage of $1 million to the entity’s buildings on March 1.

11.35 J. Griffith audited the financial statements of Mets Magnificat Corporation for the year ended December 31, 2020. She completed gathering sufficient appropriate evidence on January 30 and later learned of a stock split voted by the board of directors on February 5. The financial statements were changed to reflect the split, and she now needs to dual date the report on the entity’s financial statements. Which of the following is the proper form?

a. December 31, 2020, except as to Note X, which is dated January 30, 2021. b. January 30, 2021, except as to Note X, which is dated February 5, 2021. c. December 31, 2020, except as to Note X, which is dated February 5, 2021. d. February 5, 2021, except for the date of the auditor’s report, for which the date is

January 30, 2021. 11.36 Auditors have a responsibility related to management’s disclosure of new information

related to subsequent events until a. The date of the financial statements. b. The date of the auditor’s report. c. The audit report release date. d. The following year’s date of the financial statements.

11.37 The auditing standards regarding subsequently discovered facts refers to knowledge obtained after

a. The date the fieldwork began. b. The date of the auditor’s report. c. The date of the financial statements. d. The date interim audit work was complete.

11.38 Which of the following is not required by generally accepted auditing standards? a. Written representations. b. Attorney letter. c. Management letter. d. Engagement letter.

11.39 Which of these persons generally does not participate in writing the management letter? a. Client’s outside attorneys. b. Client’s accounting and production managers. c. Public accounting firm’s audit team on the engagement. d. Public accounting firm’s consulting and tax experts.

11.40 Which of the following is ordinarily performed last in the audit examination? a. Securing a signed engagement letter from the client. b. Performing tests of controls. c. Performing a review for subsequent events. d. Obtaining signed written representations.

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11.41 Which of the following normally occurs earliest in the audit examination? a. Discovery of an omitted audit procedure. b. Dual dating the auditor’s report on the entity’s financial statements for subsequent

events that exist at the date of the financial statements. c. Preparation of the management letter. d. Review of audit documentation.

11.42 Ambrose is auditing the financial statements of Mays (dated December 31, 2020). The date of the auditor’s report is February 17, 2021, and the audit report release date is February 20, 2021. For which of the following matters would Ambrose have the least responsibility?

a. The obsolescence of inventory held on December 31, 2020, that was identified on January 20, 2021.

b. A customer’s deteriorating financial condition that was identified on February 19, 2021. c. A merger that was announced by Mays and known by Ambrose on February 12, 2021. d. A major loss due to a catastrophe that occurred and was known by Ambrose on March 1, 2021.

11.43 Which of the following statements is most likely to be included in an attorney letter? a. “Certain representations in this letter are described as being limited to matters that are

material.” b. “If any unasserted claims or assessments are omitted from this disclosure, please pro-

vide this information directly to our auditors.” c. “Our work enabled us to notice some actions that could enhance the profitability of the

Company.” d. “Please furnish to our auditors such explanation, if any, that you consider necessary to

supplement the foregoing information.” 11.44 After the audit report release date, auditors determine that an important auditing procedure

was omitted. Which of the following initial courses of action is most appropriate? a. Perform the omitted procedure or an alternative procedure. b. Notify the board of directors and regulatory agencies that are currently relying on audi-

tor’s reports. c. Determine whether the omitted procedure is important in supporting the auditor’s opin-

ion on the entity’s financial statements. d. Engage another public accounting firm to conduct a quality assurance review.

11.45 Which of the following statements is not true with respect to written representations? a. The failure of management to furnish them is a significant scope limitation, resulting in

either an adverse opinion or a disclaimer of opinion. b. They should address management’s responsibility for designing internal control to pre-

vent and detect fraud. c. Auditors use them to corroborate information received during the audit from the client

and its employees. d. They are dated the same date as the auditor’s reports.

11.46 Hall accepted an engagement to audit the year 1 financial statements of XYZ Company. XYZ completed the preparation of the year 1 financial statements on February 13, year 2, and its auditors began the fieldwork on February 17, year 2. Hall completed gathering sufficient appropriate evidence on March 24, year 2; Hall’s report and XYZ’s financial statements were released on March 28, year 2. The written representations normally would be dated

a. February 13, year 2. b. February 17, year 2. c. March 24, year 2. d. March 28, year 2.

(AICPA adapted) 11.47 What is an auditor’s primary method to corroborate information on litigation, claims, and

assessments? a. Examining legal invoices sent by the client’s attorney. b. Verifying attorney–client privilege through interviews.

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c. Reviewing the response from the client’s lawyer to a letter of audit inquiry. d. Reviewing the written representation letter obtained from management.

(AICPA adapted) 11.48 Which of the following substantive procedures should auditors ordinarily perform regard-

ing subsequent events? a. Compare the latest available interim financial statements with the financial statements

being audited. b. Send second requests to the client’s customers who failed to respond to initial accounts

receivable confirmation requests. c. Communicate material weaknesses in internal control to the client’s audit committee. d. Review the cutoff bank statements for several months after the date of the financial

statements. (AICPA adapted)

11.49 Which of the following substantive procedures would auditors most likely perform to obtain evidence about the occurrence of subsequent events?

a. Recompute a sample of large-dollar transactions occurring after the date of the financial statements for arithmetic accuracy.

b. Investigate changes in shareholders’ equity occurring after the date of the financial statements.

c. Send confirmations to vendors with whom the client normally does business but for which no balance in accounts payable is noted.

d. Confirm bank accounts established after the date of the financial statements. (AICPA adapted)

11.50 The primary reason auditors request responses to attorney letters is to provide auditors a. The probable outcome of asserted claims and pending or threatened litigation. b. Corroboration of the information furnished by management about litigation, claims, and

assessments. c. The attorney’s opinions of the client’s historical experiences in recent similar

litigation. d. A description and evaluation of litigation, claims, and assessments that existed at the

date of the financial statements. (AICPA adapted)

11.51 The scope of an audit is not restricted when an attorney letter limits the response to a. Matters to which the attorney has given substantive attention in the form of legal

representation. b. An evaluation of the likelihood of an unfavorable outcome of the matters disclosed by

the entity. c. The attorney’s opinion of the entity’s historical experience in recent similar litigation. d. The probable outcome of asserted claims and pending or threatened litigation.

(AICPA adapted) 11.52 Lee and Kerzman is the auditor for Nance Corporation. During the course of the audit, the

audit team noticed that Nance Corporation showed signs of financial distress. In particular, Nance Corporation was at risk for defaulting on several key loans and had therefore begun the process of restructuring their debt. This, among other indicators, led the audit team to have substantial doubt regarding Nance Corporation’s ability to continue as a going con- cern. The next step the team should take is to:

a. Do nothing, as the auditors have no responsibility related to going concern assessments.

b. Obtain and discuss with management their plan to continue as a going concern and assess the likelihood the plan will be successful.

c. Issue an unmodified opinion with an emphasis of a matter paragraph related ability of Nance Corporation to continue as a going concern.

d. Resign from the engagement.

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11.53 What does the auditor need to document when there is substantial doubt that a client will continue as a going concern?

a. The conditions or events that suggest there is a going concern uncertainty. b. Management’s plan (or lack thereof) to mitigate the conditions and to continue as a

going concern. c. The auditor’s conclusion on whether, after evaluating management’s plan, substantial

doubt exists regarding the company’s ability to continue as a going concern and whether any report modifications are needed.

d. All of the above.

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11.54 Written Representations. Hart, an assistant accountant with the firm of Better & Best, CPAs, is auditing the financial statements of Tech Consolidated Industries Inc. The firm’s audit plan calls for the preparation of written representations.

Required: a. In an audit of financial statements, in what circumstances are auditors required to obtain

written representations? b. What are the major categories of items covered by written representations? c. To whom should the representations be addressed and as of what date should they be dated? d. Who should sign the representations, and what would be the effect of a refusal to sign them? e. In what respects may auditors’ other responsibilities be relieved by obtaining written

representations? (AICPA adapted)

11.55 Written Representations Omissions. During the audit of the annual financial state- ments of Amis Manufacturing Inc., the company’s president, Vance Molar, and Wanda Dweebins, the engagement partner, reviewed matters that were supposed to be included in written representations. Amis Manufacturing is a private company. Upon receipt of the following representations, Dweebins contacted Molar to state that they were incomplete. To John & Wayne, CPAs: In connection with your examination of the balance sheet of Amis Manufacturing Inc., as of December 31, 2020, and the related statements of income, retained earnings, and cash flows for the year then ended, for the purpose of expressing an opinion on whether the financial statements present fairly the financial position, results of operations, and cash flows of Amis Manufacturing Inc., in conformity with generally accepted accounting prin- ciples, we confirm, to the best of our knowledge and belief, the following representations made to you during your audit. There were no

∙ Plans or intentions that could materially affect the carrying value or classification of assets or liabilities.

∙ Communications from regulatory agencies concerning noncompliance with, or defi- ciencies in, financial reporting practices.

∙ Agreements to repurchase assets previously sold. ∙ Violations or possible violations of laws or regulations whose effects should be considered

for disclosure in the financial statements or as a basis for recording a contingent liability. ∙ Unasserted claims or assessments that our lawyer has advised are probable of assertion

that must be disclosed in accordance with Accounting Standards Codification (ASC) 450. ∙ Capital stock purchase options or agreements or capital stock reserved for options, war-

rants, conversions, or other requirements. ∙ Compensating balance or other arrangements involving restrictions on cash balances.

Vance Molar, President Amis Manufacturing Inc.

March 14, 2021

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Exercises, Problems, and Simulations

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Required: Identify the other matters that Molar’s representations should specifically confirm.

(AICPA adapted) 11.56 Written Representations. Each of the following statements is a communication from

management. Indicate whether the inclusion of each statement in written representations is appropriate. Provide your rationale for any statements whose inclusion in written represen- tations is not appropriate.

a. “Certain representations in this letter are described as being limited to matters that are material.” b. “No frauds involving management, employees who have significant roles in internal

control, or other frauds that could have a material effect on the financial statements have occurred during the year under audit.”

c. “Based on our assessment, we conclude that the Company has maintained an effective internal control over financial reporting as of December 31, 2020.”

d. “We have prepared a description and evaluation of certain contingencies for which our attorneys have devoted substantive attention on our behalf in the form of legal representation.”

e. “There are no significant deficiencies, including material weaknesses, in the design or operation of internal controls that could adversely affect our ability to record, process, summarize, and report financial data.”

f. “Summarized below are important actions taken in response to comments provided by you in the management letter dated March 22, 2021, based on your prior audit.”

g. “Our assessment of internal control over financial reporting provides us absolute assur- ance that no material misstatements will occur and be undetected by our internal control.”

h. “We have made available to you all financial records and related data.” 11.57 Written Representations. Classify each of the following issues according to whether

they will be (1) included in written representations in all audits, (2) included in written representations in audits of public entities (under PCAOB standards), or (3) not included in written representations:

a. Management acknowledgment of its responsibility for the fairness of the financial state- ments in accordance with U.S. GAAP.

b. A list of pending or threatened litigation, claims, or assessments currently outstanding against the client.

c. A description of recommendations that allow the client to improve the efficiency and effectiveness of its operations.

d. Availability of all financial records and related data. e. Information related to the presentation and disclosure of items within the financial

statements. f. Disclosure of all significant deficiencies and material weaknesses in internal control. g. Information concerning fraud involving management and employees who have signifi-

cant roles in internal control. h. Auditors’ judgment about the quality of the client’s accounting principles. i. Management’s conclusion about the effectiveness of its internal control over financial reporting. j. A statement that the financial statements are prepared according to U.S. generally

accepted accounting principles. 11.58 Client Request for Attorney Letter. The firm of Cole & Cole, CPAs, is auditing the

financial statements of Consolidated Industries Co. for the year ended December 31, 2020. On March 6, 2021, C. R. Brown, Consolidated’s chief financial officer, gave the auditors a draft of an attorney letter for Cole’s review before mailing it to J. J. Young, Consolidated’s outside counsel. This letter is intended to elicit the attorneys’ responses to corroborate information furnished to the auditors by management concerning pending and threatened litigation, claims, assessments, and unasserted claims and assessments. March 6, 2021 J. J. Young, Attorney at Law 123 Main Street, Anytown, USA Dear J. J. Young:

In connection with an audit of our financial statements at December 31, 2020, and for the year then ended, management of the Company has prepared, and furnished to our

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auditors, Cole & Cole, CPAs, a description and evaluation of certain contingencies, includ- ing those set forth below, involving matters with respect to which you have been engaged and to which you have devoted substantive attention on behalf of the Company in the form of legal consultation or representation. Your response should include matters that existed at December 31, 2020. Because of the confidentiality of all these matters, your response may be limited.

In November 2020, an action was brought against the Company by an outside salesman alleging breach of contract for sales commissions and asking an accounting with respect to claims for fees and commissions. The causes of action claim damages of $3,000,000, but the Company believes it has meritorious defenses to the claims. The possible exposure of the Company to a successful judgment on behalf of the plaintiff is slight.

In July 2020, an action was brought against the Company by Industrial Manufacturing Company (Industrial) alleging patent infringement and seeking damages of $20,000,000. On October 16, 2020, the U.S. District Court decided that the Company had infringed on seven Industrial patents and awarded damages of $14,000,000. The Company vigorously denies these allegations and has filed an appeal with the U.S. Court of Appeals. The appeal process is expected to take approximately two years, but there is some chance that Indus- trial may ultimately prevail.

Please furnish to our auditors such explanation, if any, that you consider necessary to supplement this information, including an explanation of those matters as to which your views may differ from those stated, and an identification of the omission of any pending or threatened litigation, claims, and assessments or a statement that the list of such matters is complete. Your response may be quoted or referred to in the financial statements without further correspondence with you.

You also consulted on various other matters considered to be pending or threatened litigation. However, you may not comment on these matters because publicizing them may alert potential plaintiffs to the strengths of their cases. In addition, various other matters probable of assertion that have some chance of an unfavorable outcome, as of December 31, 2020, are presently considered unasserted claims and assessments.

Respectfully, C. R. Brown Chief Financial Officer

Required: Describe the omissions, ambiguities, and inappropriate statements and terminology in Brown’s letter. Remember that this is Brown’s letter requesting a response to auditors, but it must request responses in the manner most useful to auditors.

(AICPA adapted) 11.59 Attorney Letters. Faye Jaworski, CPA, is auditing the financial statements of Fulbright

Company. As she is nearing the audit completion date, Jaworski realizes that she needs to evaluate whether all material contingencies are properly accounted for and disclosed in Fulbright’s financial statements. Because of its size, Fulbright has retained external coun- sel (Vinson, LLP) to handle its various legal matters.

Required: a. List some common procedures that Jaworski will perform with respect to Fulbright’s

litigation, claims, and assessments. b. What are the responsibilities of Jaworski, Fulbright, and Vinson with respect to litigation,

claims, and assessments? c. Attorney letters are used to provide corroboration of litigation, claims, and assessments

against the client. Briefly describe the process through which attorney letters are pre- pared, sent, and used in the audit examination.

d. What information is normally included in an attorney letter? 11.60 Uncorrected Misstatements and Performance Materiality. Aaron Rivers, CPA, is

auditing the financial statements of Charger Company, a client for the past five years. During past audits of Charger, Rivers identified some immaterial misstatements (most of which relate to isolated matters and do not have common characteristics). A summary of these misstatements follows. (To illustrate, in 2015, the misstatements would have reduced net income by $13,200 if corrected:)

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During the most recent audit, Rivers concluded that service revenue totaling $11,000 was recognized as of December 31, 2020 and it did not meet the criteria for recognition until 2021. When Rivers discussed this issue with Chris Turner, Charger Company’s chief financial officer, Turner asked Rivers about the performance materiality level used in the audit, which was $25,000. Upon learning of this, Turner remarked, “Then there’s no need to worry . . . it’s not a material amount. Why should we bother with this item?”

Required: a. How does the misstatement identified in 2020 affect net income, assets, liabilities, and

equity in 2020? (Assume a 35 percent tax rate for Charger.) b. Comment upon Turner’s remark to Rivers. Is Turner’s reasoning correct? c. Upon doing some research, Rivers learned of the rollover method and iron curtain method for

evaluating the performance materiality of misstatements. Briefly define each of these methods. d. How would Rivers evaluate the performance materiality of the $11,000 sales cutoff error

in 2020 under the rollover method and iron curtain method? e. Based on your response to part (d), what adjustments (if any) would Rivers propose to Char-

ger Company’s financial statements under the rollover method and iron curtain method? 11.61 Uncorrected Misstatements and Performance Materiality. During the conduct of an

audit, auditors may identify misstatements as a result of the completion of their substan- tive procedures. An important activity performed in the completion stages of the audit is considering the materiality of misstatements identified during the audit.

Required: a. What is an uncorrected misstatement? What is the auditors’ responsibility for uncor-

rected misstatements during the completion stage of the audit engagement? b. How do auditors use the rollover method and iron curtain method to evaluate uncorrected

misstatements? c. Assume that auditors have identified misstatements during the current audit that had a net

impact of $100,000 on expenses and payables (both were understated). If the cumulative effect of prior uncorrected misstatements was $120,000 (overstatement of net income and understatement of liabilities) and materiality was $150,000, what would the auditors’ conclu- sion be with respect to the misstatements under the rollover method and iron curtain method?

d. Based on your response to part (c), what adjustments (if any) would the auditors propose to the client’s financial statements?

e. What requirements do auditors have for communicating uncorrected misstatements iden- tified during the audit engagement?

11.62 Uncorrected Misstatements and Performance Materiality. Pat Colt is auditing the financial statements of Manning Company. The following is a summary of the uncorrected misstatements that Colt has identified during the past three years. These misstatements are immaterial and have related to isolated matters. In this summary, parentheses imply that the misstatements would have reduced balances if they had been corrected (e.g., in 2017, the misstatements would have reduced net income by $82,500, assets by $100,000, liabilities by $17,500, and equity by $82,500 if corrected).

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Year Effect on Net Income

Effect on Assets

Effect on Liabilities

Effect on Equity

2015 ($13,200) ($20,000) ($6,800) ($13,200) 2016 5,000 12,000 7,000 5,000 2017 (9,250) (11,000) (1,750) (9,250) 2018 (2,000) (5,500) (3,500) (2,000) 2019 1,000 1,000 0 1,000

Year Effect on

Net Income Effect

on Assets Effect

on Liabilities Effect

on Equity

2017 $(82,500) $(100,000) $(17,500) $(82,500) 2018 (22,000) (25,500) (3,500) (22,000) 2019 30,000 30,000 0 30,000

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During the most recent audit, Colt concluded that expenses totaling $130,000 were recognized in January 2021 (when Manning paid them) but should have been recognized in 2020.

Required: a. How does the misstatement identified in 2020 affect net income, assets, liabilities, and

equity? (Assume a 35 percent tax rate for Manning.) b. Describe the rollover method of evaluating uncorrected misstatements. Assume that per-

formance materiality was set at $170,000. How would Colt evaluate the materiality of the misstatement under the rollover method? What adjustments (if any) would Colt propose to Manning’s financial statements?

c. Describe the iron curtain method of evaluating uncorrected misstatements. Assume that performance materiality was set at $170,000. How would Colt evaluate the materiality of the $130,000 misstatement in 2020 under the iron curtain method? What adjustments (if any) would Colt propose to Manning’s financial statements?

d. If performance materiality were established at $100,000 for Manning, how would Colt evaluate the materiality of the misstatement in 2020 under the rollover method and iron curtain method?

e. Based on your response to part (d), what adjustments (if any) would Colt propose to Manning’s financial statements under the rollover method and the iron curtain method?

11.63 Subsequent Events—Internet Exercise. The following subsequent event was disclosed in Dole Food Company’s 2009 annual report:

Note 24: Subsequent Event On February 27, 2010, a significant earthquake struck the country of Chile. Although Dole’s Chilean operations resumed business after the earthquake in a matter of days, Dole is currently evaluating its impact, if any, to its financial results. Preliminary reports indicate no major structural damage to the Dole facilities. Dole maintains customary insurance for its properties, including business interruption and extra related expense.

Required: a. What is a subsequent event? b. Access Dole’s 2009 10-K (filed in 2010) from the SEC’s website (www.sec.gov).

1. What is Dole’s fiscal year-end? 2. What is the date of the auditor’s report? 3. When was Dole’s 10-K filed with the SEC?

c. Given your answers in part (b), does it appear that this event meets the definition of a “subsequent event”? Why or why not?

d. Assuming that this event did meet the definition of a subsequent event, would you clas- sify it as a subsequent event that relates to a condition that existed at the date of the finan- cial statements or one that arose after the date of the financial statements?

e. Given the preceding disclosure, what procedures do you think Dole’s auditors (Deloitte & Touche) performed with respect to this event?

11.64 Attorney Letters and Litigation—Internet Exercise. From the SEC’s website (www .sec.gov), access any company’s 10-K and review its footnote disclosures related to pending litigation.

Required: a. Briefly summarize the nature of pending litigation facing the company you selected. b. From the auditors’ perspective, what is the primary concern with respect to the disclosure

of pending litigation? c. Identify the responsibility of the company, the auditor, and its attorneys with respect to

the presentation and disclosure of this pending litigation. d. What information included in the disclosure you selected would have been

included in attorney letters? What is the attorney’s responsibility with respect to this information?

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11.65 Omitted Procedures and Subsequently Discovered Facts—Internet Exercise. From the “Inspections” section of the PCAOB’s website, access the most recent inspection reports for each of the Big Four firms (Deloitte, EY, KPMG, and PwC). Each inspection report contains the following information:

∙ An introductory preface. ∙ Inspection procedures and observations, which include specific findings related to issu-

ers (clients) (Part I). ∙ A summary of the inspection process. ∙ The firm’s response to the inspection report. Occasionally, the PCAOB’s inspection process identifies situations in which necessary audit pro- cedures were not performed or in which the auditors did not identify departures from GAAP.

Required: a. What is the auditors’ responsibility with respect to subsequently discovered facts and

omitted procedures? b. If one is provided, review and briefly summarize the firm’s response to the inspection

report. Comment on whether you believe the firm’s response to omitted procedures and subsequently discovered facts was consistent with generally accepted auditing standards.

11.66 Subsequent Events and Subsequently Discovered Facts. Michael Ewing is auditing the financial statements of Dallas Company for the year ended December 31, 2020. In conclud- ing the process of gathering sufficient appropriate evidence, Ewing has asked to meet with his supervisor on the audit (John Ross) to discuss responsibility for events occurring after the date of the financial statements.

Required: a. What is a subsequent event? During what time period is Ewing responsible for subse-

quent events? b. List some procedures that Ewing may perform to assist him in identifying subsequent

events. c. What are two types of subsequent events? How should information related to these types

of subsequent events be reflected in Dallas’s financial statements? d. Assume that on January 8, 2021, Dallas Company agreed to acquire Houston Inc. in a

significant transaction. The date of Ewing’s report was February 7, 2021, and Dallas issued its financial statements (and Ewing’s reports on its financial statements and inter- nal control over financial reporting) on February 14, 2021. How would Ewing proceed if he became aware of this subsequent event on the following dates? 1. January 10, 2021. 2. February 10, 2021. 3. February 20, 2021.

e. On March 2, 2021, Dallas announced that it also will acquire San Antonio Company in a significant transaction. What is Ewing’s responsibility with respect to this acquisition in the audit of Dallas’s financial statements for the year ended December 31, 2020?

11.67 Subsequent Events and Contingent Liabilities. Crankwell Inc. is preparing its annual financial statements and annual report to stockholders. Management wants to be sure that all of the necessary and proper disclosures have been incorporated into the financial statements and the annual report. Two classes of items that have an important bearing on the financial statements are subsequent events and contingent liabilities. The financial statements could be materially inaccurate or misleading if proper disclosure of these items is not made.

Required: a. With respect to subsequent events

1. Define what is meant by a subsequent event. 2. Identify two types of subsequent events and explain the appropriate financial state-

ment presentation of each type. 3. What are the procedures that should be performed to ascertain the existence of subse-

quent events?

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b. With respect to contingent liabilities 1. Identify the essential elements of a contingent liability. 2. Explain how a contingent liability should be disclosed in the financial statements.

c. Explain how a subsequent event may relate to a contingent liability. Give an example to support your answer.

(CMA adapted) 11.68 Subsequent Events Procedures. You are in the process of completing the gathering

of sufficient appropriate evidence for Top Stove Corporation, a company engaged in the manufacture and sale of kerosene space heaters. To date, there has been every indication that the financial statements of the client present fairly the position of the company at December 31 and the results of its operations and cash flows for the year then ended. Top Stove had total assets at December 31 of $4 million and a net profit for the year (after deducting federal and state income taxes) of $285,000. The principal records of the company include a general ledger, cash receipts record, voucher register, sales register, check register, and general journal. Financial statements are prepared monthly. Your audit report is dated February 20, and you plan to deliver the reports to the client by March 12.

Required: a. Write a brief statement about the purpose and period to be covered in a review of subse-

quent events. b. Outline the program you would follow to determine what transactions involving material

amounts, if any, have occurred since the date of the financial statements. (AICPA adapted)

11.69 Subsequent Events—Cases. In connection with your examination of the financial state- ments of Olars Manufacturing Corporation for the year ended December 31, your post- balance-sheet substantive procedures disclosed the following items:

1. January 3. The state government approved a plan for the construction of an express high- way. The plan will result in the appropriation of a portion of the land area owned by Olars. Construction will begin late next year. No estimate of the condemnation award is available.

2. January 4. Yang Olars (president of Olars Manufacturing Corporation) loaned the com- pany $25,000. He obtained these funds on July 15 by borrowing against a personal life insurance policy. The loan from Olars to Olars Manufacturing Corporation was recorded in the account Loan Payable to Officers. Olars’s source of the funds was not disclosed in the company records. The corporation pays the premiums on the life insurance policy, and the president’s wife is the owner and beneficiary of the policy.

3. January 7. The mineral content of a shipment of ore in transit on December 31 was deter- mined to be 72 percent. The shipment was recorded at year-end at an estimated content of 50 percent by a debit to Raw Materials Inventory and a credit to Accounts Payable in the amount of $20,600. The final liability to the vendor is based on the actual mineral content of the shipment.

4. January 15. A series of personal disagreements have arisen between Olars and Zane Tweedy, his brother-in-law, the treasurer. Tweedy resigned, effective immediately, under an agreement whereby the corporation would purchase his 10 percent stock ownership at book value as of December 31. Payment is to be made in two equal amounts in cash on April 1 and October 1. In December, the treasurer had obtained a divorce from Olars’s sister.

5. January 31. As a result of reduced sales, production was curtailed in mid-January and some workers were laid off. On February 5, all remaining workers went on strike. To date the strike is unsettled.

Required: Assume that the preceding items came to your attention prior to completion of your audit work on February 15. For each item

a. Give the substantive procedures, if any, that would have brought the item to your atten- tion. Indicate other sources of information that could have revealed the item.

b. Discuss the disclosure that you would recommend for the item, listing all details that should be disclosed. Indicate those items or details, if any, that should not be disclosed. Give your reasons for recommending or not recommending disclosure of the items or details.

(AICPA adapted)

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11.70 Subsequently Discovered Facts. On June 1, Sidney Faultless of A. J. Faultless & Co., CPAs, noticed some disturbing information about the firm’s client, Hopkirk Company. A story in the local paper mentioned the indictment of Tony Baker, whom Faultless knew as the assistant controller at Hopkirk. The charge was mail fraud. Faultless made discreet inquiries with the controller at Hopkirk’s headquarters and learned that Baker had been speculating in foreign currency futures. In fact, part of Baker’s work at Hopkirk involved managing the company’s foreign currency. Unfortunately, Baker had violated company policy, lost a small amount of money, and then decided to speculate some more, lost some more, and eventually lost $7 million of company funds.

The mail fraud was involved in Baker’s attempt to cover his activity until he recovered the original losses. Most of the events were in process on March 1, when Faultless had signed and dated the unmodified opinion on Hopkirk’s financial statements for the year ended on the previous December 31. Faultless determined that the information probably would affect the decisions of external users and advised Hopkirk’s chief executive to make the disclosure. She flatly refused to make any disclosure, arguing that the information was immaterial. On June 17, Faultless provided the subsequent information in question to a news reporter, and it was printed in The Wall Street Journal with a statement that the financial statements and accompanying audi- tor’s report on the company’s financial statements could not be relied on.

Required: Evaluate the actions of Faultless & Co., CPAs, with respect to the information discovered. What other action could Faultless & Co. have taken? What are the possible legal effects of the firm’s actions, if any?

11.71 Omitted Audit Procedures. The following are independent situations that have occurred in your public accounting firm, Arthur Hurdman5:

Case 1 During the internal inspection by a regional office of Arthur Hurdman, one of its clients, Wildcat Oil Suppliers, was selected for review. The reviewers questioned the thoroughness of inventory obsolescence procedures, especially in light of the depressed state of the oil exploration industry at the time. They believed that specific substantive procedures, which they considered appropriate, were not performed by your audit team.

Case 2 Top Stove, one of your clients, installed an automated system in July 2020 to process part of its accounting transactions. You completed the audit of Top Stove’s December 31, 2020, statements on February 15, 2021. During the April 2021 review work on Top Stove’s first- quarter financial information, you discovered that during the audit of the 2020 statements, only the manual records had been investigated in the search for unrecorded liabilities.

Required: a. Without regard to the specific situation given, answer the following questions:

1. What are the proper steps auditors should take if it is discovered, after the report date, that an important substantive procedure was omitted?

2. How are auditors’ decisions affected if, after review of the audit documentation, they deter- mine that other substantive procedures produced the sufficient appropriate audit evidence?

3. If, in subsequently applying the omitted procedure, auditors become aware of mate- rial new information that should have been disclosed in the financial statements, how should they proceed?

b. Describe the proper action to take in each of the preceding situations, given the following additional information:

∙ Case 1. You thoroughly consider the scope of the audit of Wildcat Oil Suppliers and have made a detailed review of the audit documentation. You have concluded that suf- ficient compensating procedures were conducted to support the valuation of inventory.

∙ Case 2. Your subsequent investigation of the information system’s records of Top Stove revealed that material liabilities were not recorded as of December 31.

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5Situation derived from examples given in Thomas R. Weirich and Elizabeth J. Ringelberg, “Omitted Audit Procedures,” CPA Journal, March 1984, pp. 34–39.

laser
Callout
We have renumber the FN 7 as FN 5 for maintain the consistency.

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11.72 Subsequent Events, Subsequently Discovered Facts, and Omitted Procedures. Jay Ralph completed the December 31, 2020, audit of Raider Company on February 3, 2021; Raider’s financial statements and Ralph’s reports on Raider’s financial statements and internal control over financial reporting were released on February 12, 2021. During April 2021, Ralph’s firm conducted a quality review over selected audits that had been completed during the most recent year, and the audit of Raider Company was randomly selected for review. The reviewer identified the following matters that Ralph had not addressed during the audit of Raider:

a. On February 9, 2021, Ralph learned of the following events during his postaudit meet- ing with Raider’s chief operating officer.

1. A class-action lawsuit was brought against Raider Company by some of its for- mer employees for workplace discrimination. An attorney on behalf of a class of employees filed the lawsuit on January 10, 2021. The letter from Raider’s attor- neys did not identify this lawsuit.

2. One of Raider’s major customers is experiencing significant financial difficul- ties; this customer’s account receivable balance on December 31, 2020, was $1.2 million, which represented 2 percent of Raider’s total accounts receivable on that date.

Because of an important deadline for submitting the financial statements to lenders for evaluation, Raider did not modify its financial statements for the preceding events despite the fact that they were material. Raider’s justification was that because the events occurred after the date of the financial statements, they were not required to be disclosed in the financial statements. Ralph acquiesced to Raider’s wishes and did not modify the report on Raider’s financial statements.

b. On March 16, 2021, Ralph initially learned of the following events affecting Raider Company, neither of which was disclosed in Raider’s financial statements:

1. Raider Company declared a significant dividend payable to its shareholders. This dividend was declared on March 14, 2021, to be paid to Raider’s shareholders of record on May 16, 2021.

2. Raider Company activated a portion of its line of credit on February 1, 2021, by borrowing $2.5 million. This additional obligation increased Raider Company’s long-term liabilities by 10 percent.

c. Reviewing Ralph’s audit documentation, it does not appear that any tests were con- ducted to evaluate the need for impairment of the carrying value of Raider Company’s property, plant, and equipment.

Required: For each of the preceding items, describe what actions Ralph should take after the firm’s quality review identified these issues.

11.73 Various Completion Matters. For each of the following independent situations, describe the most appropriate course of action that the auditors should take.

a. Drew Allison is conducting the audit of Anderson Inc. as of December 31, 2020. At the beginning of the evidence gathering, Allison becomes aware that one of Anderson’s major customers (Jones) is experiencing significant financial difficulties. Jones nor- mally accounts for 5 percent of Anderson’s net sales. After performing the necessary procedures, Allison believes that $2.8 million of Jones’s receivable balance will ulti- mately become uncollectible. Allison further believes this amount is material to Ander- son’s financial condition and results of operations.

b. Nagan Carmelo is completing the December 31, 2020, audit of Nugget Company. As part of the final procedures, Carmelo has requested representations from Nugget’s man- agement regarding their assertion as to the fairness of the financial statements and other important matters addressed by professional standards. Because Nugget’s management is attending an analyst briefing in the upcoming week, Carmelo receives these signed representations dated February 6, 2021. Carmelo has a few remaining items to com- plete, does so, and dates the auditor’s report February 9, 2021.

c. Pat Colt completed the December 31, 2020, audit of Manning and issued an unmodi- fied opinion on Manning’s financial statements dated March 15, 2021. Colt’s opinion

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was released, along with Manning’s financial statements, on March 21, 2021. Dur- ing a review of Manning’s first quarter 10-Q in late April, Colt became aware of the company’s settlement with a customer over a product warranty lawsuit; this case had been settled on March 13, 2021. Although Colt had received the necessary letter from Manning’s attorneys, the letter arrived prior to the settlement of the case and did not mention this development. After reviewing the information related to the settlement, Colt does not believe that the settlement is material to Manning’s financial condition or results of operations and believes the opinion on Manning’s financial statements is still supportable.

d. Cameron Alta completed the December 31, 2020, audit of Saxe Company on February 10, 2021. Saxe is planning to release its financial statements, along with Alta’s opinion on these financial statements and internal control over financial reporting, on February 17, 2021. On February 12, 2021, a flood in one of Saxe’s warehouses located in the Gulf Coast region destroyed more than $10 million of inventory. Although the extent to which this loss is recoverable through Saxe’s insurance is uncertain at this time, Alta believes that this loss could have a material impact on Saxe’s financial condition and results of operations.

e. During the audit of Glomco, Angel Myron identified a number of misstatements. These misstatements are not material in dollar amount, do not appear to represent any discern- able pattern, and do not represent fraudulent activity. As a result, Myron has decided that Glomco’s financial statements do not need to be adjusted to reflect the effect of these misstatements.

f. Following the completion of the 2020 audit of Blankenship Corporation and release of the financial statements and auditor’s reports, Reese Jill met with the manager to conduct a postmortem on the engagement and identify how changes in Blankenship’s operations noted during the most recent audit may affect future audits. During this review, Jill became aware that Blankenship’s process for evaluating goodwill related to an acquisition made by Blankenship during the most recent year for potential impair- ment had not been considered. Jill believes that the omitted procedure is important in supporting the opinion on Blankenship’s financial statements and that users continue to rely on the financial statements and the auditor’s reports.

11.74 Attorney Letter Responses. Omega Corporation is involved in a lawsuit brought by a competitor for patent infringement. The competitor is asking $14 million actual damages for lost profits and unspecified punitive damages. The lawsuit has been in progress for 15 months, and Omega has worked closely with its outside counsel preparing its defense. Omega recently requested its outside attorneys with the firm of Wolfe & Goodwin to provide information to its auditors.

The managing partner of Wolfe & Goodwin asked four different lawyers who have worked on the case to prepare a concise response to auditors. The auditors received these responses from the lawyers: 1. The action involves unique characteristics in which authoritative legal precedents bearing

directly on the plaintiff’s claims do not seem to exist. We believe the plaintiff will have serious problems establishing Omega’s liability; nevertheless, if the plaintiff is success- ful, the damage award may be substantial.

2. In our opinion, Omega will be able to defend this action successfully, but, if not, the pos- sible liability to Omega in this proceeding is nominal in amount.

3. We believe the plaintiff’s case against Omega is without merit. 4. In our opinion, Omega will be able to assert meritorious defenses and has a reasonable

chance of sustaining an adequate defense with a possible outcome of settling the case for less than the damages claimed.

Required: a. Interpret each of the four responses separately. Decide whether each is (1) adequate to

conclude that the likelihood of an adverse outcome is “remote,” requiring no disclosure in financial statements or (2) too vague to serve as adequate information for a decision, requiring more information from the lawyers or from management.

b. What response do you think auditors would receive if they asked the plaintiff’s counsel about the likely outcome of the lawsuit? Discuss.

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11.75 Accounting for a Contingency: Attorney Letter Information. Central City was involved in litigation brought by Mexican American Legal Defense and Educational Fund (MALDEF) over the creation of single-member voting districts (which require candidates to receive only the highest number of votes, even if not a majority) for city council positions. Auditors were working on the financial statements for the year ended December 31, 2020, and had almost completed gathering sufficient appropriate evidence by February 12, 2021.

The court heard final arguments on February 1 and rendered its judgment on February 10. The ruling was in favor of MALDEF and required the creation of certain single-member voting districts. This ruling did not impose a monetary loss on Central City, but the court also ruled that MALDEF would be awarded a judgment of court costs and attorney fees to be paid by Central City. Local newspaper reports stated that MALDEF would seek a $250,000 recovery from the city. Auditors obtained an attorney letter dated February 15 that stated the following: In my opinion, the court will award some amount for MALDEF’s attorney fees. In regard to your inquiry about an amount or range of possible loss, I estimate that such an award could be anywhere from $30,000 to $175,000.

Required: a. What weight should be given to the newspaper report of the $250,000 amount that

MALDEF might ask? What weight should be given to the attorney’s estimate? b. How should this subsequent event be reflected in the 2020 financial statements of

Central City?

LO 11-2

Apollo Shoes Completing the Audit You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Water- shed and have been assigned to the engagement team of a new audit client, Apollo Shoes Inc. You have been asked to help in performing procedures related to wrapping up the audit. Detailed instructions for performing the wrap up procedures, as well as working papers, can be found in Connect.

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Reports on Audited Financial Statements

LEARNING OBJECTIVES Management has the primary responsibility for the presentation of financial statements in accordance with generally accepted accounting principles (GAAP) or other applicable reporting frameworks. Following the substantive procedures, auditors express an opinion on the fairness of these financial statements,

which represent the culmination of the audit examination.

Your objectives are to be able to:

LO 12-1 Understand the types of reports that accom- pany an entity’s financial statements and the content of the auditors’ standard (unmodi- fied) report.

Jim Peterson. “The Rolls-Royce of Audit Reports Hits The Road: Test- Driving KPMG’s Latest Model.” Accessed November 30, 2019. https://www. jamesrpeterson.com/home/kpmg/

The interesting question is whether the world was really waiting for essays

of 500-word-length on such eye-crossingly complicated topics as revenue

and profit measurement, measurement of liabilities from sales financing

arrangements, or the concept and presentation of non-standard “underly-

ing” profit on foreign transactions. Or would information users have pre-

ferred the traditional, simple and comfortable anodyne opinion. . .

C H A P T E R 1 2

Professional Standards References

Topic AU-C/ISA Section

AS Section

Going Concern 570 2415 Audits of Group Financial Statements 600 1205 Reporting on Financial Statements 700 3101 Communicating Key Audit Matters 701 3101 Modifications to Reports on Financial Statements 705 3105 Emphasis-of-Matter and Other-Matter Paragraphs 706 3101 Consistency 708 2820 Other Information 720 2710 Supplementary Information 725 2701 Required Supplementary Information 730 2705 Summary Financial Statements 810 3315 Integrated Audit of Internal Control over Financial Reporting N/A 2201

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INTRODUCTION An emerging concern regarding U.S. audit reporting is that the reports provide little infor- mation as to major risks or issues related to the company and its financial statements. In 2013, the United Kingdom’s Financial Reporting Council (FRC) expanded existing reporting requirements (which were similar to those of the PCAOB) for certain entities to include the following elements:1

∙ A description of the risks of material misstatement that had the greatest impact on overall audit strategy, the allocation of resources in the audit, and the efforts of the engagement team.

∙ An explanation of how the auditor applied the concept of materiality in planning and performing the audit.

∙ An overview of the scope of the audit, including an explanation of how the scope was affected by the risks of material misstatement.

KPMG’s audit report on Rolls-Royce’s 2013 financial statements created quite a stir in audit reporting circles. This report addressed the expanded requirements of the FRC but went a step further by including KPMG’s audit response and findings related to the following risks:

∙ Basis of accounting for revenue and profit in Rolls-Royce’s civil aerospace business. ∙ Measurement of revenue and profit in Rolls-Royce’s civil aerospace business. ∙ Recoverability of intangible assets and amounts recoverable on contracts in Rolls-

Royce’s civil aerospace business. ∙ Accounting for the consolidation of Rolls-Royce Power Systems and valuation of

Daimler AG’s put option to purchase an interest in Rolls-Royce Power Systems. ∙ Revenue recognition related to nonrefundable cash payments under risk and revenue

sharing arrangements. ∙ Ongoing investigations of bribery and corruption related to contracting arrangements. ∙ The presentation of “underlying” profit (presented as a complement to IFRS financial

statements).2

In addition to information about the risks of material misstatement, the Rolls Royce report provided the following materiality- and scope-level disclosures:

∙ Overall materiality level of £86 million ($52.3 million based on exchange rates on December 31, 2013), representing 4.9 percent of income before taxes.

∙ Materiality levels for reporting components ranging from £0.5 million to £50 million.

LO 12-2 Identify situations in which language in the standard (unmodified) report is modified and the type of opinion issued in those situations.

LO 12-3 Identify situations in which auditors add explanatory language to an unmodified opinion.

LO 12-4 Identify other circumstances affecting auditors’ reporting responsibilities and

explain how they affect auditors’ reports on an entity’s financial statements.

LO 12-5 Understand auditors’ reporting responsibil- ity for the financial statements and internal control over financial reporting for issuers (Appendix 12A)

1 Financial Reporting Council, Internal Standard on Auditing (UK and Ireland) 700, “The Independent Auditor’s Report on Financial Statements,” June 2013; this pronouncement was supplemented by International Standard on Auditing 701, “Communicating Key Audit Matters in the Independent Auditor’s Report,” January 2015. 2http://ar.rolls-royce.com/2013/. KPMG’ s reports on Rolls-Royce’s 2014 and 2015 financial statements contained a similar level of detail and disclosures.

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∙ Any uncorrected misstatements in excess of £4 million (income statement) and £8 mil- lion (balance sheet) would be communicated to the audit committee.

∙ Audit procedures covered 98 percent of revenue, 99 percent of income before taxes, and 94 percent of total assets.

While the impact of the FRC’s expanded reporting requirements cannot yet be deter- mined, it is clear from KPMG’s audit report that expanded reporting requirements have the potential to significantly impact information provided by auditors in their reports.3 In response, the AICPA has recently revised its auditors’ report to include disclosure of key audit matters when the auditor is engaged to do so (the PCAOB made a similar modi- fication in 2017 to identify critical audit matters). Clearly, audit reporting will continue to evolve to provide important information to investors, lenders, and others who rely on audited financial statements in making economic decisions.

OVERVIEW OF AUDITORS’ REPORTS Because the entity’s management is responsible for preparing its financial statements, the auditors’ examination (and report on that examination) plays an important role in users’ ability to rely on the financial statements when making economic decisions. Issuers, or public entities (those entities that offer registered securities for sale to the general pub- lic) are required to file certain financial information with the Securities and Exchange Commission (SEC) within 60 to 90 days (depending upon their size) of their fiscal year- end. This information, which includes audited financial statements, footnotes, and other required disclosures related to the financial statements, is filed using Form 10-K.

In contrast, non-issuers (or nonpublic entities) are not subject to these filing or audit requirements. However, third-party users may demand audited financial statements as a condition for certain lending or investing activities or for use in monitoring the entity’s activities. In addition, regulatory bodies other than the SEC may require audits for gov- ernmental and other types of non-issuers.

For both issuers and non-issuers, the auditors’ report on financial statements and related disclosures provides (or disclaims) an opinion on whether the entity’s financial statements and related disclosures are presented in accordance with GAAP. This opinion is based on the tests of controls and substantive procedures that have been performed dur- ing the audit engagement and discussed throughout this text.

In addition to the auditors’ report on financial statements and related disclosures, issu- ers are subject to additional reporting requirements. The Sarbanes–Oxley Act of 2002 and Auditing Standard 2201 (AS 2201) have mandated two additional types of reports:4

1. A report, prepared by the entity’s management, on the effectiveness of the entity’s internal control over financial reporting.

2. A report, prepared by the auditors, on the effectiveness of the entity’s internal control over financial reporting.

The following is a summary of the reports that accompany an entity’s financial state- ments. The focus of this chapter is on the auditors’ report on financial statements and related disclosures for non-issuers; auditors’ reports on the financial statements and on the effectiveness of the entity’s internal control over financial reporting for issuers are discussed in Appendix A.

LO 12-1 Understand the types of reports that accompany an entity’s financial statements and the content of the auditors’ standard (unmodified) report.

3A recent study concluded that the FRC’s expanded reporting requirements did not affect audit quality (as measured by discre- tionary accruals) or investor reaction to the release of the auditors’ report in the first two years after adoption. In addition, this same study found that total audit fees were influenced by the length of the report, the length of discussion of significant risks of material misstatement, and the number of identified risks. See E. Gutierrez, M. Minutti-Meza, K. W. Minutti-Meza, K. W. Tatum, and M. Vulcheva, “Consequences of Changing the Auditor’s Report: Evidence from the U.K.,” Unpublished working paper. 4Issuers with an aggregate market value of voting and non-voting common equity of less than $75 million (known as non-accel - erated filers) are required to have management reports on internal control over financial reporting but not auditor engagements or reports on internal control over financial reporting.

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The Standard Report for Non-Issuers The auditors’ report on the financial statements expresses an opinion on whether the financial statements present the entity’s financial position, results of operations, and cash flows in accordance with GAAP (or other applicable financial reporting framework). The report should be titled independent auditor’s report (or other suitable title stressing the independence of the auditors). The report is typically addressed to the board of directors and shareholders but may also be addressed to an individual lender, creditor, or investor who requested the audit.

Because the Auditing Standards Board (ASB) prescribes the format and contents of the report for non-issuers, these reports are sometimes referred to as the Auditing Stan- dards Board ( or ASB) report. See Exhibit 12.1 for an example of a standard (unmodified) report issued for a non-issuer (the ASB report was substantially revised in 2019). The report in Exhibit 12.1 is appropriate when no material issues are encountered during the audit and the financial statements are prepared in accordance with GAAP.5

All standard (unmodified) reports contain the following major sections:

1. Opinion. This section identifies the financial statements and years examined by the audit team and the opinion on the financial statements. The report in Exhibit 12.1 identifies the balance sheet, income statement, statement of changes in shareholders’ equity, and statement of cash flows for the year ended December 31, 2020, as the financial statements and years examined. The auditors’ opinion is that these financial statements are prepared in accordance with accounting principles generally accepted in the United States of America (GAAP).

2. Basis for Opinion. This section indicates that the audit was conducted according to generally accepted auditing standards (GAAS), the auditors were independent and met other ethical responsibilities, and that the audit evidence provides a basis for the opinion.

3. Responsibilities of Management for the Financial Statements. This section identi- fies the management’s responsibility for both the fairness of the financial statements and the design, implementation, and maintenance of internal control. In addition, this section discloses management’s responsibility to evaluate whether substantial doubt about continued existence of the entity exists.

4. Auditor’s Responsibilities for the Audit of the Financial Statements. This section dis- cusses the audit team’s responsibility to obtain reasonable assurance regarding the

Type of Entity Report(s)

Issuer Mandatory reports on • Effectiveness of internal control over financial reporting (prepared by

management) • Effectiveness of internal control over financial reporting (prepared by auditors) • Fairness of financial statements and related disclosures (prepared by auditors)

Non-issuer Fairness of financial statements and related disclosures based on user demand (prepared by auditors)

REVIEW CHECKPOINTS 12.1 Identify the reports that accompany the financial statements of issuers and non-issuers. 12.2 What are the audit requirements for issuers and non-issuers?

5The report shown in Exhibit 12.1 does not include the potential impact of Statements on Auditing Standards No. 137 (“The Audi- tor’s Responsibilities Relating to Other Information Included in Annual Reports,” AICPA, July 2019) on the auditors ’ report on the financial statements.

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Independent Auditor’s Report To the Board of Directors and Shareholders of Dunder-Mifflin, Inc.

Report on the Audit of the Financial Statements Opinion We have audited the financial statements of Dunder-Mifflin, Inc., which comprise the balance sheet as of December 31, 2020, and the related statements of income, changes in stockholders’ equity, and cash flows for the year then ended, and the related notes to the financial statements. In our opinion, the accompanying financial statements present fairly, in all material respects, the financial position of Dunder-Mifflin, Inc. as of December 31, 2020, and the results of its operations and its cash flows for the year then ended in accordance with accounting principles generally accepted in the United States of America.

Basis for Opinion We conducted our audit in accordance with auditing standards generally accepted in the United States of America (GAAS). Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the Audit of the Financial Statements section of our report. We are required to be independent of Dunder-Mifflin, Inc. and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements relating to our audit. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion.

Responsibilities of Management for the Financial Statements Management is responsible for the preparation and fair presentation of the financial statements in accordance with accounting principles generally accepted in the United States of America, and for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. In preparing the financial statements, management is required to evaluate whether there are conditions or events, considered in the aggregate, that raise substantial doubt about Dunder-Mifflin, Inc.’s ability to continue as a going concern for one year following the issuance of the financial statements.

Auditor’s Responsibilities for the Audit of the Financial Statements Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with GAAS will always detect a material misstatement when it exists. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Misstatements are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users made on the basis of these financial statements. In performing an audit in accordance with GAAS, we

• Exercise professional judgment and maintain professional skepticism throughout the audit. • Identify and assess the risks of material misstatement of the financial statements, whether due to fraud or error, and design and

perform audit procedures responsive to those risks. Such procedures include examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements.

• Obtain an understanding of internal control relevant to the audit in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of Dunder-Mifflin, Inc.’s internal control. Accordingly, no such opinion is expressed.

• Evaluate the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluate the overall presentation of the financial statements.

• Conclude whether, in our judgment, there are conditions or events, considered in the aggregate, that raise substantial doubt about Dunder-Mifflin, Inc.’s ability to continue as a going concern for a reasonable period of time.

We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control–related matters that we identified during the audit.

Scranton, PA January 29, 2021

EXHIBIT 12.1  Standard (Unmodified) Report for Non-issuer

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fairness of the financial statements, identifies several important components of a GAAS audit, and discusses the audit team’s responsibility to communicate matters to those charged with governance.

Following the Auditor’s Responsibilities for the Audit of the Financial Statements sec- tion, the auditors’ report should

∙ Be signed using the firm’s name. ∙ Identify the city and state of the firm’s office. ∙ Be dated using the date when the audit team has obtained sufficient appropriate evi-

dence to support the opinion (the date of the auditors’ report).

In addition to the above, the audit team may be requested by management to communi- cate key audit matters in the report. Key audit matters are those matters communicated to those charged with governance (such as the audit committee) that are the most significant in the audit and may include areas of higher risk, areas requiring significant audit team and management judgment, or significant transactions or events. If the audit team has been engaged to communicate key audit matters, they would do so in an additional Key Audit Matters section following the Basis for Opinion section that would indicate

∙ Why the matter was considered to be a key audit matter. ∙ How the matter was addressed during the audit.

The report shown in Exhibit 12.1 assumes that the financial statements are not pre- sented along with other information (such as financial summaries, financial ratios, or management commentary on the financial statements). If other information is presented along with the financial statements, the auditors’ report would include a section address- ing the consistency of this information with the financial statements. This matter is dis- cussed later in this chapter.

Types of Opinions Users of audited financial statements are generally most interested in the Opinion sec- tion, which contains the conclusions about the financial statements. This conclusion is in the form of an opinion on whether the entity’s financial statements present its financial condition, the results of operations, and cash flows in accordance with GAAP.

Auditors may issue four types of opinions:

1. An unmodified opinion in which the conclusion is that the financial statements pres- ent the financial condition, results of operations, and cash flows in accordance with GAAP. (Until recently, this type of opinion was referred to as an unqualified opin- ion). The auditors’ standard (unmodified) report in Exhibit 12.1 is an example of an unmodified opinion; however, unmodified opinions can be issued in forms other than the standard (unmodified) report.

2. A qualified opinion in which the conclusion is that, with the exception of one or more non-pervasive issues, the financial statements present the financial condition, results of operations, and cash flows in accordance with GAAP. Qualified opinions use the phrase except for in describing the issues that give rise to the qualification. Interest- ingly, although the term “qualified” normally has a positive connotation, qualified opinions are issued when one or more issues are encountered during the audit.

3. An adverse opinion , in which the conclusion is that the financial statements do not present the financial condition, results of operations, and cash flows in accordance with GAAP.

4. A disclaimer of opinion, in which the auditors do not express an opinion on the fairness of the entity’s financial statements.

AU-C 705 refers to qualified opinions, adverse opinions, and disclaimers of opinion as modified opinions.

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CONDITIONS THAT REQUIRE MODIFICATIONS TO THE AUDITORS’ STANDARD (UNMODIFIED) REPORT

In some cases, audit teams encounter situations that require them to modify the language in the standard (unmodified) report shown in Exhibit 12.1 as well as the conclusion with respect to the entity’s financial statements. These situations include departures from GAAP and scope limitations and are discussed as follows.

Departures from GAAP6

Audit examinations may identify transactions that have not been recorded according to GAAP. In most of these situations and assuming that the results are material to the finan- cial statements, entities adjust their financial statements to reflect the proper accounting treatment for the transactions. The process through which audit teams propose adjust- ments to financial statements for misstatements identified during the audit was discussed in Chapter 11.

An entity’s management may decide to present financial statements containing an accounting treatment or disclosure that is not in accordance with GAAP. Situations in which an entity does not follow GAAP in preparing its financial statements are referred to as departures from GAAP . Exhibit 12.2 summarizes auditors’ reporting options when departures from GAAP are noted.

As with any issue, a departure from GAAP may not be material to the entity’s finan- cial statements. Recall the wording of the opinion in the auditors’ standard (unmodified) report: “In our opinion, the financial statements referred to above present fairly, in all material respects. . .” [emphasis added]. As a result, if a departure from GAAP is imma- terial, the audit team would treat the departure as if it did not exist. In this case, they can express an unmodified opinion and issue the standard (unmodified) report.

If the departure is sufficiently material to affect users’ decisions that are based on the financial statements but the departure can be compartmentalized, the auditors must qualify the opinion. By “compartmentalized,” we mean that the departure can be isolated to a particular account group (e.g., accounts receivable not valued at net realizable value) or transactions (e.g., failure to capitalize leases) without affecting other accounts to a material extent. In other words, this departure would not be considered pervasive. This qualification identifies a particular departure but indicates that the financial statements are otherwise in accordance with GAAP. The nature of the GAAP departure must be explained in the Basis for Qualified Opinion section, as shown in Exhibit 12.3.7

LO 12-2 Identify situations in which language in the standard (unmodified) report is modified and the type of opinion issued in those situations.

REVIEW CHECKPOINTS 12.3 To whom is the auditors’ report for a non-issuer addressed? 12.4 Identify the four major sections of the auditors’ standard (unmodified) report for a non-issuer and

the major contents of each section. 12.5 What are key audit matters? If the audit team is engaged to communicate key audit matters, what

type of communication is provided in their report on the financial statements? 12.6 What are the types of opinions and the conclusion of each type of opinion?

6The discussion in this section does not refer to situations in which departures from GAAP are undertaken to prevent the finan- cial statements from being misleading. In such cases, auditors should modify the standard (unmodified) report to describe the departure, its impact, and the reasons why compliance with GAAP would result in misleading financial statements. These cases (referred to as Rule 203 reports) are extremely rare and no guidance is provided in the clarified standards for appropriate report wording. 7For easier reference, all revisions to the auditors’ standard (unmodified) report in Exhibit 12.1 are shown in color and italicized in reports presented throughout this chapter.

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On the other hand, if the GAAP departure is pervasive, affecting numerous accounts and financial statement relationships, or is material to the point that the financial statements as a whole are misleading, the auditors must issue an adverse opinion. As noted earlier, in an adverse opinion, auditors conclude that the financial statements do not present fairly the financial position, results of operations, and cash flows in accordance with GAAP. As with the qualified opinion, all substantive reasons must be disclosed in the report.

EXHIBIT 12.2 GAAP Departures

No

Is the Departure Pervasive?

Adverse Opinion

No

Yes

Yes

Qualifie Opinion

Is the Departure Material?

Standard Report (Unmodifie

Opinion)

Independent Auditor’s Report To the Board of Directors and Shareholders of Dunder-Mifflin, Inc. Report on the Audit of the Financial Statements Qualified Opinion No revisions to first paragraph In our opinion, except for the effects of the matter described in the Basis for Qualified Opinion section of our report, the accompanying financial statements present fairly, in all material respects, the financial position of Dunder-Mifflin, Inc. as of December 31, 2020, and the results of its operations and its cash flows for the year then ended in accordance with accounting principles generally accepted in the United States of America. Basis for Qualified Opinion As discussed in Note 16, an additional provision in the amount of $30,000,000 for possible uncollectible receivables at December 31, 2019, was charged to operations during the year ended December 31, 2020, which, in our opinion, should have been reflected in the financial statements for 2019. Had this provision been properly recorded in the 2019 financial statements, Dunder-Mifflin, Inc. would have reported net earnings of $700,000 for the year ended December 31, 2020, rather than the net loss of $29,300,000 as reflected in the statements of income, changes in shareholders’ equity, and cash flows for that period. We conducted our audit in accordance with auditing standards . . . We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our qualified audit opinion. Responsibilities of Management for the Financial Statements No revisions to section Auditor’s Responsibilities for the Audit of the Financial Statements No revisions to section

Scranton, PA January 29, 2021

EXHIBIT 12.3 Departure from GAAP Report (Qualified Opinion)

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The example in Exhibit 12.4 assumes that the same departure in GAAP that served as the focus of the qualified opinion in Exhibit 12.3 reached a level of materiality and perva- siveness to warrant an adverse opinion.

The following summarizes modifications to the auditors’ standard (unmodified) report for departures from GAAP (assuming such departures are material). Referring to Exhib- its 12.3 and 12.4, notice that both the Opinion and Basis for Opinion sections include either “Qualified” or “Adverse” to emphasize the type of modified opinion issued.

Independent Auditor’s Report To the Board of Directors and Shareholders of Dunder-Mifflin, Inc. Report on the Audit of the Financial Statements Adverse Opinion No revisions to first paragraph In our opinion, because of the significance of the matter discussed in the Basis for Adverse Opinion section of our report, the accompanying financial statements do not present fairly [omit phrase “in all material respects”] the financial position of Dunder-Mifflin, Inc. as of December 31, 2020, and the results of its operations and its cash flows for the year then ended in accordance with accounting principles generally accepted in the United States of America. Basis for Adverse Opinion As discussed in Note 16, an additional provision in the amount of $30,000,00 0 for possible uncollectible receivables at December 31, 2019, was charged to operations during the year end ed December 31, 2020, which, in our opinion, should have been reflected in the financial statements for 2019. Had this provision been properly recorded in the 2019 financial statements, Dunder-M ifflin, Inc. would have reported net earnings of $700,000 for the year ended December 31, 2020, ra ther than the net loss of $29,300,000 as reflected in the statements of income, changes in shareholders’ equity, and cash flows for that period. We conducted our audit in accordance with auditing standards. . . We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our adverse audit opinion. Responsibilities of Management for the Financial Statements No revisions to section Auditor’s Responsibilities for the Audit of the Financial Statements No revisions to section

Scranton, PA January 29, 2021

EXHIBIT 12.4 Departure from GAAP Report (Adverse Opinion)

Section Qualified Opinion Adverse Opinion Opinion  Title of section is Qualified Opinion

Modify second paragraph to note “except for” a specific departure, financial statements are presented according to GAAP 

Title of section is Adverse Opinion Modify second paragraph to note that financial statements are not presented according to GAAP

Omit phrase “in all material respects” from second paragraph Basis for Opinion  Title of section is Basis for Qualified Opinion

Identify departure from GAAP Modify phrase “basis for our audit opinion” in last sentence to “basis for our qualified audit opinion”

Title of section is Basis for Adverse Opinion Identify departure from GAAP Modify phrase “basis for our audit opinion” in last sentence to “basis for our adverse audit opinion” 

Responsibilities of Management for the Financial Statements

No modification No modification

Auditor’s Responsibilities for the Audit of the Financial Statements

No modification No modification

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The reports for non-issuers shown in Exhibits 12.3 and 12.4 reflect the appropriate wording if departures from GAAP necessitate the issuance of qualified and adverse opin- ions. While reports for issuers are not the focus of this chapter, under the provisions of Regulation S-X, issuers are not permitted to file financial statements with the SEC if these statements would be false or misleading. As a result, if a material departure from GAAP is noted during an audit examination of an issuer, the auditors’ report must be modified to identify that departure as noted in the preceding subsections. However, the entity’s financial statements and accompanying auditors’ report would be classified as a “deficient” filing by the SEC and would not satisfy its reporting requirements.

REVIEW CHECKPOINTS 12.7 Explain the effect of pervasiveness on the auditors’ report when the entity uses an accounting

method that departs from GAAP. 12.8 What are the major differences in wording for qualified opinions and adverse opinions issued as a

result of departures from GAAP? 12.9 How is the auditors’ standard (unmodified) report modified for qualified or adverse opinions

issued as a result of departures from GAAP?

Scope Limitations A GAAS audit presumes that audit team is able to gather sufficient appropriate evidence on which to base their opinion. Two situations may create scope limitations when audit teams are unable to obtain sufficient appropriate evidence. The two arise from (1) man- agement’s deliberate refusal to provide the audit team access to evidence or to otherwise limit the audit team’s application of auditing procedures (known as a client-imposed scope limitation) and (2) circumstances beyond the audit team’s and client’s control such as the late appointment of the audit team that leads to their inability to perform certain auditing procedures (known as a circumstance-imposed scope limitation ). The auditors’ reporting options depend on the nature and materiality of the scope limitation (see Exhibit 12.5).

Exhibit 12.5 notes the following:

∙ If the scope limitation is not material or the audit team can perform alternative pro- cedures, the standard (unmodified) report can be issued. This report does not need to reference the inability to perform certain procedures or the alternative procedures performed.

∙ If the scope limitation is material and alternative procedures cannot be performed, auditors issue either a qualified opinion or disclaimer of opinion, depending upon the materiality and pervasiveness of the scope limitation.

Refer to Exhibits 12.6 and 12.7 for examples of reports when scope limitations are encountered. The failure to take physical counts of inventory could have been based on a request from the client’s management (client imposed), or it could have resulted from other circumstances such as the entity not anticipating the need for an audit and appoint- ing the audit team after the latest year-end (circumstance imposed).

In Exhibit 12.6, the opinion is qualified. In this case, the lack of evidence is consid- ered material but not pervasive to the financial statements. (This would be appropriate if Dunder-Mifflin’s inventory and cost of goods sold were not considered highly material to the financial statements). Note that the qualification is based on the inability to determine whether inventory is fairly stated due to possible effects of the scope limitation, and not the inability to perform the procedure per se. not the inability to perform the procedure per se. The report “compartmentalizes” the scope limitation to inventories.

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Alternative Procedures Available?

Is the Scope Limitation Material?

No

Is the Scope Limitation Pervasive?

Disclaimer of Opinion

No

Yes

No

Yes

Yes

Qualifie Opinion

Standard Report (Unmodifie

Opinion)

Standard Report (Unmodifie

Opinion)

EXHIBIT 12.5 Scope Limitations

Independent Auditor’s Report To the Board of Directors and Shareholders of Dunder-Mifflin, Inc. Report on Audit of the Financial Statements Qualified Opinion No revisions to first paragraph In our opinion, except for the possible effects of the matter discussed in the Basis for Qualified Opinion section of our report, the accompanying financial statements present fairly, in all material respects, the financial position of Dunder-Mifflin, Inc. as of December 31, 2020, and the results of its operations and its cash flows for the year then ended in accordance with accounting principles generally accepted in the United States of America. Basis for Qualified Opinion Dunder-Mifflin, Inc. did not make a count of its physical inventory in 2020, stated in the accompanying financial statements at $10,000,000 at December 31, 2020, and we were una ble to observe the physical quantities on hand. Dunder-Mifflin, Inc.’s records do not permit the application of other auditing procedures to the audit of inventories. Consequently, we were unable to determine whether any adjustments to these amounts were necessary. We conducted our audit in accordance with auditing standards. . . We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our qualified audit opinion. Responsibilities of Management for the Financial Statements No revisions to section Auditor’s Responsibilities for the Audit of the Financial Statements No revisions to section

Scranton, PA January 29, 2021

EXHIBIT 12.6 Scope Limitation Report (Qualified Opinion)

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In Exhibit 12.7, the situation has a more significant impact on the auditors’ opinion; that is, the scope limitation is pervasive. The audit team believes that the inventories are too material to even be able to express an opinion on the financial statements. The report then must express a disclaimer of opinion. Notice that the Opinion section indicates “[w]e were engaged to audit  .  .  .” instead of “[w]e have audited.  .  .  .” Also notice that the Auditor’s Responsibilities for the Audit of the Financial Statements section has been modified to indicate that the audit team was not able to obtain sufficient appropriate evi- dence and refers to the Basis for Disclaimer of Opinion section.

One additional consideration in evaluating reporting options when scope limitations exist is the nature of the limitation. Audit teams should carefully consider the implica- tions of a client-imposed scope limitation because such restrictions on the audit may cast doubt on management’s integrity. (Why would management restrict the audit team’s engagement?) Because of these implications, auditors normally disclaim an opinion or even withdraw from the engagement in these situations. Any client-imposed scope limita- tion should be communicated to those charged with the entity’s governance.

Independent Auditor’s Report To the Board of Directors and Shareholders of Dunder-Mifflin, Inc. Report on the Audit of the Financial Statements Disclaimer of Opinion We were engaged to audit the financial statements of Dunder-Mifflin, Inc., which comprise the balance sheet as of December 31, 2020, and the related statements of income, changes in stockholders’ equity, and cash flows for the year then ended, and the related notes to the financial statements. We do not express an opinion on the accompanying financial statements of Dunder-Mifflin, Inc. Because of the significance of the matter described in the Basis for Disclaimer of Opinion section of our report, we have not been able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on the financial statements. Basis for Disclaimer of Opinion Dunder-Mifflin Inc. did not make a count of its physical inventory in 2020, stated in the accompanying financial statements at $10,000,000 at December 31, 2020, and we were unable to observe the physical quantities on hand. Dunder-Mifflin, Inc.’s records do not permit the application of other auditing procedures to the audit of inventories. As a result, we were unable to determine whether any adjustments were necessary relating to Dunder-Mifflin, Inc.’s inventories and the effects on their balance sheet and the related statements of income, changes in stockholders’ equity, and cash flows. Standard paragraph deleted Responsibilities of Management for the Financial Statements No revisions to this section Auditor’s Responsibilities for the Audit of the Financial Statements Our responsibility is to conduct an audit of Dunder-Mifflin, Inc.’s financial statements in accordance with auditing standards generally accepted in the United States of America and to issue an auditor’s report. However, because of the matter described in the Basis for Disclaimer of Opinion section of our report, we were not able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on these financial statements. We are required to be independent of Dunder-Mifflin, Inc. and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements relating to our audit.

Scranton, PA January 29, 2021

EXHIBIT 12.7 Scope Limitation Report (Disclaimer of Opinion)

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The following summarizes modifications to the auditors’ standard (unmodified) report for scope limitations (assuming that such limitations are material and alternative auditing procedures are not available). In addition, similar to departures from GAAP, the Opinion and Basis for Opinion sections are labeled to indicate the type of opinion expressed by the auditors (either qualified or a disclaimer of opinion).

Section Qualified Opinion Disclaimer of Opinion Opinion Title of section is Qualified Opinion

Modify second paragraph to note “except for” the effects of adjustments that might have been identified, financial statements are presented according to GAAP 

Title of section is Disclaimer of Opinion Modify first paragraph to note audit team was “engaged” to audit the financial statements Modify second paragraph to disclaim an opinion and indicate the audit team was not able to obtain sufficient appropriate evidence

Basis for Opinion Title of section is Basis for Qualified Opinion Identify scope limitation Modify phrase “basis for our audit opinion” in last sentence to “basis for our qualified audit opinion”

Title of section is Basis for Disclaimer of Opinion Identify scope limitation Delete paragraph indicating that a GAAS audit was conducted

Responsibilities of Management for the Financial Statements

No modification No modification

Auditor’s Responsibilities for the Audit of the Financial Statements

No modification Modify first paragraph to note audit team was not able to obtain sufficient appropriate evidence Delete paragraphs describing an audit and required communication with those charged with governance Include sentence on requirements for independence and ethical responsibilities

• EY recently resigned as auditor of Bank of Jinzhou Co . (a Chi- nese commercial bank) only one year after being engaged. EY had requested information about loans made by the bank but were unable to get sufficient information to resolve their questions and complete the audit.

• Bharat P arikh & Associates, Chartered A ccountants’ (BPA’s) audit of an unnamed Nevada corporation was conducted entirely off-site. This decision was based on the email solicitation by the corporation that requested respondents to consider whether the

audit could be conducted “. . .over email only (no visit required).” In a disciplinary order, the PCAOB concluded that BPA failed to con- sider whether the restriction in visiting the client’s offices should have necessitated a scope limitation and a qualified opinion.   

Sources: “Ernst & Young Quits Role at China Bank.” The Wall Street Journal, June 4, 2019, p. B10; In the Matter of Bharat Parikh & Associates Chartered Accountants, Bharatkumar Balmukund Parikh, FCA, and Anuj Bharatkumar Parikh, PCAOB Release No. 105-2019-003, March 19, 2019.

Scope LimitationsAUDITING INSIGHT

REVIEW CHECKPOINTS 12.10 Distinguish between client-imposed scope limitations and circumstance-imposed scope limita-

tions. Which of these scope limitations is generally of more concern to audit teams? 12.11 If a scope limitation exists but audit teams are able to perform alternative procedures, how is the

standard (unmodified) report modified to reflect the scope limitation? 12.12 If a scope limitation exists and audit teams cannot perform alternative procedures, what are the

reporting options? 12.13 When a scope limitation exists, how would the standard (unmodified) report be modified to

express (a) a qualified opinion and (b) a disclaimer of opinion?

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AUDITS OF GROUP FINANCIAL STATEMENTS Many large entities prepare consolidated financial statements that include more than one component (division, subsidiary, or other segment); these financial statements are referred to as group financial statements. In some cases, principal auditors (known as the group engagement team or group auditors) perform the audit of a material portion of the consolidated entity’s assets, liabilities, revenues, and expenses, and other independent auditors (known as component auditors) may be engaged to audit divisions, subsidiaries, or components that are included in the group financial statements.8

Situations such as this may occur if clients have significant remote subsidiaries or if clients have an investment in another entity that is accounted for using the equity method. Because the group engagement partner’s signature appears in the report on the financial statements of a consolidated or parent entity, the group auditors must make decisions regarding the use of the work and reports of the component auditor(s).

The group auditors must first obtain information about the independence and profes- sional reputation of the component auditors. If the group auditors are satisfied with these qualities, they must next communicate with the component auditors and decide whether to refer to their work in the group auditors’ report. As shown in Exhibit 12.8, the group auditors may decide to make no reference and issue the standard (unmodified) report. In this case, the group auditors assume full responsibility for the component auditors’ work.

On the other hand, the group auditors may decide to refer to the work and reports of the component auditors; this is referred to as a division of responsibility. Such a reference is not in itself a scope limitation and the report should not be considered to be inferior to a standard (unmodified) report that does not contain such a reference. The explanation should disclose the extent of the component auditors’ work by indicating the percent or amount of assets, revenues, and expenses related to their work.

Yes

Obtain Permission and Present

Component Auditors’ Report

Standard Report (Unmodifie

Opinion)

Group Auditors Modify Report to Indicate Division

of Responsibility (Unmodified Opinion

Yes

No

No

Do Group Auditors Take Responsibility for Work of Component

Auditors?

Do Group Auditors Refer to Component Auditors by Name?

EXHIBIT 12.8 Reporting Options for Audits of Group Financial Statements

8The PCAOB recently issued a proposal that amends existing guidelines related to the supervision, planning, documentation, and engagement quality review by group auditors (referred to by the PCAOB as “lead auditors”) of the work of component auditors (referred to as “other auditors”). See Proposed Amendments Relating to the Supervision of Audits Involving Other Auditors and Proposed Auditing Standard—Dividing Responsibility for the Audit with Another Accounting Firm, PCAOB Release No. 2016-002, April 12, 2016.

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When the group auditors refer to the component auditors’ work, the component audi- tors are ordinarily not identified by name. In fact, the component auditors may be named in the group auditors’ report only by express permission and with publication of their report along with the group auditors’ report. Refer to Exhibit 12.8 for a summary of the options available to group auditors for reporting when component auditors are involved in the audit of group financial statements.9

Exhibit 12.9 is an example of a group auditors’ report that has been modified to express an unmodified opinion on financial statements and referencing the work of component auditors. Note in this report that the group auditors do not identify the “other auditors” by name.

In its 2019 auditors’ report on DowDuPont, Inc., Deloitte disclosed that other audi- tors (PwC, whose report was presented along with Deloitte’s report) audited E.I. du Pont de Nemours, a wholly owned subsidiary of DowDupont. E.I. du Pont’s assets and rev- enues were 54% and 30% of the consolidated totals, respectively.

Beginning in 2017, accounting firms are required to file a disclosure (Form AP) with the PCAOB that discloses the involvement of other firms in audit engagements of issuers. Using the PCAOB’s audit report database, 10 after excluding audits of investment compa- nies and employee benefit plans, U.S. Big Four firms filed over 6,600 Form AP disclo- sures regarding participants in audit engagements for the years 2016–2018. Of these, a

9Improving the Transparency of Audits: Rules to Require Disclosure of Certain Audit Participants on a New PCAOB Form and Related Amendments to Auditing Standards, PCAOB Release No. 2015-008, December 15, 2015, requires group auditors to dis - close specific information regarding any component auditors whose work constituted at least five percent of the total audit hours using a document known as Form AP.

Independent Auditor’s Report To the Board of Directors and Shareholders of Dunder-Mifflin, Inc. Report on the Audit of the Financial Statements Opinion We have audited the financial statements of Dunder-Mifflin, Inc., which comprise the balance sheet as of December 31, 2020, and the related statements of income, changes in stockholders’ equity, and cash flows for the year then ended, and the related notes to the financial statements. In our opinion, based on our audit and the report of the other auditors, the accompanying financial statements present fairly, in all material respects, the financial position of Dunder-Mifflin, Inc. as of December 31, 2020, and the results of its operations and its cash flows for the year then ended in accordance with accounting principles generally accepted in the United States of America. We did not audit the financial statements of B Company, a wholly-owned subsidiary, which statements reflect total assets constituting 20 percent of total assets at December 31, 2020, and total revenues constituting 18 percent of total revenues for the year then ended. Those statements were audited by other auditors whose report has been furnished to us, and our opinion, insofar as it relates to the amounts included for B Company, is based solely on the report of the other auditors. Basis for Opinion No revisions to section Responsibilities of Management for the Financial Statements No revisions to section Auditor’s Responsibilities for the Audit of the Financial Statements No revisions to section

Scranton, PA January 29, 2021

EXHIBIT 12.9 Report on Audit of Group Financial Statements

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total of 1,581 (24%) indicated that other firms participated in the audit (primarily affiliate offices of these firms, with an average of 3.5 participants per audit). In addition, a total of 22 reports divided responsibility with another Big Four firm (primarily for the audits of subsidiaries or equity/partnership investments in another entity held by the group audi- tor’s client). The Auditing Insight “Component Auditors” illustrates some of the issues that may be encountered with the use of component auditors in practice.

10 https://pcaobus.org/Pages/AuditorSearch.aspx 11 C.C. Dee, A. Lulseged, and T. Zhang, “Who Did the Audit? Audit Quality and Disclosures of Other Audit Participants in PCAOB Filings,” The Accounting Review, September 2015, pp . 1939–1967.

• Concerns over audits conducted by Big Four firms in the U.K. have led to investors questioning the quality of audits in which U.K. affiliates participate in the audit of U.S. corporations. For example, KPMG’s U.K. affiliate provided 10%–20% of the services of the audit of Citigroup, EY’s U.K. affiliate provided 5%–10% of the ser- vices in the audit of Amazon, and Deloitte’s U.K. affiliate provided 20%–30% of the services in the audit of BlackRock.

• Foreign affiliates of KPMG ($241,305), Deloitte Touche Tohmatsu ($99,057), and BDO ($50,000) were fined by the SEC for using Zimbabwe affiliate firms that were not registered with the PCAOB in the audit of an unidentified South African company.

• Five component auditors participated in Deloitte’s 2017 audit of Monsanto (two foreign affiliates in Brazil and Argentina, one nonaffiliate firm in Mexico, and two unnamed firms providing less than 5% of total audit hours). Based on the disclosed ranges, these component auditors accounted for between 20% and 45% of total audit hours.

Sources: “Investors Worry About U.K. Auditors’ Contributions to U.S. Audits,” The Wall Street Journal Online, December 9, 2018; “South African Audit Case Settled with SEC,” The Wall Street Journal, March 14, 2018, p. B13; PCAOB Form AP database, https://pcaobus.org/ form-ap-filings/13445/13445.

Component AuditorsAUDITING INSIGHT

REVIEW CHECKPOINTS 12.14 Define group auditors and component auditors. What issues are introduced when component

auditors examine a division, subsidiary, or segment of group financial statements? 12.15 What options are available to group auditors when component auditors are involved in the

examination of group financial statements? 12.16 Is the reference in the auditors’ report to work performed by component auditors a scope limita-

tion? Explain.

Shown below is a summary of reporting options for the three situations described in this section (departures from GAAP, scope limitations, and audits of group financial statements). Notice that unmodified opinions are issued for matters that are not material, qualified opinions for matters that are material but less pervasive, and adverse opinions and disclaimers of opinions for matters that are material and more pervasive. An aca- demic study found that the initial disclosure of the use of component auditors resulted in negative market reaction, but this negative reaction was not observed in following audits.11

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AUDITORS’ REPORTS REFERENCING OTHER MATTERS ENCOUNTERED DURING THE AUDIT

The preceding section illustrated reporting options for situations in which the language in the auditors’ standard (unmodified) report was modified; in many cases, these situa- tions required an opinion other than an unmodified opinion (qualified opinion, adverse opinion, or disclaimer of opinion) to be issued. In other cases, situations encountered during the audit involve adding a paragraph to the standard (unmodified) report shown in Exhibit 12.1 to describe the matter. These paragraphs are labeled as follows:

∙ Paragraphs that provide information fundamental to users’ understanding of the enti- ty’s financial statements are known as emphasis-of-matter paragraphs.

∙ Paragraphs that provide information relating to users’ understanding of the audit, audit team’s responsibility, or auditors’ report are known as other-matter paragraphs.

Emphasis-of-matter and other-matter paragraphs may be collectively referred to as explanatory paragraphs. In most cases, the auditors’ reporting responsibility is exception- based reporting, which means that the report will refer only to these matters if an issue is noted during the audit.

Consistency  The concept of consistency is based on the importance of permitting users to appropri- ately compare an entity’s financial statements across years. GAAS require that the audi- tors’ report be modified by adding an emphasis-of-matter paragraph (following the Basis for Opinion section) for the following issues related to consistency:

1. Changes in accounting principles (from one GAAP method to another GAAP method). 2. Changes in the form of the reporting entity (other than that resulting from a transaction

or event).

LO 12-3 Identify situations in which auditors add explanatory language to an unmodified opinion.

Standard (Unmodified Report

Departure from GAAP

Not Material

Not Material

Do Not Assume Responsibility for Work of Component Auditors

Material but Not Pervasive

Material and Pervasive

Material and Pervasive

Material but Not Pervasive

Assume Responsibility for Work of Component Auditors

Scope Limitation

Audit of Group Financial Statements

Unmodified Opinio with Changes to Standard Report

Qualifie Opinion

Adverse Opinion

Disclaimer of Opinion

Less Material and More Material Pervasive and Pervasive

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3. Changes in an accounting principle that is not a generally accepted accounting prin- ciple to one that is a generally accepted accounting principle (which is considered to be an adjustment to correct a misstatement in previously issued financial statements).

4. Changes in accounting principles inseparable from changes in estimates.

The following is an excerpt from EY’s 2019 report on Alphabet’s financial statements related to consistency:

Adoption of New Accounting Standard

As discussed in Note 1 to the consolidated financial statements, the Company changed its method for accounting for the recognition, measurement, presentation, and disclosure of certain equity securities in the year ended December 31, 2018.12

Changes in accounting principles may result from the issuance of new accounting stan- dards or from management’s selection of alternatives provided under existing accounting stan- dards (as noted in the preceding example). When evaluating a change in accounting principle, audit teams should be satisfied that (1) the newly adopted accounting principle is a generally accepted accounting principle, (2) the method of accounting for the change is appropriate, (3) disclosures relating to the change are appropriate, and (4) the newly adopted principle is preferable to the previously used principle. If these criteria are not met, the audit team should treat the change in principle as a departure from GAAP and modify the report accordingly.

“Going-Concern” Uncertainties  GAAP are based on the going-concern principle, which means the entity is expected to continue in operation and meet its obligations as they become due without substantially disposing of its assets outside the ordinary course of business, restructuring its debt, or taking similar actions. Hence, an opinion that financial statements are in accordance with GAAP means that continued existence may be presumed for a “reasonable time” not to exceed one year beyond the date of the financial statements. As noted in Chapter 11, one of the activities performed by audit teams during the completion of the audit is assess- ing the entity’s ability to continue as a going concern for a period not to exceed one year beyond the date the financial statements are issued.

Questions raised about the entity’s ability to continue in operation and meet its obliga- tions as they become due are known as going-concern uncertainties . The most common report issued when going-concern uncertainties exist is an unmodified opinion with a separate section in the report with the heading Substantial Doubt About the Entity’s Abil- ity to Continue as a Going Concern. This section would

∙ Identify the note in the financial statements that discloses the going-concern issue and management’s plans to address the issue.

∙ Indicate that the opinion on the financial statements is not modified with respect to the going-concern issue.

In highly unusual circumstances involving very severe going-concern uncertainties, auditors may issue a disclaimer of opinion with the auditors’ report providing all substan- tive reasons for the disclaimer.

The following is an excerpted paragraph from Deloitte & Touche’s 2016 report on Caesars Entertainment Corporation’s financial statements:

The accompanying consolidated financial statements have been prepared assuming that the Company will continue as a going concern. As discussed in Note 1 to the consolidated finan- cial statements, . . . The uncertainty of the outcome of these matters raises substantial doubt about the Company’s ability to continue as a going concern.* Management’s plans concern- ing these matters are discussed in Notes 1, 3, and 4 to the consolidated financial statements.13

12 Ernst & Young LLP. “EY’s 2019 report on Alphabet’ s. 13 Caesars Entertainment Corporation’s 2015 Form 10-K (auditors’ report dated February 26, 2016)

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These reporting options assumed that the entity has properly disclosed matters related to the going-concern uncertainty. If they have not done so, auditors would issue a quali- fied or adverse opinion on the entity’s financial statements, similar to actions taken for other departures from GAAP.

A research report by Audit Analytics covering the time period 2000– 2017 revealed the following with respect to going-concern reports.14

• The percentage of auditors’ reports indicating going-concern uncertainties ranged from 14.1% to 21.1% per year (the latter in 2008 concurrent with the financial crisis).

• The most frequent concerns raised in reports issued in 2017 (percentage of going-concern reports in parentheses) were net/ operating losses (62%), working capital/current ratio deficiencies (25%), negative cash flow from operations (25%), accumulated/ retained earnings deficit (22%), and insufficient revenues (22%) (more than one issue was mentioned in some reports).

• In 2017, smaller companies were more likely to receive a going- concern report; the percentage of auditors’ reports indicating going-concern uncertainties were lowest for large accelerated filers (public equity of $700 million or more) (0.3%), followed by accelerated filers (public equity of between $75 million and $700 million) (4.9%), then by smaller companies (19.6%).

Using the Audit Analytics database, only four going-concern reports have been received by Fortune 500 companies since 2012: American Airlines Group Inc. (2012 and 2013), Caesars Entertain - ment Corporation (2016), and NRG Energy Inc. (2017)

Audit Analytics and Going-Concern ReportsAUDITING INSIGHT

The following academic studies have examined going-concern reports:

• Chen et al. found that going-concern reports affected various aspects of loan decisions (higher interest rates, increased use of general loan covenants, reduced loan sizes and shorter maturities, and increased collateral requirements).

• Berglund et al. found that Big Four firms are more likely to issue going-concern opinions to financially distressed clients and less likely to issue going-concern opinions to firms that do not subse- quently fail compared to mid-tier firms (such as Grant Thornton and BDO USA)

• Eutsler et al. found that the issuance of a going-concern report (which documents auditors’ awareness of risk) results in a greater likelihood of enforcement actions against the auditor following a fraud.

• Geiger et al. found that auditors were more likely to issue going- concern reports to financially stressed companies following the onset of the 2008 global financial crisis than prior to the crisis.

• Ettredge et al. found that companies who were able to negoti- ate reduced fees during the “great recession” of 2007–2009 were less likely to receive a going-concern opinion in 2008; however, this relationship was not observed prior to or follow- ing 2008.

Sources: P.F. Chen, S. He, Z. Ma, and D. Stice, “The Information Role of Audit Opinions in Debt Contracting,” Journal of Accounting and Economics, Febru- ary 2016, pp. 121–144; N.R. Berglund, J.K. Eshleman, and P. Guo, “Auditor Size and Going Concern Reporting,” Auditing: A Journal of Practice & Theory, May 2018, pp. 1–25; J. Eutsler, E.B. Nickell, and S.W.G. Robb, “Fraud Risk Awareness and the Likelihood of Audit Enforcement Action,” Accounting Horizons, September 2016, pp. 379–392; M.A. Geiger, C. S. Lennox, K. Raghunandan, and M. Willekens, “Audit Reporting for Going-Concern Uncertainty: A Research Synthesis,” Auditing: A Journal of Practice & Theory, Supplement 1, 2013, pp. 353–384; M. Ettredge, E.E. Fuerherm, F. Guo, and C. Li, “Client Pressure and Auditor Independent: Evidence From the ‘Great Recession’ of 2007–2009,” Journal of Accounting and Public Policy, July 2017, pp. 262–283.

Research on Going-Concern ReportsAUDITING INSIGHT

14 2017 Going Concerns: An Eighteen Y ear Review (Audit Analytics), April 2019.

Other Information Included in Annual Reports  In many cases, audited financial statements include a variety of information that accom- panies the financial statements. For example, all annual reports to shareholders and SEC filings contain such sections as a president’s letter and management’s discussion and anal- ysis (MD&A) of operations. In addition, the financial statements may be accompanied by financial summaries, financial ratios, or other management commentary. Audit teams

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have an obligation to read the other information and determine whether this information is consistent with the audited financial statements or contains material misstatements.

When other information is presented along with the financial statements, the auditors’ report should be modified by including a section (labeled Other Information or Other Information Included in the Annual Report). This section would include the following information:

∙ A statement that management is responsible for the other information ∙ An indication that the audit team does not express an opinion or any form of assurance

on the other information ∙ The audit team’s responsibility with respect to the other information and to report any

material misstatements in the other information ∙ A description of any material misstatements of the other information (if applicable)

Required Supplementary Information  In addition to the financial statements and footnotes accompanying the financial state- ments, accounting standard-setting bodies may require companies to provide supplemen- tary information that is not part of the basic financial statements. For example, the FASB requires energy companies to present oil, gas, and other mineral reserve information as supplementary information. Other examples of such information related to specific industries or types of companies (construction, development-stage entities, financial ser- vices, and real estate) can be found in ASC 235.

Audit teams are required to perform limited procedures (inquiring of management, comparing information for consistency with the financial statements, and obtaining written representations from management) with respect to the required supplementary information. When companies present required supplementary information, auditors are required to expand their report on the financial statements to include an other-matter paragraph15 that identifies the supplementary information, describes any procedures per- formed with respect to this information, and identifies any issues related to this informa- tion. However, the paragraph specifically disclaims an opinion or any form of assurance on the supplementary information.

Other Modifications Beyond the wording in the standard (unmodified) report, auditors can enrich the informa- tion content in their reports by adding one or more paragraphs to emphasize something they believe readers should consider important or useful. Although auditing standards place no official limits on the content of these paragraphs, auditors often use them to describe circumstances that present some business or information risk. Matters that may be emphasized include a warning that a bankruptcy filing may be imminent, a descrip- tion of the auditee as a subsidiary of a larger entity, the effects of business events on the comparability of financial statements, the interaction of the auditee with related parties, and the effect of events that occur after the date of the financial statements (commonly referred to as subsequent events). For example, during the 2008–2009 financial crisis, both American International Group (AIG) and Fannie Mae’s auditors’ reports men- tioned issues encountered by these firms during this time.

Some recent examples include

∙ The fact that the Federal National Mortgage Association (Fannie Mae) and Federal Home Loan Mortgage Corp (Freddie Mac) are under the control of the Federal Housing Finance Agency (FHFA) and are dependent upon continued support from the FHFA and the United States Government (2019 auditors’ report).

15 A proposed Statement on Auditing Standards, Amendments to AU-C Sections 725, 730, 930, 935, and 940, AICPA, December 10, 2019 would require this information to be presented in a separate section with a heading such as Required Supplementary Information.

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∙ Kraft Heinz Company’s restatement of its 2016, 2017, and 2018 financial statements caused by employee misconduct related to rebates and supplier contracts (2019 audi- tors’ report).

∙ YUM! Brands Inc.’s change of its fiscal year from a 52–53 week year to a fiscal year ending on December 31 of each year (2018 auditors’ report).

∙ Tesla Inc.’s exclusion of SolarCity Corporation from management’s assessment of internal control over financial reporting (2017 auditors’ report).

Summary: Emphasis-of-Matter and Other-Matter Paragraphs Assuming that the matters discussed in this section are properly accounted for and disclosed by the entity, the auditors’ report is modified by adding a paragraph labeled “Emphasis of Matter” or “Other Matter” to the report. (As noted earlier, professional guidelines provide specific wording for the section for going-concern uncertainties and other information presented along with financial statements). It is important to reiter- ate that the opinion on the financial statements would still be unmodified. Professional guidelines indicate that the placement of the paragraph depends upon the nature and significance of the information.

An academic study analyzing audit opinions that were issued between 2000 and 2014 with explanatory paragraphs identified the following disclosures (as a percentage of all opinions with explanatory paragraphs; each report could have more than one matter ref- erenced): 16

∙ Supplementary information (65 percent) ∙ Change in accounting principles (49 percent) ∙ Restatements (3 percent) ∙ Other matters (2 percent)

16 K. Czerney, J.J. Schmidt, and A.M. Thompson, “Do Investors Respond to Explanatory Language Included in Unqualified Audit Reports?” Contemporary Accounting Research, Spring 2019, pp . 198–229.

REVIEW CHECKPOINTS 12.17 Define emphasis-of-matter and other-matter paragraphs. What type of information do auditors

provide in these paragraphs? 12.18 What types of matters would result in the auditors’ report being modified for consistency? 12.19 What are going-concern uncertainties? What is the audit team’s responsibility for evaluating

going-concern uncertainties? 12.20 What are auditors’ reporting options when going-concern uncertainties are noted? 12.21 What is the auditors’ reporting responsibility for (a) other information accompanying the audited

financial statements and (b) required supplementary information?

OTHER REPORTING TOPICS To this point, we have focused on situations in which audit teams have examined and reported on a single year’s financial statements. Additional issues are introduced when companies provide multiple years of financial statements in comparative form, auditors are engaged to examine and report on information other than the financial statements and related disclosures, and auditors’ involvement in the financial reporting process might be misunderstood by users. These situations are the focus of this section.

LO 12-4 Identify other circumstances affecting auditors’ reporting responsibilities and explain how they affect auditors’ reports on an entity’s financial statements.

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Comparative Financial Statements The SEC requires issuers to present balance sheets for two years and statements of income, changes in shareholders’ equity, and cash flows for three years in comparative (side-by-side) format. Financial statement footnotes also contain disclosures in compara- tive form. Together, these comparative financial statements and footnotes are the subject of the auditors’ work and report. Although non-issuers are not subject to similar require- ments, users may request that entities provide multiple years of financial statements in comparative form.

The issue introduced when financial statements are presented in comparative form is that users may assume that the audit team has examined all comparative years presented. Therefore, it is important that the auditor’s report specifically identify the responsibility assumed for all financial statements presented in comparative form.

Same Auditors, Same Opinions for Comparative Years When auditors issue a report on the current-year financial statements, they are required to update their report on the prior years’ financial statements by considering whether the opinions on the prior years’ financial statements are still appropriate. The updated report is based not only on the prior-year audits, but also on information that has come to the audit team’s attention since then (particularly in the course of the most recent audit). An updated report carries the most recent date of the auditors’ report, and the auditors’ responsibility for the comparative financial statements now extends to this date.

Recall the standard (unmodified) report shown in Exhibit 12.1. Assume that Dunder- Mifflin, Inc. presented balance sheets for 2019 and 2020 and statements of income, changes in shareholders’ equity, and cash flows for 2018, 2019, and 2020. If Michael Scarn had audited Dunder-Mifflin all three years and concluded that an unmodified opin- ion was appropriate in all three years, a “plural” form of the standard (unmodified) report would be issued which expresses an opinion on the financial condition for 2019 and 2020 and the results of operations and cash flows for 2018, 2019, and 2020.

An updated report differs from a reissued report. When auditors reissue a report, they simply provide additional copies of a previously issued report or grant entities permission to use a previously issued report in another document sometime after its original date. However, auditors do not attempt to update the report or otherwise consider events that have occurred since the date of the original report. The date of a reissued report is the same as that for the original report, indicating a cutoff date for the auditors’ responsibility.

Same Auditors, Different Opinions for Comparative Years Auditors can express different opinions on comparative years’ financial statements in the same report. For example, assume that Dunder-Mifflin incorrectly recorded a $30 mil- lion provision for uncollectible receivables in the 2019 financial statements instead of in 2018. As a result, both years’ financial statements were not prepared in accordance with GAAP, so Michael Scarn issued a qualified opinion in those two years. However, Scarn concluded that an unmodified opinion was appropriate in 2020. The report shown in Exhibit 12.10 would be appropriate in the circumstances.

Essentially, the report in Exhibit 12.10 combines a qualified opinion on Dunder- Mifflin’s financial statements for 2018 and 2019 with an unmodified opinion on its finan- cial statements for 2020.

Same Auditors with Modification of Previously Issued Opinion Auditors should modify the opinion expressed on prior years’ financial statements if cir- cumstances have changed in the intervening period. For example, consider the departure from GAAP shown in Exhibit 12.10 and discussed in the preceding section. In 2020, if Dunder-Mifflin restated its 2018 and 2019 financial statements to record the provision in the appropriate year (2018), all three years of financial statements would now be in accordance with GAAP. Therefore, an unmodified opinion (standard report) on all three years would now be appropriate.

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One concern with not referring to the previous opinions is that Michael Scarn’s updated opinion on the 2018 and 2019 financial statements is now different from the originally issued opinion. To alert readers to this fact, an explanatory other-matter para- graph such as the following one would be added to the report (following the Basis for Opinion section):

Other Matter In our report dated January 30, 2020, we expressed an opinion that, except for the effects of incorrectly charging the provision for uncollectible receivables, the 2019 and 2018 financial statements presented the financial position, results of operations, and cash flows in accordance with principles generally accepted in the United States of America because Dunder-Mifflin, Inc. incorrectly recorded a $30,000,000 provision for uncollectible receivables in 2019 rather than in 2018. As described in Note 2, Dunder-Mifflin, Inc. has restated its 2019 and 2018 financial statements to conform with accounting principles generally accepted in the United States of America. Accordingly, our present opinion on the restated 2019 and 2018 financial statements, as presented herein, is different from that expressed in our previous report.

Independent Auditor’s Report To the Board of Directors and Shareholders of Dunder-Mifflin, Inc.

Report on the Audit of the Financial Statements

Opinion

We have audited the financial statements of Dunder-Mifflin, Inc., which comprise the balance sheet as of December 31, 2020, 2019, and 2018 and the related statements of income, changes in stockholders’ equity, and cash flows for the years then ended, and the related notes to the financial statements.

In our opinion, except for the effects on the accompanying 2018 and 2019 fin ancial statements of incorrectly charging the provision for uncollectible receivables as described in the Basis for Qualified Opinion section of our report, the financial statements present fairly, in all material respects, the financial position of Dunder-Mifflin, Inc. as of December 31, 2020, 2019, and 2018, and the results of its operations and its cash flows for the years then ended in accordance with accounting principles generally accepted in the United States of America.

Basis for Qualified Opinion on 2019 and 2018 Financial S tatements

As discussed in Note 16, an additional provision in the amount of $30,000,000 for possible uncollectible receivables at December 31, 2018, was charged to operations during the year ended December 31, 2019, which, in our opinion, should have been reflected in the financial statements for 2018. Had this provision been properly recorded in the 2018 financial statements, net income and shareholders’ equity for 2018 would have been $30,000,000 lower than that reported and net income for 2019 would have been $30,000,000 higher than that reported, as reflected in the balance sheets and statements of income, changes in shareholders’ equity, and cash flows for those years.

No modifications to standard paragraph

Responsibilities of Management for the Financial Statements

No modifications to section

Auditor’s Responsibilities for the Audit of the Financial Statements

No modifications to section

Scranton, PA January 29, 2021

EXHIBIT 12.10 Different Opinions in Comparative Year Financial Statements

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Different Auditors in Comparative Years Assume that Michael Scarn became the auditor of Dunder-Mifflin in 2020 and another (predecessor) firm had examined the 2018 and 2019 financial statements and issued an unmodified opinion (standard report) on these statements. In this case, Michael Scarn’s report should indicate that he audited the 2020 financial statements and expressed an opinion on the 2020 financial statements. However, how should the results of the other firm’s audit of the 2018 and 2019 financial statements be communicated?

One option would be to add an other-matter paragraph (following the Basis for Opin- ion section) that summarizes the predecessor auditors’ responsibility and report. An example of this type of paragraph follows. If the predecessor auditors issued an opinion other than the standard (unmodified) opinion, the paragraph should be expanded to pro- vide information about the report modification. The predecessor auditors’ report would also be included along with the comparative financial statements.

Other Matter The financial statements of Dunder-Mifflin, Inc. as of December 31, 2019 and 2018, were audited by other auditors whose report dated February 4, 2020, expressed an unmodified opinion on those statements.

A second option would be for the successor auditor to express an opinion on the cur- rent year’s financial statements without any reference to the predecessor auditor. The predecessor auditors’ report would then be included along with the comparative financial statements. To illustrate, in 2019 EY became the successor auditor for General Motors Company (prior to that time, Deloitte had served as General Motors’ auditor since 1918!). Two auditors’ reports were included along with General Motors’ 2019 financial statements:

∙ EY’s report on General Motors’ 2019 financial statements ∙ Deloitte’s report on General Motors’ 2017 and 2018 financial statements

In a highly unusual example of multiple auditors, A-Mark Precious Met- als employed the following firms as auditors from 2012–2015:

2012: BDO USA 2013: KPMG 2014: BDO USA 2015: Grant Thornton

In each case, individual reports were provided in the comparative financial statements (for example, in 2014, BDO’s opinion for 2012 and 2014 and KPMG’s opinion on the 2013 financial statements were provided). Grant Thornton has continued to serve as A-Mark’s auditor since its appointment in 2015.

Changing Their Mind (and Auditor)AUDITING INSIGHT

Summary Financial Statements  Published financial statements are lengthy and often complex. Entities sometimes have occasion to present the financial statements in considerably less detail (e.g., summary totals of current assets, current liabilities, long-term liabilities, operating income, or other subtotals). Generally, such summary financial statements (sometimes referred to as condensed financial statements) are derived directly from the full audited financial statements. However, summary financial statements are not fair presentations of financial position, results of operations, and cash flows in accordance with GAAP.

In some cases, users may engage audit teams to examine and report on summary financial statements. Audit teams can do so only if they have audited the full financial statements. The report on summary financial statements parallels the auditors’ report on the financial statements illustrated throughout this chapter and must refer to the auditors’ report on the full financial statements, giving the date and the type of opinion expressed.

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The auditors’ conclusion on summary financial statements will not express an opinion on the summary financial statements but will indicate whether the information in the summary financial statements is fairly stated in all material respects in relation to the complete financial statements.

Supplementary Information Earlier, we discussed supplementary information that standard-setting bodies (such as the FASB) require entities to present along with their financial statements and related footnote disclosures (known as required supplementary information). Other types of supplementary information may be presented outside the basic financial statements; this information differs in that there is no expressed requirement for presenting it or any authoritative guidelines for presenting or preparing this information.

Similar to summary financial statements, users may engage audit teams to examine and report on supplementary information. The auditors’ conclusion will not express an opinion on the supplementary information but will indicate whether it is fairly stated, in all material respects, in relation to the financial statements as a whole. Auditors may report on this information either by adding an other-matter paragraph to their report on the financial statements (following the Basis for Opinion section) or by preparing a separate report on the supplementary information.17 For example, KPMG added a para- graph to its 2019 report on its audit of General Electric that references “. . . accompany- ing consolidating information appearing on pages 95, 99, and 101 [of General Electric’s annual report]” and indicates that this information “.  .  . is fairly stated in all material respects in relation to the consolidated financial statements as a whole.”18

Disclaimers of Opinion In addition to the situations described in the previous sections of this chapter, other cir- cumstances may result in auditors issuing disclaimers of opinion. Audit teams may be engaged to conduct an audit but subsequently discover a relationship involving the firm that results in a lack of independence. In other cases, audit teams may consent to the use of the firm’s name in some form of communication containing the entity’s financial state- ments or submit to their clients or others (such as third-party users) financial statements they have prepared or assisted in preparing. These situations are referred to as being asso- ciated with financial statements.

In these situations, auditors will issue a single paragraph report shown in Exhibit 12.11. Note that this report is not addressed to any specific users, nor does it reference any proce- dures performed on Dunder-Mifflin’s financial statements.

When audit teams are not independent, the report in Exhibit 12.11 would begin with the phrase “We were not independent with respect to Dunder-Mifflin, Inc.” The report should not mention any reasons for not being independent because readers may errone- ously interpret them as unimportant.

17 Similar to the guidance for required supplementary information, a proposed Statement on Auditing Standards, Amendments to AU-C Sections 725, 730, 930, 935, and 940, AICPA, December 10, 2019 would require this information to be presented in a separate section with a heading such as Supplementary Information (assuming a separate report is not prepared). 18 General Electric. “2018 Annual R eport.” Accessed November 30, 2019. https://www .ge.com/investor-relations/sites/default/ files/GE_AR18.pdf

The accompanying balance sheet of Dunder-Mifflin, Inc. as of December 31, 2020, and the related statements of income, changes in shareholders’ equity, and cash flows for the year then ended were not audited by us and, accordingly, we do not express an opinion on them.

Scranton, PA January 29, 2021

EXHIBIT 12.11 Disclaimer of Opinion on Unaudited Financial Statements

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This chapter has discussed a wide range of reporting issues. The array and variety of reports may seem confusing, but several simple rules will enable you to remember the basics of auditors’ reports on financial statements. First, begin with the standard (unmod- ified) report in Exhibit 12.1. Keeping the four sections in mind, remember that the fol- lowing basic rules apply:

∙ The Opinion section is modified when the financial statements examined changes, the responsibility assumed by auditors changes, or an opinion other than an unmodified opinion is issued.

∙ The Basis for Opinion section is modified when an opinion other than an unmodified opinion is issued.

∙ The Responsibilities of Management for the Financial Statements Section is not modi- fied for any of the issues discussed in this chapter because they are not related to man- agement’s responsibility for the financial statements and internal control.

∙ The Auditor’s Responsibilities for the Audit of Financial Statements section is mod- ified for matters that affect the auditors’ responsibility for the financial statements (material and pervasive scope limitation).

∙ Additional paragraphs are added to the report when some other matter arises related to the financial statements or audit is noted.

See Exhibit 12.12 for a comprehensive summary of auditors’ reports discussed in this chapter. In reviewing Exhibit 12.12, it is important to note that if any of the issues does not have a material effect on the financial statements, auditors can issue the standard (unmodified) report without any reference to the issue (except for a lack of independence, which is always considered to be material).

Summary

REVIEW CHECKPOINTS 12.22 What are comparative financial statements? What issue is introduced when entities present infor-

mation in comparative format? 12.23 What is an updated report? What is a reissued report? 12.24 If auditors wish to express a different opinion on prior years’ financial statements in the current

report than in a previously issued report, how should their current report be modified? 12.25 What reporting options are available if predecessor auditors examined prior years’ financial

statements presented in comparative form? 12.26 Briefly describe the options and information provided by auditors when engaged to report on (a)

summary financial statements and (b) supplementary information? 12.27 What type of report should be issued when audit teams are not independent with respect to the

entity?

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adverse opinion: The opinion issued when the auditors conclude that the financial statements do not present the financial condition, results of operations, and cash flows in accordance with GAAP, 542 associated (association) with financial statements: Situations in which auditors consent to the use of their name in some form of communication containing the entity’s financial statements or submit to their clients or others (such as third-party users) financial statements they have prepared or assisted in preparing. Auditors should issue a one-paragraph disclaimer when they are associated with (but did not audit) financial statements, 561 circumstance-imposed scope limitation: A restriction on auditors from gathering sufficient appropriate evidence because of a situation beyond control of both the auditors and client, such as late appointment of the auditors, 546 client-imposed scope limitation: A restriction on auditors from gathering sufficient appropriate evidence because of the client’s imposition of limitations on the auditor’s application of auditing procedures or the client’s deliberate refusal to provide auditors access to evidence, 546 component auditor: The auditor who audits divisions, subsidiaries, or components that are included in the group financial statements, 550 date of the auditors’ report: The date on which auditors have obtained sufficient appropriate evidence to support their opinion, 542 departure from GAAP: Situation in which an entity does not follow GAAP in preparing its financial statements. Auditors can issue qualified or adverse opinions for material departures from GAAP, 543 disclaimer of opinion: A report issued when auditors do not express an opinion on the fairness of the entity’s financial statements. Disclaimers of opinion are issued for pervasive going-concern uncertainties, pervasive scope limitations, situations in which auditors’ are associated with (but did not audit) financial statements, and situations in which the auditors are not independent, 542 division of responsibility: Situation in which the component auditors are involved with the examination of a subsidiary, branch, component, or investment that is included in the financial statements audited by group auditors, 550 emphasis-of-matter paragraph: A paragraph added to an auditors’ report that provides information fundamental to users’ understanding of the financial statements (such as consistency or going-concern uncertainties), 553 explanatory paragraph: A paragraph added to an auditors’ report that either provides information fundamental to users’ understanding of the financial statements (emphasis-of-matter paragraph) or is relevant to users’ understanding of the audit, the auditor’s responsibility, or auditors’ report (other-matter paragraph), 553 going-concern uncertainty: Situation in which questions are raised about an entity’s ability to continue operations and meet its obligations as they become due, 554 group auditors: The auditors who perform the audit of a material portion of the assets, liabilities, revenues, and expenses of an entity’s group financial statements; also known as principal auditors, 550 group financial statements: The financial statements of more than one component (division, subsidiary, or other segment), 550 integrated report: A single report issued by auditors expressing their opinion on the fairness of the financial statements and effectiveness of internal control over financial reporting (Appendix 12A), 585 introductory paragraph: issuers: An entity that offers registered securities, such as stocks and bonds, for sale to the general public (also known as a public entity). Issuers are subject to mandatory audit requirements, 539 Key audit matters: Matters that, in the audit team’s professional judgment, were of most significance in the audit of the financial statements of the current period, 539 modified opinion: Any opinion other than an unmodified opinion on an entity’s financial statements (qualified opinion, adverse opinion, or disclaimer of opinion), 542 opinion paragraph other-matter paragraph: A paragraph added to the auditors’ report that is relevant to users’ understanding of the audit, the auditor’s responsibility, or the auditors’ report, 553 qualified opinion: An opinion issued when the auditors conclude that, with the exception of one or more issue(s), the financial statements present the financial condition, results of operations, and cash flows in accordance with GAAP. Qualified opinions can be issued for material departures from GAAP and material scope limitations, 542

Key Terms

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reissued report: A copy of a previously issued report that auditors provide or grant entities permission to use in another document after its original date; the report is not modified to consider events occurring subsequent to the date of the original report, 558 scope limitation: A situation in which the auditors are unable to obtain sufficient appropriate evidence. If material, a scope limitation results in the issuance of either a qualified opinion or disclaimer of opinion, 546 unmodified opinion: An opinion issued when the auditors conclude that the financial statements present the financial condition, results of operations, and cash flows in accordance with GAAP (until recently, known as an unqualified opinion), 542 updated report: The auditors’ report on prior-year financial statements that is based on both the prior-year audit and information that has come to the auditors’ attention in the most recent audit, 558 internal control deficiency: A condition that exists when the design or operation of a control does not allow the entity’s management or employees to detect or prevent misstatements in a timely fashion, 585 critical audit matters: Matters communicated or required to be communicated to the audit committee that involve challenging, subjective, or complex auditor judgment relating to material accounts and disclosures, 583 material weakness: A deficiency or combination of deficiencies that results in a reasonable possibility that a material misstatement would not be prevented or detected on a timely basis, 585 non-issuer: An entity that does not offer registered securities, such as stocks and bonds, for sale to the general public (also known as a nonpublic entity). Non-issuers are not subject to mandatory audit requirements, 539 significant deficiency: A deficiency or a combination of deficiencies in internal control that is less severe than a material weakness yet important enough to merit attention by those charged with governance, 585

12.28 In the standard audit report under GAAS, certain conclusions are required to be stated in the report (“explicit”) while other conclusions are implied (“implicit”). Which combina- tion that follows correctly describes the auditors’ conclusions as explicit or implicit?

LO 12-1

All applicable questions are available with Connect.

Multiple-Choice Questions for Practice and Review

(a) (b) (c) (d)

1.  GAAP Explicit Explicit Implicit Implicit

2. Consistency Implicit Explicit Explicit Implicit

3. Going concern Implicit Implicit Explicit Explicit

4. Opinion Explicit Explicit Implicit Implicit

12.29 How is the auditors’ responsibility for expressing the opinion on financial statements dis- closed in the standard (unmodified) report for a non-issuer? a. Stated explicitly in the Auditor’s Responsibility for the Audit of the Financial State-

ments section. b. Unstated but understood in the Auditor’s Responsibility for the Audit of the Financial

Statements section. c. Stated explicitly in the Opinion section. d. Stated explicitly in the Basis for Opinion section.

12.30 Which of the following is not included in the standard (unmodified) report on the financial statements? a. An identification of the financial statements that were audited. b. A general description of an audit. c. An opinion that the financial statements present financial position in accordance with GAAP. d. An emphasis-of-matter paragraph commenting on the effect of economic conditions on

the entity.

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12.31 Which of the following statements is not true with respect to the audit examinations and reports for issuers and non-issuers? a. Audit examinations for non-issuers are based on user demand but for issuers audit

examinations are based on legislative requirements. b. The reports for both issuers and non-issuers express an opinion on the entity’s financial

statements. c. Auditors are required to express an opinion on internal control in the audit of non-

issuers but not in the audit of issuers. d. Management is responsible for the fairness of the financial statements for both issuers

and non-issuers. 12.32 The audit team found that the entity has not capitalized a material amount of leases in the

financial statements. When considering the materiality of this departure from GAAP, the auditors would choose between which reporting options? a. Unmodified opinion or disclaimer of opinion. b. Unmodified opinion or qualified opinion. c. Unmodified opinion with an emphasis-of-matter paragraph or an adverse opinion. d. Qualified opinion or adverse opinion.

12.33 Which of the following situations would not ordinarily require auditors to modify the Opin- ion section of the report on the financial statements of a non-issuer? a. A material departure from GAAP. b. Reference to the use of a component auditor in the examination of group financial statements. c. A significant scope limitation. d. A change from one generally accepted accounting principle to another.

12.34 In which of the following instances would a qualified opinion be an appropriate option (assuming no other issues have been encountered)?

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Scope Limitation Audit of Group Financial Statements

a. Yes Yes b. No Yes c. Yes No d. No No

12.35 If audit teams are unable to apply an auditing procedure to an account balance or class of transactions and the impact has a material effect on the audit, the audit team should first a. Attempt to determine whether alternative auditing procedures are available and can be

applied. b. Withdraw from the engagement and issue a disclaimer of opinion. c. Assess the significance of the scope limitation on the overall fairness of the financial

statements. d. Notify individuals currently relying on the financial statements that the statements may

no longer be relied upon. 12.36 Which of the following sections of the standard report on the financial statements of a non-

issuer would be modified in response to a material departure from GAAP?

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Basis for Opinion

Auditor’s Responsibilities

a. Yes Yes b. Yes No c. No Yes d. No No

12.37 When component auditors are involved in the audit of group financial statements, the group auditors may issue a report that a. Refers to the component auditors, describes the extent of the component auditors’ work,

and expresses an unmodified opinion.

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b. Does not consider or evaluate the component auditors’ work but expresses an unmodi- fied opinion in a standard report.

c. Places primary responsibility for the reporting on the component auditors. d. Names the component auditors, describes their work, and presents only the group audi-

tors’ report. 12.38 Under which of the following conditions can a disclaimer of opinion never be issued?

a. The entity’s going-concern problems are highly material and pervasive. b. The entity does not allow the audit team access to evidence about important accounts. c. Members of the audit team own stock in the entity. d. The audit team has determined that the entity uses the NIFO (next-in, first-out) inven-

tory costing method. 12.39 The audit team determined that the entity is suffering financial difficulty and its going-

concern status is seriously in doubt. Assuming that the entity adequately disclosed this matter in the financial statements, the auditors must choose between which of the following report alternatives? a. Unmodified opinion with a reference to going-concern or disclaimer of opinion. b. Standard (unmodified) report or a disclaimer of opinion. c. Qualified opinion or adverse opinion. d. Standard (unmodified) report or adverse opinion.

12.40 Which of these situations would require auditors to include an emphasis-of-matter para- graph about consistency to an otherwise unmodified opinion? a. Entity changed its estimated allowance for uncollectible accounts receivable. b. Entity corrected a prior mistake in accounting for interest capitalization. c. Entity sold one of its subsidiaries and consolidated six subsidiaries this year compared

to seven last year. d. Entity changed its inventory costing method from FIFO to LIFO.

12.41 When auditors wish to issue an unmodified opinion but highlight that the entity changed its method of accounting for software development costs, they would most appropriately identify the change in accounting method in which of the following? a. The Opinion section. b. The Basis for Opinion section. c. An emphasis-of-matter paragraph. d. An other-matter paragraph.

12.42 Which of the following would not be addressed in an emphasis-of-matter or other-matter paragraph? a. A change in accounting principles that was accounted for in conformity with GAAP. b. Information relating to a material acquisition made during the previous year. c. The financial statement effects of a material departure from generally accepted account-

ing principles. d. Procedures performed on supplementary information required by the Financial

Accounting Standards Board. 12.43 R. Wolfe became the new auditor for Royal Corporation, succeeding C. Mason, who

audited the financial statements last year. Wolfe needs to report on Royal’s comparative financial statements and should disclose in the report an explanation about other auditors having audited the prior year a. Only if Mason’s opinion last year was qualified. b. To describe the prior audit and the opinion but not name Mason as the predecessor auditor. c. To describe the audit but not reveal the type of opinion issued by Mason. d. To describe the audit and the opinion and name Mason as the predecessor auditor.

12.44 When financial statements are presented in comparative form and another firm audited the prior years’ financial statements (but the other firm’s report is not presented with the financial statements), the auditors’ report on the current-year financial statements should a. Disclaim an opinion on the prior years’ financial statements. b. Not refer to the prior years’ financial statements.

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c. Refer to any procedures performed by the current auditor to verify the opinion on the prior years’ financial statements.

d. Refer to the report and type of opinion issued by the other firm on the prior years’ financial statements.

12.45 If the opinion issued on prior years’ financial statements is no longer appropriate and financial statements are presented in comparative form, the auditors’ current report should a. Not reference the prior years’ financial statements. b. Indicate that the opinion on the prior years’ financial statements cannot be relied upon. c. Reference the type of opinion issued on the prior years’ financial statements and indi-

cate that the current opinion on these financial statements differs from that expressed in the prior years.

d. Express the revised opinion on the prior years’ financial statements without referencing the previously issued opinion.

12.46 When a predecessor auditor has examined comparative financial statements and that report is not presented with the successor auditor’s report, the successor auditor should a. Assume responsibility for the work of the predecessor auditor and report on all com-

parative years presented. b. Express an opinion on the year(s) examined by the successor auditor without referenc-

ing the comparative years examined by the predecessor auditor. c. Indicate that comparative year(s) were examined by the predecessor auditor and dis-

close the type of opinion issued. d. Express an opinion on the year(s) examined by the successor auditor and disclaim an

opinion on the comparative year(s) examined by the predecessor auditor. 12.47 If auditors examine all years presented in comparative form, which of the following best

describes their responsibility for prior years’ financial statements in their current report? a. Auditors are not required to address prior years’ financial statements in their current report. b. Auditors should consider whether information has come to their attention that might

affect their previous opinion on the prior years’ financial statements. c. Auditors should not modify their previous on prior years’ financial statements. d. Auditors are only required to consider whether new information might affect their previous

opinion on prior years’ financial statements if a report other than unmodified was issued.

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12.48 Basic Reports. The concepts of materiality and pervasiveness are important to audit teams in examinations of financial statements and expressions of opinion on these statements.

Required: How will materiality influence auditors’ reporting decisions in the following circum- stances? In your response, consider both the matter’s materiality and pervasiveness. a. The entity prohibits confirmation of accounts receivable, and sufficient and appropriate

evidence cannot be obtained using alternative procedures. b. The entity is a gas and electric utility company that follows the practice of recognizing

revenue when it is billed to customers. At the end of the year, amounts earned but not yet billed are not recorded in the accounts or reported in the financial statements.

c. The entity leases buildings for its chain of transmission repair shops under terms that qualify as capital leases under ASC 840. These leases are not capitalized as leased prop- erty assets and lease obligations.

d. The entity has lost a lawsuit in federal district court. The case is on appeal in an attempt to reduce the amount of damages awarded to the plaintiffs. No loss amount is recorded.

12.49 Departures from GAAP. For each of the following departures from GAAP, indicate the type of opinion that the auditors would issue as well as any modifications that would be made to the standard (unmodified) report in the audit of a non-issuer.

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All applicable questions are available with Connect.

Exercises and Problems

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a. A departure that had an immaterial effect on the financial statements. b. A departure that had a material effect on the financial statements (this effect was not

pervasive and affected only one account). c. A departure that had a material effect on the financial statements and was pervasive

(affected a number of accounts on both the balance sheet and income statement). 12.50 Scope Limitations. Situations in which audit teams are unable to obtain sufficient appro-

priate evidence necessary to support their opinion on the entity’s financial statements are referred to as scope limitations.

Required: a. Distinguish between client-imposed scope limitations and circumstance-imposed scope

limitations. Which of these is generally of more concern to audit teams? b. Why do scope limitations impact the auditors’ ability to express an opinion on the enti-

ty’s financial statements? c. Assume that a circumstance-imposed scope limitation prevented audit teams from perform-

ing procedures they considered to be necessary. How would each of the following factors independently influence the opinion expressed on the entity’s financial statements? 1. The account balances affected by the scope limitation are not material to the entity’s

financial position, results of operations, or cash flows. 2. The account balances affected by the scope limitation are material to the entity’s

financial position, results of operations, and cash flows. However, the audit team is able to perform alternative procedures that provide evidence supporting the accounts affected by the scope limitation.

3. The account balances affected by the scope limitation are material to the entity’s financial position, results of operations, and cash flows. Because of a lack of sup- porting documentation and key accounting records, the audit team is unable to per- form alternative procedures that provide evidence supporting the accounts affected by the scope limitation.

d. For each of the situations in part (c), briefly describe how the auditors’ report on the entity’s financial statements would be affected. (Assume the entity is a non-issuer and do not rewrite or draft the report that would be issued in each of these circumstances.)

12.51 Scope Limitations. Following are four possible scenarios that reflect scope limitations encountered by J. Bruce, CPA, during the audit of Weaver Inc., a non-issuer. In all cases, assume that the ending balance in inventory is material to Weaver’s financial position, results of operations, and cash flows. ∙ Scenario A. Because of the late appointment to the audit engagement, Bruce is unable

to observe Weaver’s physical inventory for the year ended December 31, 2020. How- ever, Weaver maintains extensive perpetual inventory records, and Bruce has been able to perform other substantive procedures and is satisfied as to the fairness of the ending inventory balance for December 31, 2020.

∙ Scenario B. Because of the late appointment to the audit engagement, Bruce is unable to observe Weaver’s physical inventory for the year ended December 31, 2020. Because Weaver’s accounting records are not complete, Bruce is unable to perform other sub- stantive procedures and is not satisfied as to the fairness of the ending inventory bal- ance for December 31, 2020.

∙ Scenario C. Because of a direct request by Weaver’s management, Bruce did not observe Weaver’s physical inventory for the year ended December 31, 2020. However, Weaver maintains extensive perpetual inventory records, and Bruce has been able to perform other substantive procedures and is satisfied as to the fairness of the ending inventory balance for December 31, 2020.

∙ Scenario D. Because of a direct request by Weaver’s management, Bruce did not observe Weaver’s physical inventory for the year ended December 31, 2020. Weaver’s accounting records are not complete, so Bruce is unable to perform other substantive procedures and is not satisfied as to the fairness of the ending inventory balance for December 31, 2020.

Required: For each of these scenarios, indicate what reporting option(s) and factors Bruce should con- sider in deciding which type of opinion to issue in the circumstances. (Do not draft Bruce’s report on Weaver Inc.’s financial statements for the year ended December 31, 2020.)

LO 12-2

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12.52 Scope Limitations. D. Brady has been engaged as the auditor of Patriot Company (a non- issuer) and is currently planning the year-end physical inventory counts. Patriot is a retailer that holds significant inventories in its warehouses and stores in six regions across the United States. Because of timing and logistics, Brady is able to observe the physical inventory at only one of Patriot’s warehouses, which accounts for 20 percent of Patriot’s inventories. In Brady’s professional judgment, the fact that inventories held at only one warehouse can be observed does not provide sufficient evidence with respect to Patriot’s inventory balances at the date of the financial statements. Although physical inventory counts could be delayed at the remaining warehouses for Brady to observe the counts, the flow of goods in and out of the warehouses would result in a discrepancy between the inventory quantities on hand at year-end and the inventory quantities on hand at the date of the count.

Required: a. Assume that Brady observes physical inventory at only the one warehouse and does not

perform alternative procedures related to inventories held at the other warehouses. Does this cause a scope limitation? If so, is this a client-imposed or circumstance-imposed scope limitation?

b. What type of opinion would Brady likely issue for the situation in part (a)? How would the wording in the standard (unmodified) report be modified to reflect this opinion?

c. What alternative procedures might be available to Brady with respect to this scope limi- tation? (Hint: You may wish to refer to Chapter 9 to identify alternative procedures for inventory.)

d. Assume that Brady performs one or more of the alternative procedures in part (c) and is able to gather evidence to support the recorded balance in inventory. What type of opinion would Brady issue on Patriot’s financial statements (assuming that no other issues were identified in the audit examination)?

12.53 Audit of Group Financial Statements. Lando Corporation is a non-issuer domestic company with two wholly owned subsidiaries. Michaels, CPA, has been engaged to audit the financial statements of the parent company and one of its subsidiaries and to serve as the group auditor. Thomas, CPA, has audited the financial statements of the other subsid- iary whose operations are material in relation to the consolidated financial statements.

The work performed by Michaels is sufficient for serving as the group auditor and to report as such on the financial statements. Michaels has not yet decided whether to refer to the part of the audit performed by Thomas.

Required: a. What responsibilities does Michaels have with respect to Thomas when deciding

whether to rely on the work of Thomas? b. What are the reporting requirements with which Michaels must comply in naming

Thomas and referring to the work done by Thomas? c. What report should be issued if Michaels does not wish to assume responsibility for

Thomas’s work or refer to Thomas’s work? 12.54 Various Reporting Situations. Assume that the audit team encountered the following

separate situations when deciding on the report to issue for the current-year financial state- ments for a non-issuer. 1. The audit team decided that sufficient appropriate evidence could not be obtained to

complete the audit of significant investments the entity held in a foreign entity. 2. The entity failed to capitalize lease assets and obligations but explained them fully in

the notes to the financial statements. These lease obligations meet the criteria for capi- talization under ASC 840.

3. The entity is defending a lawsuit on product liability claims. (Customers allege that power saw safety guards were improperly installed.) All facts about the lawsuit are disclosed in the notes to the financial statements, but the audit team believes the entity should record a loss based on a probable settlement mentioned by the entity’s attorneys.

4. The entity hired the audit team after taking inventory on December 31. The accounting records and other evidence are not reliable enough to enable the audit team to have suf- ficient evidence about the proper inventory amount.

5. The FASB requires the energy company to present supplementary oil and gas reserve information outside the basic financial statements. The audit team finds that this informa- tion, which is not required as a part of the basic financial statements, has been omitted.

6. The auditors are group auditors of the parent company, but they reviewed the compo- nent auditors’ work and reputation, and decided not to take responsibility for the work

LO 12-2

LO 12-2

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of the component auditors on three subsidiary companies included in the consolidated financial statements. The component auditors’ work amounts to 32 percent of the con- solidated assets and 39 percent of the consolidated revenues.

7. The entity changed its depreciation method from units of production to straight line, and its audit team believes the straight-line method is the more appropriate method in the circumstances. The change, fully explained in the notes to the financial statements, has a material effect on the year-to-year comparability of the comparative financial statements.

8. Because the entity has experienced significant operating losses and has had to obtain waiv- ers of debt payment requirements from its lenders, the audit team decides that there is sub- stantial doubt that the entity can continue as a going concern. The entity has fully described all problems in a note in the financial statements and the audit team believes that, while material, the uncertainty is not serious enough to warrant a disclaimer of opinion.

Required: a. What kind of opinion should the auditors express in each separate case? b. What other modification(s) or addition(s) to the standard (unmodified) report is (are)

required for each separate case? 12.55 Various Reporting Situations. Assume that Stanford CPAs encountered the following

issues during its various audit engagements for non-issuers in 2020: 1. Stanford conducted the audit of Luck, a new client, this past year. Last year, Luck was

audited by another CPA, who issued an unmodified opinion on its financial statements. Luck is presenting financial statements for 2019 and 2020 in comparative form.

2. One of Stanford’s clients is RealCo, a real estate holding company. Assume that RealCo experienced a significant decline in the value of its investment properties during the past year because of a downturn in the economy and has appropriately recognized that decline in market value under GAAP. Stanford wishes to emphasize the decline in the economy and its impact on RealCo’s financial position and results of operations for 2020 in its audit report.

3. For the past five years, Stanford has conducted the audits of TechTime, a company that provides technology consulting services, and has always issued unmodified opinions on its financial statements. Based on its 2020 audit, Stanford believes that an unmodified opinion is appropriate; however, Stanford did note that TechTime reported its third con- secutive operating loss and has experienced negative cash flows because of the inability of some of its customers to promptly pay for services received.

4. Stanford has assisted Cardinal Inc. with the preparation of its financial statements but has not audited, compiled, or reviewed those financial statements. Cardinal wishes to include these financial statements in a communication that would describe Stanford’s involvement in the preparation of the financial statements. Stanford believes that Cardi- nal’s communication is adequate and appropriately describes Stanford’s limited role in the preparation of the financial statements.

5. Trees Inc. presents summary financial information along with its financial statements. The summary financial information has been derived from the complete set of financial statements that Stanford has audited (and issued an unmodified opinion on the com- plete financial statements). A lender has engaged Stanford to evaluate and report on Trees’ summary financial information; Stanford believes that the summary financial information is fairly stated in relation to Trees’ complete financial statements.

6. Stanford believes that some of the verbiage in Plunkett’s Management Discussion & Analysis section is inconsistent with the firm’s financial statements. Stanford has concluded that Plunkett’s financial statements present its financial position, results of operations, and cash flows in accordance with GAAP and has decided to issue an unmodified opinion on Plunkett’s financial statements.

7. Oil Patch is a client in the energy industry that is required to present supplementary oil and gas reserve information. Stanford has performed certain procedures regarding this information and concluded that it is presented in accordance with FASB presentation guidelines and does not appear to depart from GAAP. Based on Stanford’s audit, it plans to issue an unmodified opinion on Oil Patch’s financial statements.

Required: How would each of these issues affect Stanford’s report on the client’s financial state- ments? (Do not draft the report that Stanford would issue in each situation).

12.56 Various Reporting Situations. For each of the following situations, indicate the type of opinion(s) that auditors could issue in the audit of a non-issuer (more than one opinion may

LO 12-2, 12-3, 12-4

LO 12-2, 12-3, 12-4

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be appropriate in each circumstance). Unless otherwise noted, assume that no departures from GAAP were identified in the audit engagement. In addition, indicate how the standard (unmodified) report would be modified, if appropriate. 1. The audit team has identified an immaterial departure from GAAP in their examina-

tion, but the entity has not adjusted its financial statements for this departure or dis- closed this departure in its financial statements or related disclosures.

2. Because they were appointed to the engagement after the date of the financial state- ments, the audit team has experienced a significant scope limitation and was unable to perform standard auditing procedures used in their engagements. The account(s) affected by this scope limitation were material and pervasive. However, the audit team has been able to completely satisfy themselves as to the fairness of the related account balances and classes of transaction by performing alternative procedures.

3. During the year, the entity changed its method of accounting for inventories from FIFO to LIFO and has disclosed this change in the footnotes to the financial statements and accounted for the change properly. However, the audit team does not agree with the rationale for the change and believes that it was made to report a higher level of earnings.

4. Subsequent to accepting the audit engagement, the audit team determined that they are not independent with respect to the client because of a financial interest in the client held by a newly admitted partner to the audit firm.

5. Evidence gathered during the audit examination and inquiry of the client’s manage- ment revealed substantial doubt about the client’s ability to continue in existence. The audit team believes that the client has appropriately disclosed the going-concern uncertainties in its financial statements and footnotes.

6. The auditors wish to emphasize the company’s acquisition of two large subsidiaries during the most recent year.

7. The auditors have engaged component auditors to conduct a portion of the audit but do not wish to assume responsibility for their work. The auditors have not approached the component auditors about presenting their reports with the company’s financial state- ments and do not plan to do so.

8. The client has not recognized a material loss related to a decline in the market value of its investments. Because the audit team believes this decline in value is not temporary, they believe the financial statements do not present the client’s financial position and results of operations in accordance with GAAP.

9. The audit team has experienced a significant scope limitation and is unable to satisfy them- selves as to the fairness of the affected account balances through alternative procedures.

12.57 Various Reporting Situations. For each of the following situations, indicate the type of report that would be required as well as how various paragraphs/sections of the auditors’ report would be modified in the audit of a non-issuer. Assume any amount in question is material on an overall basis (but not pervasive) unless otherwise noted. 1. The entity is subject to a going-concern uncertainty and has properly disclosed this

uncertainty in its financial statements. 2. The entity has changed from an accounting principle in accordance with GAAP to an

accounting principle not in accordance with GAAP. 3. The audit team encounters a material, but not pervasive, scope limitation; this limita-

tion has not been imposed by the client. 4. The entity’s financial statements are presented in accordance with GAAP. 5. The entity has changed from one accounting principle in accordance with GAAP to

another principle in accordance with GAAP; this change has been properly reported by restating prior years’ financial statements.

6. After accepting the engagement, the audit team determines that the firm is not independent. 7. The entity’s financial statements contain a material and pervasive departure from GAAP. 8. The group auditors’ opinion on group financial statements is based partially on the

report of component auditors. 9. The entity presents summary financial statements along with its full set of financial

statements. 10. The audit team was unable to observe ending inventories because of late appointment;

this represented a material and pervasive limitation on the scope of their examination. 12.58 Audit Report Deficiencies. On September 23, 2021, Betsy Ross drafted the following

report on Continental Corporation’s (a non-issuer) financial statements.

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To Whom It May Concern:

Report on the Audit of the Financial Statements

Opinion

We have audited the accompanying financial statements of Continental Corporation, which comprise the balance sheet as of July 31, 2021, and the related statements of income and changes in shareholders ’ equity for the year then ended, and the related notes to the financial statements.

In our opinion, with the e xplanation given below and with the e xception of some minor errors we consider immaterial, the financial statements referred to above present the financial position of Continental Corporation as of July 31, 2021, and the results of its operations and its cash flows for the year then ended in accordance with pronouncements of the Financial Accounting Standards Board.

Basis for Opinion

In accordance with instructions by Continental’s management, we have conducted a complete audit. Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the Audit of the Financial Statements section of our report. We are required to be independent of Continental Corporation and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements relating to our audit. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion.

Emphasis of Matter

In many respects, this was an unusual year for Continental Corporation. The weakening of the economy in the early part of the year and the strike of plant employees in the summer led to a decline in sales and net income . After making several tests of the sales records, nothing came to our attention that would indicate sales have not been properly recorded.

Responsibilities of Management for the Financial Statements

Management is responsible for the preparation and fair presentation of the financial statements in accordance with account - ing principles generally accepted in the United S tates of America, and for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstate - ment, whether due to fraud or error.

In preparing the financial statements, management is required to evaluate whether there are conditions or events, consid- ered in the aggregate, that raise substantial doubt about Continental Corporation’s ability to continue as a going concern for one year following the issuance of the financial statements.

Auditor’s Responsibilities for the Audit of the Financial Statements

Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with GAAS will always detect a material misstatement when it exists. The risk of not detect- ing a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Misstatements are considered mate- rial if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users made on the basis of these financial statements.

In performing an audit in accordance with GAAS, we:

[Standard report language on professional judgment and skepticism, risks of misstatement, internal control, accounting policies and estimates, and going concern]

We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control–related matters that we identified during the audit.

Philadelphia, PA July 31, 2021

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Required: List and explain the deficiencies and omissions in the report prepared by Ross on Conti- nental Company’s financial statements. (Assume that Ross was not engaged to communi- cate key audit matters.)

12.59 Audit Report Deficiencies: Adverse Opinion. The board of directors of Cook Indus- tries Inc. (a non-issuer) engaged Brown & Brown, CPAs, to audit the financial statements for the year ended December 31, 2020.

Required: Identify the deficiencies in the following draft of the report (assume that Brown & Brown were not engaged to communicate key audit matters). Do not rewrite the report.

(AICPA adapted)

LO 12-2

Independent Auditor’s Report

To the President of Cook Industries Inc.:

Report on the Audit of the Financial Statements

Opinion

We have audited the financial statements of Cook Industries, Inc. as of December 31, 2020 , and the related notes to the financial statements. W e conducted our audit in accordance with auditing standards generally accepted in the United States of America (GAAS). Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the A udit of the Financial S tatements section of our report. W e believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion.

In our opinion, the financial statements referred to above present fairly , in all material respects, the financial position of Cook Industries Inc. as of December 31, 2020, and the results of its operations and its cash flows for the year then ended in accordance with accounting principles generally accepted in the United States of America.

Basis for Adverse Opinion

As discussed in Note G to the financial statements, the Company carries its property and equipment at appraisal values and provides depreciation on the basis of such values. Furthermore, the Company does not provide for income taxes with respect to differences between financial income and taxable Income arising from the use, for income tax purposes, of the installment method of reporting gross profit from certain types of sales.

Auditor’s Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. R eason- able assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with GAAS will always detect a material misstatement when it exists. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forg- ery, intentional omissions, misrepresentations, or the override of internal control. Misstatements are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users made on the basis of these financial statements.

In performing an audit in accordance with GAAS, we:

[Standard report language on professional judgment and sk epticism, risks of misstatement, internal control, accounting policies and estimates, and going concern]

We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control–related matters that we identified during the audit.

Los Angeles, CA March 14, 2021

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12.60 Audit Report Deficiencies: Comparative Reporting. An assistant drafted the following auditors’ report at the completion of the audit of Cramdon Inc. (a non-issuer) on March 5, 2021. The partner in charge of the engagement has decided the opinion on the 2020 finan- cial statements should be modified only with reference to the change in the method of com- puting the cost of inventory. In 2019, Cramdon used the next-in, first-out (NIFO) method, which is not permissible under GAAP, but in 2020 changed to FIFO and restated the 2019 financial statements. The auditors’ report on the 2019 financial statements was prepared by the same firm and dated March 5, 2020.

LO 12-4

Independent Auditor’s Report

To the Board of Directors of Cramdon Inc.:

Report on the Audit of the Financial Statements

Opinion

We have audited the financial statements of Cramdon, Inc. as of December 31, 2020 and 2019, and the related notes to the financial statements.

In our opinion, based upon the following, the financial statements referred to above present fairly , in all material respects, the financial position of Cramdon Inc. as of December 31, 2020 , and the results of operations and cash flows for the year then ended in accordance with accounting principles generally accepted in the United S tates of America, consistently applied, e xcept for the changes in the method of computing inventory cost as described in Note 7 to the financial statements.

Basis for Opinion

We conducted our audits in accordance with auditing standards generally accepted in the United S tates of America (GAAS). Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the Audit of the Financial Statements section of our report. We are required to be independent of Cramdon Inc. and to meet our other ethical respon- sibilities, in accordance with the relevant ethical requirements relating to our audits. W e believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinions.

As discussed in Note 7 to the financial statements, the company changed its method of accounting for inventory cost from NIFO to FIFO. The 2019 financial statements have been restated to reflect this change in accordance with accounting prin - ciples generally accepted in the United States of America. Accordingly, our present opinion on the 2019 financial statements, as presented herein, is different from the opinion we expressed in our previous report.

Responsibilities of Management for the Financial Statements

Management is responsible for the preparation and fair presentation of the financial statements in accordance with account- ing principles generally accepted in the United S tates of America, and for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstate- ment, whether due to fraud or error.

In preparing the financial statements, management is required to evaluate whether there are conditions or events, considered in the aggregate, that raise substantial doubt about Cramdon Inc.’s ability to continue as a going concern for one year following the issuance of the financial statements.

Auditor’s Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with GAAS will always detect a material misstatement when it exists. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error , as fraud may involve collusion, forgery , intentional omissions, misrepre - sentations, or the override of internal control. Misstatements are considered material if , individually or in the aggregate , they could reasonably be expected to influence the economic decisions of users made on the basis of these financial statements.

In performing an audit in accordance with GAAS, we:

[Standard report language on professional judgment and skepticism, risks of misstatement, internal control, accounting poli- cies and estimates, and going concern]

We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control–related matters that we identified during the audit.

New York, NY March 5, 2021

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Required: Identify the deficiencies and errors in the draft report and write an explanation of the rea- sons they are errors and deficiencies (assume that the auditors were not engaged to com- municate key audit matters). Do not rewrite the report.

12.61 Audit Report Deficiencies: Audits of Group Financial Statements and Other Oper- ating Matters. Following is Rex Wolf’s report on Bonair Corporation’s (a non-issuer) financial statements. Bonair publishes general-purpose financial statements for distribu- tion to owners, creditors, potential investors, and the general public.

LO 12-2

Independent Auditor’s Report

To the Board of Directors and Shareholders of Bonair Corporation:

Report on the Audit of the Financial Statements

Opinion

We have audited the financial statements of Bonair Corporation, which comprise the balance sheet as of December 31, 2020, and the related statements of income , changes in stockholders ’ equity, and cash flows for the year then ended, and the related notes to the financial statements.

In our opinion, except for the matter of the report of the component auditors, the financial statements referred to above pres- ent fairly, in all material respects, the financial position of Bonair Corporation as of December 31, 2020 , and the results of its operations and its cash flows for the year then ended.

We did not examine the financial statements of Caet Company, a wholly owned subsidiary. Those statements were audited by Nero Stout, CPA, whose report has been furnished to us, and our opinion insofar as it relates to the amounts included for Caet Company, is based solely on the report of other auditors.

Basis for Group Financial Statement Opinion

With the exception of the matter discussed above , we conducted our audit in accordance with auditing standards generally accepted in the United S tates of America (G AAS). Our responsibilities under those standards are further described in the A udi- tor’s Responsibilities for the Audit of the Financial Statements section of our report. We are required to be independent of Bonair Corporation and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements relating to ou r audit. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion.

Other Matter

As noted Opinion section of this report, Nero Stout, CPA, audited the financial statements of Caet Company, a wholly owned subsidiary.

Responsibilities of Management for the Financial Statements

Management is responsible for the preparation and fair presentation of the financial statements in accordance with account - ing principles generally accepted in the United S tates of America, and for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstate - ment, whether due to fraud or error.

In preparing the financial statements, management is required to evaluate whether there are conditions or events, consid - ered in the aggregate, that raise substantial doubt about Bonair Corporation’s ability to continue as a going concern through December 31, 2021.

Auditor’s Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are free from material misstatement, whether due to fraud or error, and to issue an auditor’s report that includes our opinion. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with GAAS will always detect a material misstatement when it exists. The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from error, as fraud may involve collusion, forgery, intentional omissions, misrepre- sentations, or the override of internal control. Misstatements are considered material if , individually or in the aggregate , they could reasonably be expected to influence the economic decisions of users made on the basis of these financial statements.

In performing an audit in accordance with GAAS, we:

[Standard report language on professional judgment and sk epticism, risks of misstatement, internal control, accounting poli - cies and estimates, and going concern]

We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control–related matters that we identified during the audit.

Minneapolis, MN March 5, 2021

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Required: Describe the reporting deficiencies and explain why they are considered deficiencies. Orga- nize your response according to each of the paragraphs or sections in the standard (unmod- ified) report. (Assume that Wolf was not engaged to communicate key audit matters.)

12.62 Audit Report Deficiencies: Disclaimer of Opinion. Your partner drafted the following report in the audit of a non-issuer yesterday. You need to describe the reporting deficien- cies, explain the reasons for them, and discuss with the partner how the report should be corrected. You have decided to prepare a three-column worksheet showing the deficien- cies, reasons, and corrections needed. Your partner’s report follows:

LO 12-4

I made my examination in accordance with auditing standards generally accepted in the United S tates of America. However, I am not independent with respect to Mavis Corporation because my wife owns 5 percent of the company’ s outstanding common stock. The accompanying balance sheet as of December 31, 2020 , and the related statements of income , changes in shareholders’ equity, and cash flows for the year then ended were not audited by me . Accordingly, I do not e xpress an opinion on them.

Required: Prepare the three-column worksheet described.

12.63 Audit Report Deficiencies: Accounting Change and Uncertainty. The following audi- tors’ report was drafted by Quinn Moore, a staff auditor with Tyler & Tyler, CPAs, at the completion of the audit of the financial statements of Park Publishing Company (a non- issuer) for the year ended September 30, 2020. The engagement partner reviewed the audit documentation and properly decided to issue an unmodified opinion. In drafting the report, Moore considered the following: ∙ During fiscal year 2020, Park changed its depreciation method. The engagement part-

ner concurred with this change in accounting principles and its justification. ∙ The 2020 financial statements are affected by an uncertainty concerning a lawsuit,

the outcome of which cannot presently be estimated. Moore included an emphasis-of- matter paragraph in the report to disclose this uncertainty.

∙ The financial statements for the year ended September 30, 2019, are to be presented for comparative purposes. Tyler & Tyler previously audited these statements and expressed an unmodified opinion.

LO 12-3, 12-4

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Independent Auditor’s Report

To the Board of Directors of Park Publishing Company:

Report on the Audit of the Financial Statements

Opinion

We have audited the financial statements of Park Publishing Company, which comprise the balance sheet as of September 30, 2020 and 2019, and the related statements of income, changes in stockholders’ equity, and cash flows for the two years then ended, and the related notes to the financial statements.

In our opinion, e xcept for the accounting change , with which we concur , the financial statements referred to above present fairly, in all material respects, the financial position of P ark Publishing Company as of December 31, 2020 , and the results of its operations and its cash flows for the year then ended in accordance with accounting principles generally accepted in the United States of America.

As discussed in Note X to the financial statements, the company changed its method of computing depreciation in fiscal 2020.

Basis for Opinion

We conducted our audits in accordance with auditing standards generally accepted in the United States of America (GAAS). Our responsibilities under those standards are further described in the Auditor’s Responsibilities for the Audit of the Financial Statements section of our report. We are required to be independent of Park Publishing Company and to meet our other ethical responsibilities, in accordance with the relevant ethical requirements relating to our audits. W e believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for determining whether any material modifications should be made to the financial statements.

Emphasis of Matter

As discussed in Note Y to the financial statements, the company is a defendant in a lawsuit alleging infringement of certain copyrights. The company has filed a counteraction, and preliminary hearings on both actions are in progress. Accordingly, any provision for liability is subject to adjudication of this matter.

Responsibilities of Management for the Financial Statements

Management is responsible for the preparation and fair presentation of the financial statements and for the design, implemen- tation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error.

In preparing the financial statements, management is required to evaluate whether there are conditions or events, considered in the aggregate, that raise substantial doubt about Park Publishing Company’s ability to continue as a going concern for one year following the issuance of the financial statements.

Auditor’s Responsibilities for the Audit of the Financial Statements

Our objectives are to obtain reasonable assurance about whether the financial statements as a whole are fairly presented. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore is not a guarantee that an audit conducted in accordance with G AAS will always detect a material misstatement when it e xists. The risk of not detect - ing a material misstatement resulting from fraud is higher than for one resulting from error , as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of internal control. Misstatements are considered material if, individually or in the aggregate, they could reasonably be expected to influence the economic decisions of users made on the basis of these financial statements.

In performing an audit in accordance with GAAS, we:

[Standard report language on professional judgment and sk epticism, risks of misstatement, internal control, accounting poli - cies and estimates, and going concern]

We are required to communicate with those charged with governance regarding, among other matters, the planned scope and timing of the audit, significant audit findings, and certain internal control–related matters that we identified during the audit.

Tacoma, WA November 5, 2021

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Required: Identify the deficiencies in the auditors’ report as drafted by Moore (assume that Tyler & Tyler were not engaged to communicate key audit matters). Group the deficiencies by sec- tion or paragraph and in the order in which they appear. Do not rewrite the report.

(AICPA adapted)

Preparing Auditors’ Reports Cases 12.64 through 12.70 require you to draft auditors’ reports. A Word file (AUDIT REPORT NON-ISSUER) containing the standard (unmodified) report can be found in Connect. This report can be modified (as necessary) for the conditions noted in the follow- ing cases. Unless instructed otherwise, assume the following in drafting your reports: (1) your firm, Anderson, Olds, & Watershed (AOW), conducted the audit examination of the identified client; (2) the fiscal year-end is December 31, 2020; (3) the date of the auditors’ report is February 10, 2021; (4) your firm was not engaged to identify and communicate key audit matters; and, (5) the client is a non-issuer and, therefore, not subject to the audit- ing and reporting requirements of AS 2201.

12.64 Financial Difficulty: The “Going-Concern” Problem. Pitts Company has experienced significant financial difficulty. Current liabilities exceed current assets by $1 million, cash has decreased to $10,000, the interest on the long-term debt has not been paid, and a cus- tomer has brought a lawsuit against Pitts for $500,000 on a product liability claim. Signifi- cant questions concerning the going-concern status of the company exist. The lawsuit and information about the going-concern status have been appropriately described in footnote 3 to the financial statements, along with Pitts’ acknowledgment that substantial doubt exists about its ability to continue as a going concern.

Required: a. Draft AOW’s report, assuming that the audit team decides that an unmodified opinion

instead of a disclaimer of opinion is appropriate in the circumstances. b. Draft AOW’s report, assuming that the audit team decides the uncertainties are so seri-

ous that they do not wish to express an opinion on Pitts’ financial statements. 12.65 Disagreement with Auditors. Officers of Richnow Company do not wish to disclose

information about a product liability lawsuit filed by a customer seeking $500,000 in dam- ages. They believe the suit is frivolous and without merit. Outside counsel is more cautious. The audit team insists on disclosure. Angered, Richnow’s chair of the board threatens to sue AOW if a standard (unmodified) report is not issued within three days.

Required: Draft AOW’s report appropriate under the circumstances.

12.66 Late Appointment of the Audit Team. AOW has completed the audit of the financial statements of Musgrave Company for the year ended December 31, 2020, and is now pre- paring the report. AOW has audited Musgrave’s financial statements for several years, but this year Mus- grave delayed the start of the audit work, so AOW was not present to observe the taking of the physical inventory on December 31, 2020. The inventory balance is $194,000, which represents 39 percent of Musgrave’s total assets and 69 percent of its current assets. How- ever, AOW performed alternative procedures including (1) examination of shipping and receiving documents with regard to transactions since the date of the financial statements, (2) extensive review of the inventory count sheets, and (3) discussion of the physical inven- tory procedures with responsible company personnel. AOW also is satisfied about the pro- priety of the inventory valuation calculations and the consistency of the valuation method. Musgrave determines year-end inventory quantities solely by means of physical count.

Required: Draft AOW’s report on the balance sheet at the end of the current year and on the state- ments of operations, changes in shareholders’ equity, and cash flows for the year then ended. (Hint: Did the alternative procedures produce sufficient appropriate evidence?)

12.67 Audits of Group Financial Statements. AOW is the group auditor for the December 31, 2020, consolidated financial statements of Ferguson Company and subsidiaries. How- ever, component auditors perform the work on certain subsidiaries for the year under audit amounting to 29 percent of total assets and 36 percent of total revenues. AOW investigated the component auditors, as required by auditing standards, and they furnished AOW their reports. AOW has decided to rely on their work and to refer to the

LO 12-3

LO 12-4

LO 12-2

LO 12-2

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component auditors in their report. None of the audit work revealed any issues with respect to Ferguson Company or its subsidiaries.

Required: Draft AOW’s report.

12.68 Other Information in a Financial Review Section of an Annual Report. Gustav Hum- phreys (chair of the board) and Ingrid VanEns (vice president, finance) prepared the draft of the financial review section of the annual report. You are reviewing it for consistency with the audited financial statements. The draft contains the following explanation about income coverage of interest expense: Last year, operating income before interest and income taxes covered interest expense by a ratio of 6:1. This year, on an incremental basis, the coverage of interest expense increased to a ratio of 6.59:1. The relevant portion of the audited financial statements showed the following:

LO 12-3

Current Year Prior Year

Operating income $400,000 $360,000 

Extraordinary gain from realization of tax benefits    100,000 0 

Interest expense     (81,250) (60,000)

Income taxes   (127,500)  (120,000)

Net income $291,250 $180,000 

Required: a. Determine whether the financial review section statement about coverage of interest is

or is not consistent with the audited financial statements. Be able to show your conclu- sion with calculations.

b. Assume that you find an inconsistency and the officers disagree with your conclusions. Draft the appropriate language you should include in your auditors’ report.

12.69 Departures from GAAP. On January 1, Graham Company purchased land (the site of a new building) for $100,000. Soon thereafter, the state highway department announced that a new feeder road would run next to the site. The effect was a dramatic increase in local property values. Comparable land located nearby sold for $700,000 in December of the current year. Graham presents the land at $700,000 in its accounts and, after reduction for implicit taxes at 33 percent, the fixed asset total is $400,000 higher than historical cost with the same amount shown separately in the shareholder equity account Current Value Incre- ment. The valuation is fully disclosed in a footnote to the financial statements with a letter from a certified property appraiser attesting to the $700,000 value.

Required: a. Draft the appropriate auditors’ report, assuming that you believe the departure from

GAAP is material but not pervasive enough to cause you to issue an adverse opinion. b. Draft the appropriate auditors’ report, assuming that you believe an adverse opinion is

necessary. 12.70 Reporting on an Accounting Change. In December of the current year, Williams Com-

pany changed its method of accounting for inventory and cost of goods sold from LIFO to FIFO. The account balances shown in the trial balance have already been recalculated and adjusted retroactively as required by ASC 250. The accounting change and the financial effects are described in Note 2 in the financial statements.

Required: a. Assume that you believe the accounting change is justified as required by ASC 250.

Draft the report appropriate in the circumstances. b. Assume that you believe the accounting change is not justified and causes the financial

statements to be materially misstated. Inventories that would have been reported at $1.5 million (LIFO) are reported at $1.9 million (FIFO); operating income before tax that would have been $130,000 is reported at $530,000. As a result of this change, current assets, total assets, and shareholders’ equity have increased by 17 percent, 9 percent, and 14 percent, respectively. Draft the report appropriate in the circumstances.

LO 12-2

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Appendix 12A

AUDITORS’ REPORTS FOR ISSUERS (PUBLIC ENTITIES) This chapter focused on auditors’ reports for non-issuers. As noted, in addition to the opinion on the entity’s financial statements, auditors are also required to express an opin- ion on the effectiveness of the entity’s internal control over financial reporting (ICFR) for larger issuers (known as accelerated filers). This appendix summarizes auditors’ reports and the related reporting responsibility for the financial statements and ICFR of issuers.

Auditors’ Reports on Financial Statements In October 2017, the Securities and Exchange Commission approved a revised form of the PCAOB report, which is incorporated into the professional standards as Auditing Standard 3101 (AS 3101) (this version is also known as the PCAOB report). The stan- dard PCAOB report is shown in Exhibit 12A.1.19

The above report assumes that the audit team prepares two separate reports: one on the financial statements and one on ICFR (professional standards allow either two separate reports or a combined report). The above report contains three major sections:

1. Opinion on the Financial Statements. The first paragraph of this section identifies the financial statements and years examined by the audit team and expresses the audit team’s opinion on the financial statements. The second paragraph references the audit team’s opinion on the ICFR.

2. Basis for Opinion. The first paragraph of this section indicates the responsibilities of management, the responsibilities of the audit team, the fact that the firm is registered with the PCAOB and meets the independence requirements of the SEC and PCAOB. The second paragraph provides a description of the audit and the fact that the audit provides a reasonable basis for the opinion.

3. Critical Audit Matters. This section identifies any critical audit matters identified dur- ing the audit engagement (see below for additional discussion).

Although the length of the report and format varies from the report for non-issuers shown in Exhibit 12.1, you should see many similarities in the general content and mes- sage communicated by the two reports. Some noteworthy differences are

∙ In describing the standards under which the audit is conducted, the PCAOB report references “standards of the Public Company Accounting Oversight Board (United States)” (because these audits are conducted under PCAOB standards) rather than “auditing standards generally accepted in the United States of America.”

∙ The PCAOB report has a paragraph that references the auditors’ report and opinion on ICFR, which is required in the audit of larger issuers (a similar requirement does not exist for the audit of a non-issuers).

∙ The PCAOB report requires the audit team to communicate critical audit matters in the report (this requirement is effective for fiscal years ending on or after June 30, 2019, for large accelerated filers and for fiscal years ending on or after December 15, 2020, for other filers).

∙ The PCAOB report contains a statement disclosing the year in which the auditor began serving as the company’s auditor.

LO 12-5 Understand auditors’ reporting responsibility for the financial statements and internal control over financial reporting for issuers.

19 Issuers are required to present two years of comparative balance sheets and three years of comparative statements of income, changes in stockholders’ equity, and cash flows. Thus, a report on a single year (such as that shown in Exhibit 12A.1) would not be appropriate for an issuer. A single year is illustrated to allow comparisons of this report with that for non-issuers (Exhibit 12.1).

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Report of Independent Registered Public Accounting Firm

To the Board of Directors and Shareholders of Dunder-Mifflin, Inc. Opinion on the Financial Statements We have audited the accompanying balance sheet of Dunder-Mifflin Inc. as of December 31, 2020 and the related statements of income, changes in stockholders’ equity, and cash flows for the period ended December 31, 2020,  and the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of Dunder-Mifflin Inc. as of December 31, 2020, and the results of its operations and its cash flows for the period ended December 31, 2020 in conformity with accounting principles generally accepted in the United States of America. We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (“PCAOB”), Dunder-Mifflin’s internal control over financial reporting as of December 31, 2020, based on criteria established in Internal Control – Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission and our report dated January 29, 2021 expressed an unqualified opinion thereon. Basis for Opinion These financial statements are the responsibility of Dunder-Mifflin Inc.’s management. Our responsibility is to express an opinion on Dunder- Mifflin Inc.’s financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion. Critical Audit Matters The critical audit matter communicated is a matter arising from the current period audit of the financial statements that was communicated or required to be communicated to the audit committee and that: (1) relates to accounts or disclosures that are material to the financial statements and (2) involved our especially challenging, subjective, or complex judgments. The communication of critical audit matters does not alter in any way our opinion on the financial statements, taken as a whole, and we are not, by communicating the critical audit matter below, providing separate opinions on the critical audit matter or on the accounts or disclosures to which it relates.  As described in Notes 1 and 8 of the consolidated financial statements, Dunder-Mifflin’s consolidated goodwill balance was $110 million at December 31, 2020. The determination of the fair value of reporting units comprising this balance requires management to make significant estimates and assumptions that could have a significant impact on the fair value of the reporting units, the amount of any goodwill impairment charge, or both. We identified the goodwill impairment assessment as a critical audit matter. The primary procedures we performed to address this critical audit matter included: • Testing the effectiveness of controls related to management’s goodwill impairment tests. • Testing management’s process for determining the fair value of units included in the goodwill balance, including evaluating the

reasonableness of management’s forecasts of future revenues and operating margins. • Utilizing a valuation specialist to assist in testing Dunder-Mifflin’s discounted cash flow model and certain significant assumptions,

including the discount rate. • Evaluating the reasonableness of Dunder-Mifflin’s assumptions based on past performance, third party market data, and consistency with

evidence obtained in other areas of the audit.

We have served as Dunder-Mifflin’s auditor since 2007 Scranton, PA January 29, 2021 NOTE: The example in the Critical Audit Matters section was drawn from Critical Audit Matters: Lessons Learned, Questions to Consider, and an Illustrative Example, Center for Audit Quality, December 2018.

EXHIBIT 12A.1  Standard PCAOB Report for Issuer

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The inclusion of critical audit matters is particularly noteworthy; then-PCAOB Chair- man James Doty described this as “. . . the first significant change to the standard form of the auditor’s report in more than 70 years.”20 Critical audit matters (referred to as key audit matters in other jurisdictions) are those issues communicated or required to be com- municated to the audit committee that involve challenging, subjective, or complex audit team judgment relating to material accounts and disclosures. For each critical matter identified, the auditor’s report should

∙ Describe the considerations that led the audit team to identify the critical audit matter. ∙ Describe how the critical audit matter was addressed in the audit. ∙ Refer to the relevant financial statement accounts or disclosures that relate to the criti-

cal audit matter.

20“PCAOB OKs First Big Change to Audit Report in 70 Years,”CFO.com, June 1, 2017.

• Sirois et al. found that the identification of an issue as a key audit matter increased the level of attention paid to the related disclo- sures in lending judgments (credit risk scores, loan approvals, loan amounts, and interest rate premiums).

• Christensen et al. found that disclosure of critical audit matters in researcher-developed auditor’s reports influences nonprofes- sional investors’ decisions.

• An analysis of the first group of auditors’ reports subject to the crit- ical audit matters requirement identified goodwill and intangible assets (35% of all critical matters cited), revenue (19%), income taxes (15%), acquisitions and related liabilities (6%), inventory

(5%), and other liabilities (5%) as commonly cited matters. One noteworthy issuer (Microsoft) had critical audit matters related to revenue recognition and uncertain income tax provisions men- tioned in its auditors’ report issued by Deloitte.

Sources: L.P. Sirois, J. Bedard, and P. Bera, “The Informational Value of Key Audit Matters in the Auditor’s Report: Evidence from an Eye-Tracking Study,” Accounting Horizons, June 2018, pp. 141-162; B.E. Christensen, S.M. Glover, and C.J. Wolfe, “Do Critical Audit Matter Paragraphs in the Audit Report Change Nonprofessional Investors’ Decision to Invest?,” Auditing: A Journal of Practice & Theory, November 2014, pp. 71-93; “Heads Up - Critical Audit Mat- ters Make their Debut!,” Deloitte U.S. Accounting Standards and Communica- tions, August 30, 2019.

Critical/Key Audit MattersAUDITING INSIGHT

Modifications from the Standard Report As with non-issuers, circumstances may require audit teams to depart from the wording in the standard report. These situations are handled in a similar manner to those encoun- tered in the audit of non-issuers and are summarized in Exhibit 12A.2. Modified exam- ples of auditors’ reports corresponding to those presented in Chapter 12 for non-issuers can be found in the Instructor Library in Connect and are identified in a similar manner and designated with an “I” (for example, Exhibit 12.4 shows report modifications when a departure from GAAP results in a qualified opinion; the corresponding report for issu- ers is Exhibit 12.4I). Note from Exhibit 12A.2 that the section on critical audit matters is not included when either an adverse or disclaimer of opinion is issued to ensure that this section does not distract report users from the serious nature of the auditors’ opinion on the financial statements.

Comparative Financial Statements The SEC requires issuers to present two years of balance sheets and three years of state- ments of income, changes in shareholders’ equity, and cash flows; as a result, the PCAOB report shown in Exhibit 12A.1 would normally refer to all of the years presented in com- parative form in the Opinion on the Financial Statements section and refer to multiple years of audits in the Basis for Opinion section (“We conducted our audits  .  .  .; “Our audits included. . .”, etc.).

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Issue Opinion on the Financial Statements Section

Basis for Opinion Section

Critical Audit Matters Section

Departure from GAAP (Qualified or Adverse Opinions) AS 3105.22 and AS 3105.43

• Modify first paragraph to express qualified or adverse opinion and refer to separate paragraph disclosing departure(s) from GAAP

• Disclose departure(s) from GAAP in separate paragraph immediately following the first paragraph

No modifications • Consider whether reason(s) for the qualified opinion are critical audit matter(s)

• Do not include section if adverse opinion is issued

Scope Limitations (Qualified Opinion) AS 3105.09

• Modify first paragraph to express qualified opinion and refer to separate paragraph disclosing scope limitation(s)

• Disclose scope limitation(s) in separate paragraph immediately following the first paragraph

In second paragraph, refer to paragraph in Opinion on the Financial Statements section discussing scope limitation(s)

Consider whether reason(s) for the qualified opinion are critical audit matter(s)

Scope Limitations (Disclaimer of Opinion) AS 3105.47

• Modify section title to Disclaimer of Opinion on the Financial Statements

• Modify first paragraph to note that “we were engaged to audit”

• Modify first paragraph to disclaim opinion and indicate the audit team was not able to obtain sufficient appropriate evidence

• Disclose scope limitation(s) in separate paragraph immediately following the first paragraph

• Modify section title to Basis for Disclaimer of Opinion

• Delete sentence discussing audit team’s responsibility in first paragraph

• Delete second paragraph related to the conduct of the audit

Do not include section

Audit of Group Financial Statements AS 1205.09

• Modify first paragraph to refer to report of component auditor(s)

• Disclose involvement (including percentages) of component auditor(s) in separate paragraph immediately following the first paragraph of section

Modify second paragraph to refer to report of component auditor(s)

No modifications

Explanatory Language added to Unqualified Opinion21 AS 2415.13, A S 2705.03, AS 2710.04, A S 2820.13, AS 3101.19

Add a separate explanatory paragraph (including an appropriate title) immediately following this section

No modifications Consider whether reason(s) giving rise to the explanatory language are critical audit matter(s)

EXHIBIT 12A.2  Modifications to the Standard PCAOB Report

As with the reports for non-issuers discussed in Chapter 12, certain circumstances may result in report modifications. A brief summary of the modifications to the auditors’ report for issuers follows:

Issue Opinion on the Financial Statements Section Same auditors/Different opinions for comparative years

• Express opinion on all years presented in comparative form • Add separate paragraph following the first paragraph in this section to identify

issue(s) giving rise to modified opinion in any year(s) presented in comparative form

Same auditors/Modification of previously issued opinion

Add separate paragraph following the first paragraph to indicate • Previously issued opinion • Reason(s) why the previously issued opinion is no longer appropriate • The current opinion on the comparative financial statements differs from the

previously issued opinion Different auditors in comparative years/ Predecessor auditors’ report presented

• Express opinion on year(s) examined by current auditors • Predecessor auditors’ report will address year(s) examined by predecessor

auditors

Different auditors in comparative years/ Predecessor auditors’ report not presented

Add separate paragraph following the first paragraph to indicate • Financial statements of a prior period were audited by the other auditors • The date of the other auditors’ report • The type of report issued by the other auditor • If other auditors’ report is other than unqualified, the nature of the modification

21 AS 2415.12 (footnote 4) notes that a disclaimer of opinion may be issued for significant going-concern uncertainties. In these cases, report modifications would be necessary in response to the disclaimer and the Critical Audit Matters section would not be included

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Auditors’ Reports on Internal Control Over Financial Reporting (ICFR) Under PCAOB Auditing Standard 2201 (AS 2201), the audit team must plan and perform the audit to express an opinion on the effectiveness of ICFR.22 Essentially, this requires the audit team to plan and perform the audit to provide reasonable assurance about whether the entity maintained effective ICFR. In making this determination, AS 2201 identifies three levels of internal control deficiencies (from least to most significant):

1. An internal control deficiency is a situation in which the design or operation of the con- trol does not allow the entity’s management or employees to detect or prevent mis- statements in a timely fashion.

2. A significant deficiency is a deficiency or combination of deficiencies less severe than a material weakness but important enough to merit attention to those changed with governance.

3. A material weakness is a deficiency, or combination of deficiencies, that results in a reasonable possibility that a material misstatement would not be prevented or detected on a timely basis.

In evaluating the effectiveness of the entity’s ICFR, the audit team focuses on whether a material weakness in ICFR exists at the end of the year being reported on. If a material weakness exists, the entity’s ICFR cannot be considered effective.

PCAOB standards require that the audit of ICFR be integrated with the financial state- ment audit and not performed as a separate engagement. This requirement imposes addi- tional responsibilities for the audit team compared to the audit of a non-issuer. In the audit of a non-issuer, the audit team is required to obtain an understanding of internal controls to determine the nature, timing, and extent of further audit procedures to be per- formed and is only required to test controls for operating effectiveness if they plan to rely on those controls to reduce substantive tests.

In the audit of issuers, the audit team is required to evaluate and express an opinion on the effectiveness of the entity’s ICFR. The options for reporting on ICFR are

1. Issue separate reports on the financial statements (as shown in Exhibit 12A.1) and ICFR, with each of these reports referencing the other (see the second paragraph in the Opinion on the Financial Statements section in Exhibit 12A.1).

2. Issue a single report that expresses opinions on Dunder-Mifflin Inc.’s financial state- ments and ICFR. This report (sometimes referred to as an integrated report) essen- tially combines the report on Dunder-Mifflin Inc.’s financial statements (shown in Exhibit 12A.1) with a report on its ICFR.

Information on the audit reports of Fortune 500 companies (largest 500 U.S. compa- nies based on revenues) available on the Audit Analytics database indicates that 37 per- cent used an integrated report and 63 percent used two separate reports.

REVIEW CHECKPOINTS 12A.1 What are the major contents of the PCAOB report for the audit of the financial statements of

issuers? 12A.2 Define critical audit matters. What is the audit team’s responsibility for reporting critical audit

matters?

22This requirement applies only to accelerated filers (issuers with an aggregate market value of voting and non-voting common equity of $75 million or greater). Non-accelerated filers (issuers with an aggregate market value of voting and non-voting com- mon equity of less than $75 million) are required to have management reports on ICFR but not auditor engagements or reports on ICFR.

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Report of Independent Registered Public Accounting Firm To the Board of Directors and Shareholders of Dunder-Mifflin, Inc. Opinion on Internal Control over Financial Reporting We have audited Dunder-Mifflin, Inc.’s internal control over financial reporting as of December 31, 2020, based on criteria established in Internal Control-Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (2013 framework) (the COSO criteria). In our opinion, Dunder-Mifflin, Inc. maintained, in all material respects, effective internal control over financial reporting as of December 31, 2020, based on the COSO criteria. We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), the 2020 consolidated financial statements of the Company and our report dated January 29, 2021, expressed an unqualified opinion thereon. Basis for Opinion The Company’s management is responsible for maintaining effective internal control over financial reporting and for its assessment of the effectiveness of internal control over financial reporting included in the accompanying Management’s Report on Internal Control over Financial Reporting. Our responsibility is to express an opinion on the Company’s internal control over financial reporting based on our audit. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all material respects. Our audit included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness exists, testing and evaluating the design and operating effectiveness of internal control based on the assessed risk, and performing such other procedures as we considered necessary in the circumstances. We believe that our audit provides a reasonable basis for our opinion. Definition and Limitations of Internal Control over Financial Reporting A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company’s assets that could have a material effect on the financial statements. Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Scranton, PA January 29, 2021

EXHIBIT 12A.3  Report on ICFR for Issuer (Separate Report)

Exhibit 12A.3 provides an example of a report on ICFR, assuming that separate reports are prepared on the financial statements and ICFR and that no material weaknesses in ICFR were identified.

The major components of this report include the following three sections:

1. The auditors’ opinion on ICFR, along with a reference to the auditors’ opinion and report on the financial statements (Opinion on Internal Control Over Financial Reporting section)

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2. Management’s and the audit team’s responsibility for ICFR (Basis for Opinion section) 3. A definition of ICFR and the inherent limitations of ICFR (Definition and Limitation

of Internal Control Over Financial Reporting section)

A combined report on the financial statements and ICFR is structured with the follow- ing four sections:

Section Report on Financial Statements Report on ICFR

Opinions on the Financial Statements and Internal Control over Financial Reporting

Combine the content of the two reports (Exhibits 12A.1 and 12A.3)

Basis for Opinion Combine the content of the two reports (Exhibits 12A.1 and 12A.3)

Definition and Limitations of Internal Control Over Financial Reporting

Not applicable Same as separate report (Exhibit 12A.3)

Critical Audit Matters Same as separate report (Exhibit 12A.1)

Not applicable

Modifications to the Standard Report on ICFR The report in Exhibit 12A.3 is an unqualified opinion on ICFR. This type of opinion would be appropriate when no material weaknesses in internal control were identified and no significant restriction was placed on the scope of the engagement. When a mate- rial weakness in ICFR is identified, the auditors’ report would express an adverse opinion on ICFR which would include a section (normally titled Material Weakness or Material Weaknesses) that

∙ Defines a material weakness. ∙ Lists specific material weakness(es) identified during the audit as well as any mate-

rial weakness(es) identified in management’s assessment of ICFR (if the material weakness(es) are not included in management’s assessment, the auditors’ report should so indicate)

∙ Indicates that the material weakness(es) were considered in determining the nature, timing, and extent of audit tests and that the report on ICFR does not affect the opinion on the financial statements

∙ Expresses an opinion that the entity has not maintained effective ICFR

In situations where a scope limitation is encountered, the auditors’ report would express a disclaimer of opinion on ICFR. This report would include

∙ A statement that the audit team does not express an opinion on ICFR ∙ A paragraph describing the scope limitation (if the audit team has performed some

limited procedures that enable them to conclude that a material weakness exists, the report should define a material weakness and provide a description of any material weakness(es) identified)

Finally, in the audit of group financial statements, when other auditors examine the financial statements of a subsidiary or significant component of a consolidated issuer, they examine the ICFR. In these cases, the group auditor’s report on ICFR would be modified to refer to the report of the component auditors and note that the opinion on ICFR is based, in part, on the report of the component auditors. Assuming no mate- rial weaknesses are identified or scope limitation is encountered, an unqualified opinion would be issued on ICFR.

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Provisions for Non-accelerated Filers Issuers with an aggregate market value of voting and nonvoting common equity of less than $75 million are known as non-accelerated filers. Non-accelerated filers are required to have management reports on ICFR but are not required to have auditor engagements or reports on the effectiveness of ICFR. In these cases, the reports (either separate reports or integrated reports) should be modified to indicate that (1) the entity is not required to have an audit of its ICFR and (2) the auditor does not express an opinion on ICFR.

• Using the Audit Analytics database, from 2014–2018, 2.4% of Fortune 500 companies received adverse opinions on their ICFR; the average number of material weaknesses cited in these reports was 1.5 per company, with Hertz Global Holdings having the greatest number in any year (6 in 2016). Areas cited by their audi- tor (PwC) included controls related to risk assessment, non-fleet procurement processes, accounting estimates, information tech- nology systems, completeness and accuracy of system-generated reports used in accounting for estimates related to revenue earn- ing vehicles, and accounting for income taxes.

• Using this same database, companies receiving multiple adverse opinions during this period include Federal National Mortgage Association (Fannie Mae) (5 years), Federal Home L oan Mort - gage Corporation (Freddie Mac ) (5 years), Targa R esources (3 years), Hertz Global Holdings (2 years), Navistar International (2 years), and Tenneco Inc. (2 years).

• The Securities and Exchange Commission imposed a cease- and-desist order against Lifeway Foods, Inc. (an Illinois-based

dairy food producer). In their order, the SEC noted that Lifeway disclosed material weaknesses in ICFR from 2007–2016, did not complete its ICFR assessment in 2013 and 2014, and announced three financial statement restatements since 2012.

• In the 15-year history of auditor reporting on ICFR, the percent- age of adverse opinions ranged from 15.9% (in 2004) to 3.5% (in 2010), with a level of 6.0% in 2018. The five most commonly cited issues in 2018 were (1) inadequate accounting personnel and resources; (2) lack of segregation of duties; (3) ineffective audit committee; (4) inadequate disclosure controls; and, (5) material and/or numerous year-end adjustments.

Sources: Audit Analytics database, Accounting and Auditing Release No. 4016 “In the Matter of Lifeway Foods, Inc.”, Securities and Exchange Commission, January 29, 2019; SOX 404 Disclosures: A Fifteen Year Review, Audit Analytics, September 2019.

Reporting on ICFR AUDITING INSIGHT

REVIEW CHECKPOINTS 12A.3 Define internal control deficiency, significant deficiency, and material weakness. Which of these

is reported by auditors in their report on ICFR? 12A.4 What alternatives are available to auditors for reporting on the financial statements and ICFR? 12A.5 What are the major contents of the auditors’ report on ICFR (assume a separate report is pre-

pared on ICFR)? 12A.6 What situations may result in modifying the report on ICFR? What type of opinion would be

expressed in these situations?

In addition to the following, multiple-choice questions 12.28–12.47 related to the type of opinions issued and modifications to the standard opinion applicable to the auditors’ report on the financial statements of issuers can be found on Connect.

All applicable Exercises and Problems are available with Connect.

Multiple-Choice Questions for Practice and Review

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12A.7 A material weakness in ICFR is a situation in which a. It is probable that an immaterial financial statement misstatement would not be

detected on a timely basis. b. There is a remote likelihood that a material misstatement would be detected on a

timely basis. c. It is reasonably possible that a material misstatement would not be detected on a timely

basis. d. It is reasonably possible that an immaterial misstatement would not be detected on a

timely basis. 12A.8 Which report would not be appropriate for a public accounting firm to provide on the

ICFR for issuers? a. Unqualified—no material weaknesses found. b. Disclaimer of opinion—unable to perform all necessary procedures. c. Disclaimer of opinion—significant deficiencies exist. d. Adverse—material weaknesses exist.

12A.9 Which of the following statements is not true with respect to the auditors’ report on ICFR? a. The report will be dated as of the date of the financial statements. b. The report will express an opinion on the effectiveness of ICFR. c. The auditor will issue an adverse opinion if one or more material weaknesses exist. d. The report may be presented with the report on the entity’s financial statements as a

combined report. (AICPA adapted)

12A.10 Which of the following is not an element or statement included in the Basis for Opinion Section of a standard (unmodified) report on the financial statements of an issuer? a. The responsibilities of the audit team and management in the financial reporting

process. b. A broad overview of procedures performed during the audit. c. The requirement for audit teams to be independent with respect to the issuer. d. The tenure of the auditor

12A.11 If the auditors decide to present separate reports on the entity’s financial statements and ICFR in the audit of an issuer, which of the following should be modified to refer to the other report?

LO 12-5

Report on Financial Statements

Report on ICFR

a. Yes Yes

b. Yes No

c. No Yes

d. No No

12A.12 Which of the following information would be included in the Basis for Opinion section of the auditors’ report on ICFR if the report is presented separately from the auditors’ report on the entity’s financial statements of an issuer? a. The fact that the auditors conducted an audit of the entity’s financial statements. b. The definition of a material weakness in ICFR. c. Statements identifying the responsibility of the auditors and management for ICFR. d. A reference to the auditors’ report and opinion on the entity’s financial statements.

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In addition to the following, exercises and problems 12.48–12.70 applicable to the auditors’ report on the financial statements of issuers can be found on Connect.

12A.13 Internet Exercise: Reports on Financial Statements. One of the great resources for auditors is the SEC’s Electronic Data Gathering, Analysis and Retrieval (EDGAR) sys- tem database at www.sec.gov. Issuers file SEC-required documents electronically. The SEC makes this information available on its web page.

Required: The following are the largest five companies in the United States, based on the Fortune 500, along with their ticker symbols. After accessing the EDGAR database, download copies of auditors’ reports from the Form 10-K filings and complete the following table (Walmart has been done as an example). (Hint: Search the 10-K filing by using the key word “indepen- dent,” as in Report of Independent Registered Public Accounting Firm.) Use the following responses in completing the table. Report on Financial Statements: Type of Opinion (Unmodified, Qualified, Adverse, Dis- claimer) and any additional matters discussed in report Report on ICFR: Type of Opinion (Unmodified, Adverse, Disclaimer) and any additional matters discussed in report Form of Reports: Combined or Separate Auditor: Identify Name of Firm Tenure: Year in which firm began serving as auditor

LO 12-5

All applicable Exercises and Problems are available with Connect.

Exercises and Problems

Company/Date Report on Financial Statements Report on ICFR Form of Reports Auditor Tenure

Walmart (WMT) 3/28/19 Unqualified opinion; mentioned adoption of ASU No. 2016-01

Unqualified opinion; evaluation of ICFR did not include internal controls of subsidiary

Separate EY 1969

Exxon Mobil (XOM) 2/27/2019

Berkshire Hathaway (BRKA) 2/23/2019

Apple (AAPL) 11/05/2018

Amazon.com, Inc. (AMZN) 1/31/2019

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12A.14 Reports on Internal Control over Financial Reporting (Report Modifications). For each of the following situations, describe how the auditors’ report on internal control over financial reporting would be modified from the standard, unqualified report. Do not write the actual reports. a. The audit team has identified a material weakness in the processing of sales transac-

tions. This weakness has been disclosed by management in its report. b. Because a relatively short period of time has passed since a control weakness was

remediated, the audit team does not believe that sufficient evidence can be obtained with respect to the operating effectiveness of the entity’s internal control over financial reporting.

c. Component auditors have audited a significant component of the group financial statements, including internal control over financial reporting relating to that compo- nent. They did not find a material weakness in internal control, and the group auditor believes the component auditor’s work can be relied on.

d. The audit team believes that the entity’s management has not adequately disclosed a material weakness in its internal control over financial reporting.

12A.15 Reports on Internal Control over Financial Reporting (Identify Report Deficien- cies). Sorrell, CPA, is auditing the financial statements of Van Dyke as of December 31, 2020. Sorrell’s substantive procedures and other tests indicated that Van Dyke’s financial statements were prepared in accordance with generally accepted accounting principles and, accordingly, Sorrell’s report (dated February 7, 2021) expressed an unqualified opin- ion on those financial statements. Because Van Dyke’s securities are registered with the Securities and Exchange Commission, Van Dyke is subject to the reporting requirements of AS 2201. During its assessment of internal control over financial reporting, Van Dyke’s management identified material weaknesses related to (1) the method of accounting for sales commissions and (2) separation of duties related to purchase transactions. Sorrell was able to gather sufficient evidence and did not encounter limitations with respect to the evaluation of Van Dyke’s internal control over financial reporting. Sorrell prepared the following draft report on Van Dyke’s internal control over financial reporting.

Required: Identify the deficiencies in the audit report drafted by Sorrell. Group the deficiencies by paragraph and in the order in which they appear. Do not rewrite the report. Cite the relevant sections from the professional standards.

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Report of Independent Registered Public Accounting Firm

To the Board of Directors and Shareholders of Van Dyke:

Opinion on Internal Control Over Financial Reporting

We have audited the accompanying Management’s Report on Internal Control over Financial Reporting, that Van Dyke has not maintained effective internal control over financial reporting as of December 31, 2020, based on criteria established in Internal Control—Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO criteria). In our opinion, because of the effect of the material weaknesses described in the Material Weakness Section of our report on the achievement of the objectives of the control criteria, Van Dyke has not maintained, in all material respects, effective internal control over financial reporting as of December 31, 2020, based on the COSO criteria.

We have also audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States), Van Dyke’s 2020 consolidated financial statements.

Basis for Opinion

Van Dyke’s management is responsible for assessing the effectiveness of internal control over financial reporting included in the accompanying Management’s Report on Internal Control over Financial Reporting. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to Van Dyke in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the Public Company Accounting Oversight Board (United States). Those standards require that we plan and perform the audit to obtain reasonable assurance about whether effective internal control over financial reporting was maintained in all material respects. 

Our audit included obtaining an understanding of internal control over financial reporting, assessing the risk that a material weakness exists, testing and evaluating the design and operating effectiveness of internal control based on the assessed risk, and performing such other procedures as we considered necessary in the circumstances. 

Definition and Limitations of Internal Control Over Financial Reporting

A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispos itions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use, or disposition of the company’s assets that could have a material effect on the financial statements.

Material Weakness

Two material weaknesses identified and included in Management’s Report on Internal Control Over Financial Reporting were related to the design and operation of internal controls over the accounting for sales commissions and separation of duties related to purchases of inventory. Given the nature of the transactions and processes involved and the potential for a misstatement to occur as a result of the internal control deficiencies existing on December 31, 2020, we have concluded that there is more than a remote likelihood that a material misstatement in the annual or interim financial statements would not have been prevented or detected by internal controls.

These material weaknesses were considered in determining the nature, timing, and extent of audit tests applied in our audit of the 2020 financial statements.

In addition to the material weaknesses noted above, we identified several deficiencies in internal control over financial reporting that we deemed to be less significant than a material weakness. These deficiencies have been separately communicated to Van Dyke’s management.

Sorrell, CPA Seattle, WA

December 31, 2020

Apollo Shoes Auditor’s Report on the Financial Statements and Internal Controls Over Financial Reporting  You are a recently promoted senior (in charge) auditor for Anderson, Olds, and Water- shed and have been assigned to the engagement team of a new audit client, Apollo Shoes Inc. You have been asked to assist in developing the report on the financial statements and internal control over financial reporting (Apollo Shoes is an issuer and subject to PCAOB reporting standards). Detailed instructions, as well as any information that may be impact the auditor’s report, can be found in Connect.

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12.28 When reporting under GAAS, certain statements are required in all auditors’ reports (“explicit”) and others are required only under certain conditions (“implicit”). Which com- bination that follows correctly describes the auditors’ responsibilities for reporting?LO 12-1

All applicable questions are available with Connect.

Multiple-Choice Questions for Practice and Review

(a) (b) (c) (d)

1. GAAP Explicit Explicit Implicit Implicit

2. Consistency Implicit Explicit Explicit Implicit

3. Going concern Implicit Implicit Explicit Explicit

4. Opinion Explicit Explicit Implicit Implicit

12.29 How is the auditors’ responsibility for expressing the opinion on financial statements dis- closed in the standard (unmodified) report for an issuer? a. Stated explicitly in the Opinion on the Financial Statements section. b. Unstated but understood in the Opinion on the Financial Statements section. c. Stated explicitly in the Basis for Opinion section. d. Unstated but understood in the Basis for Opinion section.

12.30 Which of the following is not included in the standard (unmodified) report on the financial statements? a. An identification of the financial statements that were audited. b. A general description of an audit. c. An opinion that the financial statements present financial position in accordance with

GAAP. d. A separate (emphasis) paragraph commenting on the effect of economic conditions on

the entity. 12.31 Which of the following statements is not true with respect to the audit examinations and

reports for issuers and non-issuers? a. Audit examinations for non-issuers are based on user demand but based on legislative

requirements for issuers. b. The reports for both issuers and non-issuers express an opinion on the entity’s financial

statements. c. Auditors are required to express an opinion on internal control in the audit of non-

issuers but not in the audit of issuers. d. Management is responsible for the fairness of the financial statements for both issuers

and non-issuers. 12.32 Auditors found that the entity has not capitalized a material amount of leases in the finan-

cial statements. When considering the materiality of this departure from GAAP, the audi- tors would choose between which reporting options? a. Unmodified opinion or disclaimer of opinion. b. Unmodified opinion or qualified opinion. c. Unmodified opinion with a separate (emphasis) paragraph or an adverse opinion. d. Qualified opinion or adverse opinion.

12.33 Which of the following situations would not ordinarily require auditors to modify the Opinion on the Financial Statements Section of their report on the financial statements of an issuer? a. A material departure from GAAP. b. The use of a component auditor in the examination of group financial statements. c. A significant scope limitation. d. A change from one generally accepted accounting principle to another.

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12.34 In which of the following instances would a qualified opinion be an appropriate option?LO 12-2

Scope Limitation

Audit of Group Financial Statements

a. Yes Yes

b. No Yes

c. Yes No

d. No No

12.35 If auditors are unable to apply an auditing procedure to an account balance or class of transactions, the auditors should first a. Attempt to determine whether alternative auditing procedures are available and can be

applied. b. Withdraw from the engagement and issue a disclaimer of opinion. c. Assess the significance of the scope limitation on the overall fairness of the financial

statements. d. Notify individuals currently relying on the financial statements that the statements may

no longer be relied upon. 12.36 Which of the following sections of the standard report on the financial statements of an

issuer would be modified in response to a material departure from GAAP?

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LO 12-2

Opinion on the Financial Statements Section

Basis for Opinion Section

a. Yes Yes

b. Yes No

c. No Yes

d. No No

12.37 When component auditors are involved in the audit of group financial statements, the group auditors may issue a report that a. Refers to the component auditors, describes the extent of the component auditors’ work,

and expresses an unmodified opinion. b. Does not consider or evaluate the component auditors’ work but expresses an unmodi-

fied opinion in a standard report. c. Places primary responsibility for the reporting on the component auditors. d. Names the component auditors, describes their work, and presents only the group audi-

tors’ report. 12.38 Under which of the following conditions can a disclaimer of opinion never be issued?

a. The entity’s going-concern problems are highly material and pervasive. b. The entity does not allow the auditors access to evidence about important accounts. c. The auditors own stock in the entity. d. The auditors have determined that the entity uses the NIFO (next-in, first-out) inventory

costing method. 12.39 The auditors determined that the entity is suffering financial difficulty and its going-

concern status is seriously in doubt. Assuming that the entity adequately disclosed this matter in the financial statements, the auditors must choose between which of the following auditors’ report alternatives? a. Unmodified opinion with a reference to going-concern or disclaimer of opinion. b. Standard (unmodified) report or a disclaimer of opinion. c. Qualified opinion or adverse opinion. d. Standard (unmodified) report or adverse opinion.

LO 12-2

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12.40 Which of these situations would require auditors to append a separate (emphasis) para- graph about consistency to an otherwise unqualified opinion? a. Entity changed its estimated allowance for uncollectible accounts receivable. b. Entity corrected a prior mistake in accounting for interest capitalization. c. Entity sold one of its subsidiaries and consolidated six subsidiaries this year compared

to seven last year. d. Entity changed its inventory costing method from FIFO to LIFO.

12.41 When auditors wish to issue an unqualified opinion but highlight that the entity changed its method of accounting for software development costs, they would most appropriately identify the change in accounting method in which of the following? a. The Opinion on the Financial Statements section. b. The Basis for Opinion section. c. A separate (emphasis) paragraph. d. The Critical Audit Matters section.

12.42 Which of the following would not be addressed in a separate (emphasis) paragraph? a. Potential going-concern issues facing the client. b. Information relating to a material acquisition made during the previous year. c. The financial statement effects of a material departure from generally accepted account-

ing principles. d. Procedures performed on supplementary information required by the Financial

Accounting Standards Board. 12.43 R. Wolfe became the new auditor for Royal Corporation, succeeding C. Mason, who

audited the financial statements last year. Wolfe needs to report on Royal’s comparative financial statements and should disclose in the report an explanation about other auditors having audited the prior year a. Only if Mason’s opinion last year was qualified. b. To describe the prior audit and the opinion but not name Mason as the predecessor auditor. c. To describe the audit but not reveal the type of opinion issued by Mason. d. To describe the audit and the opinion and name Mason as the predecessor auditor.

12.44 When financial statements are presented in comparative form and another firm audited the prior years’ financial statements (but the other firm’s report is not presented with the financial statements), the auditors’ report on the current-year financial statements should a. Disclaim an opinion on the prior years’ financial statements. b. Not refer to the prior years’ financial statements. c. Refer to any procedures performed by the current auditor to verify the opinion on the

prior years’ financial statements. d. Refer to the report and type of opinion issued by the other firm on the prior years’

financial statements. 12.45 If the opinion issued on prior years’ financial statements is no longer appropriate and

financial statements are presented in comparative form, the auditors’ current report should a. Not reference the prior years’ financial statements. b. Indicate that the opinion on the prior years’ financial statements cannot be relied upon. c. Reference the type of opinion issued on the prior years’ financial statements and indi-

cate that the current opinion on these financial statements differs from that expressed in the prior years.

d. Express the revised opinion on the prior years’ financial statements without referencing the previously issued opinion.

12.46 When a predecessor auditor has examined comparative financial statements and their report is not presented with the successor auditor’s report, the successor auditor should a. Assume responsibility for the work of the predecessor auditor and report on all com-

parative years presented. b. Express an opinion on the year(s) examined by the successor auditor without referenc-

ing the comparative years examined by the predecessor auditor. c. Indicate that comparative year(s) were examined by the predecessor auditor and dis-

close the type of opinion issued.

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d. Express an opinion on the year(s) examined by the successor auditor and disclaim an opinion on the comparative year(s) examined by the predecessor auditor.

12.47 If auditors examine all years presented in comparative form, which of the following best describes their responsibility for prior years’ financial statements in their current report? a. Auditors are not required to address prior years’ financial statements in their current

report. b. Auditors should consider whether information has come to their attention that might

affect their previous opinion on the prior years’ financial statements. c. Auditors should not modify their previous on prior years’ financial statements. d. Auditors are only required to consider whether new information might affect their pre-

vious opinion on prior years’ financial statements if a report other than unmodified was issued.

LO 12-4

12.48 Basic Reports. The concepts of materiality and pervasiveness are important to auditors in examinations of financial statements and expressions of opinion on these statements.

Required: How will materiality influence auditors’ reporting decisions in the following circumstances? In your response, consider both the matter’s materiality and pervasiveness.

a. The entity prohibits confirmation of accounts receivable, and sufficient and appropriate evidence cannot be obtained using alternative procedures.

b. The entity is a gas and electric utility company that follows the practice of recognizing revenue when it is billed to customers. At the end of the year, amounts earned but not yet billed are not recorded in the accounts or reported in the financial statements.

c. The entity leases buildings for its chain of transmission repair shops under terms that qualify as capital leases under ASC 840. These leases are not capitalized as leased prop- erty assets and lease obligations.

d. The entity has lost a lawsuit in federal district court. The case is on appeal in an attempt to reduce the amount of damages awarded to the plaintiffs. No loss amount is recorded.

12.49 Departures from GAAP. For each of the following departures from GAAP, indicate the type of opinion that the auditors would issue as well as any modifications that would be made to the standard (unmodified) report in the audit of an issuer: a. A departure that had an immaterial effect on the financial statements. b. A departure that had a material effect on the financial statements (this effect was not

pervasive and affected only one account). c. A departure that had a material effect on the financial statements and was pervasive

(affected a number of accounts on both the balance sheet and income statement). 12.50 Scope Limitations. Situations in which auditors are unable to obtain sufficient appro-

priate evidence necessary to support their opinion on the entity’s financial statements are referred to as scope limitations.

Required: a. Distinguish between client-imposed scope limitations and circumstance-imposed scope

limitations. Which of these is generally of more concern to auditors? b. Why do scope limitations impact the auditors’ ability to express an opinion on the enti-

ty’s financial statements? c. Assume that a circumstance-imposed scope limitation prevented auditors from perform-

ing procedures they considered to be necessary. How would each of the following fac- tors independently influence the opinion expressed on the entity’s financial statements? 1. The account balances affected by the scope limitation are not material to the entity’s

financial position, results of operations, or cash flows.

LO 12-2

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LO 12-2

All applicable questions are available with Connect.

Exercises and Problems

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2. The account balances affected by the scope limitation are material to the entity’s financial position, results of operations, and cash flows. However, the auditors are able to perform alternative procedures that provide evidence supporting the accounts affected by the scope limitation.

3. The account balances affected by the scope limitation are material to the entity’s financial position, results of operations, and cash flows. Because of a lack of sup- porting documentation and key accounting records, auditors are unable to perform alternative procedures that provide evidence supporting the accounts affected by the scope limitation.

d. For each of the situations in part (c), briefly describe how the auditors’ report on the entity’s financial statements would be affected. (Assume the entity is an issuer and do not rewrite or draft the report that would be issued in each of these circumstances.)

12.51 Scope Limitations. Following are four possible scenarios that reflect scope limitations encountered by J. Bruce, CPA, during the audit of Weaver Inc., an issuer. In all cases, assume that the ending balance in inventory is material to Weaver’s financial position, results of operations, and cash flows.

Scenario A. Because of the late appointment to the audit engagement, Bruce is unable to observe Weaver’s physical inventory for the year ended December 31, 2020. However, Weaver maintains extensive perpetual inventory records, and Bruce has been able to per- form other substantive procedures and is satisfied as to the fairness of the ending inven- tory balance for December 31, 2020. Scenario B. Because of the late appointment to the audit engagement, Bruce is unable to observe Weaver’s physical inventory for the year ended December 31, 2020. Because Weaver’s accounting records are not complete, Bruce is unable to perform other substan- tive procedures and is not satisfied as to the fairness of the ending inventory balance for December 31, 2020. Scenario C. Because of a direct request by Weaver’s management, Bruce did not observe Weaver’s physical inventory for the year ended December 31, 2020. However, Weaver maintains extensive perpetual inventory records, and Bruce has been able to perform other substantive procedures and is satisfied as to the fairness of the ending inventory balance for December 31, 2020. Scenario D. Because of a direct request by Weaver’s management, Bruce did not observe Weaver’s physical inventory for the year ended December 31, 2020. Weaver’s accounting records are not complete, so Bruce is unable to perform other substantive procedures and is not satisfied as to the fairness of the ending inventory balance for December 31, 2020.

Required: For each of these scenarios, indicate what reporting option(s) and factors Bruce should con- sider in deciding which type of opinion to issue in the circumstances. (Do not draft Bruce’s report on Weaver Inc.’s financial statements for the year ended December 31, 2020.)

12.52 Scope Limitations. D. Brady has been engaged as the auditor of Patriot Company (an issuer) and is currently planning the year-end physical inventory counts. Patriot is a retailer that holds significant inventories in its warehouses and stores in six regions across the United States. Because of timing and logistics, Brady is able to observe the physical inventory at only one of Patriot’s warehouses, which accounts for 20 percent of Patriot’s inventories. In Brady’s professional judgment, the fact that inventories held at only one warehouse can be observed does not provide sufficient evidence with respect to Patriot’s inventory balances at the date of the financial statements. Although physical inventory counts could be delayed at the remaining warehouses for Brady to observe the counts, the flow of goods in and out of the warehouses would result in a discrepancy between the inventory quantities on hand at year-end and the inventory quantities on hand at the date of the count.

Required: a. Assume that Brady observes physical inventory at only the one warehouse and does not

perform alternative procedures related to inventories held at the other warehouses. Does this cause a scope limitation? If so, is this a client-imposed or circumstance-imposed scope limitation?

b. What type of opinion would Brady likely issue for the situation in part (a)? How would the wording in the standard (unmodified) report be modified to reflect this opinion?

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c. What alternative procedures might be available to Brady with respect to this scope limi- tation? (Hint: You may wish to refer to Chapter 9 to identify alternative procedures for inventory.)

d. Assume that Brady performs one or more of the alternative procedures in part (c) and is able to gather evidence to support the recorded balance in inventory. What type of opinion would Brady issue on Patriot’s financial statements (assuming that no other issues were identified in the audit examination)?

12.53 Audit of Group Financial Statements. Lando Corporation is an issuer domestic com- pany with two wholly owned subsidiaries. Michaels, CPA, has been engaged to audit the financial statements of the parent company and one of its subsidiaries and to serve as the group auditor. Thomas, CPA, has audited the financial statements of the other subsidiary whose operations are material in relation to the consolidated financial statements. The work performed by Michaels is sufficient for serving as the group auditor and to report as such on the financial statements. Michaels has not yet decided whether to refer to the part of the audit performed by Thomas.

Required: a. What responsibilities does Michaels have with respect to Thomas when deciding

whether to rely on the work of Thomas? b. What are the reporting requirements with which Michaels must comply in naming

Thomas and referring to the work done by Thomas? c. What report should be issued if Michaels does not wish to assume responsibility for

Thomas’s work or refer to Thomas’s work? 12.54 Various Reporting Situations. Assume that the auditors encountered the following

separate situations when deciding on the report to issue for the current-year financial state- ments for an issuer. 1. The auditors decided that sufficient appropriate evidence could not be obtained to com-

plete the audit of significant investments the entity held in a foreign entity. 2. The entity failed to capitalize lease assets and obligations but explained them fully in the

notes to the financial statements. These lease obligations meet the criteria for capitaliza- tion under ASC 840.

3. The entity is defending a lawsuit on product liability claims. (Customers allege that power saw safety guards were improperly installed.) All facts about the lawsuit are dis- closed in the notes to the financial statements, but the auditors believe the entity should record a loss based on a probable settlement mentioned by the entity’s attorneys.

4. The entity hired the auditors after taking inventory on December 31. The accounting records and other evidence are not reliable enough to enable the auditors to have suf- ficient evidence about the proper inventory amount.

5. The FASB requires the energy company to present supplementary oil and gas reserve information outside the basic financial statements. The auditors find that this infor- mation, which is not required as a part of the basic financial statements, has been omitted.

6. The auditors are group auditors of the parent company, but they reviewed the compo- nent auditors’ work and reputation, and decided not to take responsibility for the work of the component auditors on three subsidiary companies included in the consolidated financial statements. The component auditors’ work amounts to 32 percent of the con- solidated assets and 39 percent of the consolidated revenues.

7. The entity changed its depreciation method from units of production to straight line, and its auditors believe the straight-line method is the more appropriate method in the circumstances. The change, fully explained in the notes to the financial statements, has a material effect on the year-to-year comparability of the comparative financial statements.

8. Because the entity has experienced significant operating losses and has had to obtain waivers of debt payment requirements from its lenders, the auditors decide that there is substantial doubt that the entity can continue as a going concern. The entity has fully described all problems in a note in the financial statements and the auditors believe that, while material, the uncertainty is not serious enough to warrant a disclaimer of opinion.

LO 12-2

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Required: a. What kind of opinion should the auditors express in each separate case? b. What other modification(s) or addition(s) to the standard (unmodified) report is (are)

required for each separate case? 12.55 Various Reporting Situations. Assume that Stanford CPAs encountered the following

issues during its various audit engagements for issuers in 2020: 1. One of Stanford’s clients is RealCo, a real estate holding company. Assume that RealCo

experienced a significant decline in the value of its investment properties during the past year because of a downturn in the economy and has appropriately recognized that decline in market value under GAAP. Stanford wishes to emphasize the decline in the economy and its impact on RealCo’s financial position and results of operations for 2020 in its audit report.

2. For the past five years, Stanford has conducted the audits of TechTime, a company that provides technology consulting services, and has always issued unmodified opinions on its financial statements. Based on its 2020 audit, Stanford believes that an unmodified opinion is appropriate; however, Stanford did note that TechTime reported its third con- secutive operating loss and has experienced negative cash flows because of the inability of some of its customers to promptly pay for services received.

3. Stanford has assisted Cardinal Inc. with the preparation of its financial statements but has not audited, compiled, or reviewed those financial statements. Cardinal wishes to include these financial statements in a communication that would describe Stanford’s involvement in the preparation of the financial statements. Stanford believes that Cardi- nal’s communication is adequate and appropriately describes Stanford’s limited role in the preparation of the financial statements.

4. Trees Inc. presents summary financial information along with its financial statements. The summary financial information has been derived from the complete set of financial statements that Stanford has audited (and issued an unmodified opinion on the complete financial statements). A lender has engaged Stanford to evaluate and report on Trees’ summary financial information; Stanford believes that the summary financial informa- tion is fairly stated in relation to Trees’ complete financial statements.

5. Stanford believes that some of the verbiage in Plunkett’s Management Discussion & Analysis section is inconsistent with the firm’s financial statements. Stanford has con- cluded that Plunkett’s financial statements present its financial position, results of opera- tions, and cash flows in accordance with GAAP and has decided to issue an unmodified opinion on Plunkett’s financial statements.

6. Oil Patch is a client in the energy industry that is required to present supplementary oil and gas reserve information. Stanford has performed certain procedures regarding this information and concluded that it is presented in accordance with FASB presentation guidelines and does not appear to depart from GAAP. Based on Stanford’s audit, it plans to issue an unmodified opinion on Oil Patch’s financial statements.

Required: How would each of these issues affect Stanford’s report on the client’s financial state- ments? (Do not draft the report that Stanford would issue in each situation).

12.56 Various Reporting Situations. For each of the following situations, indicate the type of opinion(s) that auditors could issue in the audit of an issuer (more than one opinion may be appropriate in each circumstance). Unless otherwise noted, assume that no departures from GAAP were identified in the audit engagement. In addition, indicate how the standard (unmodified) report would be modified, if appropriate. 1. Auditors have identified an immaterial departure from GAAP in their examination, but

the entity has not adjusted its financial statements for this departure or disclosed this departure in its financial statements or related disclosures.

2. Because they were appointed to the engagement after the date of the financial state- ments, the auditors have experienced a significant scope limitation and were unable to perform standard auditing procedures used in their engagements. The account(s) affected by this scope limitation were material and pervasive. However, the auditors have been able to completely satisfy themselves as to the fairness of the related account balances and classes of transaction by performing alternative procedures.

LO 12-2, 12-3, 12-4

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3. During the year, the entity changed its method of accounting for inventories from FIFO to LIFO and has disclosed this change in the footnotes to the financial statements and accounted for the change properly. However, the auditors do not agree with the ratio- nale for the change and believe that it was made to report a higher level of earnings.

4. Subsequent to accepting the audit engagement, the auditors determined that they are not independent with respect to the client because of a financial interest in the client held by a newly admitted partner to the audit firm.

5. Evidence gathered during the audit examination and inquiry of the client’s manage- ment revealed substantial doubt about the client’s ability to continue in existence. The auditors believe that the client has appropriately disclosed the going-concern uncer- tainties in its financial statements and footnotes.

6. The auditors wish to emphasize the company’s acquisition of two large subsidiaries during the most recent year.

7. The auditors have engaged component auditors to conduct a portion of the audit but do not wish to assume responsibility for their work. The auditors have not approached the component auditors about presenting their reports with the company’s financial state- ments and do not plan to do so.

8. The client has not recognized a material loss related to a decline in the market value of its investments. Because the auditors believe this decline in value is not temporary, they believe the financial statements do not present the client’s financial position and results of operations in accordance with GAAP.

9. The auditors have experienced a significant scope limitation and are unable to sat- isfy themselves as to the fairness of the affected account balances through alternative procedures.

12.57 Various Reporting Situations. For each of the following situations, indicate the type of report that would be required as well as how various paragraphs/sections of the auditors’ report would be modified in the audit of an issuer. Assume any amount in question is mate- rial on an overall basis (but not pervasive) unless otherwise noted. 1. The entity is subject to a going-concern uncertainty and has properly disclosed this

uncertainty in its financial statements. 2. The entity has changed from an accounting principle in accordance with GAAP to an

accounting principle not in accordance with GAAP. 3. The auditors encounter a material, but not pervasive, scope limitation; this limitation

has not been imposed by the client. 4. The entity’s financial statements are presented in accordance with GAAP. 5. The entity has changed from one accounting principle in accordance with GAAP to

another principle in accordance with GAAP; this change has been properly reported by restating prior years’ financial statements.

6. After accepting the engagement, the auditors determine that they are not independent. 7. The entity’s financial statements contain a material and pervasive departure from GAAP. 8. The group auditors’ opinion on group financial statements is based partially on the

report of component auditors. 9. The entity presents summary financial statements along with its full set of financial

statements. 10. The auditors were unable to observe ending inventories because of late appointment;

this represented a material and pervasive limitation on the scope of their examination. 12.58 Audit Report Deficiencies. On September 23, 2021, Betsy Ross drafted the following

report on Continental Corporation’s (an issuer) financial statements.

Required: List and explain the deficiencies and omissions in the report prepared by Ross on Conti- nental Company’s financial statements. Assume that Betsy Ross issued a separate report on internal control over financial reporting.

LO 12-2, 12-3

LO 12-2, 12-3

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To Whom It May Concern:

Opinion on the Financial Statements

We have audited the accompanying balance sheet of Continental Corporation as of July 31, 2021, the related statements of income and changes in shareholders’ equity for the period ended July 31, 2021, and the related notes (collectively referred to as the “financial statements”). In our opinion, with the explanation given below and with the exception of some minor errors we consider immaterial, the financial statements present fairly the financial position of Continental Corporation as of July 31, 2021, and the results of its operations and its cash flows for the period ended July 31, 2021, in accordance with pronouncements of the Financial Accounting Standards Board.

Basis for Opinion

These financial statements are the responsibility of the Continental Corporation’s management. Our responsibility is to express an opinion on Continental Corporation’s financial statements based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with instructions by Continental’s management, which represented a complete audit. Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.

Economic Factors

In many respects, this was an unusual year for Continental Corporation. The weakening of the economy in the early part of the year and the strike of plant employees in the summer led to a decline in sales and net income. After making several tests of the sales records, nothing came to our attention that would indicate sales have not been properly recorded.

Critical Audit Matters

[Assume critical audit matters are appropriately documented and reported]

We have served as Continental Corporation’s auditor since 2018. Philadelphia, PA

July 31, 2021

12.59 Audit Report Deficiencies: Adverse Opinion. The board of directors of Cook Indus- tries Inc. (an issuer) engaged Brown & Brown, CPAs, to audit the financial statements for the year ended December 31, 2020.

Required: Identify the deficiencies in the following draft of the report. Assume that Brown & Brown issued a separate report on internal control over financial reporting. Do not rewrite the report.

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Report of Independent Registered Public Accounting Firm

To the President of Cook Industries Inc.:

Opinion on the Financial Statements

We have audited the accompanying financial statements of Cook Industries, Inc. as of December 31, 2020, and the related notes (collectively referred to as the “financial statements”). We conducted our audit in accordance with the standards of the Public Company Accounting Oversight Board (United States) (“PCAOB”) and believe that our audit provides a reasonable basis for our opinion.

In our opinion, the financial statements referred to above present fairly, in all material respects, the financial position of Cook Industries Inc. as of December 31, 2020, and the results of its operations and its cash flows for the period ended December 31, 2020, in accordance with accounting principles generally accepted in the United S tates of America.

We also have audited, in accordance with the standards of the PCAOB, Cook Industries’ internal control over financial reporting as of December 31, 2020, based on criteria established in Internal Control – Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission; however, because of the matter discussed in the Accounting for Property and Equipment section, we are unable to express an opinion on Cook Industries’ internal control over financial reporting.

Basis for Opinion

Our responsibility is to express an opinion on Cook Industries’ financial statements based on our audit. We are a public accounting firm registered with the PCAOB.

Our audit included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements.

Accounting for Property and Equipment

As discussed in Note G to the financial statements, Cook Industries carries its property and equipment at appraisal values and provides depreciation on the basis of such values. Furthermore, Cook Industries does not provide for income taxes with respect to differences between financial income and taxable Income arising from the use, for income tax purposes, of the installment method of reporting gross profit from certain types of sales.

Critical Audit Matters

[Assume critical audit matters are appropriately documented and reported]

We have served as Cook Industries’ auditor since 2001.

Los Angeles, CA March 14, 2021

(AICPA adapted)

12.60 Audit Report Deficiencies: Comparative Reporting. An assistant drafted the follow- ing auditors’ report at the completion of the audit of Cramdon Inc. (an issuer) on March 5, 2021. The partner in charge of the engagement has decided the opinion on the 2020 finan- cial statements should be modified only with reference to the change in the method of com- puting the cost of inventory. In 2019, Cramdon used the next-in, first-out (NIFO) method, which is not permissible under GAAP, but in 2020 changed to FIFO and restated the 2019 financial statements. The auditors’ report on the 2019 financial statements was prepared by the same firm and dated March 5, 2020.

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Required: Identify the deficiencies and errors in the draft report and write an explanation of the rea- sons they are errors and deficiencies. Assume that Costanza issued a separate report on internal control over financial reporting. Do not rewrite the report.

12.61 Audit Report Deficiencies: Audits of Group Financial Statements and Other Operat- ing Matters. Following is Rex Wolf’s report on Bonair Corporation’s (an issuer) finan- cial statements. Bonair publishes general-purpose financial statements for distribution to owners, creditors, potential investors, and the general public.

LO 12-2

Report of Independent Registered Public Accounting Firm

To the Shareholders and Board of Directors of Cramdon Inc.:

Opinion on the Financial Statements

We have audited the financial statements of Cramdon, Inc. as of December 31, 2020 and 2019, and the related notes (collectively referred to as the “financial statements”.) In our opinion, based upon the following, the financial statements present fairly, in all material respects, the financial position of Cramdon Inc. as of December 31, 2020, and the results of its operations and cash flows for the year ending December 31, 2020, in accordance with accounting principles generally accepted in the United States of America, consistently applied, except for the changes in the method of computing inventory cost as described in Note 7 to the financial statements.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (“PCAOB”), Cramdon’s internal control over financial reporting as of December 31, 2020, based on criteria established in Internal Control – Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission and our report dated March 5, 2021, e xpressed an unqualified opinion thereon.

Basis for Opinion

These financial statements are the responsibility of Cramdon’s management. Our responsibility is to express an opinion on Cramdon’s financial statements based on our audits. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

As discussed in Note 7 to the financial statements, the company changed its method of accounting for inventory cost from NIFO to FIFO. The 2019 financial statements have been restated to reflect this change in accordance with accounting principles generally accepted in the United States of America. Accordingly, our present opinion on the 2019 financial statements, as presented herein, is different from the opinion we expressed in our previous report.

Critical Audit Matters

[Assume critical audit matters are appropriately documented and reported]

We have served as Cramdon Inc.’s auditor since 1990. New York, NY

March 5, 2021

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Report of Independent Registered Public Accounting Firm

To the Board of Directors and Shareholders of Bonair Corporation:

Opinion on the Financial Statements

We have audited the accompanying balance sheet of Bonair Corporation as of December 31, 2020, the related statements of income, changes in stockholders’ equity, and cash flows for the period ended December 31, 2020, and the related notes (collectively referred to as the “financial statements”). In our opinion, except for the matter of the report of the component auditors, the financial statements present fairly, in all material respects, the financial position of Bonair Corporation as of December 31, 2020, and the results of its operations and its cash flows for the period ended December 31, 2020.

We did not examine the financial statements of Caet Company, a wholly-owned subsidiary. Those statements were audited by Nero Stout, CPA, whose report has been furnished to us, and our opinion insofar as it relates to the amounts included for Caet Company, is based solely on the report of other auditors.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (“PCAOB”), Bonair Corporation’s internal control over financial reporting as of December 31, 2020, based on criteria established in Internal Control – Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission and our report dated March 5, 2021, e xpressed an unqualified opinion thereon.

Basis for Group Financial Statement Opinion

These financial statements are the responsibility of Bonair Corporation’s management. Our responsibility is to express an opinion on Bonair Corporation’s financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to Bonair Corporation’s in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

With the exception of the matter discussed above, we conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audit provides a reasonable basis for our opinion.

Other Auditors

As noted in the Opinion on the Financial Statements section of this report, Nero Stout, CPA, audited the financial statements of Caet Company, a wholly-owned subsidiary.

Critical Audit Matters

[Assume critical audit matters are appropriately documented and reported]

We have served as Bonair Corporation’s auditor since 1955. Minneapolis, MN

March 5, 2021

Required: Describe the reporting deficiencies and explain why they are considered deficiencies. Orga- nize your response according to each of the paragraphs or sections in the standard (unmodi- fied) report. Assume that Rex Wolf issued a separate report on internal control over financial reporting.

12.62 Audit Report Deficiencies: Disclaimer of Opinion. Your partner drafted the following report in the audit of an issuer yesterday. You need to describe the reporting deficiencies, explain the reasons for them, and discuss with the partner how the report should be cor- rected. You have decided to prepare a three-column worksheet showing the deficiencies, reasons, and corrections needed. Your partner’s report follows:

LO 12-4

I made my examination in accordance with auditing standards generally accepted in the United States of America. However, I am not independent with respect to Mavis Corporation because my wife owns 5 percent of the company’s outstanding common stock. The accompanying balance sheet as of December 31, 2020, and the related statements of income , changes in shareholders’ equity, and cash flows for the year then ended were not audited by me. Accordingly, I do not express an opinion on them.

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Required: Prepare the three-column worksheet described.

12.63 Audit Report Deficiencies: Accounting Change and Uncertainty. The following audi- tors’ report was drafted by Quinn Moore, a staff auditor with Tyler & Tyler, CPAs, at the completion of the audit of the financial statements of Park Publishing Company (an issuer) for the year ended September 30, 2020. The engagement partner reviewed the audit documentation and properly decided to issue an unmodified opinion. In drafting the report, Moore considered the following:

∙ During fiscal year 2020, Park changed its depreciation method. The engagement partner concurred with this change in accounting principles and its justification.

∙ The 2020 financial statements are affected by an uncertainty concerning a lawsuit, the outcome of which cannot presently be estimated. Moore included a separate (emphasis) paragraph in the report to disclose this uncertainty.

∙ The financial statements for the year ended September 30, 2019, are to be presented for comparative purposes. Tyler & Tyler previously audited these statements and expressed an unmodified opinion.

LO 12-3, 12-4

Report of Independent Registered Public Accounting Firm

To the Shareholders and Board of Directors of Park Publishing Company:

Opinion on the Financial Statements

We have audited the accompanying balance sheets of Park Publishing Company as of September 30, 2020 and 2019, the related statements of income, changes in stockholders’ equity, and cash flows for each of the two years in the period ended September 30, 2020, and the related notes (collectively referred to as the “financial statements”). In our opinion, except for the accounting change, with which we concur, the financial statements referred to above present fairly, in all material respects, the financial position of Park Publishing Company as of September 30, 2020, and the results of its operations and its cash flows for each of the two years in the period ended September 30, 2020, in accordance with accounting principles generally accepted in the United States of America.

We also have audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (“PCAOB”), Park Publishing Company’s internal control over financial reporting as of December 31, 2020, based on criteria established in Internal Control – Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission.

As discussed in Note X to the financial statements, the company changed its method of computing depreciation in fiscal 2020.

Basis for Opinion

These financial statements are the responsibility of the Park Publishing Company’s management. We are a public accounting firm registered with the PCAOB and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are fairly presented. Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for determining whether any material modifications should be made to the financial statements.

Litigation

As discussed in Note Y to the financial statements, the company is a defendant in a lawsuit alleging infringement of certain copyrights. The company has filed a counteraction, and preliminary hearings on both actions are in progress. Accordingly, any provision for liability is subject to adjudication of this matter.

We have served as Park Publishing Company’s auditor since 2005. Tacoma, WA

November 5, 2021

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Required: Identify the deficiencies in the auditors’ report as drafted by Moore. Group the deficiencies by section or paragraph and in the order in which they appear. Assume that Tyler & Tyler issued a separate report on internal control over financial reporting. Do not rewrite the report.

(AICPA adapted)

Preparing Auditors’ Reports Cases 12.64 through 12.70 require you to draft auditors’ reports. A Word file (AUDIT REPORT ISSUER) containing the standard (unmodified) report can be found in Connect. This report can be modified (as necessary) for the conditions noted in the following cases. Unless instructed otherwise, assume the following in drafting your reports: (1) your firm, Anderson, Olds, & Watershed (AOW), conducted the audit examination of the identified cli- ent; (2) the fiscal year-end is December 31, 2020; (3) the date of the auditors’ report is Febru- ary 10, 2021; (4) your firm has served as the auditor since 2000; (5) assume all critical audit matters have been appropriately documented and disclosed; and, (6) the client is an issuer and an your firm has issued an unqualified opinion on internal control over financial reporting.

12.64 Financial Difficulty: The “Going-Concern” Problem. Pitts Company has experienced significant financial difficulty. Current liabilities exceed current assets by $1 million, cash has decreased to $10,000, the interest on the long-term debt has not been paid, and a cus- tomer has brought a lawsuit against Pitts for $500,000 on a product liability claim. Signifi- cant questions concerning the going-concern status of the company exist. The lawsuit and information about the going-concern status have been appropriately described in footnote 3 to the financial statements.

Required: a. Draft AOW’s report, assuming that the auditors decide that an unmodified opinion

instead of a disclaimer of opinion is appropriate in the circumstances. b. Draft AOW’s report, assuming that the auditors decide the uncertainties are so serious

that they do not wish to express an opinion on Pitts’ financial statements. 12.65 Disagreement with Auditors. Officers of Richnow Company do not wish to disclose

information about a product liability lawsuit filed by a customer seeking $500,000 in dam- ages. They believe the suit is frivolous and without merit. Outside counsel is more cau- tious. The auditors insist on disclosure. Angered, Richnow’s chair of the board threatens to sue AOW if a standard (unmodified) report is not issued within three days.

Required: Draft AOW’s report appropriate under the circumstances.

12.66 Late Appointment of Auditors. AOW has completed the audit of the financial state- ments of Musgrave Company for the year ended December 31, 2020, and is now preparing the report. AOW has audited Musgrave’s financial statements for several years, but this year Mus- grave delayed the start of the audit work, so AOW was not present to observe the taking of the physical inventory on December 31, 2020. The inventory balance is $194,000, which represents 39 percent of Musgrave’s total assets and 69 percent of its current assets. How- ever, AOW performed alternative procedures including (1) examination of shipping and receiving documents with regard to transactions since the date of the financial statements, (2) extensive review of the inventory count sheets, and (3) discussion of the physical inven- tory procedures with responsible company personnel. AOW also is satisfied about the pro- priety of the inventory valuation calculations and the consistency of the valuation method. Musgrave determines year-end inventory quantities solely by means of physical count.

Required: Draft AOW’s report on the balance sheet at the end of the current year and on the statements of operations, changes in shareholders’ equity, and cash flows for the year then ended. (Hint: Did the alternative procedures produce sufficient appropriate evidence?)

12.67 Audits of Group Financial Statements. AOW is the group auditor for the December 31, 2020, consolidated financial statements of Ferguson Company and subsidiaries. How- ever, component auditors perform the work on certain subsidiaries for the year under audit amounting to 29 percent of total assets and 36 percent of total revenues. AOW investigated the component auditors, as required by auditing standards, and they furnished AOW their reports. AOW has decided to rely on their work and to refer to the

LO 12-3

LO 12-4

LO 12-2

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component auditors in their report. None of the audit work revealed any issues with respect to Ferguson Company or its subsidiaries.

Required: Draft AOW’s report.

12.68 Other Information in a Financial Review Section of an Annual Report. Gustav Hum- phreys (chair of the board) and Ingrid VanEns (vice president, finance) prepared the draft of the financial review section of the annual report. You are reviewing it for consistency with the audited financial statements. The draft contains the following explanation about income coverage of interest expense: Last year, operating income before interest and income taxes covered interest expense by a ratio of 6:1. This year, on an incremental basis, the coverage of interest expense increased to a ratio of 6.59:1. The relevant portion of the audited financial statements showed the following:

LO 12-3

Current Year Prior Year Operating income $400,000 $360,000  Extraordinary gain from realization of tax benefits

   100,000 0 

Interest expense     (81,250) (60,000) Income taxes  (127,500)  (120,000) Net income $291,250 $180,000 

Required: a. Determine whether the financial review section statement about coverage of interest is

or is not consistent with the audited financial statements. Be able to show your conclu- sion with calculations.

b. Assume that you find an inconsistency and the officers disagree with your conclusions. Draft the separate (emphasis) paragraph you should include in your auditors’ report.

12.69 Departures from GAAP. On January 1, Graham Company purchased land (the site of a new building) for $100,000. Soon thereafter, the state highway department announced that a new feeder road would run next to the site. The effect was a dramatic increase in local property values. Comparable land located nearby sold for $700,000 in December of the current year. Graham presents the land at $700,000 in its accounts and, after reduction for implicit taxes at 33 percent, the fixed asset total is $400,000 higher than historical cost with the same amount shown separately in the shareholder equity account Current Value Incre- ment. The valuation is fully disclosed in a footnote to the financial statements with a letter from a certified property appraiser attesting to the $700,000 value.

Required: a. Draft the appropriate auditors’ report, assuming that you believe the departure from

GAAP is material but not pervasive enough to cause you to issue an adverse opinion. b. Draft the appropriate auditors’ report, assuming that you believe an adverse opinion is

necessary. 12.70 Reporting on an Accounting Change. In December of the current year, Williams Com-

pany changed its method of accounting for inventory and cost of goods sold from LIFO to FIFO. The account balances shown in the trial balance have already been recalculated and adjusted retroactively as required by ASC 250. The accounting change and the financial effects are described in Note 2 in the financial statements.

Required: a. Assume that you believe the accounting change is justified as required by ASC 250.

Draft the report appropriate in the circumstances. b. Assume that you believe the accounting change is not justified and causes the financial

statements to be materially misstated. Inventories that would have been reported at $1.5 million (LIFO) are reported at $1.9 million (FIFO); operating income before tax that would have been $130,000 is reported at $530,000. As a result of this change, current assets, total assets, and shareholders’ equity have increased by 17 percent, 9 percent, and 14 percent, respectively. Draft the report appropriate in the circumstances.

LO 12-2

LO 12-2, 12-3

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Warren Beatty and Faye Dunaway, actor and actress known for their roles in Bonnie and Clyde

And the Academy Award for best picture..La La Land

Other Public Accounting Services

M O D U L E A

There’s a mistake. Moonlight, you guys won best picture Jordan Horowitz, film producer known for the movie La La Land

* References are as follows: AU-C (Statements on Auditing Standards), AT-C (Statements on Standards for Attestation Engagements), AR-C (Statements on Standards for Accounting and Review Services), ISA (International Standards on Auditing), ISAE (International Standards on Assurance Engagements), ISRE (International Standards for Review Engagements), AS (Auditing Standards), and AT (PCAOB Attestation Standards).

Topic AICPA/ISA Reference PCAOB Reference

Special Audit Reporting    

Special Purpose Frameworks AU-C 800 / ISA 800 AS 3305

Elements, Accounts, or Items of Financial Statements AU-C 805 / ISA 805 AS 3305

Compliance with Contractual and Regulatory Requirements AU-C 806 AS 3305

Attestation Engagements    

Agreed-Upon Procedures Engagements AT-C 215 / ISAE 4400 AT 201

Prospective Financial Information AT-C 305 / ISAE 3400 AT 301

Compliance Attestation AT-C 315 AT 601

Controls at Service Organizations AT-C 320 / ISAE 3402 AS 2601

Accounting and Review Service Engagements    

Preparation of Financial Statements AR-C 70 N/A

Compilation Engagements AR-C 80 / ISRE 4410 N/A

Review Engagements AR-C 90 / ISRE 2400 N/A

Professional Standards References

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LEARNING OBJECTIVES Certified public accountants (CPAs) are trusted professionals with a reputation for objectivity and integrity. The reputation has its foundation in a long history of service to the business community and the general public. Individuals and businesses view their CPAs as trusted business professionals who add value to their businesses and provide valuable guidance concerning difficult business decisions. In this tradition, CPAs and other accountants offer numerous assurance and attestation services on information other than audited financial statements. These services result from consumer demand for assurance by objective experts. This module covers several areas of public accounting practice related to accountants’ association with information other than audited historical financial statements discussed in Chapter 12.

Your objectives are to be able to:

LO A-1 Explain and provide examples of attestation engagements.

LO A-2 Identify special reporting considerations involving GAAS audits

LO A-3 Identify attestation engagements other than audits and understand the content of reports on those engagements.

LO A-4 Describe review, compilation, and preparation engagements for historical financial information and prepare appropriate reports given specific factual circumstances.

LO A-5 Explain and provide examples of assurance services engagements.

INTRODUCTION For more than 80 years, PwC has worked behind the scenes at one of Hollywood’s pre- miere events (the Academy Awards) securing the ballots submitted by voters and tabu- lating the results. Other than a brief reference during the telecast, their work has largely gone unnoticed. This all changed in February 2017 when Brian Cullinan (a PwC partner) handed presenters Warren Beatty and Faye Dunaway the wrong envelope that indicated La La Land had won the Academy Award for best picture (the mistake was corrected before the telecast ended to recognize the actual winner, Moonlight).1

While tabulating the results of the Academy Awards seems to be an unusual service for accounting firms, PwC is not alone in providing this type of service. Deloitte (Country Music Awards, Heisman Trophy, Grammy Awards), Grant Thornton (Tony Awards), and EY (Emmy Awards, Golden Globe Awards) also provide services of this nature. These are just a few examples of how accounting firms have expanded their services beyond the traditional audit examination.

To this point in the text, we have focused on one type of engagement performed by CPAs (an audit of the historical financial statements and footnotes accompanying the historical financial statements). However, in practice, CPAs perform a wide range of engagements on both historical financial statements as well as other matters. Three broad types of engagements/services have emerged:

∙ Attestation engagements: Engagements in which CPAs provide assurance and report on an assertion that is the responsibility of another party (because the financial statements are an assertion of management, an audit is an example of an attestation engagement).

∙ Accounting and review engagements: Engagements less in scope than an audit that are performed by CPAs on historical financial statements.

∙ Assurance engagements: Engagements performed by CPAs that improve the quality of information for decision makers.

The following summarizes these three types of engagements. While accounting and review engagements are currently limited to historical financial information, the type of

1“The Accountant: Who is Brian Cullinan,”The Wall Street Journal, March 1, 2017, p. A13.

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information that might serve as the focus of an attestation or assurance engagement is almost unlimited and is constantly expanding. Our discussion focuses on the more com- mon types of services provided in practice.

  Attestation Engagement Accounting and Review Engagement Assurance Engagement

Levels of service • Examination • Review • Agreed-upon procedures

• Compilation • Review • Preparation

Varies

Information evaluated/ examples

• Historical financial statements/information • Financial forecasts and projections • Compliance • Controls at service organization

Historical financial statements • Sustainability reporting • WebTrust services • SysTrust services

Conclusion provided • Opinion • Limited assurance • Findings

• None • Limited assurance

• Opinion • Findings

The Auditing Insight “Assurance on Bayer’s Acquisitions” provides a recent example of the broad array of assurance services that may be provided by accountants and others.

REVIEW CHECKPOINTS A.1 Define attestation, accounting and review, and assurance engagements. Provide some examples of

information that are evaluated in each type of engagement.

INTRODUCTION TO ATTESTATION ENGAGEMENTS Although the majority of this textbook is devoted to the audit of financial statements, audit services are really a subset of a larger group of services referred to as attestation services or simply attestation engagements. An attestation is defined as an engagement

in which a practitioner is engaged to issue or does issue an examination, a review, or an agreed-upon procedures report on subject matter, or an assertion about the subject matter . . . that is the responsibility of another party. [AT-C 105.01]

While an audit conducted using generally accepted auditing standards (GAAS) focuses on historical financial statements and accompanying footnotes, the subject matter of an attest engagement may include a wide variety of information, such as

∙ Historical or prospective performance or conditions (for example, backlog data). ∙ Physical characteristics (for example, narrative descriptions, square footage of facilities). ∙ Historical events (for example, the price of a market basket of goods on a certain date).

LO A-1 Explain and provide examples of attestation engagements.

On the heels of a $63 billion acquisition of Monsanto that exposed the company to significant litigation risks related to its Roundup weedkiller product, Bayer AG has indicated that it would engage an independent (unnamed) expert to review its policies for evaluating

acquisitions, as well as specifically reviewing how it evaluated risks in the acquisition of Monsanto.

Source: “Bayer Toughens Scrutiny of Deals,” Wall Street Journal, February 28, 2020, p. B1, B2.

Assurance on Bayer’s AcquisitionsAUDITING INSIGHT

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∙ Analyses (for example, break-even analyses). ∙ Systems and processes (for example, internal control). ∙ Behavior (for example, corporate governance, compliance with laws and regulations,

and human resource practices).

A key feature of attestation engagements in the preceding definition is the role of a responsible party. The responsible party is the person at the client who is accountable for the information (e.g., the company’s controller for financial information.). The accoun- tant2 should obtain written acknowledgment or other evidence of the party’s responsibil- ity for the subject matter or the written assertion.

The preceding definition of attestation identifies three types of engagements:

∙ An examination is similar in substance to an audit, only the subject matter may be asser- tions other than the financial statements and footnotes. In these engagements, accountants evaluate internal controls and assess the risk of material misstatement, gather evidence in support of the assertions, and render opinions that represent a high level of assurance.

∙ A review provides only a limited level of assurance. The procedures performed in a review engagement are generally limited to making inquiries and performing analyti- cal procedures3.

∙ In an agreed-upon procedures engagement, a specific user (known as an engaging party) delineates exactly what procedures it wants accountants to perform. Therefore, the level of assurance provided by such an engagement varies depending on the proce- dures requested.

2Because this module discusses a wide variety of engagements, the word accountant is used to refer to practitioners performing nonaudit engagements rather than the word auditor, which has been used to this point in the text. 3An AICPA Exposure Draft (Proposed Statement on Standards for Attestation Engagements: Revisions to Statement on Standards for Attestation Engagements No. 18, Attestation Standards: Clarification and Recodification, AICPA, July 11, 2018) would change the term “review engagement” to “limited assurance engagement.” This change would only affect review engagements per- formed under attestation standards and not review engagements of unaudited financial statements performed under Statements on Standards for Accounting and Review Services (discussed in a subsequent section of this module). 4At the time this text was prepared, the professional guidance for reports illustrated in this section had not been revised to com- ply with the new format of the auditors’ report for non-issuers approved by the Auditing Standards Board in May 2019. See AICPA Exposure Draft Proposed Statement on Auditing Standards Amendments to AU-C Sections 800, 805, and 810 to Incorporate Auditor Reporting Changes from SAS No. 134, AICPA, August 28, 2019. The major differences between the standard auditors’ report and these reports are not affected by the provisions of this Exposure Draft.

REVIEW CHECKPOINTS A.2 What is attestation? Provide some examples of attestation engagements. A.3 What is a responsible party? Why is it necessary for the accountant to identify one? A.4 What are the differences among an examination, a review, and agreed-upon procedures

engagements?

ATTESTATION ENGAGEMENTS: SPECIAL AUDIT REPORTING CONSIDERATIONS

Chapter 12 provides a discussion of reports issued following an audit conducted under generally accepted auditing standards. In those cases, the auditors’ report expressed an opinion as to whether the financial statements and footnotes presented the financial condition, results of operations, and cash flows in accordance with generally accepted accounting principles (GAAP). While this is a fairly common setting for audit engage- ments, there are instances where auditors may conduct audit engagements and issue spe- cial reports4 in connection with

LO A-2 Identify special reporting considerations involving GAAS audits.

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∙ Financial statements prepared using a framework other than GAAP. ∙ Specified elements, accounts, or items of a financial statement. ∙ Compliance with contractual agreements or regulatory requirements as part of a

GAAS audit.

Special Purpose Frameworks As noted throughout this text, issuers (or public entities) are required to prepare financial statements using GAAP or another appropriate financial reporting framework (such as International Financial Reporting Standards, or IFRS). While many non-issuers will also use GAAP, smaller non-issuers often choose to report using special purpose frameworks, also known as other comprehensive bases of accounting, or OCBOA. A special purpose framework in this context refers to a coherent accounting treatment in which substantially all important financial measurements are governed by criteria other than GAAP. Some examples include statements prepared under (1) regulatory agency accounting rules, (2) tax basis accounting, (3) cash basis accounting (i.e., no accruals) or modified cash basis accounting (i.e., limited accruals such as long-term assets and liabilities or inventory), and (4) some other method required for contractual purposes.

The Private Companies Practice Section (PCPS) of the AICPA Division for Firms has promoted special purpose frameworks to its members as a way to accomplish simplified reporting. The position is that special purpose framework financial statements can be less expensive to prepare and easier to interpret than GAAP financial statements. However, PCPS also notes that special purpose frameworks are appropriate only when they meet user needs. Companies that are not subject to SEC regulations and filing requirements can choose to present financial information in accordance with special purpose frameworks.

Professional standards warn that special purpose framework financial statements should not use the titles normally associated with GAAP statements (such as balance sheet, state- ment of financial position, statement of operations, income statement, statement of com- prehensive income, and statement of cash flows). Instead, special purpose framework statements should use titles such as statement of assets and liabilities and statement of rev- enue and expenses, with a designator for the basis used (regulatory, cash, income tax, etc.).

The only difference introduced for auditors is that a basis of accounting different from GAAP is used in the preparation of the financial statements. In addition to the normal procedures performed in a GAAS audit, audits of financial statements prepared under special purpose frameworks introduce the following requirements:

∙ Obtain an understanding of (1) the purpose for which the financial statements are pre- pared, (2) the intended users, and (3) the steps taken by management to determine that the special purpose framework is acceptable in the circumstances.

∙ Obtain the agreement of management that it acknowledges and understands its respon- sibility to include all informative disclosures that are appropriate for the special pur- pose framework used to prepare the financial statements.

∙ In the case of special purpose financial statements prepared in accordance with a con- tractual basis of accounting, obtain an understanding of any significant interpretations of the contract that management made in the preparation of those financial statements and to evaluate whether the financial statements adequately describe such interpretations.

Exhibit A.1 provides an example of a report on financial statements prepared under the cash basis of accounting. Some of the key differences in this report and the report prepared for financial statements prepared under GAAP (see Chapter 12) include

∙ The names of the financial statements reflect the special purpose framework (e.g., statement of assets and liabilities arising from cash transactions) and not GAAP (bal- ance sheet).

∙ The report identifies the special purpose framework and explicitly notes manage- ment’s responsibility for determining that this framework is acceptable.

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∙ The report expresses the opinion as it relates to the special purpose framework (“in accordance with the cash basis of accounting described in Note 1”) and not GAAP.

∙ An emphasis-of-matter paragraph indicates that the financial statements are prepared using a special purpose framework other than GAAP and references disclosures that describe the framework.

Specified Elements, Accounts, or Items Either as part of the audit of the complete financial statements or a separate engage- ment, entities may have a lender or another user request an opinion on a single financial statement (e.g., balance sheet only) or an element, account, or item within the financial

EXHIBIT A.1  Report on Financial Statements Prepared Using Special Purpose Framework (Cash Basis)

Independent Auditor’s Report To the Board of Directors and Shareholders

Dunder-Mifflin, Inc.

Report on the Financial Statements We have audited the accompanying financial statements of Dunder-Mifflin, Inc., which comprise the statement of assets and liabilities arising from cash transactions as of December 31, 2020, and the related statement of revenue collected and expenses paid for the year then ended, and the related notes to the financial statements.

Management’s Responsibility for the Financial Statements Management is responsible for the preparation and fair presentation of these financial statements in accordance with the cash basis of accounting described in Note 1; this includes determining that the cash basis of accounting is an acceptable basis for the preparation of the financial statements in the circumstances. Management is also responsible for the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error.

Auditor’s Responsibility Our responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit in accordance with auditing standards generally accepted in the United States of America. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free from material misstatement.

An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the partnership’s preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the partnership’s internal control. Accordingly, we express no such opinion. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluating the overall presentation of the financial statements.

We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinion.

Opinion In our opinion, the financial statements referred to above present fairly, in all material respects, the assets and liabilities arising from cash transactions of Dunder-Mifflin, Inc., as of December 31, 2020, and its revenue collected and expenses paid during the year then ended in accordance with the cash basis of accounting described in Note 1.

Basis of Accounting We draw attention to Note 1 of the financial statements, which describes the basis of accounting. The financial statements are prepared on the cash basis of accounting, which is a basis of accounting other than accounting principles generally accepted in the United States of America. Our opinion is not modified with respect to this matter.

Michael Scarn, LLP Scranton, PA

January 29, 2021

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statements. The only issue introduced in these situations is that both the scope of the engagement and the auditors’ conclusion are limited to the specific element, account, or item within the financial statements. In cases where a complete audit of the financial state- ments is not undertaken, AU 805 notes that auditors should determine whether engage- ments on elements, accounts, or items within the financial statements are practicable.

The auditors’ report on a single statement or elements, accounts, or items is very similar to the auditors’ standard (unmodified) report on the complete set of financial statements. The introductory paragraph, Management’s Responsibility for the Financial Statements section, Auditor’s Responsibility section, and opinion paragraph will be lim- ited to the specific element, account, or item examined (e.g., the accompanying sched- ule of accounts receivable). However, it is important to note that an opinion can still be expressed with respect to the fairness of the element, account, or item.

If the report is issued in conjunction with an audit of the complete set of financial statements and an adverse opinion or disclaimer of opinion is issued for the financial statements taken as a whole, the auditors may separately report only on an element, account, or item in the financial statements if that report is not published with the report containing the adverse or disclaimer of opinion, and the element is not a major por- tion of the financial statements and is not related to stockholders’ equity or net income. Auditors cannot express an unmodified opinion on a single financial statement if they expressed a disclaimer or adverse opinion on the complete set of financial statements. This is intended to ensure that the positive opinion on the element, account, or item does not distract from the adverse opinion or disclaimer of opinion on the financial statements.

Compliance with Contractual Agreements or Regulatory Requirements Management often must report its compliance with contractual obligations to third par- ties. For example, entities may have restrictive covenants in loan agreements, and lenders may require a periodic report on whether the entity has complied with these covenants. Contractual agreements could include dividend limitations, loan limitations, mandatory debt-to-equity ratios, or limitations on geographic operations. In addition, companies and governmental agencies must comply with applicable laws and regulations.

Companies subject to these reporting requirements may request auditors to report on compliance based on the procedures performed during the GAAS audit of their financial statements. It is important to note that the audit team does not perform procedures specif- ically designed to evaluate compliance, but is considering whether evidence they gather during the financial statement audit indicates instances of noncompliance. The AICPA refers to these reports on compliance as by-product reports, as evaluating and reporting on compliance were not the primary objective of the audit.

In these cases, the audit team can either issue a separate report on compliance or a combined report that expresses an opinion on the financial statements as well as compli- ance with contractual agreements or regulatory requirements. These reports should

∙ Indicate that a GAAS audit has been conducted. ∙ Assuming that no instances of noncompliance have been identified, indicate that the

audit team is unaware of any instances of noncompliance (any instances of noncompli- ance should be identified in the report). (Shown as an other-matter paragraph follow- ing the opinion on the financial statements in a combined report.)

∙ Indicate that the audit was not directed toward identifying noncompliance and addi- tional procedures might have revealed instances of noncompliance.

∙ Indicate that the communication on compliance is intended solely for the use of cer- tain parties (ordinarily, the management, board of directors, and a third party). (In a combined report, this would be shown in a Restricted Use Relating to the Other Matter section following the other matter paragraph).

An example of a separate report on compliance with contractual terms of an indenture is shown in Exhibit A.2.

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In other instances, entities may engage accountants to specifically report on compliance; this is a separate type of attestation engagement and is discussed in the following section.

REVIEW CHECKPOINTS A.5 What is a special purpose framework? Provide some examples of special purpose frameworks. A.6 What is an advantage of preparing financial statements using a special purpose framework? A.7 What are the major modifications to the auditors’ report when a non-issuer uses a special purpose

framework to prepare its financial statements? A.8 What are the major modifications to the auditors’ report when an opinion is expressed on a speci-

fied element, account, or item within the financial statements? A.9 What are the reporting options when an auditor examines compliance with contractual agree-

ments or regulatory requirements in conjunction with a GAAS audit? A.10 What information related to compliance with contractual agreements or regulatory requirements is

communicated in the auditors’ report on compliance conducted in conjunction with a GAAS audit?

EXHIBIT A.2  Report on Compliance with Contractual Agreements

Independent Auditor’s Report To the Board of Directors and Shareholders

Dunder-Mifflin, Inc.

We have audited, in accordance with auditing standards generally accepted in the United States of America, the financial statements of Dunder-Mifflin, Inc., which comprise the balance sheet as of December 31, 2020, and the related statements of income, changes in stockholders’ equity, and cash flows for the year then ended, and the related notes to the financial statements, and have issued our report thereon dated January 29, 2021.

In connection with our audit, nothing came to our attention that caused us to believe that Dunder-Mifflin, Inc. failed to comply with the terms of the Indenture dated July 21, 2030, with ABC Bank insofar as they relate to accounting matters. However, our audit was not directed primarily toward obtaining knowledge of such noncompliance. Accordingly, had we performed additional procedures, other matters may have come to our attention regarding the Company’s noncompliance with the above-referenced terms, covenants, provisions, or conditions of the Indenture, insofar as they relate to accounting matters.

This report is intended solely for the information and use of the board of directors and management of Dunder-Mifflin, Inc. and ABC Bank and is not intended to be and should not be used by anyone other than these specified parties.

Michael Scarn, LLP Scranton, PA

January 29, 2021

OTHER ATTESTATION ENGAGEMENTS As noted previously, audits (and examination engagements) are only one example of an attestation engagement that may be performed by an accountant. In addition to examina- tions, accountants may perform engagements of a lesser scope that provide lower levels of assurance than an examination. Two other broad types of attestation engagements are review engagements and agreed-upon procedures engagements. This section discusses some of the more common attestation engagements performed in practice.

Applying Agreed-Upon Procedures Specified parties (including clients or third party users) sometimes engage accountants to perform specified procedures, known as agreed-upon procedures. For example, restau- rant managers may ask their accountants to classify and summarize customer comment

LO A-3 Identify attestation engagements other than audits and understand the content of reports on those engagements.

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cards, or a music composer might ask an accountant to verify the mathematics on a roy- alty report. Such engagements should not be considered audits because the specified sets of agreed-upon procedures are usually not sufficient to be considered as a GAAS audit. Agreed-upon procedures engagements have a limited scope, so the performance prin- ciples (assessing the risk of material misstatement and obtaining sufficient appropriate evidence for an opinion) and the reporting principle do not apply.

When performing agreed-upon procedures engagements, accountants must reach a clear understanding with the client and the report users about the users’ needs and the procedures to be performed. For these types of engagements, clearly worded engage- ment letters specifically delineating the desired procedures to be performed are of utmost importance. Reports are to be restricted to the specified users who participate in and take responsibility for defining the scope of the engagement (referred to as specified parties)5.

A report on an agreed-upon procedures engagement is quite different from the stan- dard audit report, with the following major differences:

∙ The report identifies the specified parties and describes the specific procedures per- formed by the accountant.

∙ The report specifically notes that an examination was not performed by the accountant and disclaims an opinion.

∙ The report provides a summary of findings as a result of performing the agreed-upon procedures.

Prospective Financial Information Prospective financial information is financial information representing the financial position, results of operations, and cash flows for some period of time in the future. A financial forecast is prospective financial information based on expected conditions and courses of action. A financial projection is prospective financial information based on the occurrence of one or more hypothetical events that change the entity’s existing business structure (e.g., possible addition of a new distribution center, potential new product line).

In many cases, the entity is negotiating directly with a single user (limited use) that has requested prospective financial information for use in making economic decisions

5 An AICPA Exposure Draft (Proposed Statement on Standards for Attestation Engagements: Revisions to Statement on Standards for Attestation Engagements No. 18, Attestation Standards: Clarification and Recodification, AICPA, July 11, 2018) would revise guidance for agreed-upon procedures engagements by (1) no longer requiring parties involved in the engagement to take responsibility for the procedures performed and (2) allowing the reports to be issued for general use, in certain circumstances. “Proposed Statement on Standards for Attestation Engagements: Revisions to Statement on Standards for Attestation Engage- ments No. 18, Attestation Standards: Clarification and Recodification” should be in italics)

As part of its financial reporting system, the National Collegiate Athletics Association (NCAA) requires member institutions to sub- mit  financial information which has been subjected to an agreed- upon  procedures engagement performed by an independent accountant. In its 2019 reporting guidelines, the NCAA identifies the following:

• A minimum of 28 specific agreed-upon procedures for all revenue items comprising at least 4 percent of total revenues (for example, comparing tickets sold to the related revenues and attendance and recalculating totals).

• A minimum of 38 specific agreed-upon procedures for all expense items comprising at least 4 percent of total expenses (for exam- ple, selecting a sample of coaches’ contracts and comparing and agreeing the terms to salaries, benefits, and bonuses recorded during the period).

• A minimum of 8 specific agreed-upon procedures for other items (for example, agreeing the total fair market value of institutional endowments to supporting documentation).

Source: 2019 NCAA Agreed-Upon Procedures (http://www.ncaa.org/about/ resources/finances/ncaa-membership-financial-reporting-system)

Agreed-Upon Procedures and the NCAAAUDITING INSIGHT

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(e.g., for a bank loan). Both financial projections and financial forecasts can be used for limited purposes because users directly requested the information and are aware of the nature of this information. In other instances, the entity may be preparing financial state- ments that it intends to present to a large number of users (general use), none of whom it is negotiating with at the current time. Only financial forecasts can be provided for gen- eral use because the users may not be familiar with the hypothetical event(s) underlying a financial projection.

Prospective financial statements take the form of a complete set of financial state- ments or are limited to certain minimum items, which include the following:

∙ Specific income statement components (sales or gross revenues, gross profit or cost of sales, unusual or infrequently occurring items, provision for income taxes, discontin- ued operations, income from continuing operations, net income and basic and diluted earnings per share).

∙ Significant changes in financial position. ∙ A description of the nature of the prospective financial statements, a statement that

the assumptions are based on the responsible party’s judgment, and a caveat that the expected results might not be achieved.

∙ Summary of significant assumptions. ∙ Summary of significant accounting policies.

A presentation of prospective financial information that omits any of the above items is known as a partial presentation; partial presentations are only appropriate for specific users with whom the entity is negotiating (limited use).

Exhibit A.3 illustrates an accountants’ report on an examination of a financial fore- cast that will be used by Allied National Bank in considering extending a line of credit.

EXHIBIT A.3  Accountants’ Report on Examination of Financial Forecast

Independent Auditor’s Report To Allied National Bank

We have examined the accompanying forecast of Dunder-Mifflin, Inc. which comprises the forecasted balance sheet as of December 31, 2020 and the related forecasted statements of income, changes in shareholders’ equity, and cash flows for the year then ending, based on the guidelines for the presentation of a forecast established by the American Institute of Certified Public Accountants. Dunder-Mifflin’s management is responsible for preparing and presenting the forecast in accordance with the guidelines for the presentation of a forecast established by the American Institute of Certified Public Accountants. Our responsibility is to express an opinion on the forecast based on our examination.

Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. Those standards require that we plan and perform the examination to obtain reasonable assurance about whether the forecast is presented in accordance with the guidelines for the presentation of a forecast established by the American Institute of Certified Public Accountants, in all material respects. An examination involves performing procedures to obtain evidence about the forecast. The nature, timing, and extent of the procedures selected depend on our judgment, including an assessment of the risks of material misstatement of the forecast, whether due to fraud or error. We believe that the evidence we obtained is sufficient and appropriate to provide a reasonable basis for our opinion.

In our opinion, the accompanying forecast is presented, in all material respects, in accordance with the guidelines for the presentation of a forecast established by the American Institute of Certified Public Accountants, and the underlying assumptions are suitably supported and provide a reasonable basis for management’s forecast.

There will usually be differences between the forecasted and actual results because events and circumstances frequently do not occur as expected, and those differences may be material. We have no responsibility to update this report for events and circumstances occurring after the date of this report.

Michael Scarn, LLP Scranton, PA May 1, 2021

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REVIEW CHECKPOINTS A.11 What role does a specified party play in an agreed-upon procedures engagement? A.12 What are the general contents of an accountants’ report on an agreed-upon procedures engagement? A.13 Distinguish between financial forecasts and financial projections. Which of these presentations of

prospective financial information is appropriate for general use? A.14 What are the basic contents of the accountants’ report on an examination of a financial forecast?

What additional information is provided in the report of an examination of a financial projection? A.15 What levels of assurance are provided in agreed-upon procedures and examination engagements

on prospective financial information?

Note the following differences in this report compared to that for an audit on historical financial statements:

∙ Guidelines for the presentation of a forecast established by the AICPA are identified as the appropriate criteria (rather than GAAP).

∙ Attestation standards are referenced as the basis for the examination, rather than GAAS. ∙ An opinion is expressed on both the forecast information and the reasonableness of the

assumptions as a basis for the forecast. ∙ The report acknowledges that differences may occur between actual and forecasted results.

For examinations of financial projections, the accountants’ report will also identify the hypothetical assumption(s) upon which the projection is based and note that the report is not intended to be used by those other than the specified parties.

In addition to examination engagements, accountants may perform agreed-upon pro- cedures engagements on prospective financial information. These engagements are lesser in scope than an examination and the reports will be modified to describe the nature of the engagement as well as the level of assurance provided by the accountant.

Exhibit A.4 provides a summary of engagements related to prospective financial information.

The results of an academic study indicate significant differences in beliefs among accountants, users, and preparers of prospective financial information concerning forecast reliability and the role and responsibilities of accountants and management. Contrary to the usual published studies on the expectation gap between accountants and the public, researchers found that accountants believe that forecasts

are more reliable than users or preparers do. Accountants also believe that they have a higher level of responsibility and accountability than is attributed to them by users or preparers.

Source: P. Schelluch and G. Gay, “Assurance Provided by Auditors’ Reports on Prospective Financial Information: Implications for the Expectation Gap,” Accounting and Finance, 46 (December 2006), p. 653.

Attestation Expectation Gap?AUDITING INSIGHT

EXHIBIT A.4  Comparison of Engagements on Prospective Financial Information

  Agreed-Upon Procedures Examination

Level of assurance List of findings Opinion on financial information and assumptions

Distribution of report Limited use (to specified parties) • General use (forecast) • Limited use (projection)

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Compliance Attestation In a previous section of this module, we discussed auditor reporting on compliance in conjunction with the audit of the entity’s financial statements. In other cases, manage- ment of entities not subject to the requirements of an audit examination must report its compliance with contractual obligations to third parties. In such cases, accountants may be engaged to report on (1) the entity’s compliance with laws, regulations, rules, con- tracts, or grants; or (2) the effectiveness of an entity’s internal controls that ensure com- pliance with these requirements.

To conduct an engagement related to compliance, three conditions must be met:

1. Management must accept responsibility for compliance. 2. Compliance or the controls over compliance are capable of evaluation and measure-

ment against reasonable criteria. 3. Sufficient evidence must be available to support management’s evaluation.

Two levels of accountant services related to compliance are examination engagements and agreed-upon procedures engagements. The major steps in an examination engage- ment related to compliance are

∙ Understand the specific compliance requirements and assess planning materiality. ∙ Plan the engagement and assess inherent risk. ∙ Understand relevant controls over compliance, assess control risk, and design tests of

compliance giving consideration to detection risk. ∙ Obtain sufficient evidence related to compliance, including written representations

from management. ∙ Consider subsequent information that bears on the management assertion and subse-

quent events of noncompliance after the assertion date.

The standard unmodified report in a compliance examination engagement (Exhibit A.5) expresses the accountants’ opinion as to compliance.

Other considerations that may affect the accountants’ report on compliance include the following:

EXHIBIT A.5  Standard Unmodified Compliance Attestation Report

Independent Accountant’s Report To the Agency

We have examined the Agency’s compliance with Department of Employment Regulation JR-52 during the year ended December 31, 2020. Management is responsible for the Agency’s compliance with the specified requirements. Our responsibility is to express an opinion on the Agency’s compliance with the specified requirements based on our examination.

Our examination was conducted in accordance with attestation standards established by the American Institute of Certified Public Accountants. Those standards require that we plan and perform the examination to obtain reasonable assurance about whether the Agency complied, in all material respects, with the specified requirements referenced above. An examination involves performing procedures to obtain evidence about whether the Agency complied with the specified requirements. The nature, timing, and extent of the procedures selected depend on our judgment, including an assessment of the risks of material noncompliance, whether due to fraud or error. We believe that the evidence we obtained is sufficient and appropriate to provide a reasonable basis for our opinion.

Our examination does not provide a legal determination on the Agency’s compliance with specified requirements.

In our opinion, the Agency complied, in all material respects, with Department of Employment Regulation JR-52 for the year ended December 31, 2020.

Michael Scarn, LLP Scranton, PA

February 15, 2021

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∙ The above report assumes that the Agency complied with Department of Employment Regulation JR-52. If the entity is not in full compliance, the report may be modified to (1) disclose a noncompliance event (while still expressing an unqualified opinion), (2) express a qualified opinion for material noncompliance, or (3) express an adverse opinion indicating that the entity is not in compliance.

∙ In many cases, management will make an assertion about compliance in a written communication (for example, “the Agency is in full compliance with the Department of Employment Regulation JR-52.”) In those cases, the report would be modified to indicate that management’s assertion related to compliance is being examined and the accountant will express an opinion on management’s assertion related to compliance.

∙ If an agreed-upon procedures engagement is performed, the report will identify the specific procedures performed and the findings related to those procedures. In addi- tion, because an examination was not performed, the report will disclaim an opinion on compliance.

Broker–Dealer Compliance In 2010, in response to several high-profile broker–dealer collapses, including Madoff Investment Securities, the Dodd–Frank Wall Street Reform and Consumer Protection Act gave the PCAOB the authority to oversee audits of broker–dealers. The SEC responded in 2011 with Rule 17a-5, which outlines reporting, audit, and notification requirements for broker–dealers. Among other requirements, this rule requires a broker’s or dealer’s compliance report to include the following assertions:

∙ Internal control over compliance was effective during the most recent fiscal year. ∙ Internal control over compliance was effective at the end of the most recent fiscal year. ∙ The broker–dealer was in compliance with rules relating to net capital requirements

and reserve requirements at the end of the most recent fiscal year. ∙ The information used to assess compliance with the net capital requirements and

reserve requirements rules was derived from the broker–dealer’s records.

The PCAOB established AT 1 to guide accountant performing examination engage- ments related to the above assertions. Similar to audit engagements, accountants must (1) test both the design and operating effectiveness of the entity’s internal control over com- pliance, (2) perform sufficient procedures to support the broker-dealer’s compliance with the net capital rule and reserve requirement rule, (3) obtain a management representation letter, and (4) express an opinion on the broker-dealer’s assertions.

Rule 17a-5 identifies certain provisions that exempt broker–dealers from the SEC’s compliance reporting requirements (for example, if broker–dealers trade on their own behalf and do not hold customer funds). In such cases, broker–dealers must file an exemp- tion report containing the following statements/information:

∙ Provisions under which the broker–dealer claimed an exemption. ∙ Statement that these provisions were met during the most recent fiscal year or identi-

fies exceptions from these provisions during the most recent fiscal year. ∙ If exceptions existed, identification of the exceptions, the nature of the exceptions, and

the date(s) on which the exceptions existed.

The exemption report is subject to a review engagement under AT 2. The SEC con- cluded that because safeguarding customer assets is so important, some degree of assur- ance is required. The review standard requires auditors to obtain moderate assurance whether conditions exist that would indicate that the broker–dealer should not have claimed an exemption. Procedures performed during a review include identifying the exemption provisions claimed by the broker–dealer, performing various inquiries, read- ing internal compliance reports, and reading regulatory filings relevant to the exemption provisions.

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Service Organizations Often, a service organization processes clients’ transactions that are likely to be relevant to the client’s internal control over financial reporting. Examples of service organiza- tions include payroll processing companies, computerized information processing ser- vice centers, trust departments of banks, insurers that maintain the accounting records for reinsurance transactions, mortgage bankers and savings and loan associations that service loans for owners, and transfer agents that handle the shareholder accounting for mutual and money market investment funds. The fact that management is outsourcing some of its noncore functions does not absolve management of its responsibility for internal con- trol over those functions. Management (as well as the audit team) of user entities must gain assurance that appropriate controls have been placed in operation and are operating effectively.

The solution to this dilemma is a special purpose report on internal control (formerly referred to as an SSAE 16 / SAS 70 report) in which the service organization’s auditors (service auditors) report on the effectiveness of the service organization’s internal control to the user entities (and their auditors, known as user entity auditors). The relationship among these parties is shown in the following diagram:

If, as part of a GAAS audit, user entity auditors require assurance on the operating effectiveness of controls in place at a service organization, management of the service organization is required to provide the user entity auditor with a written assertion with respect to

∙ The fairness of the presentation of the description of the service organization’s system. ∙ The suitability of the design of controls to achieve the related control objectives. ∙ The operating effectiveness of the controls.

User Entity

Conduct GAAS Audit

Provide report expressing opinion on controls at Service Organization

Evaluate controls at Service

Organization

Provide services involving internal control

Service Organization

Service Auditor

User Entity Auditor

Since its inception through December 31, 2018, the PCAOB has settled 265 disciplinary orders with accountants or firms; of these, 42 were related to engagements and reporting for broker–dealers. The issues cited in these sanctions are as follows (totals exceed 42 because some sanctions had more than one violation):

• Independence (35) • Engagement quality review (9)

• Sufficient evidence (4) • Internal control (3) • Documentation (3) Source: https://pcaobus.org/Enforcement/Decisions/Pages/default.aspx

Broker–Dealer Compliance and PCAOB Sanctions

AUDITING INSIGHT

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The service auditors will provide a report to the user entity and user entity auditors that includes the following major components. This report is known as a Service Organi- zation Control (SOC) 1 “Type 2” report and includes

∙ A description of the service organization’s assertions regarding internal controls. ∙ The service auditors’ responsibility to express an opinion on the fairness of the presen-

tation of the description of internal control, suitability of the design of controls, and operating effectiveness of the controls.

∙ A summary of the tests of operating effectiveness of the controls (tests of controls) performed by the service auditor.

∙ The service auditors’ opinion on the fairness of the presentation of the description of internal control, the suitability of design of controls, and operating effectiveness of the controls.

∙ A restriction on the use of the report to the service organization, user entities of the service organization, and user entity auditors.

Note that the above report provides the service auditors’ opinion on both the design of the controls and the operating effectiveness of the controls. Because user entity auditors are required to report on both the financial statements and internal control over financial reporting in the audits of issuers, a Type 2 report would be requested from service audi- tors in the audit of issuers.

Recall that, in a GAAS audit of a non-issuer, if the audit team chooses not to rely on internal control over financial reporting, they are not required to conduct tests of the operating effectiveness of controls but are required to obtain an understanding of the design of controls. A “Type 1” report addresses the description of the service organiza- tion’s system and design of the controls, but does not address the operating effectiveness of the controls. Essentially, the report is similar to that for a Type 2 report, with the exception that it specifically indicates that the service auditor did not perform any proce- dures regarding the operating effectiveness of controls and does not express an opinion on operating effectiveness.

As shown in the following Auditing Insight “SOC Reports and User Controls,” the work of service auditors is often dependent upon controls implemented at both the user organization and service organization.

While not of sufficient scope to satisfy the requirements of audit engagements, other types of SOC reports (referred to as SOC 2 and SOC 3 reports) are related to Trust Ser- vice Engagements and are discussed in a later section of this module.

The following deficiency from a PCAOB inspection report illustrates how controls at user organizations may impact service auditors’ reports.

The Firm selected for testing a control over payroll costs  .  .  . [t]his control consisted of (1) the review of the service auditor’s reports provided by the service organization that the issuer used to perform its payroll function and (2) the documentation of the necessary user controls specified in the service auditor’s report. The Firm, however,

did not test the issuer’s [user organization’s] control over the accuracy and completeness of payroll data transmitted by the issuer to the ser- vice organization that was identified as a necessary user control in the service auditor’s reports.

Source: Report on 2017 Inspection of KPMG, Public Company Accounting Oversight Board, January 24, 2019 (PCAOB Release No. 104-2019-002).

SOC Reports and User ControlsAUDITING INSIGHT

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Other Attestation Engagements and Summary In addition to the engagements noted above, professional standards provide accountants with guidance for performing and reporting on engagements related to pro forma finan- cial information, internal control over financial reporting (for non-issuers), and Man- agement’s Discussion and Analysis disclosures accompanying the financial statements. While the nature of the subject matter subject to evaluation obviously differs from the engagements discussed above, the general nature of the engagement and the assurance provided by the accountants in these engagements is similar.

Exhibit A.6 summarizes the types of engagements and distribution of the reports for the attestation engagements discussed in this section. One general conclusion that may be drawn from Exhibit A.6 is that the use of the accountants’ reports in agreed-upon pro- cedures engagements is limited to the individual(s) who participated in determining the scope of the engagement, while the use of the reports in examination and review engage- ments is generally not limited in this manner.

The following finding from a PCAOB Inspection Report on the audits conducted by KPMG illustrates some of the issues associated with controls implemented by service organizations.

The issuer used a service organization to generate retail deposit customer statements using information from the issuer’s retail deposit system. The Firm identified and tested a control that included testing the mathematical accuracy of information appearing on a sample of

retail deposit statements, recalculating interest and fees, and com- paring the information on the statements to the retail deposit system. The Firm, however, failed to identify and test any controls over the completeness of the information transferred from the issuer’s retail deposit system to the service organization.

Source: PCAOB Report on the 2016 Inspection of KPMG LLP (January 15, 2019).

PCAOB Inspections and Service OrganizationsAUDITING INSIGHT

Subject of engagement Type of engagement Distribution of reports

Historical financial information (AU-C 800, AT-C 215) • Examination (audit) • Agreed-upon procedures

• General use (examination) • Limited use (agreed-upon procedures)

Prospective financial information (AT-C 305) • Examination • Agreed-upon procedures

• General use (financial forecast and examination) • Limited use (financial projection and

examination) • Limited use (agreed-upon procedures)

Compliance (AU-C 806, AT-C 315) • Examination • Agreed-upon procedures

• General use (examination) • Limited use (agreed-upon procedures)

Broker-dealer compliance (PCAOB AT 1, AT 2) • Examination (compliance report)

• Review (exemption report)

• General use

Service organizations (AT-C 320) • Examination • Limited use

Pro forma information (AT-C 310) • Examination • Review

• General use

Management’s Discussion and Analysis (AT-C 395) • Examination • Review

• General use

Internal control over financial reporting (non-issuer) (AU-C 940)

• Examination • General use

EXHIBIT A.6 Summary of Attestation Engagements and Reports

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ACCOUNTING AND REVIEW SERVICES FOR HISTORICAL FINANCIAL INFORMATION

As noted throughout this text, issuers are required to have audits (a form of examina- tion engagement) on their historical financial statements. However, non-issuers are not required to have audits; in some cases, lenders and other users of their financial statements may request a lower (and less costly) level of assurance than provided by an audit; these services are collectively referred to as accounting and review engagements. The Account- ing and Review Services Committee issues Statements on Standards for Accounting and Review Services (SSARS), which apply to accountants’ engagements on unaudited finan- cial statements of non-issuers.

Review Engagements A review engagement is a service performed by accountants to obtain limited assurance that no material modifications should be made to the financial statements in order for the statements to be in conformity with the applicable reporting framework (usually GAAP). Because some assurance is provided in a review engagement, accountants must be inde- pendent in order to perform review services.

After obtaining a written understanding with management about the nature of a review engagement (through an engagement letter), the accountant performs the following pro- cedures during a review of unaudited financial statements:

1. Obtaining knowledge of the entity’s business, accounting principles in the entity’s industry, and the entity’s organization and operations.

2. Making certain inquiries of management; presumptively mandatory inquiries include inquiries related to

∙ Whether the financial statements have been prepared and fairly presented in accor- dance with the applicable financial reporting framework.

∙ Significant transactions and journal entries. ∙ Uncorrected misstatements identified during a previous review. ∙ Subsequent events. ∙ Knowledge of fraud or suspected fraud. ∙ Noncompliance with laws and regulations. ∙ Related-party transactions. ∙ Litigation. ∙ The reasonableness of significant estimates. ∙ Actions taken at meetings of shareholders, directors, and other important executive

committees.

LO A-4 Describe review, compilation, and preparation engagements for historical financial information and prepare appropriate reports given specific factual circumstances.

REVIEW CHECKPOINTS A.16 What types of engagements may be performed by an accountant in a compliance attestation?

What type of assurance is provided in each of these engagements? A.17 What are the two types of reports (and the related level of accountant assurance) that may be filed

by broker-dealers under Rule 17a-5? A.18 What are the roles of a user entity auditor and a service entity auditor in an audit of a service orga-

nization’s controls? A.19 What is a service organization? Why would it engage an auditor to report on its controls? A.20 Distinguish between a SOC 1 Type 1 and SOC 1 Type 2 report. Which of these reports would most

likely be requested by an issuer?

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3. Conducting analytical procedures (presumptively mandatory analytical procedures include): ∙ Comparing current financial statements with comparable information for the prior

period. ∙ Comparing recorded amounts or ratios developed from recorded amounts to

expectations developed based on an understanding of the entity and its industry. 4. Reconciling the financial statements to the underlying records. 5. Obtaining written representations from management.

While the above does provide some limited audit evidence, a review engagement is far less extensive than an audit (for example, a review does not require the accountant to obtain an understanding of the entity’s internal control). As a result, a review engagement does not provide a basis for expressing an opinion on financial statements. Instead, the accountant will provide limited assurance (formally known as negative assurance) through a phrase such as “we are not aware of any material modifications” that are necessary for the financial statements to be in conformity with an appropriate financial reporting frame- work. In addition, each page of the company’s financial statements should be marked “See independent accountants’ review report” to clearly indicates to users that an audit engage- ment was not performed. An example of a review report is provided in Exhibit A.7.

Note the following from the above report:

∙ The first paragraph summarizes the procedures performed in a review engagement, acknowledges that these procedures are less in scope than an audit, and indicates that these procedures do not permit the accountant to express an opinion on the financial statements.

Independent Accountant’s Review Report To the Board of Directors of Dunder-Mifflin, Inc.

We have reviewed the accompanying financial statements of Dunder-Mifflin, Inc., which comprise the balance sheet as of December 31, 2020, and the related statements of income, changes in stockholders’ equity, and cash flows for the year then ended, and the related notes to the financial statements. A review includes primarily applying analytical procedures to management’s financial data and making inquiries of company management. A review is substantially less in scope than an audit, the objective of which is the expression of an opinion regarding the financial statements as a whole. Accordingly, we do not express such an opinion.

Management’s Responsibility for the Financial Statements Management is responsible for the preparation and fair presentation of these financial statements in

accordance with accounting principles generally accepted in the United States of America; this includes the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement whether due to fraud or error.

Accountant’s Responsibility Our responsibility is to conduct the review engagement in accordance with Statements on Standards

for Accounting and Review Services promulgated by the Accounting and Review Services Committee of the AICPA. Those standards require us to perform procedures to obtain limited assurance as a basis for reporting whether we are aware of any material modifications that should be made to the financial statements for them to be in accordance with accounting principles generally accepted in the United States of America. We believe that the results of our procedures provide a reasonable basis for our conclusion.

Accountant’s Conclusion Based on our review, we are not aware of any material modifications that should be made to the

accompanying financial statements in order for them to be in accordance with accounting principles generally accepted in the United States of America.

Michael Scarn, LLP Scranton, PA

March 1, 2021

EXHIBIT A.7  Example Review Report

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∙ The Management’s Responsibility for the Financial Statements and Accountant’s Responsibility sections are similar in nature to those section in an auditors’ report (modified for the nature of a review engagement)

∙ The Accountant’s Conclusion section provides limited assurance on the financial statements.

Other Matters with Review Engagements

1. Similar to audit reports, if the accountants’ review procedures reveal a departure from GAAP (or other appropriate financial reporting framework), the report should discuss the departure in a separate paragraph and refer to the departure in the Accountant’s Conclusion section.

2. Similar to audit reports, accountants may include emphasis-of-matter paragraphs and other-matter paragraphs in review reports to draw users’ attention to certain matters or communicate matters other than those presented or disclosed in the financial statements.

3. If the reviewed financial statements are presented in comparative form, the accoun- tants’ report should refer to each year presented.

4. If a client requests a change in scope of an engagement from an audit to a review, the accountant would normally agree to this change if the reason is because of changes in the needs of the client (a lender indicated a willingness to accept a review rather than an audit) or a misunderstanding about the level of services.

5. Accountants may perform review engagements on a single financial statement (for example, the balance sheet) or specific elements or accounts of a financial statement (for example, accounts receivable).

Compilation Engagements The purpose of a compilation engagement is to assist management in presenting finan- cial information that is the representation of management in the form of financial statements—without providing any assurance on the accuracy or completeness of that information. Essentially, you may think of a compilation as assembling a balance sheet, income statement, statement of cash flows, and so on, from account information supplied by the entity’s management.

When performing a compilation engagement, the accountant has no responsibility to assess the conformity of the entity’s financial statements with GAAP or other financial reporting frameworks. After obtaining an engagement letter from the client, accountants should perform the following procedures:

∙ Obtain an understanding of the entity’s business and applicable accounting principles in the entity’s industry.

∙ Read the financial statements, looking for obvious clerical or accounting errors. ∙ Follow up on information that is incorrect, incomplete, or otherwise unsatisfactory.

Note that accountants are not required to conduct tests of the operating effectiveness of control procedures or to perform any other evidence-gathering procedures. Given the very limited procedures performed, accountants do not express an opinion or any form of assurance on the conformity of the financial statements with GAAP. Because no assur- ance is provided, accountants are not required to be independent to perform compilation engagements or issue compilation reports. However, accountants must assess whether they are independent and disclose any lack of independence in their report.

An example report for a compilation engagement is presented in Exhibit A.8. Note that this report specifically indicates that the accountant did not perform any procedures to verify management’s information and disclaims an opinion, conclusion, or any form of assurance on the financial statements. In addition to the report, each page of the financial statements should be marked “See accountants’ compilation report.”

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In addition to the scope of the engagement and level of assurance provided, two signif- icant differences between compilation reports and other reports discussed in this module can be noted:

∙ Because compilation engagements do not require accountants to be independent, the report is not titled using the word “independent.”

∙ Because no assurance is provided, the report is not addressed to a particular user(s) or group of user(s).

Other potential issues (and reporting implications) related to compilation engagements include

1. Similar to an audit, if the accountants’ compilation procedures revealed a departure from GAAP (or other appropriate financial reporting framework), a paragraph should be added to the compilation report describing the departure.

2. If the entity decides to omit all footnote disclosures required by GAAP (believing such dis- closures are not necessary for their purposes), the accountants’ report would note the omis- sion and indicate that the omission of these disclosures might influence users’ conclusions.

3. If accountants are not independent, their report should specifically state their lack of independence and may provide a general description of the reason for their lack of independence.

Preparation Engagements In some cases, entities wished to engage accountants to assemble financial statements without performing even the limited procedures in a compilation engagement or issuing a report. In response, the AICPA created a new type of engagement known as a preparation engagement. When performing a preparation of financial statements engagement, the accountant should prepare an engagement letter, but he or she is not required to perform any procedures, evaluate their independence, or issue a report.

Examples of engagements include preparation of

∙ Financial statements prior to audit or review by another accountant. ∙ Financial statements presented alongside the entity’s tax return. ∙ Personal financial statements for presentation alongside a financial plan. ∙ Individual financial statements with substantially all disclosures omitted. ∙ Financial statements from information in a general ledger outside of an accounting

software system.

The accountant should prepare the financial statements using the client’s records and should include a statement on each page of the financial statements indicating that “no assurance is provided.” Alternatively, while not a requirement, the accountant could issue

EXHIBIT A.8  Example Compilation Report

Management is responsible for the accompanying financial statements of Dunder-Mi�in, Inc., which comprise the balance sheet as of December 31, 2020 and the related statements of income, changes in stockholders’ equity, and cash flows for the years then ended, and the related notes to the financial statements in accordance with accounting principles generally accepted in the United States of America. We have performed a compilation engagement in accordance with Statements on Standards for Accounting and Review Services promulgated by the Accounting and Review Services Committee of the AICPA. We did not audit or review the financial statements, nor were we required to perform any procedures to verify the accuracy or completeness of the information provided by management. Accordingly, we do not express an opinion, a conclusion, or provide any form of assurance on these financial statements.

Scranton, PA

March 1, 2021

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a disclaimer of opinion indicating that the financial statements were not subject to an audit, review, or compilation and that no opinion, conclusion or assurance is provided on the financial statements.

REVIEW CHECKPOINTS A.21 Identify and provide a brief overview of the procedures required under the three engagements

defined under SSARS. A.22 What are the major content(s) of the accountants’ report in a review engagement? A compilation

engagement? A.23 What is limited assurance? Why is limited assurance (and not an opinion) provided in a review

engagement? A.24 How does a preparation engagement differ from a compilation engagement?

Summary of Engagements on Historical Financial Information This section discussed accountant engagements on historical financial statements hav- ing a lesser scope than an audit (examination engagement). Exhibit A.9 summarizes the differences between these engagements as well as two other alternatives (audit engage- ments and agreed-upon procedures engagements). As shown below, these engagements involved a wide range of professional standards (AICPA Statements on Auditing Stan- dards, AICPA Attestation Standards, AICPA Statements on Standards for Accounting and Review Services, and PCAOB Auditing Standards) and varying scope of accountant procedures and levels of assurance.

A survey of practicing CPAs and bankers found that both groups reported confidence and were likely to place some reliance on plain-paper state- ments. This confidence was even greater when a CPA was involved with the financial statements (such as in a preparation engagement).

Source: A. Reinstein, B. P. Green, and C. L. Miller, “Evidence of Perceived Quality of ‘Plain-Paper Statements,’” Auditing: A Journal of Practice & Theory, November 2006, pp. 85–94.

Do Plain-Paper Financial Statements Have Any Value?

AUDITING INSIGHT

  Audits Review Compilation Preparation Agreed-Upon Procedures

Procedures Audit procedures required by GAAS

Inquiries and analytical procedures

Read financial statements for obvious errors

Assemble financial statements

Procedures requested by specific users

Assurance/Conclusion Opinion Limited assurance None None List of Findings

Independence required?

Yes Yes No No Yes

Professional Standards PCAOB Auditing Standards (issuers) and ASB Statements on Auditing Standards (non-issuers)

AICPA Statements on Standards for Accounting and Review Services (SSARS)

AICPA SSARS AICPA SSARS AICPA Statements on Standards for Attestation Engagements

Distribution of Report Not limited Not limited Not limited Not limited (if disclaimer issued)

Limited to specific users

EXHIBIT A.9 Summary of Engagements on Historical Financial Information

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ASSURANCE SERVICES ENGAGEMENTS Auditing courses focus on the role of auditors in the financial reporting process, but students should not lose sight of the fact that accountants require sufficient revenue to cover expenses, provide profit, and provide funds for continued growth. One of the objec- tives of the AICPA has been to identify additional niche services that accountants might offer to enhance their value to clients, attract new clients, and improve the potential for growth as a business. Such services include tax and consulting, personal financial plan- ning, forensic, and valuation services.

Scope of Assurance Services Assurance services are independent professional services that improve the quality of infor- mation, or its context, for decision makers. A large group of activities can fit within this definition; for example, most of the services discussed to this point in the module meet these criteria. While attestation and audit services are highly structured and intended to be useful for large groups of decision makers (e.g., investors, lenders), assurance services are more customized and intended to be focused on the needs of smaller, targeted groups of decision makers. In this sense, assurance services resemble consulting services. (The vignette at the beginning of this module on PwC’s work with the Academy of Motion Picture Arts and Sciences is an example.)

Although there are many potential assurance services with more emerging continu- ously, several have been featured by the AICPA’s Assurance Services Executive Commit- tee (ASEC) as having potential to provide value and improve the quality and transparency of information entities provide to their constituents. Currently, the ASEC has created task forces and working groups in the following broad areas:6

1. Continuous assurance and continuous controls monitoring: These services involve “real-time” assurance and monitoring of controls as transactions are processed by clients.

2. Audit data standards: These services relate to enhancing the efficiency and effective- ness of audits by standardizing formats of files and fields commonly requested for audits and other purposes.

3. Risk assurance and advisory services: These services relate to advising clients on enterprise risk management processes.

4. Sustainability assurance and advisory services: Sustainability (sometimes referred to as corporate social responsibility) is defined by the AICPA as “the triple-bottom-line of (1) economic viability, (2) social responsibility, and (3) environmental responsibility.”7

The AICPA recently issued a Sustainability Attestation Guide8 to provide guidance to accountants for engagements related to sustainability-related information. These engage- ments (and the related accountant assurance) will vary greatly from engagement to engagement. For example, Moss Adams LLP (a regional accounting firm with offices in Washington and California) provided assurance on the following information contained in Starbucks Coffee Company’s Global Social Impact Performance report:9

∙ Volume of ethically sourced coffee purchases as a percentage of total coffee purchases (99%)

∙ Volume of ethically sourced tea purchases as a percentage of total tea purchases (72%) ∙ Amount of commitment or investment in loans to farmers ($22.3 million)

LO A-5 Explain and provide examples of assurance services engagements.

6https://www.aicpa.org/interestareas/frc/assuranceadvisoryservices.html 7http://www.aicpa.org/InterestAreas/InformationTechnology/Resources/SOC/TrustServices/DownloadableDocuments/ TrustServicesPrinciples-TSP100.pdf. 8Attestation Engagements on Sustainability Information (including Greenhouse Gas Emissions Information), AICPA, July 27, 2017. 9Starbucks 2017 Global Social Impact Performance Report

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Moss Adams’ report outlined the procedures performed, including testing the effective- ness of the internal reporting system used to collect and compile information, performing specific procedures to validate the information, and confirming certain information with third parties.

The following Auditing Insight “Trends in Corporate Responsibility Reporting” high- lights the increasing frequency of corporate responsibility reporting (including sustain- ability reporting), third-party assurance on these reports, and benefit to the companies for providing third-party assurance on these reports.

Trust Services Electronic commerce (or e-commerce), the sale of goods and services via the Internet, is exploding. According to the U.S. Census Bureau, U.S. e-commerce revenues repre- sented 11.2 percent of all retail sales in the fourth quarter of 2018, up from 7.0 percent in the same quarter of 2013.10 Although the growth of e-commerce continues unabated, security issues, both real and perceived, have prevented many potential customers from purchasing goods and services via the Internet. Many customers and business owners dis- trust the Internet as a medium of conducting business. Indeed, a general lack of security is the top reason nonbuyers give for not purchasing products online and the top concern among current online buyers. Specifically, prospective buyers have expressed concerns about ascertaining whether an e-commerce company is authentic, is trustworthy (the e-tailer will do what it says it will do), and will safeguard buyers’ personal information. Customers also want to be reassured that they can get their products, services, and repairs on a timely basis. Despite growing familiarity with doing business on the Internet, these security issues have not diminished for potential customers.

For significant customer–supplier business relationships, company computers are often directly linked through Internet-based virtual private networks. Purchase orders for goods are made and sent via computer, and payment is made automatically through electronic funds transfer directly to the vendors bank. The primary benefit of such a relationship is an increase in the timeliness of the process; transactions that once took several weeks to com- plete manually (from customer purchase order generation to final payment being depos- ited to the suppliers bank account) now take only as long as it takes to ship and receive the goods. However, just as Internet customers are wary of purchasing online, business customers are often cautious about entering into such relationships with other businesses.

10Latest Quarterly Retail E-Commerce Sales (time series), https://www.census.gov/retail/index.html

• The Governance & Accountability Institute reports that 85 percent of the S&P 500 companies published sustainability reports in 2017, up from 20 percent in 2011.

• A KPMG survey reports that 93% of the Fortune 250 companies (referred to as the G250) and 75% of the 100 largest companies in each of 49 different countries (for a total of 4,900 companies, referred to as the N100) published corporate responsibility reports in 2017. Third-party assurance was provided for 67% and 45% of reports for the G250 and N100, respectively.

• An academic study found that companies engaging third-parties to provide assurance on corporate responsibility reports have a lower cost of capital (by 0.7%) than those issuing corporate responsibility reports without such assurance.

• An academic study found that external assurance improved the perceived quality of environmental, social, and governmental dis- closures (measured by receipt of an EY Excellence in Integrated Reporting Award); this quality was influenced even more signifi- cantly when the assurance was provided by a Big Four firm.

Source: https://www.ga-institute.com/press-releases/article/flash-report- 85-of-sp-500-indexR-companies-publish-sustainability-reports-in-2017.html; The Road Ahead: The KPMG Survey of Corporate Responsibility Reporting 2017 (KPMG, 2017); R.J. Casey and J.H. Grenier, “Understanding and Contributing to the Enigma of Corporate Social Responsibility (CSR) Assurance in the United States,” Auditing: A Journal of Practice & Theory, February 2015, pp. 97–130; W. Maroun, “Does External Assurance Contribute to Higher Quality Integrated Reports?,” Journal of Accounting and Public Policy, July-August 2019.

Trends in Corporate Responsibility ReportingAUDITING INSIGHT

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In response to these concerns, the AICPA and the Canadian Institute of Chartered Accountants (CICA) developed WebTrust Services to provide assurance to the consumer on the reliability of Internet websites and SysTrust Services to focus on a company’s systems as a means of increasing the reliability of business-to-business (B-to-B) computer transac- tions. Because these two services have a common framework to address risks and techno- logical opportunities, the AICPA has adopted the term trust services to define a set of professional attestation and advisory services based on a core set of principles and criteria that address the risks and opportunities of IT-enabled systems and privacy programs.11

Trust Services comprise a set of professional attestation and advisory services based on a core set of principles and criteria that address the risks and opportunities of IT- enabled systems and privacy programs. Practitioners use the following principles and related criteria in the performance of trust services engagements:

∙ Security. The system is protected against unauthorized access (both physical and logical).

∙ Availability. The system is available for operation and use as committed or agreed. ∙ Processing integrity. System processing is complete, accurate, timely, and authorized. ∙ Confidentiality. Information designated as confidential is protected as committed or

agreed. ∙ Privacy. Personal information is collected, used, retained, disclosed, and destroyed in

conformity with the commitments in the entity’s privacy notice and with criteria set forth in generally accepted privacy principles issued by the AICPA and CICA.12

Two common types of reports issued in conjunction with Trust Service engagements are

∙ SOC 2 reports, which provide assurance on the above principles for limited use (man- agement and/or specified parties).

∙ SOC 3 reports, which provide assurance on the above principles for general use.

SOC 2 and SOC 3 are similar in content, with the primary difference being the intended recipients of the reports. As with SOC 1 reports requested in conjunction with the examination of internal control over financial reporting for an issuer, two versions of these reports reflect differences in the scope of the engagement and assurance provided by the accountant. A Type 1 report provides assurance on the effectiveness of design of relevant controls, while a Type 2 report provides assurance on both the effectiveness of design and operations of relevant controls. The controls can be related to individual prin- ciples of a combination of principles.

The accompanying Auditing Insight “Amazon Trust Services” provides an example of assurances provided in one such situation.

11AICPA TSP 100 2015, para. 1. 12http://www.aicpa.org/interestareas/businessindustryandgovernment/resources/sustainability/pages/sustainabilityfaqs.aspx.

In 2018, BDO provided assurance on Amazon Trust Services’ (ATS) Certification Authority operations as follows:

• Trust Service Principles and Criteria for Certification Authorities (Version 2.2)

• WebTrust Principles and Criteria for Certification Authorities (SSL Baseline with Network Security, Version 2.2)

• WebTrust Principles and Criteria for Certification Authorities (Extended Validation SSL, Version 1.6)

• WebTrust Principles and Criteria for Certification Authorities (Extended Validation Code Signing, Version 1.4)

These assurances related to disclosure of ATS’ various business practices, provision of services in accordance with the disclosed busi- ness practices, and the effectiveness of controls over those business practices.

Source: https://www.amazontrust.com/repository/

Amazon Trust ServicesAUDITING INSIGHT

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The Future of Assurance Services While it is difficult to identify specific areas that may emerge, it is safe to say that accountant assurance services will continue to evolve and expand, creating both oppor- tunities and challenges for practitioners. One particular likely area of future expansion is the use of blockchain technologies to conduct transactions and update ledgers without the involvement of intermediaries. A recent whitepaper prepared by the Chartered Profes- sional Accountants of Canada and the AICPA identified the following potential applica- tions of assurance services in this arena13

∙ Verifying that smart contracts embedded in a blockchain are implemented with the correct business logic.

∙ Verifying the interface between smart contracts and external data sources that trigger business events.

∙ Ensuring the effectiveness of controls that protect sensitive information included in a blockchain platform.

∙ Ensuring the effectiveness of controls over participant access to blockchain platforms.

13Blockchain Technology and Its Potential Impact on the Audit and Assurance Profession (CPA Canada and AICPA, 2017)

REVIEW CHECKPOINTS A.25 What are the four broad areas of assurance services currently being evaluated by the ASEC? Pro-

vide a brief summary of each area. A.26 What is sustainability reporting? Why would a company choose to provide a sustainability report

and seek independent assurance? A.27 Identify and define the two types of trust services developed by the AICPA and CICA.

While the focus in this text has been on audit engagements provided by accounting firms, other forms of services have arisen. This module discussed the following three broad types of engagements:

1. Attestation engagements: Engagements in which CPAs provide assurance and report on an assertion that is the responsibility of another party.

2. Accounting and review engagements: Engagements performed by CPAs on histori- cal financial statements that are less in scope than an audit.

3. Assurance engagements: Engagements performed by CPAs that improve the quality of information for decision makers.

Professional standards provide guidance for a wide range of engagements, which differ in terms of scope as well as the intended level of assurance provided by the accountant, as shown below (an agreed-upon procedures engagement will vary in terms of scope, depending upon the extensiveness of the procedures performed).

Summary

Greater Scope Greater Assurance

Engagement

Assurance

Compilation

No assurance

Preparation

No assurance

Agreed-upon procedures Review

Findings (Agreed-upon procedures) Limited assurance (Review)

Examination

Opinion

Lesser Scope Lesser Assurance

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accounting and review engagements: Engagements performed by accountants on historical financial statements that are less in scope than an audit, 609 agreed-upon procedures: An engagement in which the accountant performs procedures that are specified by specific user(s), 596 appropriate financial reporting framework: The financial reporting treatment (i.e., GAAP, IFRS, etc.) adopted by management and, when appropriate, those charged with governance in the preparation of the financial statements that is acceptable in view of the nature of the entity and the objective of the financial statements, or that is required by law or regulation, 000 assurance services: The independent professional functions that improve the quality of information, or its context, for decision makers, 614 attestation: An accounting service resulting in a report on subject matter or an assertion about subject matter that is the responsibility of another party, 595 broker–dealer: An individual or company involved in the business of buying and selling investment securities either for its own account or on behalf of customers, 603 cash basis accounting: A special purpose framework in which revenues are recognized when cash is received and expenses are incurred when cash is disbursed, 597 compilation: An engagement in which an accountant performs limited procedures (such as reading the entity's financial statements) in assembling financial information but does not provide any assurance on that information, 611 examination: An attestation engagement similar in nature to an audit, 596 eXtensible Business Reporting Language (XBRL): The communication terminology required by the Securities and Exchange Commission for companies to use to provide financial statement information that has a computer-readable identifying tag for each item of data, 000 financial forecast: The prospective financial information reflecting an entity’s estimates of what is likely to occur in a future period, 601 financial projection: The prospective financial information reflecting a transaction or event that may occur in the future, 601 interim financial information: The financial information or statements covering a period less than a full year or for a 12-month period ending on a date other than the entity’s fiscal year-end, 000 management’s discussion and analysis: A required section of financial reports of public companies in which management analyzes the results of operations and cash flows for the periods presented, 000 modified cash basis accounting: A special purpose framework that provides limited accruals for items such as fixed assets or inventories and long-term debt, 597 pro forma: The description of financial information reflecting historical data as if a certain transaction had occurred, 000 preparation: An engagement in which an accountant assembles financial statements without performing any additional procedures or issuing a report. responsible party: The person or persons, either as individuals or representatives of the entity, responsible for the subject matter of an attestation engagement, 596 review: An engagement in which an accountant performs inquiries and analytical procedures and provides limited assurance about financial information, 596, 609 review evidence: The evidence required to provide limited assurance obtained by (1) inquiring of management, (2) conducting analytical procedures, and (3) obtaining written representations from management, 000 service organization: An entity that provides services to user entities that are likely to be relevant to user entities’ internal control over financial reporting, 606 special-purpose framework: A coherent accounting framework in which substantially all important financial measurements are governed by criteria other than GAAP or IFRS, 597 sustainability: The triple-bottom-line of economic viability, social responsibility, and environmental responsibility, 614 SysTrust Services: An assurance function that reviews an entity’s computer system to provide confidence to business partners and customers concerning the security, privacy, and confidentiality of information in addition to system availability and processing integrity, 616 trust services: A set of professional attestation and advisory functions based on a core set of principles and criteria that addresses the risks and opportunities of IT-enabled systems and privacy programs, 616 WebTrust Services: An assurance function designed to reduce the concerns of Internet users regarding the existence of a company and the reliability of key business information placed on its website, 616

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Multiple-Choice Questions for Practice and Review

All applicable questions are available with Connect.

A.28 Which of the following would not be included in an auditors’ report on financial statements prepared using a special purpose framework? a. A statement that the financial statements are the responsibility of management. b. An identification of the financial statements and years examined. c. An opinion on the appropriateness of the special purpose framework. d. A reference to a footnote or other disclosure discussing the special purpose framework

used in preparing the financial statements. A.29 Auditors may accept an engagement and express an unmodified opinion on an element,

account, or item of the financial statements if they a. Perform analytical procedures related to all significant account balances and classes of

transactions. b. Limit the distribution of their report to specified users. c. Conduct the engagement in accordance with generally accepted auditing standards. d. Have expressed an adverse opinion on the full financial statements.

A.30 Which of the following sections or paragraphs of the auditors’ report would be modified if the report expresses an opinion on financial statements prepared using the cash basis of accounting rather than generally accepted accounting principles?

  Paragraph preceding Management’s

Responsibility Section Auditor’s Responsibility

Section

a. Yes Yes b. Yes No c. No Yes d. No No

A.31 Which of the following statements is not true regarding an auditors’ report on compliance with contractual provisions conducted in conjunction with a GAAS audit? a. Auditors may issue either a separate report on compliance with contractual provisions or

a combined report on compliance included with the report on the financial statements. b. The auditors’ report expresses an opinion on the financial statements and compliance

with contractual provisions. c. The distribution of the auditors’ report is limited. d. The auditors’ report acknowledges that the audit was not conducted with the purpose of

obtaining knowledge regarding compliance with contractual provisions. A.32 When accountants are not independent, which of the following reports can they issue?

a. Compilation report on historical financial statements. b. Standard unmodified audit report on historical financial statements. c. Examination report on a financial forecast. d. Examination of internal control over financial reporting for an issuer.

A.33 To perform an attestation engagement on prospective financial information, accountants must do all of the following except a. Obtain knowledge about the entity’s business and accounting principles. b. Understand the internal controls used in the processes that generated the prospective

financial information. c. Obtain an understanding of the process through which the prospective financial informa-

tion was developed. d. Evaluate the assumptions used to prepare the prospective financial information.

LO A-2

LO A-2

LO A-2

LO A-2

LO A-2, A-3, A-4

LO A-3

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A.34 Which of the following is not correct with respect to a user auditors’ request for a SOC 1 report? a. A SOC 1 report should be requested in the audit of an issuer. b. Type 1 reports would be most appropriate for auditors’ reporting requirements for issuers. c. The user entity is the entity on whom the audit of the financial statements and internal

control over financial reporting is being conducted. d. A SOC 1 report expresses an opinion on the design and/or operating effectiveness of

internal controls. A.35 Which of the following statements should be included in a practitioners’ report on the appli-

cation of agreed-upon procedures? a. A statement that the practitioner performed an examination of prospective financial

statements. b. A statement of scope limitation that will qualify the practitioners’ opinion. c. A statement referring to standards established by the AICPA. d. A statement of limited assurance based on procedures performed.

(AICPA adapted) A.36 Which of the following statements would not be included in an accountants’ report on an

examination of a financial forecast? a. The examination was conducted in accordance with attestation standards established by

the AICPA. b. An opinion on the likelihood of achieving the forecasted results. c. An acknowledgement that differences may occur between forecasted and actual results. d. A statement indicating the accountants have no responsibility to update the report for

future events and circumstances. A.37 In which of the following engagements would general distribution of the accountants’ report

be appropriate? a. Agreed-upon-procedures engagement. b. Examination of financial projection. c. Examination of financial forecast. d. None of the above.

A.38 Prospective financial information that reflects the results assuming the occurrence of one or more hypothetical events is referred to as a a. Financial estimate. b. Financial forecast. c. Financial projection. d. Pro forma financial information.

A.39 An SOC 1 Type 2 report supporting the auditors’ report on internal control over financial reporting for an issuer provides assurance with respect to

  Controls placed in operation Operating effectiveness of controls

a. Yes Yes b. Yes No c. No Yes d. No No

A.40 The conclusions provided in an accountants’ report on an agreed-upon procedures engage- ment are in the form of a(n) a. Limited assurance. b. Summary of findings. c. Opinion. d. No conclusions are provided in an agreed-upon procedures engagement.

LO A-3

LO A-3

LO A-3

LO A-3

LO A-3

LO A-3

LO A-3

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A.41 Which of the following would be included in an accountants’ report on an agreed-upon pro- cedures engagement?

  Summary of findings Summary of procedures performed

a. Yes Yes b. Yes No c. No Yes d. No No

A.42 Which of the following would not be included in an accountants’ report on compliance with laws, regulations, or other matters conducted separately from an audit? a. Identification of the law, regulation, or other matter that serves as the basis for the

engagement. b. A statement that the engagement was conducted in accordance with AICPA standards. c. A statement that the accountants’ engagement provides a legal determination with respect

to compliance. d. The accountants’ conclusion with respect to compliance.

A.43 Which of the following is not a condition that must be met for an engagement to evaluate compliance with laws, regulations, or other matters? a. Management must accept responsibility for compliance. b. Management’s evaluation of compliance is capable of evaluation and is measured against

reasonable criteria. c. Sufficient evidence is available to support management’s evaluation. d. Management provides a report attesting to satisfactory compliance.

A.44 Which of the following best describes the scope of audit and compilation engagements com- pared to a review engagement?

  Audit Compilation

a. Lesser than review Lesser than review b. Greater then review Lesser than review c. Lesser than review Greater than review d. Greater than review Greater than review

A.45 Accountants are permitted to express limited assurance in which of the following reports? a. Standard unmodified report on audited financial statements. b. Compilation report on unaudited financial statements. c. Review report on unaudited financial statements. d. Adverse opinion on audited financial statements.

A.46 During a review of a non-issuer’s financial statements, accountants are required to make cer- tain inquiries of management. Which of the following inquiries is not required by SSARS? a. The basis for the preparation of financial statements. b. Internal control deficiencies. c. Significant transactions occurring near the end of the reporting period. d. Material subsequent events.

A.47 Which of the following would not ordinarily be included in an accountants’ review report on a non-issuer’s financial statements? a. An indication that a review engagement is substantially less in scope than an audit

engagement. b. A statement that a review engagement was conducted in accordance with SSARS. c. A statement that a review engagement is greater in scope than a compilation. d. Limited assurance on the fairness of the financial statements.

LO A-3

LO A-3

LO A-3

LO A-4

LO A-4

LO A-4

LO A-4

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A.48 Dale, CPA, was engaged to conduct an audit of the financial statements of AM Company (a non-issuer). After considering the scope and cost of an audit engagement, AM Company has asked Dale to modify the scope of the engagement to a review. Which of the following best describes the professional guidance for this situation? a. Dale would be required to issue a disclaimer of opinion on the financial statements

because of the limited scope of a review engagement. b. Dale would be permitted to modify the scope of the engagement if AM Company’s

request is based on their lender’s willingness to accept a review engagement rather than an audit.

c. Dale would be permitted to modify the scope of the engagement, regardless of the reason for AM Company’s request.

d. Dale would be precluded from modifying the scope of the engagement under any circumstances.

A.49 In which of the following engagements would an accountant be required to be independent of the client?

  Compilation engagement Preparation engagement

a. Yes Yes b. Yes No c. No Yes d. No No

A.50 If a non-issuer prepares financial statements that omit substantially all footnote disclosures required by GAAP, the accountants’ compilation report a. Is not affected, since no assurance is provided in a compilation engagement. b. Should be modified to provide the omitted disclosures. c. Should indicate that the disclosures are omitted and that this omission might affect users’

conclusions. d. Should disclaim an opinion on the financial statements because of a significant scope

limitation. A.51 If an accountant is not independent with respect to a non-issuer and has been requested to

conduct a compilation engagement, the accountant should a. Decline to accept the engagement because of the lack of independence. b. Decline to accept the engagement and conduct a preparation engagement. c. Accept the engagement and disclose the lack of independence in the compilation report. d. Accept the engagement and express limited assurance on the financial statements because

of the lack of independence. A.52 Which of the following is not true with respect to a preparation engagement?

a. The accountant should obtain an engagement letter from the client. b. While not required to be independent, the accountants’ communication to third parties

should disclose their lack of independence. c. The accountants’ communication should include a statement on the financial statements

such as “no assurance is provided.” d. The accountant may issue a report disclaiming an opinion or assurance on the financial

statements. A.53 Statements on Standards for Accounting and Review Services are applicable to engagements

involving a. Audited financial statements of issuers. b. Unaudited financial statements of issuers. c. Unaudited financial statements of non-issuers. d. Audited financial statements of non-issuers.

LO A-4

LO A-4

LO A-4

LO A-4

LO A-4

LO A-4

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A.54 In providing assurance services to clients, CPAs are building on their reputations for a. Knowledge and integrity. b. Objectivity and integrity. c. Expertise in accounting and financial matters. d. Professionalism and trust.

A.55 An assurance service is defined as a service that a. Expands auditing services to nonfinancial information. b. Reviews unaudited financial information. c. Improves the quality of information for decision makers. d. Reduces the risk in management decision making.

A.56 B. Harper is shopping online and finds a great pair of running shoes at a really low price. However, he is not familiar with the company and is concerned with the accuracy of the website in presenting the quality of the shoes. Harper may be more willing to place an order with this company if a. The website displays the WebTrust seal. b. The company provides its annual report and the report of the independent auditors on its

website. c. The company provides a money-back guarantee. d. Only a partial payment is required prior to receiving the product.

LO A-5

LO A-5

LO A-5

Exercises and Problems

All applicable questions are available with Connect.

A.57 Attestation Evaluation Criteria. The local high school experienced performance issues two years ago. Its graduation rates had declined to the bottom 10 percent in the state, college admission rates were low, and graduates had a high unemployment rate. The school board and administration have notified the state Department of Education and the taxpayers in the school district that these problems have been fixed. Graduation rates have increased, a higher per- centage of students are continuing with their education, and a higher percentage of graduates are employed. The Department of Education wants an independent attestation to these asser- tions. It is concerned not only about the performance results claimed by the school board and administration but also about the underlying process and means used to obtain these results.

Required: Establish a list of criteria you would use to validate the claim of the school board and admin- istration and to determine the processes and means used to obtain these numbers.

A.58 Reporting on a Special Purpose Framework. You are issuing a report on the financial statements of Mega Offshore Trust for the year ended December 31, 2020. Mega uses a special purpose framework and prepares two major financial statements: (1) a statement of assets and liabilities arising from cash transactions and (2) a statement of revenue collected and expenses paid. The following footnote from Mega’s financial statements describes the basis of accounting used to prepare Mega’s financial statements. Note 2: Financial Statement Presentation The financial statements have been prepared using the cash basis of accounting, which is a com- prehensive basis of accounting other than accounting principles generally accepted in the United States (“U.S. GAAP”). Consequently, inflows or receipts are recognized when received rather than when earned, and expenses or disbursements are recognized when paid rather than when the obligation is incurred. Cash basis accounting excludes accounts such as accounts receivable, prepaid expenses, accounts payable, fixed assets accrued liabilities, and long-term debt.

Required: Assuming that the financial statements are fairly stated, prepare a draft of the Opinion sec- tion of the auditors’ report along with any necessary explanatory language related to the use of the special purpose framework.

LO A-1

LO A-2

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A.59 Reporting on a Special Purpose Framework. Brooklyn Life Insurance Company prepares its financial statements in conformity with a special purpose framework (the accounting prac- tices prescribed and permitted by the Insurance Department of the State of New York). The use of this framework results in financial statements that differ materially from statements prepared in conformity with generally accepted accounting principles. For example, using this framework, agents’ first-year commissions are expensed instead of being partially deferred.

The company engaged its auditors, Major and Major Associates, to audit the financial statements and express an opinion on whether they are prepared in accordance with the spe- cial purpose framework. Footnote 10 in the statements contains a narrative description and a numerical table explaining the differences between the framework and GAAP accounting. Footnote 10 also reconciles the assets, liabilities, income, expense, and net income deter- mined under the framework to these same subtotals determined under GAAP.

Required: Write the audit report appropriate in the circumstances. The year-end date is December 31, 2020, and the audit fieldwork was completed on February 20, 2021. Assume that no issues were encountered during the audit and that the financial statements were fairly presented in accordance with the special purpose framework.

A.60 Reporting on a Special Purpose Framework. Indicate (either yes or no) whether each of the following would be included in an auditors’ report on financial statements prepared using a special purpose framework. 1. A statement that the engagement was performed under auditing standards related to the

special purpose framework. 2. Statements providing a general description of an audit examination. 3. The auditors’ opinion on the fairness of the financial statements. 4. A statement indicating that the financial statements were prepared using a special pur-

pose framework as well as identifying footnote or other disclosures providing further information about the special purpose framework.

5. The auditors’ opinion on the appropriateness of the special purpose framework for general use. 6. Statements describing management’s responsibility for the financial statements. 7. A statement indicating that management is responsible for the selection of the special

purpose framework used to prepare the financial statements. 8. The auditors’ opinion on the materiality of differences between the financial informa-

tion prepared using the special purpose framework and that under generally accepted accounting principles.

A.61 Reporting on Compliance in Conjunction with an Audit Engagement. Prescott is con- ducting the audit of the financial statements of Mueller. In addition to the financial statement audit, various union groups have requested that Mueller provide evidence of compliance with the Fair Labor Standards Act (FLSA) of 1938. When discussing this matter with Prescott, he indicated that he could expand the auditors’ report to reference compliance with the FLSA.

Required: a. Under generally accepted auditing standards, is Prescott permitted to evaluate compli-

ance with FLSA? If so, what procedures beyond those in a financial statement audit should he perform?

b. What are the options available to Prescott for reporting on compliance with the FLSA in conjunction with his audit of the financial statements?

c. What matters should Prescott address with respect to compliance with the FLSA in his report (assume that a separate report on compliance is prepared)? (Do not write the actual report).

A.62 Prospective Financial Information. For each of the following statements, indicate whether it is appropriately related to financial forecasts (FF), financial projections (FP), both (B), or neither (N).

1. Financial information is prepared based on expected conditions or courses of action. 2. Accountant may perform an examination engagement. 3. Accountant is required to be independent to conduct engagement. 4. Engagement is conducted under attestation standards.

LO A-2

LO A-2

LO A-2

LO A-3

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5. Financial information is prepared based on the occurrence of one or more hypothetical events. 6. Accountants’ report indicates that differences between prospective financial information

and actual results may occur. 7. Accountant may perform a review engagement. 8. Distribution of the accountants’ report is limited to specific users. A.63 Prospective Financial Information. TrailBlazer, Inc. is considering the acquisition of

Sonic Company and has prepared prospective financial statements under the assumption that financing would be received and the transaction would be approved by their respec- tive boards of directors and would be consummated by March 15, 2021. In order to obtain financing, TrailBlazer has approached Oregon National Bank for a $10 million loan. After reviewing the prospective financial statements, Oregon National Bank has requested having an independent accountant evaluate the prospective financial statements.

Required: a. Identify and briefly define the two types of prospective financial information. b. Based on the scenario above, which type of information has been prepared by TrailBlazer? c. What are the major types of engagements that can be performed on prospective financial

information? What type of assurance is provided in each type of engagement? d. For each type of engagement in (c), indicate whether the following statements or issues

would be referenced in an accountants’ report on that engagement. (Your responses may be “Yes,” “No,” or “Possibly.”)

1. The financial statements/information evaluated by the accountant. 2. The accountants’ opinion on the presentation of the prospective financial information. 3. A description of the nature of the engagement. 4. A limitation on the distribution of the accountants’ report. 5. The procedures performed by the accountant on TrailBlazer’s internal control over

financial reporting. 6. A notation that differences between prospective financial information and actual results

may occur. 7. An opinion on the achievability of the results reflected in the prospective financial

information. 8. A detailed listing of procedures performed by the accountant. 9. The accountants’ opinion on the reasonableness of the assumptions used in preparing the

prospective financial information. A.64 Review of Forecast Assumptions. Dodd Manufacturing Corporation has engaged you to

attest to the reasonableness of the assumptions underlying its forecast of revenues, costs, and net income for the next calendar year, 2021. Four of the assumptions used by Dodd follow:

1. Dodd intends to sell certain real estate and other facilities held by Division B at an after- tax profit of $600,000; the proceeds of this sale will be used to retire outstanding debt.

2. Dodd will call and retire all outstanding 9 percent subordinated debentures (callable at 108). The debentures are expected to require the full call premium given present market interest rates of 8 percent on similar debt. A rise in market interest rates to 9 percent would reduce the loss on bond retirement from the projected $200,000 to $190,000.

3. Current labor contracts expire on September 1, 2021, and the new contract is expected to result in a wage increase of 5.5 percent. Given the forecasted levels of production and sales, after-tax operating earnings would be reduced approximately $50,000 for each per- centage point of wage increase in excess of the expected contract settlement.

4. The sales forecast for Division A assumes that the new Portsmouth facility will be com- plete and operating at 40 percent of capacity on February 1, 2021. It is highly improb- able that the facility will be operational before January 2021. Each month’s delay would reduce Division A sales by approximately $80,000 and operating earnings by $30,000.

Required: For each assumption, state the sources of evidence and procedures you would use to deter- mine the reasonableness of that assumption.

LO A-3

LO A-3

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A.65 Service Organization Control Reports. SA has accepted the engagement as auditor of Love Company (an issuer). Love uses an outside entity (Worknight) to process a significant volume of transactions related to a material account balance. Because SA will need to obtain some assurance as to the operating effectiveness of those controls for both the opinion on the finan- cial statements and the opinion on internal control over financial reporting, they are consider- ing various alternatives, including engaging PM to test key controls applied at Worknight.

a. Define user auditor, service auditor, user organization, and service organization. Iden- tify the parties who meet these definitions in this scenario.

b. Identify and define the two major types of Service Organization Controls 1 (SOC 1) reports. What are the major differences in these two types of SOC 1 reports?

c. In this particular instance, which type of SOC 1 report should SA request? Why? d. Identify the major contents of the SOC 1 report that would be appropriate for SA in this

engagement. A.66 Compliance Reporting. Accountants can report on compliance with laws and regulations

either in conjunction with an audit engagement or as a separate engagement.

Required: a. What type of procedures are performed in a separate attestation engagement to examine

compliance with laws and regulations? How does this differ from the procedures per- formed if compliance is evaluated in conjunction with a GAAS audit?

b. What are the major contents of the auditors’ report on compliance with laws and regula- tions if conducted in conjunction with an audit engagement? How do these contents dif- fer if the examination of compliance is conducted as a separate engagement?

c. If reporting on compliance with laws and regulations in conjunction with an audit engage- ment, what are the auditors’ options for reporting on compliance?

A.67 Accounting and Review Services. Henry Horkheimer, MD, is considering expanding his office as a result of adding a new doctor to his family medical practice. Dr. Horkheimer knows that his business is profitable, but he does not produce regular financial statements, nor does he possess the technical knowledge to do so. Although he is financially savvy enough to know that he needs financial statements to obtain financing to expand his business, he is completely unsure as to what services he needs or even what is available. He has asked you for advice.

Required: Consider Dr. Horkheimer’s need for financing and write a memo outlining the pros and cons of four services an accountant could provide: audit, review, compilation, and preparation of financial statements. Conclude your memo with a recommendation for which service you believe would best suit Dr. Horkheimer’s needs.

A.68 Errors in an Accountants’ Review Report. M. Jordan & E. Stone, CPAs, audited the financial statements of Tech Company, a non-issuer, for the year ended December 31, 2019, and expressed an unmodified opinion. For the year ended December 31, 2020, Tech issued comparative financial statements. Jordan & Stone reviewed Tech’s 2020 financial state- ments and B. Kent, an assistant on the engagement, drafted the accountants’ review report that follows. Stone, the engagement supervisor, decided not to reissue the prior-year audit report but instructed Kent to include a separate paragraph in the current-year review report describing the responsibility assumed for the prior-year audited financial statements.

Stone reviewed Kent’s draft and indicated in the following supervisor’s review notes that the draft contained several deficiencies.

Accountants’ Review Report—Kent’s Draft We have reviewed and audited the accompanying financial statements of Tech Co, which comprise the balance sheets as of December 31, 2020 and 2019, and the related statements of income, changes in stockholders’ equity, and cash flows for the years then ended, and the related notes to the financial statements. These engagements were conducted in accordance with Statements on Standards for Accounting and Review Services promulgated by the Accounting and Review Services Committee of the AICPA and generally accepted audit- ing standards. A review includes primarily applying analytical procedures to management’s financial data and making inquiries of company management. A review is substantially less in scope than an audit, the objective of which is the expression of an opinion regarding the financial statements as a whole.

LO A-3

LO A-2, A-3

LO A-4

LO A-4

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Management’s Responsibility for the Financial Statements Management is responsible for the preparation and fair presentation of these financial statements; this includes the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement whether due to fraud or error.

Accountant’s Responsibility We are required to perform procedures to obtain limited assurance as a basis for reporting whether we are aware of any material modifications that should be made to the financial statements for them to be in accordance with accounting principles generally accepted in the United States of America. We believe that the results of our procedures provide a reasonable basis for our conclusion.

Accountant’s Conclusion Based on our review, we are not aware of any material modifications that should be made to the accompanying financial statements in order for them to be in accordance with account- ing principles generally accepted in the United States of America. Because of the inherent limitations of a review engagement, this report is intended for the information of manage- ment and should not be used for any other purpose.

Other Matter We audited the financial statements for the year ended December 31, 2019, and our report was dated March 2, 2020. We have no responsibility for updating that report for events and circumstances occurring after that date.

Jordan and Stone, CPAs Chicago, IL

March 1, 2021

Required: These supervisor’s review notes may or may not be correct. For each item a–m, indicate whether Stone is correct (C) or incorrect (I) in the criticism of Kent’s draft.

a. The report should contain no reference to the prior-year audited financial statements in the first paragraph.

b. All current-year financial statements are not properly identified in the first paragraph. c. The report should contain no reference to the American Institute of Certified Public

Accountants in the first paragraph. d. The basic procedures performed in a review (analytical procedures and inquiries) should

be provided in the Accountant’s Responsibility Section of the report and not the first paragraph.

e. The report should contain no comparison of the scope of a review to an audit in the first paragraph.

f. Limited assurance should be expressed on the current-year reviewed financial statements in the first paragraph.

g. The report should contain a statement that no opinion is expressed on the current-year financial statements in the first paragraph.

h. The report should contain a reference to “accounting principles generally accepted in the United States of America” in the Management’s Responsibility for the Financial State- ments Section.

i. The report should not express a restriction on the distribution of the accountants’ review report in the Accountant’s Conclusion Section.

j. The report should not contain a reference to “material modifications” in the Accountant’s Conclusion Section.

k. The report should indicate the type of opinion expressed on the prior-year audited finan- cial statements in the other-matter paragraph.

l. The report should indicate that no auditing procedures were performed after the date of the report on the prior-year financial statements in the other-matter paragraph.

m. The report should not contain a reference to “updating the prior-year auditors’ report for events and circumstances occurring after that date” in the other-matter paragraph.

(AICPA adapted)

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A.69 Compilation and Review Procedures. The following numbered items 1–10 state pro- cedures accountants should consider performing in review engagements and compilation engagements on the annual financial statements of non-issuers.

Required: For each item (taken separately), tell whether the item is required in all review engagements and/or required in all compilation engagements. For each item, give two responses, one regarding review engagements and the other regarding compilation engagements.

1. The accountants should establish an understanding in writing with the entity’s manage- ment regarding the nature and limitations of the services to be performed.

2. The accountants should make inquiries concerning actions taken at the board of direc- tors’ meetings.

3. The accountants, as the entity’s successor accountants, should communicate with the predecessor accountants to obtain access to the predecessors’ documentation.

4. The accountants should obtain a level of knowledge of the accounting principles and practices of the entity’s industry.

5. The accountants should obtain an understanding of the entity’s internal control over financial reporting.

6. The accountants should perform analytical procedures designed to identify unusual relationships.

7. The accountants should assess the risk of material misstatement. 8. The accountants should obtain a letter from the entity’s attorney to corroborate the infor-

mation furnished by management concerning litigation. 9. The accountants should obtain written representations from the entity’s management. 10. The accountants should study the relationship of the financial statement elements that

would be expected to conform to a predictable pattern. (AICPA adapted)

A.70 Limited Assurance in Review Reports. One portion of the report on a review services engagement is the following: “Based on my review, I am not aware of any material modifica- tions that should be made to the accompanying financial statements in order for them to be in conformity with accounting principles generally accepted in the United States of America [or another framework for financial reporting].”

Required: a. Does this paragraph represent “limited assurance” provided by the accountants? b. Why is limited assurance generally prohibited in audit reports? c. What justification is there for permitting limited assurance in a review engagement on the

financial statements of a non-issuer? (AICPA adapted)

A.71 Prepare a Compilation Report. The Coffin brothers have engaged you to compile their financial schedules from books and records maintained by James Coffin. The brothers own and operate three auto parts stores in Central City. Even though their business is growing, they have not wanted to employ a full-time bookkeeper. James specifies that all he wants is a balance sheet, a statement of operations, and a statement of cash flows. He does not have time to prepare footnotes to accompany the financial statements.

James directed the physical count of inventory on June 30, 2021 and adjusted and closed the books on that date. You find that he actually is a good accountant, having taken some night courses at the community college. The accounts appear to have been maintained in conformity with generally accepted accounting principles. At least you have noticed no obvious errors.

Required: You are independent with respect to the Coffin brothers and their Coffin Auto Speed Shop business. Prepare a report on your compilation engagement.

A.72 Reporting on Comparative Unaudited Financial Statements. A. Jones, CPA, performed a review service for the Independence Company in 2020. He wants to present comparative financial statements. However, the 2019 statements were compiled by Able and Associates,

LO A-4

LO A-4

LO A-4

LO A-4

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CPAs, and Able has not agreed to reissue the prior-year compilation report. Jones has no indication that any adjustments should be made to either the 2020 or the 2019 financial statements, which are to be presented with all necessary disclosures. However, he does not have time to perform a review of the 2019 financial statements. Jones completed his work on January 15, 2021, for the financial statements dated December 31, 2020.

Required: Write Jones’s review report and include the paragraph describing the report on the 2019 statements. List any assumptions Jones needs to make to write the report.

A.73 Various Engagement and Reporting Standards. Indicate the type of standards [Statements on Auditing Standards (SAS), Statements on Standards for Attestation Engagements (SSAE), PCAOB Attestation Standards (PCAOB), and Statements on Standards for Accounting and Review Services (SSARS)] that may apply to engagements associated with the following:

1. Historical financial information. 2. Prospective financial information. 3. Compliance with laws and regulations (conducted in conjunction with an audit) 4. Operating effectiveness of internal controls applied at a service organization. 5. Performing agreed-upon procedures on historical financial statements. 6. Matters relating to broker–dealer compliance. 7. Audited financial statements prepared using a special purpose framework. 8. Compliance with laws and regulations for a non-issuer (not conducted in conjunction

with a financial statement audit). 9. Engagements lesser in scope than an audit on historical financial information 10. Audits on elements, account or items of a financial statement A.74 Various Engagements on Historical Financial Information. Indicate which of the

engagements performed on historical financial information [examination (E), agreed-upon procedures (AU), review (R), compilation (C), and preparation (P)] are associated with the following statements. (Your responses may be “Yes,” “No,” or “Possibly.”)

1. Accountant prepares an engagement letter with the client to document an understanding of the scope of the engagement.

2. Accountant works with identified users in establishing the scope of the engagement. 3. Accountant performs the engagement in accordance with generally accepted auditing

standards. 4. Engagement requires accountant to perform some level of substantive procedures. 5. Engagement allows accountant to express limited assurance on the fairness of the finan-

cial statements. 6. Accountant is required to be independent to conduct engagement. 7. Accountant will perform inquiries of management during the engagement. 8. Engagement allows accountant to express an opinion on the fairness of the financial

statements. 9. Distribution of the accountants’ report is limited to specified users. 10. Accountant obtains an understanding of the client’s internal control over financial

reporting. A.75 Internet Exercise: CPA WebTrust. Visit the AICPA WebTrust site (www.webtrust.org).

Required: a. What is WebTrust? b. Why is WebTrust needed? c. How does an Internet user know that a website has received the WebTrust service? A.76 Assurance Services. Davis has a store that sells old baseball cards. To expand the business,

he has decided to open an Internet site where potential customers can view the cards and place orders. Davis hires Johnson, who is an expert in constructing websites for small busi- nesses. She explains that even with a quality website and pictures of the merchandise for sale, customers may be reluctant to purchase baseball cards from Davis’s website.

LO A-2, A-3, A-4

LO A-2, A-3, A-4

LO A-5

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Required: a. Explain the reasons for Johnson’s concerns. b. What steps can Davis and Johnson take to reduce customer’s reluctance to make pur-

chases on the Internet? A.77 Assurance Services. Henry’s Health Food Store maintains a perpetual inventory on its

computer. The sales representative from A-Plus Vitamins has recommended the following to Henry:

∙ All the files should have password protection. ∙ A-Plus Vitamins should be given the URL and the password for Henry’s inventory file on

the computer, which can be accessed from outside. ∙ A-Plus Vitamins will search the inventory for items that fall below an established reorder

point and will automatically ship a set amount of product to Henry’s.

Required: a. What are the advantages of this arrangement for Henry’s? For A-Plus Vitamins? b. What concerns might Henry’s have in this arrangement? c. How might these concerns be addressed? A.78 Internet Assignment: Global Reporting. Go to the Global Reporting Initiative web-

site (www.globalreporting.org) and obtain the G4 Reporting Principles and Standard Disclosures.

Required: a. Identify the three categories of topic-specific standard disclosures. For each category,

identify the subcategories of disclosures. b. How can accountants provide assurance for sustainability reporting as a service to their

clients?

LO A-5

LO A-5

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Theodore Roosevelt, 26th President of the United States (1858–1919)

To educate a person in mind and not in morals is to educate a menace

to society.

Professional Ethics

M O D U L E B

Always do right—this will gratify some and astonish the rest.

Mark Twain, famous American writer (1835–1910)

Topic AU-C/ISA Section

AS Section

Responsibilities and Functions of the Independent Auditor 200 1001 Independence 1005 Training and Proficiency of the Independent Auditor 1010 Due Professional Care in the Performance of Work 1015 Engagement Quality Review 220 1220 Responsibility Not to Knowingly or Recklessly Contribute to Violations Rule 3502 Auditor Independence Rule 3520 Contingent Fees Rule 3521 Tax Transactions Rule 3522 Tax Services for Persons in Financial Reporting Oversight Roles Rule 3523 Audit Committee Preapproval of Certain Tax Services Rule 3524 Audit Committee Preapproval of Nonaudit Services Related to Internal Control over Financial Reporting Rule 3525 Communication with Audit Committees Concerning Independence Rule 3526

ET Section† Members in Public Practice ET 1.000 –1.800 Members in Business ET 2.000–2.400 Other Members ET 3.000–3.400 AICPA Council Resolution Designating Bodies to Promulgate Technical Standards ET Appendix A AICPA Council Resolution Concerning Form of Organization and Name (Rule 505) ET Appendix B AICPA Code of Conduct Revision History Table ET Appendix C AICPA Code of Conduct Mapping Document ET Appendix D

Professional Standards References

†ET references represent sections in the AICPA Code of Professional Conduct.

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LEARNING OBJECTIVES As described in Chapter 2, the responsibilities principle identifies three specific responsibilities. Two of the responsibilities—(1) having appropriate competence and capabilities to perform the audit and (2) maintaining professional skepticism and exercising professional judgment throughout the planning and performance of the audit—have been focused on in other chapters of this book. This module focuses on the third responsibility: complying with relevant ethical requirements. In this spirit, this module is designed to teach you about the AICPA Code of Professional Conduct and demonstrate why it is so important to your success as a professional accountant. As you will soon learn, regulation of the profession, including any discipline for violations, depends on the prevailing published codes of ethics and enforcement practices. As a result, we believe this module is essential to your success.

Your objectives are to be able to:

LO B-1 Understand general ethics and a series of steps for making ethical decisions.

LO B-2 Reason through an ethical decision problem using the imperative, utilitarian, and virtue theories of moral philosophy.

LO B-3 Identify the different entities that make ethics rules for CPAs and public accounting firms.

LO B-4 With reference to American Institute of Certified Public Accounting (AICPA), Government Accountability Office (GAO), Public Company Accounting Oversight Board (PCAOB), and Securities and Exchange Commission (SEC) rules, analyze factual situations and decide whether an accountant’s conduct does or does not impair independence.

LO B-5 With reference to AICPA rules on topics other than independence, analyze factual situations and decide whether an accountant’s conduct does or does not conform to the AICPA Code of Professional Conduct.

LO B-6 Explain the types of penalties that can be imposed on accountants.

INTRODUCTION Scott London seemed to have it all. One of three sons of a Los Angeles certified public accountant, he followed his father into the accounting business. He graduated in 1984 from California State University–Northridge, and soon landed a job at a firm that later became part of KPMG. From an outsider’s perspective, London appeared to have an ideal personal life. He and his wife Michele had two children and lived in an expensive home at the end of a cul-de-sac in a Los Angeles suburb known as the gateway to the Santa Monica Mountains. Professionally, as the KPMG partner in charge of the firm’s Pacific Southwest Audit practice, he had more than 50 partners and 500 employees reporting to him. After 29 years with the firm, he seemed to be set financially. However, with all this going for him, he plead guilty to passing confidential client information to a golf buddy who then traded stocks based on the information to make more than $1 million in illegal gains. Although the information was initially passed “innocently” in casual conversation on the golf course, London began accepting payments of cash and jewelry in exchange for the tips. Bryan Shaw, the recipient of the information who profited from the illegal trades, cooperated with authorities, including agreeing to wear a wire to gain evidence against his benefactor. In return for the confidential information, London received more than $50,000 in cash and gifts, including a $12,000 Rolex watch; however, the total value of these “gifts” is clearly immaterial given London’s estimated salary of greater than $1 million per year.

The sting operation that nabbed London was the result of a joint investigation by the FBI, SEC, and Department of Justice. When first notified of the allegations, KPMG acted immediately and decisively, firing London, who the firm said “violated the firm’s rig- orous policies and protections, betrayed the trust of clients as well as colleagues, and

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acted with deliberate disregard for KPMG’s long-standing culture of professionalism and integrity.”1 The firm also took legal action against London. Due to independence concerns, the firm resigned as auditor of Skechers and Herbalife, companies whose audits London oversaw. KPMG also announced that it would reassess its quality control standards, which include employee training, monitoring key employees’ personal invest- ments, and a whistleblowing hot line.

In addition to losing his job and being sued by his former employer, London ended up serving 14 months in prison and paying $100,000 in fines. He is still on probation and performing community service. He has openly confessed to his misconduct and has expressed his remorse: “I cannot begin to apologize for my incredibly stupid actions. There is no excuse for my wrongful conduct.” However, even in hindsight, London has trouble explaining his behavior: “I felt guilt about it regularly—I can’t explain it to be honest with you. . . . I look back at when this started and I can’t explain it. . . . I guess [the] best way to describe it is that humans make mistakes.”2

We may never know the true motives behind his actions, but we do know that London made a conscious decision to betray his employer, his clients, and his profession, violating a number of rules from the AICPA Code of Professional Conduct in the process. In this module, we discuss the AICPA Code of Professional Conduct and many of the rules that London violated when sharing stock tips on the golf course.

GENERAL ETHICS What is ethics? Wheelwright defined ethics as “that branch of philosophy which is the systematic study of reflective choice, of the standards of right and wrong by which it is to be guided, and of the goods toward which it may ultimately be directed.”3 In this definition, you can detect three key elements about ethics. First, ethics involves ques- tions requiring reflective choice (decision problems). Second, ethics involves guides of right and wrong (moral principles). And third, ethics is concerned with the consequences (good or bad) of decisions.

What is an ethical problem? A problem situation exists when an individual must make a choice among alternative actions and the right choice is not absolutely clear. An ethi- cal problem situation may be described as one in which the choice of alternative actions affects the well-being of other persons. Although these are technical definitions of ethical dilemmas, we are often faced with situations in which what we want to do conflicts with what we know is the right course of action. While pure ethicists may argue that these are not “pure” ethical dilemmas, this does not make the decisions any easier to make.

What is ethical behavior? You can find three standard philosophical answers to this question: Ethical behavior is that which (1) produces the greatest good, and/or (2) con- forms to moral rules and principles, and/or (3) best demonstrates the virtues you value most. The most difficult problem situations arise when two or more rules conflict or when a rule and the criterion of “greatest good” conflict. However, as a professional auditor, you must always conform to the code of ethical behavior that applies to your jurisdiction or face the possibility of being formally sanctioned by the profession.

Why does an individual or group need a code of ethical conduct? A code makes explicit some of the criteria for conduct unique to the profession. Codes of professional ethics provide guidance in addressing situations that may not be specifically available in general ethics theories. An individual is better able to know what the profession expects. From the viewpoint of the organized profession, a code is a public declaration of principled conduct

1Geller, Martinne, and Emily Flitter. “FBI probes trading as KPMG quits Herbalife, Skechers audits.” Reuters, April 9, 2013. https:// www.reuters.com/article/us-herbalife-auditor/fbi-probes-trading-as-kpmg-quits-herbalife-skechers-audits-idUSBRE9380N920130409. 2“Insider Trader Is Identified,” The Wall Street Journal, April 11, 2013, p. C1. 3Philip Wheelwright, A Critical Introduction to Ethics, 3rd ed. (Indianapolis, IN: Odyssey Press, 1959).

LO B-1 Understand general ethics and a series of steps for making ethical decisions.

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and a means of facilitating enforcement of standards of conduct. Once again, you can see the value of ethical behavior. Remember that accounting is the only business discipline that is considered a profession similar to those of doctors and lawyers. As a student of auditing, you must commit yourself to knowing and understanding the AICPA Code of Professional Conduct. Understanding the Code of Professional Conduct will allow you to be better prepared to handle difficult situations like the one posed in the following ethical example.

AN ETHICAL DECISION PROCESS When considering general ethics, your primary goal is to arrive at a personal framework for making ethical decisions. Consequently, an understanding of some of the general principles of ethics can provide background for a detailed consideration of standards for professional conduct.

In the earlier definition of ethics, one of the key elements was reflective choice. This involves engaging in an important sequence of events beginning with the recognition of a decision problem. Collection of evidence, in the ethics context, refers to thinking about rules of behavior and outcomes of alternative actions. The process ends with analyzing the situation and taking an action. Ethical decision problems almost always involve pro- jecting yourself into the future to live with your decisions. Professional ethics decisions usually turn on these questions: “What written and unwritten rules govern my behav- ior?” and “What are the possible consequences of my choices—whom will my deci- sion affect?” Principles of ethics can help you think about these two questions in real situations.

A good way to approach ethical decision problems is to think through several steps:

1. Define all facts and circumstances known at the time you need to make the decision. They are the “who, what, where, when, and how” dimensions of the situation. Identify the actor who needs to decide what to do. a. Because ethical decision problems are defined in terms of their effects on people,

identify the people involved in the situation or affected by it. These are the “stake- holders”; be careful not to expand the number of stakeholders beyond the bounds of reasonable analysis.

b. Identify and describe the stakeholders’ rights and responsibilities in general and to each other.

2. Specify the actor’s major alternative decision actions and their consequences (good, bad, short-run, long-run).

3. The actor must choose among the alternative actions.

Let’s apply the preceding ethical framework to the following ethical decision.

LO B-2 Reason through an ethical decision problem using the imperative, utilitarian, and virtue theories of moral philosophy.

In a famous experiment conducted by Stanley Milgram (a psychologist at Yale University), subjects were told to ask questions of an individual in another room. If the individual answered incorrectly, the subjects were told to inflict an electric shock as punishment. In reality, no shock was actually administered; however, the subjects believed they were admin- istering one and could hear shouts, cries, and appeals to stop emanating from the next room. The experimenter ordered the subjects to continue

to apply the shocks at ever-increasing amounts. Many subjects increased the voltage to intensities labeled as dangerous and continued even after the individual in the next room asked for a doctor. Why do you think the subjects continued to apply shocks? What would you have done in this circumstance? Many have used the Milgram study result as an explana- tion for how good people often get caught up in wide-reaching accounting frauds, by subordinating their judgments to authority figures.

A Shocking Example of Unethical Behavior

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PHILOSOPHICAL PRINCIPLES IN ETHICS We could skip a discussion of ethical theories if we were willing to accept a simple rule: “Let your conscience be your guide.” Such a rule is appealing because it calls on an indi- vidual’s own judgment, which may be based on wisdom, insight, adherence to custom, or an authoritative code. However, it also might be based on caprice, immaturity, ignorance, stubbornness, or misunderstanding. Often, as in the Milgram experiments, undue pressures might cause us to act in a way that we will later regret. The problem with using conscience as a guide is that it sometimes tells you about a wrong decision after you take action!

In a similar manner, reliance on the opinions of others or on the weight of opinions of a particular social group is not always enough. Another person or a group of persons may perpetuate a custom or habit that is wrong. To adhere blindly to custom or to group habits is to abdicate individual responsibility. Titus and Keeton summarized this point succinctly: “Each person capable of making moral decisions is responsible for making his own decisions. The ultimate locus of moral responsibility is in the individual.”4 This does not mean you should not consult with friends, colleagues, or family members when facing a dilemma, but that only you have the final responsibility.

There are several philosophies, often referred to as ethical principles, that may be used to guide the ethical decision process. Thus, the function of ethical principles is not to provide a simple and sure rule but to provide some guides for your individual decisions and actions. Of course, as a professional auditor, you are required to follow the code of professional conduct. So, in that sense, professional auditors must always apply the imperative principle first and foremost. However, because many decisions go beyond the code, the principle of utilitarianism and the generalization argument are also considered. Finally, the decision must align with your own character (or virtue).

The Imperative Principle The imperative principle directs a decision maker to act according to the requirements of moral rules and principles. Strict versions of the imperative principle maintain that a decision should be made without trying to predict whether an action will create the 4H. H. Titus and M. Keeton, Ethics for Today, 4th ed. (New York: American Book–Stratford Press, 1966), p. 131.

Step 1: Define the Problem Kathy Ellis (the chief financial officer) ordered Jorge Santos (a staff accountant) to “improve” net income in the financial statements to be submitted in a loan application to Spring National Bank by understating the allowance for uncollectible accounts receivable say- ing, “It’s an estimate anyway and we need the loan for a short time to keep from laying off our loyal employees.” What should Santos do?

Step 1a: Define the Stakeholders The stakeholders include the direct participants—Ellis, Santos, and Luis Perez (Spring National Bank’s loan officer)—and some indirect participants—bank stockholders and loyal employees. Other people may be affected—Santos’s mother, citizens who depend on the solvency of the banking system as a whole, taxpayers who may eventually need to bail out the insolvent banking system, and others—but identifying them probably will not improve the analysis.

Step 1b: Define the Responsibilities of the Individuals Ellis and Santos should act with integrity, and Ellis should not pressure Santos to cut cor- ners with financial statements. Perez should make careful loan approval decisions. Rights: Santos should not be subject to pressures to cut corners with “improved financial statements.” Perez should receive information that is not materially misstated or manipulated. (Some rights of employees and bank stockholders also could be identified.)

Step 2: Determine the Consequences (a) Santos can follow orders and improve the financial statements: Ellis is happy, he keeps his job; Perez

gets fooled and approves the loan; the employees keep their jobs; the company may fail; the bank may be unable to collect the loan; the employ- ees are laid off anyway; and Ellis and Santos are prosecuted and con- victed of making false statements to a federal institution and go to federal prison. (b) Santos can refuse to “improve” the financial statements: Ellis is not happy; Santos is fired; Ellis prepares the financial statements herself; and so on. (c) Santos persuades Ellis of the potential problems and Perez refuses the loan, and the company must find another way to survive;or Perez approves the loan anyway and the bank takes the risk; or Ellis does not agree, and Santos must again face alternatives (a) and (b) anyway. There is a fourth alternative, (d): Santos could resign. This alternative may seem like an ideal way for Santos to extricate himself from the situation, but the problem facing others in this scenario does not go away.

In addition to weighing the consequences, Santos also should consider general and professional rules. If he is a CPA, some of the relevant profes- sional rules relate to maintaining integrity (AICPA Rule 102), application of accounting standards (AICPA Rule 203), and the prohibition of discredit- able acts (AICPA Rule 501). Santos needs to decide whether to follow rules or balance the expected consequences in the particular situation. Step 3 Choose a Course of Action: As the actor, Santos must choose one of the alternative actions and justify it by presenting a convincing argument for its superiority. He can base the argument on rules, conse- quences, or a combination of both.

AN EXAMPLE OF AN ETHICAL DECISION PROCESS

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greatest balance of good over evil. Rather, ethics in the imperative sense is a function of moral rules and principles and as such does not involve a situation-specific calculation of the consequences.5

The philosopher Immanuel Kant (1724–1804) was perhaps the foremost advocate of the imperative school. Kant maintained that reason and the strict duty to be consistent should govern our actions. He believed that individuals should act only as they think everyone should act all of the time. This law of conduct (in moral philosophy) is known as Kant’s categorical imperative, meaning that it specifies an unconditional obligation. One such maxim (rule), for example, is “Lying is wrong.”

Suppose you believe that Santos (from our earlier ethical decision process example) should agree with Ellis and do everything she asked for by “improving the financial state- ments,” thus participating in a lie (knowingly misrepresenting the facts about the allow- ance for uncollectible accounts receivable). The Kantian test of the morality of such a lie is this: Can this maxim be a moral rule that should be followed without exception by all persons who have the opportunity to fool a bank loan officer for a good cause? If Santos refuses to manipulate the financial statements and the loan is refused, the result may be economic hardship and employee layoffs. Kant maintained that motive and duty alone define a moral act, not the consequences of the act. This reasoning places the highest value on the duty to be consistent and a lower value on the consequences, in this case the fate of the employees.

The general objection to the imperative principle is the belief that so-called universal rules always turn out to have exceptions. The general response to this objection is that if the rule is stated properly to include the exceptional cases, the principle is still valid. The prob- lem with this response, however, is that human experience is complicated, and extremely complex universal rules would have to be constructed to try to cover all possible cases.6

Most professional codes of ethics have characteristics of the imperative type of theory. As a general matter, professionals are expected to act in a manner in conformity with the rules. As it relates to your work as an audit professional, this principle would lead you to follow the code of professional conduct to the letter of the law. This, of course, is what you must do to avoid being sanctioned by the profession. However, society frequently questions not only conduct itself, but also the rules on which conduct is based. Thus, a dogmatic impera- tive approach to ethical decisions may not be completely sufficient for the maintenance of professional standards. Society may question the rules, and conflicts among them are always possible. A means of estimating the consequences of alternative actions may be useful.

5I. Kant, Foundations of the Metaphysics of Morals, trans. Lewis W. Beck (Indianapolis, IN: Bobbs-Merrill, 1959; originally published in 1785). 6Several rules in the AICPA Code of Professional Conduct are explicitly phrased to provide for exceptions to the general rules, nota- bly Rules 203 and 301. Imperative rules also seem to generate borderline cases, so the AICPA Ethics Division issues interpretations and rulings to explain the applicability of the rules.

An Ethical Conflict Consolidata Inc. was a tax client of Alexander Grant & Company, CPAs (AG). Consolidata prepared payrolls for 38 customers, received the cus- tomers’ money, and then paid the payrolls. AG learned that Consolidata was in serious financial difficulty and advised the company to inform its customers, but company officials did not do so. When AG learned that the company’s officers and directors had resigned, AG telephoned 12 Consoli- data customers who were also AG clients, told them of the situation, and advised them not to entrust further payroll funds to Consolidata. The 12 were spared the risk of losing their money when Consolidata went out of business one month later.

Consolidata accused AG of breach of contract for breaking an obliga- tion of confidentiality required by the AICPA Code of Professional Conduct (discussed later in this module). One SEC attorney said she thought AG should have alerted all 38 customers, not just the 12 AG clients. Accoun- tants and SEC officials viewed the situation as a balancing of confiden- tiality (AICPA rule) against the public interest (Consolidata customers who needed a warning). Ethicists would view this dilemma as a conflict between an imperative principle (client confidentiality) and the principle of utilitarianism (what action benefits the most parties), which is now dis- cussed in detail.

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The Principle of Utilitarianism The principle of utilitarianism emphasizes examining the consequences of action rather than following some rules. The criterion of producing the greater good is made an explicit part of the decision process. The principle is very useful, but be sure to notice that it does not specify the values that enable you to determine the good or evil of an action. In act- utilitarianism, the center of attention is the individual act as it is affected by the specific circumstances of a situation. The general difficulty with act-utilitarianism is that it seems to permit too many exceptions to well-established rules. By focusing attention on individ- ual acts, the long-run effect of setting examples for other people appears to be ignored. If an act-utilitarian decision is to break a moral rule, the decision’s success usually depends on everyone else’s adherence to the rule, which is highly unlikely in auditing.

Rule-utilitarianism, on the other hand, emphasizes the centrality of rules for ethical behavior while still maintaining the criterion of the greatest universal good. This kind of utilitarianism means that decision makers must first determine the rules that will promote the greatest general good for the largest number of people. The initial question is not which action has the greatest utility but which rule.

The Generalization Argument The generalization argument may be considered a judicious combination of the impera- tive and utilitarian principles. Basically, the generalization argument considers the con- sequences of a decision made by similar persons acting under similar circumstances.7 A more everyday expression of the argument is this question: “What would happen if every- one acted in that certain way?” If the answer to the question is that the consequences would be undesirable, the conclusion, according to the generalization test, is that the way of acting is unethical and should not be done.

In our ethical decision example, Santos’s problem as a professional accountant and as an employee arose when Ellis asked him to “improve the financial statements” and he saw the enhancement as a lie. His generalization question may be something like this: “What if all accountants fudged financial statements and fooled loan officers when their companies needed to obtain loans?” Most people will see an easy answer: The result would be undesirable (because it might succeed often and cause considerable losses to banks along with other undesirable personal consequences for the actors in addition to the problem of having broken a rule that requires truth telling). Another kind of conflict subject to the generalization test is illustrated by the decision made by Equifax to wait six weeks to notify the public about the largest data breach in history. (See the Auditing Insight “Equifax Breach Exposes Personal Information.”)

Virtue Ethics Virtue ethics can be traced not only to the Greek philosophers Aristotle and Plato (his Republic discusses the Four Cardinal Virtues: wisdom, justice, fortitude, and temper- ance), but also to Buddhist ethical tradition. Rather than a focus on following rules or weighing outcomes, virtue ethics emphasizes the role of one’s character in the decision- making process. Questions that may be asked include, “What action will help me become my ideal self?” or, “What action would I be the proudest of?”

To contrast the different approaches, consider the example of cheating on a class assign- ment. A utilitarian approach might weigh the potential positive outcome of cheating (“I need to pass this class”) against the negatives ones (hurting others’ grades, possibly getting caught). Under Kant’s categorical imperative approach, cheating is always wrong, no matter what pos- itive outcomes may come from it. Under the Aristotelian virtue ethics approach, one would consider whether cheating was most aligned with the person the student aspired to be.

This brief review of ethical principles provides some important background to the ways that many people approach difficult ethical decision problems. As a professional auditor,

7M. G. Singer, Generalization in Ethics (New York: Atheneum, 1961, 1971), esp. pp. 5, 10–11, 61, 63, 73, 81, 105–122.

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you are required to adhere to the prevailing code of conduct in all your duties. However, there will be times in your career when the code does not go far enough. In those situations, it is important to consider the three major approaches to ethical decision making—the categorical imperative’s focus on rules, utilitarianism’s focus on outcomes, and virtue ethics’ focus on character—and apply them to decisions. Deciding how you will behave (i.e., what ethical principle you will follow) before you find yourself in an ethical dilemma can prepare you for the kind of pressures the Milgram subjects and our hypothetical Santos experienced and allow you to make decisions of which you will be proud.

REVIEW CHECKPOINTS B.1 What roles must a professional accountant be prepared to perform in regard to ethical decision problems? B.2 When might the rule “Let your conscience be your guide” not be a sufficient basis for (a) your per-

sonal ethical decisions and (b) your professional ethical decisions? B.3 Assume that you accept the following ethical rule: “Failure to tell the whole truth is wrong.” In the text-

book illustration about Santos’s problem with Ellis’s instructions, (a) what would this rule require Santos to do, and (b) why is an unalterable rule such as this classified as an element of imperative ethical theory?

B.4 How do utilitarian ethics differ from imperative ethics?

ETHICAL CODES OF CONDUCT Independence, professionalism, and integrity have long been concerns of the auditing profession, but the accounting scandals that occurred at the turn of the century (e.g., Enron, WorldCom, Waste Management) and the financial crisis that occurred later that decade brought a renewed focus and emphasis on these issues that remain today. The PCAOB was created, in part, to help bring a new level of independence and integrity to the profession. In that spirit, the PCAOB has issued a number of rules that apply to audi- tors of issuers. Furthermore, public accounting firms and CPAs also must follow rules set forth by the SEC and the AICPA Professional Ethics Executive Committee (PEEC). Public accounting firms and CPAs completing multinational audits also must comply with the International Federation of Accountants (IFAC) Code of Ethics for Professional Accountants. If you are an internal auditor, you will be expected to observe the rules of conduct of the Institute of Internal Auditors (IIA). As a management accountant, the standards of ethical conduct for management accountants of the Institute of Management Accountants (IMA) will apply to you. Certified fraud examiners are expected to observe

LO B-3 Identify the different entities that make ethics rules for CPAs and public accounting firms.

The largest data breach in history resulted in the names, addresses, and social security numbers of over 147 million Americans being stolen. The data breach occurred in May 2017 but wasn’t discovered by Equifax until July 29, nearly two months later. It took the com- pany another six weeks before notifying the public that names and social security numbers of millions had been stolen. Can you imagine if all CEOs waited so long to notify affected customers about a data breach? The generalization argument would clearly suggest an unde- sirable outcome.

Interestingly, in the aftermath, the SEC brought charges against former Equifax Chief Information Officer Jun Ying in March of 2018,

for using his knowledge of the breach to sell shares of the compa- ny’s stock before the breach was made public. By then, Equifax had already fired Ying in October 2017 following his disclosure to execu- tives in September 2017 that he sold his stock, perhaps after thinking about the generalization argument.

https://www.cnet.com/news/former-equifax-executive-charged- with-insider-trading/

https://www.secureworldexpo.com/industry-news/day-by-day-timeline- of-equifax-breach

Equifax Breach Exposes Personal InformationAUDITING INSIGHT

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the Association of Certified Fraud Examiners (ACFE) Code of Ethics. If you find this “alphabet soup” of ethics rule makers confusing, imagine those CPAs who have to deal with complex and often conflicting rules on a daily basis. As a CPA, you will be expected to observe rules of conduct published in several codes of ethics, depending on your own jurisdiction and service area. In summary, if you join the AICPA and a state society of CPAs and practice before the U.S. Securities and Exchange Commission (SEC) on a mul- tinational audit client, you will be subject to the following:

Source of Rules of Conduct Applicable to

U.S. Securities and Exchange Commission (SEC) Persons who practice before the SEC as accountants and auditors for SEC-registered companies

Public Company Accounting Oversight Board (PCAOB)

Registered firms and individuals who perform audits of companies under the jurisdiction of the PCAOB

International Federation of Accountants (IFAC) Public accounting firms and CPAs performing audits of multinational companies

American Institute of CPAs (AICPA) AICPA members

Applicable state society of CPAs Members of a state society of CPAs

Applicable state board of accountancy Persons licensed by the state to practice accounting

U.S. Securities and Exchange Commission (SEC) The SEC has federal statutory authority to regulate the public accounting profession for the purposes of (1) protecting the reliability and integrity of the financial statements of public companies and (2) promoting investor confidence in financial statements and the securities markets. The SEC’s jurisdiction covers only issuers that are required by federal securities laws to file financial statements audited by independent accountants. In addiv- tion to the duties outlined earlier, the passage of the Sarbanes–Oxley Act in 2002 requires the SEC to oversee the PCAOB.

The Public Company Accounting Oversight Board (PCAOB) The PCAOB is responsible for setting standards for public accounting firms and to oversee quality control, ethics, and independence issues for accounting professionals who audit the financial statements of issuers. Students are urged to review the PCAOB website (www.pcaobus.org) for the latest standards and rules issued by the PCAOB.

The final authority for all matters related to the audits of issuers remains with the SEC. As a result, the SEC must approve all PCAOB proposed rules and standards before they are final. Also, even though the PCAOB has authority over the audits of only public entities, it would be a mistake to believe that the PCAOB’s influence ends there. Indeed, several states (e.g., California) have passed legislation that incorporates PCAOB rules into state law applicable to audits of all companies, both public and private.

A trial board of the ACFE found that a member had wrongfully repre- sented himself as a certified internal auditor when in fact he did not hold the CIA designation. Such conduct is in violation of Article 1.A.4 of the Certified Fraud Examiners Code of Professional Ethics, and the member was summarily expelled from the organization.

L. Jackson Shockey, CFE, CPA, CISA, chairperson of the board of regents, said: “We are saddened that a member has been expelled for

such conduct. However, in order to maintain the integrity of the CFE program, the trial board vigorously investigates violations of the Code of Professional Ethics. When appropriate, the board of regents will not hesitate to take necessary action.”

Source: CFE News.

Fraud Auditor Expelled for Committing FraudAUDITING INSIGHT

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The International Federation of Accountants (IFAC) For audits of multinational companies, auditors must follow the guidelines promulgated by the IFAC. IFAC’s International Ethics Standards Board for Accountants is responsible for the Code of Ethics for Professional Accountants (IESBA Code), which is the code of conduct that governs the audits of multinational companies.8 Although there are differences between the IESBA Code and the AICPA Code of Professional Conduct used to govern the audits of U.S. companies (which will be described later in this module), the codes are actually quite similar. In general, a CPA should always comply with the more restrictive standard that is applicable on a particular audit engagement. Not surprisingly, with the dramatic increase in audits of multinational companies by public accounting firms from the United States, the importance of the IESBA Code has increased. Indeed, the AICPA has just completed a convergence and codification project designed to align the AICPA and IESBA codes and simplify the overall structure of the AICPA Code.

The Professional Ethics Executive Committee (PEEC) of the American Institute of CPAs (AICPA) The PEEC is the AICPA committee that makes and enforces all rules of conduct for CPAs (i.e., the AICPA Code of Professional Conduct) who are AICPA members. You might think that if you were not in public accounting and not a member of the AICPA, the rules would not apply. However, state and federal court proceedings and disciplinary bodies have consistently upheld that CPAs must adhere to professional ethical standards even if they are not members of the AICPA. Furthermore, most states incorporate the AICPA Code of Professional Conduct into their own accounting statutes.

Back in 2014, the PEEC completed a project to completely recodify the AICPA’s ethics standards in an effort to increase its accessibility and usefulness to members. The code is structured into topical areas and now reflects a “conceptual framework” type of approach. Importantly, the recodified standards closely follow the IESBA ethical standards. The AICPA Code of Professional Conduct contains four parts. The first section, referred to as the Preface, includes a discussion of the Principles of Professional Conduct, a set of six positive essays expressing the profession’s high ideals:

I. Responsibilities. In carrying out their responsibilities as professionals, members should exercise sensitive professional and moral judgments in all of their activities.

II. The public interest. Members should accept the obligation to act in a way that will serve the public interest, honor the public trust, and demonstrate commitment to professionalism.

III. Integrity. To maintain and broaden public confidence, members should perform all professional responsibilities with the highest sense of integrity.

IV. Objectivity and independence. A member should maintain objectivity and be free of conflicts of interest in discharging professional responsibilities. A member in public practice should be independent in fact and appearance when providing auditing and other attestation services.

V. Due care. A member should observe the profession’s technical and ethical standards, strive continually to improve competence and quality of services, and discharge pro- fessional responsibility to the best of the member’s ability.

VI. Scope and nature of services. A member in public practice should observe the Prin- ciples of the Code of Professional Conduct in determining the scope and nature of services to be provided.

The responsibility to the public interest clearly sets accountants apart from other busi- ness professionals. It is the reason that accounting is considered a profession even beyond other professionals such as doctors and lawyers whose primary responsibility is to their patients/clients. However, this responsibility to the public interest demands that CPAs’ work must reflect high levels of moral judgment, true commitment to the public interest, 8The most recent edition of the IESBA Code of Ethics for Professional Accountants was published on July 31, 2018, and is avail- able at http://www.ifac.org/publications-resources/2018-handbook-international-code-ethics-professional-accountants

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and excellent performance. The scope and nature of services refer to the issue of balancing public accounting firms’ commitment to clients (giving business advice and consulting) and commitment to the public (giving opinions on financial statements).

Although the first section of the AICPA Code of Professional Conduct embodies prin- ciples to which CPAs should adhere, they are very general in nature, and thus are difficult, if not impossible, to enforce on their own. The three remaining parts contain enforceable rules that were derived from the six Principles of Professional Conduct. Part 1 applies to members practicing public accounting; Part 2 does the same for those CPAs working in business; and Part 3 applies to all other members, including those who are retired or are between jobs.

REVIEW CHECKPOINTS B.5 In regard to ethics rules, what are the jurisdictions of the (a) AICPA PEEC, (b) SEC, (c) PCAOB, and (d) IFAC? B.6 What organizations and agencies have rules of conduct that you must observe when you practice

(a) public accounting, (b) internal auditing, (c) management accounting, and (d) fraud examination?

AICPA Code of Professional Conduct

AICPA Code of Professional Conduct

Preface: Applicable to All Members

0.100 Overview of the Code of Professional Conduct 1.500 Fees and Other Types of Remuneration 0.200 Structure and Application of the AICPA Code 1.600 Advertising and Other Forms of Solicitation 0.300 Principles of Professional Conduct 1.700 Confidential Information 0.400 Definitions 1.800 Form of Organization and Name 0.500 Nonauthoritative Guidance Part 2 – Members in Business 0.600 New, Revised, and Pending Interpretations and Other Guidance 2.000 Introduction 0.700 Deleted Interpretations and Other Guidance 2.100 Integrity and Objectivity Part 1 – Members in Public Practice 2.300 General Standards 1.000 Introduction 2.310 Compliance with Standards 1.100 Integrity and Objectivity 2.320 Accounting Principles 1.200 Independence 2.400 Acts Discreditable 1.300 General Standards Part 3 – Other Members

1.310 Compliance with Standards 3.000 Introduction 1.320 Accounting Principles 3.400 Acts Discreditable 1.400 Acts Discreditable

The PEEC also publishes interpretations of the Code of Professional Conduct, which are detailed explanations of specific rules necessary to help members understand particu- lar applications. Finally, the PEEC also publishes “rulings” on the applicability of rules in specific situations.9

9The full text of the code of professional conduct, including principles interpretations and rules, is available on the AICPA website ( https://www.aicpa.org/content/dam/aicpa/research/standards/codeofconduct/downloadabledocuments/2014december15conte ntasof2016august31codeofconduct.pdf ).

Principles Aspirational goals of behavior

Rules Enforceable ethical regulations that CPAs must follow

Interpretations Applications of rules to specific business situations

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AN EMPHASIS ON INDEPENDENCE At the time the U.S. Senate passed the Sarbanes–Oxley Act in July 2002 (by a vote of 99–0), the investing public was outraged by the magnitude of the financial statement frauds at both Enron and WorldCom (among many other frauds). The audacity of these frauds is mind boggling. Consider that in 2000, Enron was the seventh largest company on the Fortune 500 with reported assets of $65 billion and sales revenues of $100 billion. However, just a year later, Enron filed for bankruptcy, and billions of shareholder dollars were lost. In June 2002, WorldCom announced that it would be restating its financial statements due to improper accounting that took two major forms: the over- statement of revenue by at least $958 million and the understatement of line costs, its largest category of expenses, by more than $7 billion. The passage of Sarbanes–Oxley was a direct response to these financial statement frauds. Indeed, a number of the sec- tions of the act are specifically targeted to prevent the threats to auditor independence that existed on both the Enron and WorldCom audit engagements. For example, Sec- tion 201 of Sarbanes–Oxley makes it unlawful for a public accounting firm to provide most consulting type services to its audit clients, including information systems design and implementation (e.g., SAP) and internal audit outsourcing. This regulation was clearly designed to prevent the type of relationship that existed between Enron and Arthur Andersen (Andersen). In 2000, Enron paid Andersen $25 million for finan- cial statement audit services and $27 million for consulting and other services, such as internal audit services. The significant amount of revenue generated on consulting services was considered a threat to independence by many, especially considering that the compensation of audit partners at Andersen depended, in part, on consulting sales to its audit clients.

As you will soon learn, the AICPA Code of Professional Conduct (the Code) is crystal clear about the importance of independence. The responsibilities principle requires auditors to maintain independence in mental attitude; that is, auditors are expected to be unbiased and impartial with respect to all professional judgments and to the financial statements they audit. This “state of mind” is often referred to as the auditor’s possess- ing independence in fact. It is important for auditors not only to be unbiased but also to appear to be unbiased. Independence in appearance relates to financial statement users’ perceptions of auditors’ independence. For example, even if the auditors do not have any direct or indirect financial interest or obligation with the audit client, they must ensure that no part of their behavior or actions appears to affect their independence in the opinion of the public. Simply stated, audit quality and the value of the profes- sion depend on independence. If an auditor’s independence is doubted, users of audited financial statements are likely to question the motives of the public accounting firm in completing the audit, greatly diminishing the value of the audit. As a result of its impor- tance, public accounting firms now spend a substantial amount of time making sure they maintain their independence at all times.

American Institute of Certified Public Accountants The PEEC makes independence rules for CPAs that are applicable not only for audits of issuers but also for all other audits (audits of non-issuers, not-for-profit organizations, and government units) and attestation engagements. Independence is required for both audit and attestation engagements, including reviews of financial statements. The Independence Rule, now discussed in detail, is derived from the AICPA Code of Professional Conduct’s objectivity and independence principle.10

LO B-4 With reference to American Institute of Certified Public Accounting (AICPA), Government Accountability Office (GAO), Public Company Accounting Oversight Board (PCAOB), and Securities and Exchange Commission (SEC) rules, analyze factual situations and decide whether an accountant’s conduct does or does not impair independence.

10The AICPA publishes a “Plain English Guide to Independence,” which is designed to increase understanding of the complex independence rules. The guide can be downloaded from the AICPA website athttps://www.aicpa.org/content/dam/aicpa/intere- stareas/professionalethics/resources/tools/downloadabledocuments/plain-english-guide.pdf

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Independence Rule

A member in public practice shall be independent in the performance of professional services as required by standards promulgated by bodies designated by Council. (1.200.001)11

The Independence Rule itself has very little substantive content. Instead, it incorporates PEEC interpretations that are explained in the following paragraphs. The fundamental thrust of these interpretations is that auditors preserve independence, the mental attitude and appearance that auditors are not influenced by others in making judgments and deci- sions, by (1) avoiding financial connections that make it appear that the auditor’s wealth depends on the outcome of the audit and (2) avoiding managerial connections that make it appear that the auditors are involved in management decisions for the audit client (thus auditing their own work).

Essentially, covered members are prohibited from having any financial interest in clients that could affect their audit judgment (independence in fact) or would appear to others to have an influence on their judgment (independence in appearance). In addition, immediate family members are under the same restrictions as the auditor. Again, the appearance of independence would be jeopardized if the auditor’s child owned stock in a client. Similarly, if a close relative or immediate family member worked for a client in a position that could influence the audit (e.g., a controller), independence in appearance, if not in fact, is impaired. Exhibit B.1 provides impor- tant definitions from both the AICPA and the SEC to help professionals clearly under- stand these these issues.

As you can imagine, the application of these definitions by professionals in prac- tice can be difficult. As a result, an important role of the PEEC is to provide inter- pretations of the formal rules. Exhibit B.2 summarizes the PEEC interpretations and other independence matters. So, what do all of these PEEC interpretations mean for applying the independence rules? For most practical purposes, the people who are prohibited from having financial and managerial relationships with the client are the audit engagement team, the people in the chain of command, the covered persons in the public accounting firm, their close family members, and immediate family members.

11The “bodies designated by Council” refers to the PEEC.

EXHIBIT B.1 Comparison of SEC and AICPA Selected Definitions AICPA Definition SEC Definition

Engagement Team Professionals participating in the audit or attest engagement, including those who perform reviews. The audit or attest engagement team includes all professionals and contractors who participate in the audit or attest engagement, irrespective of their functional classification (for example, audit, tax, or management consulting services). The audit or attest engagement team excludes specialists and individuals who perform only routine clerical functions.

All partners, principals, shareholders, and professional employees participating in an audit, review, or attestation engagement of an audit client, including those conducting reviews and all persons who consult with others on the audit engagement team during the audit, review, or attestation engagement regarding technical or industry- specific issues, transactions, or events.

Chain of Command

Partner: A proprietor, shareholder, equity or nonequity partner, or any individual who assumes the risks and benefits of firm ownership or who is held out by the firm to be the equivalent of an owner or partner. Manager: A professional employee of the firm who has either of the following responsibilities: 1. Continuing responsibility for the overall planning and

supervision of engagements for specified clients. 2. Authority to determine that an engagement is

complete subject to final partner approval.

All persons who (1) supervise or have direct management responsibility for the audit, (2) evaluate the performance or recommend the compensation of the audit engagement partner, or (3) provide quality control or other oversight of the audit.

(Continued)

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EXHIBIT B.1 Comparison of SEC and AICPA Selected Definitions AICPA Definition SEC Definition

Covered Person The following are considered covered members: 1. An individual on the audit or attest engagement team; 2. An individual in a position to influence the audit or

attest engagement; 3. A partner or manager who provides nonattest services

to the audit or attest client beginning once he or she provides 10 hours of nonattest services to the audit or attest client within any fiscal year and ending on the later of the date (i) the firm signs the report on the financial statements for the fiscal year during which those services were provided or (ii) he or she no longer expects to provide 10 or more hours of nonattest services to the audit or attest client on a recurring basis;

4. A partner in the office in which the lead audit or attest engagement partner primarily practices in connection with the audit or attest engagement;

5. The firm, including the firm’s employee benefit plans; or 6. An entity whose operating, financial, or accounting

policies can be controlled (as defined by generally accepted accounting principles [GAAP] for consolidation purposes) by any of the individuals or entities described in (1) through (5) or by two or more such individuals or entities if they act together.

The following partners, principals, shareholders, and employees of an accounting firm are considered covered members: 1. An individual on the audit engagement team, 2. An individual in the chain of command, 3. Any other partner, principal, shareholder, or managerial

employee of the firm who has provided 10 or more hours of nonaudit services to the audit client for the period beginning on the date such services are provided and ending on the date the accounting firm signs the report on the financial statements for the fiscal year during which those services are provided, or who expects to provide 10 or more hours of nonaudit services to the audit client on a recurring basis, and

4. Any other partner, principal, or shareholder from an office of the accounting firm in which the lead audit engagement partner primarily practices in connection with the audit.

Authors’ Note: In essence, the “covered members” are the firm’s professionals closely connected to the audit engagement and the firm’s owners who are located in the office where the lead engagement partner practices. However, the SEC added the category of manager-level professionals and owners who provide nonaudit (tax, consulting) services for the audit client. Therefore, almost everyone who provides services of any type for an audit client must observe the independence rules.

Close Family Member

Parent, sibling, or nondependent child. Person’s spouse, spousal equivalent, parent, dependent child, nondependent child, or sibling.

Immediate Family Member

Spouse, spousal equivalent, or dependents (whether or not related).

Person’s spouse, spousal equivalent, or dependents.

A covered member cannot • Have a direct financial interest in a client. • Have a material indirect financial interest in a client. • Be a trustee or administrator of an estate that has a direct or material indirect financial interest in a client. • Have a joint investment with a client that is material to the covered member. • Have a loan to or from a client, any officer of the client, or any individual owning more than 10 percent of

the client (except as specifically described in Interpretation 101-5). • Participate on an attest engagement if she or he was formally employed by the client in a position to

influence the audit or acted as an officer, director, promoter, underwriter, or trustee of a pension or profit- sharing trust of the client.

A covered member’s immediate family cannot • Have a direct financial interest in a client. • Have a material indirect financial interest in a client. • Have vested retirement benefits at a client.

A covered member’s close relatives cannot • Have a key management level position with a client. • Have a material financial interest in a client that is known to the covered member. • Have a financial interest in a client that allows the relative to have significant influence in a client. • Be in a position to influence the audit.

A partner or a professional employee cannot • Be associated with a client as a director, officer, employee, promoter, underwriter, voting trustee, or trustee

of a pension or profit-sharing trust of the client.

EXHIBIT B.2 Summary of Independence Rule Interpretations

(Continued)

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When a questionable practice or relationship arises, the CPA must evaluate whether the practice or relationship poses an unacceptable risk to a CPAs’ independence. Because there is not a rule or interpretation for every ethical dilemma a CPA might face, the PEEC adopted a Conceptual Framework (Exhibit B.3) that CPAs can use when facing a situation that is not explicitly covered in the Code of Conduct.

The Conceptual Framework uses a three-step risk-based approach that involves (1) identifying and evaluating threats to independence, (2) determining whether safeguards eliminate or sufficiently mitigate the identified threats, and (3) determining whether independence is impaired.

Identified threats to independence include the following:

1. Adverse interest threat. CPAs acting in opposition to clients (e.g., through litigation). 2. Undue influence threat. Attempts to coerce or otherwise influence the CPA member

(e.g., significant gifts or threats to replace the auditor over an accounting principles disagreement).

3. Advocacy threat. CPAs promoting a client’s interests or position. 4. Management participation threat. CPAs taking on the role of client management or

otherwise performing management functions. 5. Familiarity threat. CPAs becoming too sympathetic to client interests because of long-

standing or close relationships. 6. Self-interest threat. CPAs having a financial relationship with a client. 7. Self-review threat. CPAs reviewing their own work.

Next we take a closer look at each of these threats to independence.

Adverse Interest and Undue Influence Threats Conditions can arise when a public accounting firm and a client move into an adversary relationship instead of the cooperative relationship needed in an attest or audit engage- ment. Public accounting firm independence is considered impaired when the firm is involved in threatened or actual litigation involving an audit. Such cases may be rare, but the AICPA has provided auditors a way out of the difficult audit situation by this rule requiring them to declare “nonindependence” and the ability to give only a disclaimer on financial statements or other information. Essentially, the CPA–client relationship ends and the litigation begins a new relationship.

EXHIBIT B.3 AICPA Code of Conduct Conceptual Framework Source: www.aicpa.org.

Step 1 Identify threats

Step 2 Evaluate threats

No threats proceed

Threats not significant proceed

Step 4 Evaluate

safeguards

Threats at acceptable

proceed

Threats not acceptable level...stop

Conceptual Framework

Existing New

Step 3 Identify

safeguards

Ethics Codification

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Occasionally, the public accounting firm may find that it is a defendant in a lawsuit initiated by a third party or parties. Normally, this type of litigation is not considered to adversely impact the independence of the public accounting firm. However, sometimes these lawsuits result in claims from the client’s management that existing problems are the result of audit deficiencies or claims from the auditor that deficiencies are the result of fraud or deceit on the part of management. When such cross-claims are threatened or filed, independence may be impaired.

Advocacy and Management Participation Threats In addition to prohibitions against financial relationships with clients, a covered member is prohibited from acting in the capacity of a manager, employee, promoter, or trustee of a client. Generally, independence is impaired if the public accounting firm even appears to outside observers to be working in the capacity of management or employees of the client. The client management (including its board of directors and audit commit- tee) must understand that they are responsible for establishing and maintaining internal control and directing the internal audit function, if any. The board of directors and/or audit committee (i.e., those charged with governance) must understand their roles and responsibilities with regard to extended audit services including the establishment of guidelines for both management and the public accounting firm to follow in carrying out these responsibilities and monitoring how well the respective responsibilities have been met.

In addition to the guidance discussed in the previous paragraphs, the following additional activities would impair independence:12

∙ Performing ongoing monitoring or control activities. ∙ Determining which, if any, recommendations for improving internal control should be

implemented. ∙ Reporting to the board of directors or audit committee on behalf of management or the

individual responsible for the internal audit function. ∙ Authorizing, executing, or consummating transactions or otherwise exercising authority

on behalf of the client. ∙ Preparing source documents for transactions. ∙ Having custody of assets. ∙ Approving or being responsible for the overall internal audit work plan including the

determination of the internal audit risk and scope project priorities and the frequency of performance of audit procedures.

∙ Performing forensic accounting services, litigation support work, or any other service in which it appears that the CPA is taking an advocacy position on the client’s behalf. Although performing tax compliance work would not normally impair independence, certain tax work in which an advocacy position is required does (e.g., representing a client in court to resolve a tax dispute).

∙ Being connected with the client as an employee or in any capacity equivalent to a member of client management (for example, being listed as an employee in client directories or other client publications, permitting himself or herself to be referred to by title or description as supervising or being in charge of the client’s internal audit function, or using the client’s letterhead or internal correspondence forms in communications).

12Although the following information does not prohibit auditors from providing internal audit and a variety of other services, it should be emphasized that the interpretation covers client companies that are public and private. Audits of public companies must comply with the rules of the SEC, the appropriate stock exchange, and the PCAOB. These agencies have rules that prohibit auditors from providing internal audit services to audit clients in most cases and have more stringent requirements regarding extended services.

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Although this list is not all-inclusive, a prohibited activity is any that would force the CPA to act either in the capacity of management or as an advocate for management.

As noted, independence is ordinarily impaired if a CPA serves on an organization’s board of directors. However, members can be honorary directors of organizations such as charity hospitals, fund drives, symphony orchestra societies, and similar not-for-profit organizations so long as (1) the position is purely honorary, (2) the CPA is identified as an honorary director on letterheads and other literature, (3) the only form of participation is the use of the CPA’s name, and (4) the CPA does not vote with the board or participate in management functions. When all of these criteria have been satisfied, the CPA/board member can perform audit and attest services because the appearances of independence will have been preserved.

Familiarity Threat An immediate family member may not hold a position of influence (key position) in an audit client. The close family member’s definition comes into play in connection with (1) ownership or control of an audit client or (2) employment with an audit client. An example of (1) is the impairment of the public accounting firm’s independence when a close fam- ily member of a covered person in the firm owns a material investment in an audit client or is in a position to exert significant influence over an audit client. An example of (2) is the impairment of the public accounting firm’s independence when a close family member works in an accounting or financial reporting role at an audit client or was in such a role during any period covered by an audit for which the person in the firm is a covered person. (Neither an immediate family member nor a close family member can work in a capacity such as a member of the board of directors, chief executive officer, president, chief financial officer, chief operating officer, general counsel, chief accounting officer, controller, director of internal audit, director of financial reporting, treasurer, or vice president of marketing.)

Independence problems do not end when owners (partners, shareholders) and profes- sional employees retire, resign, or otherwise leave a public accounting firm. A former owner or professional can cause independence to be impaired if a relationship continues with a client of the former firm. However, the problems are solved and independence is not impaired if (l) the person’s retirement benefits are fixed, (2) the person is no longer active in the public accounting firm (sometimes retired owners remain “active”), and (3) the former owner is not held out to be associated with the public accounting firm.

In addition to the preceding considerations, the public accounting firm must ensure that appropriate consideration is given to any increase in risks that may exist due to the former partner’s or professional’s knowledge of the firm’s audit plan and procedures. The firm must consider the following:

∙ The interaction with the former partner or professional. ∙ The ability of audit team members to manage the interaction with the former partner

or professional employee. ∙ Modification of the engagement procedures. ∙ The appropriateness of the review to determine that an appropriate level of skepticism

was maintained.

For many years, a national public accounting firm encouraged its pro- fessionals to become active members of the boards of directors of cor- porations. The purpose was to provide expertise to businesses in the metropolitan area and to enable the public accounting firm to become well known and well respected. The public accounting firm changed its policy to prohibit such service after it had to refuse the opportunity to obtain some of these corporations as audit clients because of independence

concerns. The public accounting firm’s audit independence was consid- ered impaired when a member of the firm had served in a director or management capacity during the period covered by the financial state- ments the corporations wanted the firm to audit. The generalization test was this: If members of the firm serve on the boards of directors of all corporations that may become audit clients, none of these corporations can be accepted as audit clients—a result that is undesirable.

Service versus IndependenceAUDITING INSIGHT

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Financial Self-Interest Threat Any direct financial interest (e.g., ownership of common or preferred stock) is prohib- ited. This requirement is the strictest one in the code. There are no exceptions; indirect financial interests, on the other hand, are allowed up to the point of materiality (with reference to the member’s wealth). This provision permits members to have some lim- ited business transactions with clients so long as they do not reach material proportions. Other provisions define certain specific types of prohibited and allowed indirect financial interests. Immediate family members are subject to the same provisions that prescribe the acceptable actions of the covered person. Like the covered person, an immediate family member may not have a direct financial or material indirect financial interest in a client.

We already understand that a covered member cannot have a financial relationship with a client. However, suppose the client is an investor in another company and the covered member has invested in that company. Has independence been impaired? If the covered member’s investment is a direct or materially indirect financial interest in a non- client investee, independence is considered to be impaired. The reasoning for the basic rule is that the client investor, through its ability to influence a nonclient investee, can increase or decrease the CPA’s financial stake in the investee by an amount material to the CPA, and therefore, the CPA may not appear to be independent. If the investment by the client is not material to the nonclient (i.e., there does not appear to be any influ- ence over the investee), then independence is not impaired unless the covered member’s investment allows the member to exercise significant influence over the nonclient.

Material cooperative arrangements with clients (i.e., joint participation in a business activity) also impair independence. Examples include joint ventures to develop or market products or to market a package of client and CPA services or one party working to mar- ket the products or services of the other.

Most loans to or from audit clients are prohibited: “Independence is considered impaired if a covered member has a loan from a client, officer, director, or any individual owning 10 percent or more of a client.” Similarly, independence is impaired if there are unpaid fees or a note receivable arising from unpaid fees from the client outstanding for more than a year. The only loans permitted are “grandfathered loans” and “other permitted loans.”

Grandfathered loans are those loans that were obtained either (1) before the indepen- dence rules changed (but met the requirements of the Independence Rule in effect at that time) or (2) from a financial institution before it became a client for services requiring independence. These grandfathered loans must at all times be current under all of their terms, and the terms shall not be renegotiated. The specific types of loans that are grand- fathered are home mortgages, loans not material to the CPA’s net worth, and secured loans for which the collateral value must exceed the balance of the loan at all times.

Other permitted loans include ∙ Auto loans and leases collateralized by the automobile. ∙ Insurance policy loans based on policy surrender value. ∙ Loans collateralized by cash deposits at the same financial institution. ∙ Credit card balances and cash advances of $10,000 or less.

Ethics rules do not cover all circumstances in which the appearance of independence might be questioned. It is the member’s responsibility to determine whether the personal and business relationships would lead a reasonable person aware of all the relevant facts to conclude that there is an unacceptable threat to the member’s and the firm’s independence.

Self-Review Threat Independence is impaired if the public accounting firm performs the bookkeeping or makes accounting or management decisions for a company whose management does not know enough about the financial statements to take primary responsibility for them. The problem in this situation is the appearance of the public accounting firm having both prepared the financial statements or other information and provided the auditors’ report or other attesta- tion on its own work. In the final analysis, the management must be able to say, “These are

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our financial statements (or other information); we made the choices of accounting prin- ciples; we take primary responsibility for them.” The auditors cannot authorize transactions, control assets, sign checks or reports, prepare source documents, supervise the client’s per- sonnel, or serve as the client’s registrar, transfer agent, or general counsel.

Other Threats? Other Independence Rule interpretations include relationships with governmental entities and alternative practice structures. The full list of interpretations, with accompanying detail, can be found on the AICPA’s website.13 As you can see, the detail is substantial, yet you have no choice but to understand the full details of the AICPA independence requirements. Lack of knowledge of the appropriate jurisdiction’s ethical requirements is not a defense when facing severe sanctions and penalties.

We have examined a number of threats that have been identified that impair inde- pendence. What about those not specifically covered? When those situations arise, the Conceptual Framework guides the CPA to make the best decision to address the threats. Note that the Conceptual Framework is to be used only when specific guidance is not in the Code. It cannot be used to override existing rules or interpretations.

In addition to identifying and considering the significance of each threat, the CPA should identify safeguards that might eliminate or reduce the threat to an acceptable level. Safeguards can be client or firm-specific, including policies and procedures in place to prevent ethical problems. Examples include training on the importance of independence, threats of disciplinary action, hotlines to discuss ethical dilemmas, tone at the top, and the use of different offices (or different firms) to perform parts of the engagement.

Lastly, whenever the CPA runs into ethical issues, especially those in which safeguards are identified to eliminate or reduce significant threats, the CPA must document the deci- sions reached. Failure to do so would be a violation of the Compliance with Standards Rule (discussed later in this module).

13(https://www.aicpa.org/content/dam/aicpa/research/standards/codeofconduct/downloadabledocuments/2014december15cont entasof2016august31codeofconduct.pdf).

SEC and PCAOB Independence Rules Prior to the issuance of Sarbanes–Oxley in 2002, the SEC accepted most of the inde- pendence rules established by the PEEC. However, the SEC became concerned about the public accounting profession’s emphasis on consulting fees and the resulting effect on public accounting firm independence. In fact, the SEC issued a comprehensive independence rule in November 2000. The rule is based upon two premises: (1) inde- pendence in fact is a mental state of objectivity and lack of bias and (2) independence in appearance depends on whether a reasonable investor, with knowledge of all rel- evant facts and circumstances, can conclude that the auditor is not capable of exercis- ing objective and impartial judgment. Hence, an auditor’s independence depends on auditors both having the proper mental state and passing the appearance test.

In a preface to the rule, the SEC stated four principles for determining whether a pub- lic accounting firm is independent of an audit client, factors the SEC will first consider

PricewaterhouseCoopers, LLP (PwC) was the auditor of Alteryx, a software company focusing on “self-service data and analytics.” Unfortunately for PwC, the firm’s use of the software platform and PwC’s subsequent promotion of the software to their clients, resulted in their dismissal as the auditor of the company. The reason for their

dismissal? Concern by executives at Alteryx regarding the indepen- dence of their auditing firm. As such, they replaced PwC with Deloitte and made note of it in their annual filing, or 10K.

Source: Alteryx Form 10-K found at: https://investor.alteryx.com/financials/ sec-filings/sec-filings-details/default.aspx?FilingId=13270348

When Using a Client’s Product Results in Losing ThemAUDITING INSIGHT

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when making independence determinations in controversial cases. Auditors are not independent if they have a relationship that

∙ Creates a mutual or conflicting interest between the public accounting firm and the audit client.

∙ Places the public accounting firm in the position of auditing its own work. ∙ Results in the public accounting firm personnel acting as management or employees

of the audit client. ∙ Places the public accounting firm in a position of being an advocate for the audit client.

The SEC independence rules relating to financial relationships are very similar to the AICPA Code of Professional Conduct Rule 101 Interpretations explained earlier. The most significant categories addressed by the SEC rules are in the areas of financial and employment relationships, nonaudit services (e.g., taxation, consulting), and dis- closure of fees.

Nonaudit Services The SEC is very concerned about the fact and appearance of independence when pub- lic accounting firms perform consulting services for audit clients. A major issue in the Enron case was that more than half of the fee it paid to Arthur Andersen was for con- sulting services. This fact exacerbated the concern that auditors would allow a client’s improper financial reporting for the sake of preserving lucrative fees from other services. The SEC’s concern in this regard is controversial, but the PCAOB has reinforced it. The SEC and PCAOB independence rules prohibit or place restrictions on the following types of nonaudit services provided to audit clients:

∙ Bookkeeping or other services related to the audit client’s accounting records or finan- cial statements (including maintaining or preparing the accounting records, preparing the financial statements, or preparing or originating source data underlying the finan- cial statements except in emergency situations).

∙ Financial information systems design and implementation (including operating or supervising the client’s information system, designing or implementing a hardware or software system that generates information that is significant to the client’s financial statements unless the audit client’s management takes full and complete responsibility for all design, implementation, internal control, and management decisions about the hardware and software).

∙ Appraisal or valuation services or fairness opinions (including any such services mate- rial to the financial statements when the auditor might audit the results of the public accounting firm’s own work, but the public accounting firm’s valuation experts may audit actuarial calculations, perform tax-oriented valuations, and perform nonfinan- cial valuations for audit clients).

∙ Actuarial services (including determination of actuarial liabilities unless the audit cli- ent management first uses its own actuaries and accepts responsibility for significant actuarial methods and assumptions).

∙ Internal audit services (including those related to the client’s internal accounting con- trols, financial systems, or financial statements).

∙ Management functions (including acting temporarily or permanently as a director, officer, or employee of an audit client, or performing any decision-making, supervi- sory, or ongoing monitoring function for the audit client).

∙ Human resources (including all aspects of executive search activities, reference checking, status and compensation determination, and hiring advice).

∙ Broker–dealer services (including acting as a broker–dealer, promoter, or underwriter on behalf of an audit client; making investment decisions or otherwise having discre- tionary authority over investments; executing a transaction to buy or sell investments; or having custody of assets).

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∙ Legal services (including any service under circumstances in which the per- son providing the service must be admitted to practice before the courts of a U.S. jurisdiction).

∙ Expert services (including providing expert opinions or other services to an audit client or legal representative of an audit client for the purpose of advocating the audit client’s interests in litigation, regulatory, or administrative investigations or proceedings; the auditor may perform internal investigations at the direction of the audit committee or its legal counsel).

∙ Any service performed for an audit client where the auditor is paid a contingent fee or commission.

∙ Tax services that are based on judicial proceedings or aggressive interpretations of tax law.

∙ Planning or opining on the tax consequence of a transaction. ∙ Tax services for key company executives.

The PCAOB’s Rule 3526 (Communication with Audit Committees Concerning Independence) requires public accounting firms to discuss any independence issues with the audit committee (or those charged with governance) prior to accepting an initial engagement. This discussion must be documented (usually in the engagement administrative file workpapers).

Disclosures about Fees The SEC believes that investors who use financial statements and auditors’ reports can be enlightened with information about auditors’ fee arrangements with clients. Hence, SEC rules require that companies (not auditors) disclose the following in proxy statements delivered to their shareholders:

∙ Total audit fees paid to the public accounting firm for the annual audit and the reviews of quarterly financial information.

∙ Total fees paid to the public accounting firm for tax and other advisory work (over and above the audit fees).

∙ Whether the audit committee or the board of directors considered the public accounting firm’s advisory work to be compatible with maintaining the auditor’s independence.

∙ The percentage of the audit hours performed by persons other than the principal audi- tor’s full-time, permanent employees, if greater than 50% of the total audit hours. (This disclosure refers to “leased employees” in an “alternative practice structure” arrangement.)

Sounds easy, to change auditors, but when you’re as big as GE, such changes never come easy. KPMG has been auditing GE since 1909 but after 35% of shareholders recently voted to switch auditors, the Company indicated it will begin looking for a new auditor after the 2019 audit is completed. It won’t be an easy task. PricewaterhouseCoopers (PwC) performs GE’s tax work (tax planning, advice, and compliance work) to the tune of $1 billion in yearly

revenue. Ernst & Young provides lobbying services for GE while Deloitte provides nonaudit work and “has business relationships with GE that would be barred” under the SEC’s independence rules. So while in theory making a switch to another auditor sounds simple, the reality is that it is anything but.

Source: https://www.wsj.com/articles/for-ge-dropping-kpmg-wont-be-easy- 11553691353

Changing Auditors after 100 Years Is Not EasyAUDITING INSIGHT

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Other Effects of Sarbanes–Oxley on Auditor Independence Sarbanes–Oxley required the SEC to modify its position on auditor independence in several ways. Perhaps the most important change in independence arises from the changing role of the audit committee. While auditors must always be vigilant in estab- lishing and monitoring their own independence to ensure that they are in fact indepen- dent of their clients, Sarbanes–Oxley has placed the responsibility for the determination of independence in appearance at the door of the audit committee. This is particularly evident by the fact that the audit committee bears the responsibility for determining the scope of services provided by the auditor and reviewing independence issues prior to the appointment of the auditor. The audit committee may do this on a case-by-case basis or may establish a set of policies and procedures that establish acceptable and unacceptable services.

In addition, Sarbanes–Oxley limits the engagement partners and concurring audit partners on an engagement to five-year terms, after which they must rotate off the engagement. Other partners associated with the engagement are limited to seven-year terms with that client. Partners also are deemed as not independent if they receive com- pensation that is based on selling services to an audit client other than audits, reviews, or attestations.

In the past, it was not unusual for a member of an audit team, usually a manager or higher, to leave the public accounting firm to take a financial management position with a client. Under the rules established by Sarbanes–Oxley, a public accounting firm cannot perform an audit of a company in which an individual with financial reporting oversight responsibilities was a member of the audit engagement team for the audit period, up to the audit date.

Government Accountability Office (GAO) Independence Requirements Many state agencies and local municipalities use public accounting firms to perform audits required by government charters, laws, or contractual obligations (usually as part of a grant). During these audits, the public accounting firm is required to follow all GAO standards included in the Government Auditing Standards manual (also called the Yellow Book; see Module D). These standards require the auditor to be independent with respect to the government entity. These standards differ from the SEC, AICPA, and Sarbanes–Oxley requirements in the following ways. Nonaudit services are allowed providing that the audit organization does not perform management functions, make management decisions, or audit its own work. However, the audit organization must employ the following safeguards:

1. Personnel who provide nonaudit services are prohibited from planning, conducting, or reviewing audit work related to the nonaudit services.

2. The audit organization may not reduce the scope or extent of work performed on the audit because a member of the firm performed the nonaudit work. The extent of the audit work may be reduced by an amount consistent with a reduction had the nonaudit been performed by another public accounting firm.

3. The audit organization must document its reasons that the nonaudit services do not affect the firm’s independence.

4. The audit organization must document an understanding with the client regarding the objectives, scope, and work product for the nonaudit service.

5. The audit organization must have established policies and procedures to ensure that effects of nonaudit services on the present and future audits are considered.

6. The audit organization must communicate to the government entity any situation in which the nonaudit service would prohibit it from performing the audit.

7. When subjected to a peer review, the audit organization must identify all nonaudit services provided to the audited entity.

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AICPA RULES OF CONDUCT: INTEGRITY AND OBJECTIVITY, RESPONSIBILITIES TO CLIENTS, AND OTHER RESPONSIBILITIES

Now that we have discussed the Independence Rule, we can turn to the other AICPA rules of conduct.

Integrity and Objectivity Rule

In the performance of any professional service, a member shall maintain objectivity and integrity, shall be free of conflicts of interest, and shall not knowingly misrepresent facts or subordinate his or her judgment to others. (1.100.001 and 2.100.001)

The Integrity and Objectivity Rule applies not only to CPAs in public practice but also to CPAs working in business. (Santos, the staff accountant in the decision process illustration in Ethical Example 2, is a business CPA.) The rule requires integrity and objectivity in all types of professional work—tax practice and consulting practice as well as audit practice for public accountants—and all types of accounting work performed by CPAs employed in corporations, not-for-profit organizations, governments, and indi- vidual practices. The rule holds CPAs to the highest of standards of maintaining their integrity and objectivity at all times.

In addition to integrity and objectivity, this rule emphasizes (1) being free from con- flicts of interest between CPAs and others, (2) representing facts truthfully in reports and

LO B-5 With reference to AICPA rules on topics other than independence, analyze factual situations and decide whether an accountant’s conduct does or does not conform to the AICPA Code of Professional Conduct.

REVIEW CHECKPOINTS B.7 Yolanda is the executive in charge of the Santa Fe office of Best & Co, an international public

accounting firm. She is responsible for the practice in all areas of audit, tax, and consulting, but she does not serve as a field audit partner or a reviewer. Javier is the partner in charge of the Besame Inc. audit (an SEC filing). Is Best & Co independent if (a) Yolanda owns common stock of Besame or (b) her brother owns 10 shares of the common stock of Besame?

B.8 Can audit managers on the audit engagement team, who are also attorneys admitted to the state bar, assist in the defense of a lawsuit against an audit client for product liability defects?

B.9 Why do you think the SEC requires companies to disclose fees paid to independent accounting firms for audit and consulting services? What must be disclosed?

B.10 What do the SEC disclosure rules and PCAOB Rule 3526 have in common with auditors’ relations with an audit client’s board of directors and its audit committee?

B.11 Given what you have learned about independence, do you believe that there would be a per- ceived independence problem concerning members of an audit engagement team entertaining employment offers from audit clients? Why or why not?

KPMG was struggling with an audit deficiency rate of nearly 46% when several partners at the Big 4 audit firm decided to game the system by find- ing out which of its audits would be inspected by the PCAOB. Those audits would then be re-reviewed by firm personnel and occasionally more audit work was performed. David Middendorf, KPMG’s former managing part- ner for audit quality, along with Jeffery Wada, and inspections leader for

the PCAOB, were both found guilty on March 11, 2019, of wire fraud and conspiracy to commit wire fraud as a result of their actions related to the leaked inspections. Four other partners were charged in relation to the mat- ter; three have pleaded guilty, and one is due to go on trial at a later date.

Source: https://news.bloombergtax.com/financial-accounting/ex-kpmg-partner- audit-oversight-staffer-found-guilty-of-fraud

Integrity and the PCAOB Inspection ProcessAUDITING INSIGHT

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discussions, and (3) not letting other people dictate or influence the CPA’s judgment and professional decisions.

Conflicts of interest refer to the need to avoid having business interests in which the accountant’s personal financial relationships or the accountant’s relationships with other clients might tempt the accountant to fail to serve the best interests of a client or the public. Some examples of conflicts of interest are those in which the CPA

∙ Is engaged to perform litigation support services for a plaintiff in a lawsuit filed against a client.

∙ Recommends that a client makes an investment in a business in which the CPA has a financial interest.

∙ Performs management consulting for a client and has a financial or managerial interest in a major competitor.

The phrases “shall not knowingly misrepresent facts” and “shall not subordinate his or her judgment to others” emphasize conditions people ordinarily identify with the con- cepts of integrity and objectivity. Accountants who know about a client’s fraudulent tax return, about false journal entries, about material misrepresentations in financial state- ments, and yet do nothing have violated both the spirit and the letter of the Integrity and Objectivity Rule.

The prohibition of misrepresentations in financial statements applies to the manage- ment accountants who prepare companies’ statements. Business CPAs should not subor- dinate their professional judgment to superiors who try to produce materially misleading financial statements and fool their external auditors. They must be candid and not know- ingly misrepresent facts or fail to disclose material facts when dealing with their employ- er’s external auditor. They also cannot have conflicts of interest in their jobs and their outside business interests that are not disclosed to their employers and approved. The importance of integrity and objectivity for business CPAs cannot be overemphasized. Too often, CPAs relate the Code of Professional Conduct only to CPAs in public practice. In fact, one of the objectives of the recodification of the AICPA Code of Conduct is to emphasize the importance of business CPAs adhering to ethics rules that relate to them.

The Integrity and Objectivity Rule has two other applications. One concerns serving as a client advocate, which occurs frequently in taxation and rate regulation practice as well as in supporting clients’ positions in FASB and SEC proceedings. Client advocacy in support or advancement of client positions is acceptable only so long as the member acts with integrity, maintains objectivity, and does not subordinate judgment to others. (Accountants-as-advocates do not adopt the same attitude as defense attorneys in a court- room.) The other application is directed specifically to your college professors: They are supposed to maintain integrity and objectivity, be free of conflicts of interest, and not knowingly misrepresent facts to students.

General Standards Rule A member shall comply with the following standards and with any interpretations thereof by bodies designated by Council: A. Professional competence. Undertake only those professional services that the member or

the member’s firm can reasonably expect to be completed with professional competence. B. Due professional care. Exercise due care in the performance of professional services. C. Planning and supervision. Adequately plan and supervise the performance of profes-

sional services. D. Sufficient relevant data. Obtain sufficient relevant data to afford a reasonable basis for

conclusions or recommendations in relation to any professional services performed. (1.300.001 and 2.300.001)

The General Standards Rule is a comprehensive statement of general standards that accountants are expected to observe in all areas of practice. This is the rule that enforces the various series of professional standards. The AICPA Council has authorized the

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following agencies, boards, and committees to issue enforceable standards under this rule:

∙ Public Company Accounting Oversight Board (PCAOB). ∙ Auditing Standards Board. ∙ Accounting and Review Services Committee. ∙ Tax Executive Committee. ∙ Management Consulting Services Executive Committee.

The General Standards Rule effectively prohibits the acceptance of any engagement that the CPA cannot competently complete. Such engagements may involve audits that require specialized industry knowledge or technical expertise the practitioner does not possess. Practitioners are allowed to accept an engagement if, through education, hiring of additional staff, or contracting with auditors’ specialists, the practitioners can obtain the required knowledge prior to the conclusion of the engagement. As a result, a prac- titioner can accept an engagement for which he or she does not possess knowledge as long as this knowledge can be obtained prior to the conclusion of the engagement. This rule covers all areas of public accounting practice except personal financial planning and business valuation. Of course, a CPA may have to do some research to learn more about a unique problem or technique and may need to engage a colleague as a consultant.

Compliance with Standards Rule

A member who performs auditing, review, compilation, management consulting, tax, or other professional services shall comply with standards promulgated by bodies designated by Council. (1.310.001 and 2.31.001)

The Compliance with Standards Rule requires adherence to duly promulgated technical standards in all areas of professional service. These areas include the ones cited in the rule: auditing, review and compilation (unaudited financial statements), consulting, tax, or “other” professional services. The “bodies designated by Council” are the Auditing Standards Board, the Accounting and Review Services Committee, the Tax Executive Committee, and the Con- sulting Services Executive Committee. The practical effect of this rule is to make noncom- pliance with technical standards (in addition to the general standards) subject to disciplinary proceedings. Therefore, failure to follow auditing standards, accounting and review standards, tax standards, and consulting standards is a violation of the Compliance with Standards Rule.

Accounting Principles Rule

A member shall not (1) express an opinion or state affirmatively that the financial statements or other financial data of any entity are presented in conformity with generally accepted accounting principles or (2) state that he or she is not aware of any material modifications that should be made to such statements or data in order for them to be in conformity with generally accepted accounting principles, if such statements or data contain any departure from an accounting principle promulgated by bodies designated by Council to establish such principles that has a material effect on the statements or data taken as a whole. If, however, the statements or data contain such a departure and the member can demonstrate that due to unusual circumstances the financial statements or data would otherwise have been misleading, the member can comply with the rule by describing the departure, its approximate effects, if practicable, and the reasons why compliance with the principle would result in a misleading statement. (1.320.001 and 2.320.001)

The AICPA Council has designated three rule-making bodies to pronounce accounting prin- ciples under the Accounting Principles Rule. The Financial Accounting Standards Board (FASB) is designated to pronounce standards in general, the Governmental Accounting Standards Board (GASB) has the responsibility to pronounce accounting standards for state and local government entities, and the Federal Accounting Standards Advisory Board (FASAB) is charged with respect to statements of federal accounting standards.

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The Accounting Principles Rule requires adherence to official pronouncements unless such adherence would be misleading. The consequences of misleading statements to outside decision makers would be financial harm, so presumably the greater good would be realized by explaining a departure and thereby “breaking the rule of officially promulgated accounting principles.” Such an instance occurs in very rare situations, and the burden of proving that following pronouncements would be misleading is the responsibility of the auditor.

CPAs in business also can be subject to the Accounting Principles Rule. These accountants produce and certify financial statements and sign written management representation letters for their external auditors. They also present financial statements to regulatory authorities and creditors. Business accountants generally “report” that the company’s financial statements conform to GAAP, and this report is taken as an expression of opinion (or negative assurance) of the type governed by the Accounting Principles Rule. The result is that accountants who present financial statements containing any undisclosed departures from official pronouncements face disciplinary action for violating the rule.

Confidential Client Information Rule

A member in public practice shall not disclose any confidential information without the specific consent of the client. (1.700.001)

Confidential information is any information that is not available to the public (or in the public domain). As Scott London in this module’s opening vignette was well aware, such information should not be disclosed to outside parties unless demanded by a court or an administrative body having subpoena or summons power. Privileged information is information that cannot even be demanded by a court. Common-law privilege exists for husband–wife and attorney–client relationships. While physician–patient and priest–penitent relationships have obtained the privilege through state statutes, no accountant–client privilege exists under federal law, and no state-created privilege has been recognized in federal courts. In all recognized privilege relationships, the professional per- son is obligated to observe the privilege, which can be waived only by the client, patient, or penitent. (These persons are said to be the holders of the privilege.)

The rules of privileged and confidential communication are based on the belief that they facilitate a free flow of information between parties to the relationship. The nature of accounting services makes it necessary for the accountant to have access to information about salaries, products, contracts, merger or divestment plans, tax matters, and other information required for the best possible professional work. Managers would be less likely to reveal such information if they could not trust the accountant to keep it confidential. If accountants were to reveal such information, the resulting reduction of the information flow might be undesirable, so no accountant should break the confidentiality rule without a good reason.

What would you do if a government intelligence agent approached you to assist him in a “top secret” assignment involving national security? Guy Enright, an accountant with KPMG’s Financial Advisory Services Ltd. in Bermuda, said “yes” to Nick Hamilton, a British intelligence officer, and agreed to deposit confidential audit documents in plastic containers at “dead drop” sites located throughout Bermuda. Unfor- tunately for Enright, KPMG, and its client, IPOC International Growth Fund Ltd. (IPOC), “Nick Hamilton” was in fact Nick Day, a cofounder of Diligence Inc., a Washington-based private intelligence firm that was gathering information for one of IPOC’s business competitors.

The setup was quite elaborate. “Hamilton” required Enright to undergo a detailed background check, even producing an official- looking questionnaire with a British government seal at the top, before he could participate on “Project Yucca.” The undercover mission came to an abrupt end when someone (still unknown) dropped off a pack- age of Diligence business records and e-mails involving “Project Yucca” at KPMG’s Montvale office. After KPMG sued, Diligence ended up paying $1.7 million.

Source: “Spies, Lies, and KPMG,” www.businessweek.com, February 26, 2007.

Spies, Lies, and Client ConfidentialityAUDITING INSIGHT

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Difficult problems arise over auditors’ obligations to “blow the whistle” about clients’ shady or illegal practices. For all practical purposes, information is not considered confi- dential if its disclosure is necessary to prevent financial statements from being mislead- ing. If a client refuses to accept an auditors’ report that has been modified because of the inability to obtain sufficient appropriate evidence about a suspected illegal act, failure to account for or disclose properly a material amount connected with an illegal act, or inability to estimate amounts involved in an illegal act, the public accounting firm should withdraw from the engagement and give the reasons in writing to the board of directors. In such an extreme case, the withdrawal amounts to whistleblowing, but the action results from the client’s decision not to disclose the information.

Auditors are not, in general, legally obligated to blow the whistle on clients. However, circumstances in which auditors are legally justified in making disclosures to a regula- tory agency or a third party may exist. Such circumstances include when (1) a client has intentionally and without authorization associated or involved a CPA in its misleading conduct (e.g., used the CPA’s name on financial statements), (2) a client has distributed misleading draft financial statements prepared by a CPA for internal use only, or (3) a client prepares and distributes in an annual report or prospectus misleading information for which the CPA has not assumed any responsibility. In addition, the Private Securities Litigation Reform Act of 1995 imposed another reporting requirement in connection with clients’ illegal acts (see Module C).

The Confidential Client Information Rule possibly provides accountants the most dif- ficulties and may be the most violated procedure. First, in its strictest interpretation, the principle of confidentiality applies to the communication of information to anyone who is not involved in the audit except as noted by the rule. Over lunch or after hours, however, you might find auditors discussing the day’s work with other members of the firm or com- pany. Second, CPAs should not view the Confidential Client Information Rule as an excuse for inaction when action may be appropriate to right a wrongful act committed or about to be committed by a client. In some cases, auditors’ inaction may be viewed as part of a conspiracy or willingness to be an accessory to a wrong. A useful initial course of action is to consult an attorney about possible legal pitfalls of both whistleblowing and silence.

Accountants can permit other accountants to review confidential audit documentation and other information about clients in connection with arrangements to sell or merge an accounting practice. The AICPA advises accountants to have an agreement among them- selves that extends the confidentiality safeguard to the prospective purchasing accountant as it existed with the original accountant.

CPAs also may disclose confidential information without the client’s permission to remain in compliance with applicable laws (e.g., responding to a subpoena), as part of an ethics investigation (of a CPA), or as part of a peer review or PCAOB investigation of public accounting firm practices. The exception related to ethics violations applies only to investigative or disciplinary bodies under the AICPA’s jurisdiction, namely the AICPA Professional Ethics Division, the ethics enforcement committees in the various state soci- eties of CPAs, and state boards of accountancy.

Every audit staff member should know that it is not only unethical but also illegal to use information gleaned from an audit or other “inside” information to purchase shares of stock. However, EY staff audi- tor Nima Hedayati must have skipped training the day those issues were discussed. In 2015, Hedayati used confidential client informa- tion to purchase 40 contracts for call options and advised his mother

to purchase shares as well. The ill-gotten gains resulted in the junior staff auditor’s firing from EY coupled with a settlement with the SEC for over $87,000, including $43,000 of penalties. Hedayati is also suspended from practicing as an accountant before the SEC.

Source: https://www.accountingtoday.com/news/sec-charges-ey-auditor-with- insider-trading

Insider Trading Is Never a Good IdeaAUDITING INSIGHT

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While the Client Confidential Information Rule specifically addresses CPA’s respon- sibilities to clients, CPAs (both in public practice and in business) must also keep their employers’ proprietary information confidential. Failure to do so would be a violation of the Acts Discreditable Rule, discussed later in this module.

Fees and Other Types of Remuneration Contingent Fees

A member in public practice shall not: (1) Perform for a contingent fee any professional services for, or receive such a fee from, a

client for whom the member or the member’s firm performs: (a) an audit or review of a financial statement; or (b) a compilation of a financial statement when the member expects, or reasonably

might expect, that a third party will use the financial statement and the member’s compilation report does not disclose a lack of independence; or

(c) an examination of prospective financial information; or (2) Prepare an original or amended tax return or claim for a tax refund for a contingent fee

for any client. (1.510.001)

Suppose you are a shareholder in New Medical Corporation. You have some concerns about the company’s revenue practices, but the fact that New Medical received an unmodified audit opinion reassures you. Now let’s assume that you discover that the New Medical contract with its auditor paid the auditor more for an unmodified opinion than a qualified opinion. How might that affect the value you placed on the auditor’s report?

A contingent fee is a fee established for the performance of any service in an arrange- ment in which no fee will be charged unless a specific finding or result is attained or the fee otherwise depends on the result of the service. (Fees are not contingent if they are fixed by a court or other public authority or, in tax matters, determined as a result of the findings of judicial proceedings or the findings of government agencies; nor are fees contingent when they are based on the complexity or time required for the work.) CPAs can charge contingent fees for work such as representing a client in an IRS tax audit and certain other tax matters, achieving goals in a consulting service engagement, or helping a person obtain a bank loan in a financial planning engagement. However, the PCAOB has issued an independence rule that prohibits all contingent fees for audit clients of registered public accounting firms. CPAs are allowed to receive contingent fees except from clients for whom the CPAs perform attest services when users of financial information may be relying on the CPAs’ work. The prohibitions in items 1(a), 1(b), and 1(c) all refer to attest engagements in which independence is required. Acceptance of contingent fee arrange- ments during the period in which the member or the member’s firm is engaged to perform any of these attestations or during the period covered by any historical financial statements involved in any of these engagements is considered an impairment of independence.

An Ernst & Young partner was convicted of six counts of securities fraud related to insider trading arising from a relationship that began on an extramarital dating website. The principal witness against the partner was a woman who had befriended him online, and through a guessing game they played from their respective offices, guessed the impending mergers he was working on. She then traded 18 times on the insider information, netting approximately $400,000 on the transactions. Her trading was funded by another man she met on the

same website. Her suspicious trading just before the mergers were announced caused her name to repeatedly appear on SEC watch lists. When confronted, she cut a deal, pleading guilty to 15 counts of securities fraud and agreeing to testify against the EY partner who apparently was unaware of the insider trading scheme and did not make a cent off the trades.

Source: “Insider Affair: An SEC Trial of the Heart,” The Wall Street Journal, July 28, 2009, p. C1.

Crimes of the Heart?AUDITING INSIGHT

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Contingent fees are also prohibited in connection with the everyday tax practice of prepar- ing original or amended tax returns. This prohibition arose from an interesting conflict of government agencies. The Federal Trade Commission (FTC) wanted to see contingent fees permitted, but the IRS objected on the grounds that such fees might induce accountants and clients to “play the audit lottery”—understate tax improperly in the hope of escaping audit. The IRS asserted that if the AICPA permitted such contingent fees, the IRS would make its own rules prohibiting them. The FTC agreed that the AICPA rule could contain this prohibition.

Commissions and Referral Fees A. Prohibited Commissions A member in public practice shall not recommend or refer to a client any product or service for a commission, or recommend or refer any product or service to be supplied by a client for a commission, or receive a commission, when the member or the member’s firm also performs for that client: (a) an audit or review of a financial statement; or (b) a compilation of a financial statement when the member expects, or reasonably might

expect, that a third party will use the financial statement and the member’s compilation report does not disclose a lack of independence; or

(c) an examination of prospective financial information. This prohibition applies during the period in which the member is engaged to perform any of the services listed above and the period covered by any historical financial statements involved in such listed services.

B. Disclosure of Permitted Commission A member in public practice who is not prohibited by this rule from performing services for, or receiving a commission from, and who is paid or expects to be paid a commission, shall disclose that fact to any person or entity to whom the member recommends or refers a product or service to which the commission relates.

C. Referral Fees Any member who accepts a referral fee for recommending or referring any service of a CPA to any person or entity or who pays a referral fee to obtain a client shall disclose such acceptance or payment to the client. (1.520.001)

A commission is generally defined as a percentage-based fee charged for professional services in connection with executing a transaction or performing some other business activity. Examples are insurance sales commissions, real estate sales commissions, and securities sales commissions. A CPA can earn commissions except in connection with any client for whom the CPA performs attestation services.

Commissions are an impairment of independence similar to contingent fees. Recall that contingent fees are based on attaining a specific finding or result and are prohibited for attestation clients. When involved in an attest engagement with a client, the CPA can- not receive a commission from anyone for (1) referring a product or service to the client or (2) referring to someone else a product or service supplied by the client. It does not matter which party actually pays the commission.

Commissions are permitted provided that the engagement does not involve attestation of the types cited in part A of the rule. This permission is tempered by the requirement that the CPA must disclose to clients an arrangement to receive a commission.

Most of the commission fee activity takes place in connection with personal financial planning services. CPAs often recommend insurance and investments to individuals and fam- ilies. Some critics point out that clients cannot always trust commission agents (e.g., insur- ance salespersons, securities brokers) to have clients’ best interests in mind when the agents’ own compensation depends on clients’ buying the product that produces commissions.

Referral fees are fees (1) a CPA receives for recommending another CPA’s services or (2) a CPA pays to obtain a client. Referral involves the practice of sending business to another CPA and paying other CPAs or outside agencies for drumming up business.

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Some CPAs have hired services that solicit clients on their behalf, paying a fixed or per- centage fee. Many CPAs frown on these arrangements, but they are permitted. However, CPAs must disclose such fees to clients.

Acts Discreditable Rule

A member shall not commit an act discreditable to the profession. (1.400.001, 2.400.001, and 3.400.001)

The Acts Discreditable Rule may be called the moral clause of the code, but it is only occasionally the basis for disciplinary action. Penalties normally are invoked automatically under the AICPA bylaws, which provide for expulsion of members found by a court to have committed any fraud, filed false tax returns, been convicted of any criminal offense, or found by the AICPA Trial Board to have been guilty of an act discreditable to the profession.

AICPA interpretations have determined the following to be discreditable acts:

∙ Withholding a client’s books and records and important documentation when the client has requested his or her return.

∙ Being found guilty by a court or administrative agency as having violated employ- ment antidiscrimination laws, including ones related to sexual and other forms of harassment.

∙ Failing to follow government audit standards and guides in governmental audits when the client or the government agency expects such standards to be followed.

∙ Failure to follow the requirements of governmental bodies, commissions, or other regulatory bodies including the PCAOB.

∙ Soliciting or disclosing CPA Examination questions and answers from the CPA Examination.

∙ Failing to file tax returns or remit payroll and other taxes collected for others (e.g., employee taxes withheld).

∙ Making, or permitting others to make, false and misleading entries in records and financial statements.

This last item is specifically applicable to all CPAs, whether in public practice, in business, between jobs, or in retirement. Any management accountant who participates in the production of false and misleading financial statements commits a discreditable act.

Advertising and Other Forms of Solicitation Rule

A member in public practice shall not seek to obtain clients by advertising or other forms of solicitation in a manner that is false, misleading, or deceptive. Solicitation by the use of coercion, overreaching, or harassing conduct is prohibited. (1.600.001)

It’s never a good idea to cheat. It will cost KPMG $50 million in fines to settle with the SEC over charges of cheating on internal training exams, and also using “stolen” information to fix audit workpapers for audits that would be examined in the future by the PCAOB. The scope and scale of the cheating on the training exams however, was extensive. The SEC discovered that both staff and partners shared the answer key and also changed the metric by which an exam would

pass or fail. In some cases, the bar was lowered to 25% so that staff could fail 75% of the exam and still earn a passing grade. In the end however, it didn’t pay to cheat. It will cost the firm millions, along with the requirement that KPMG “retain an independent consultant to review and assess its ethics and integrity controls.” Source: https://www.accountingtoday.com/news/kpmg-to-pay-50m-for-cheating- on-pcaob-exams

Cheating on the Watchdog Will Earn You a Bite. . . .in the Wallet

AUDITING INSIGHT

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Advertising consists of messages designed to attract business that are broadcast widely to an undifferentiated audience (e.g., print, radio, television, billboards). Advertising is permitted with only a few limitations. The current rule applies only to CPAs practicing public accounting and relates to their efforts to obtain clients. The guidelines basically prohibit false, misleading, and deceptive messages:

∙ Advertising may not create false or unjustified expectations of favorable results. ∙ Advertising may not imply the ability to influence any court, tribunal, regulatory

agency, or similar body or official. ∙ Advertising may not contain a fee estimate when the CPA knows it is likely to be sub-

stantially increased unless the client is notified. ∙ Advertising may not contain any other representation likely to cause a reasonable per-

son to misunderstand or be deceived.

Most CPAs carry out only modest advertising efforts, and many do no advertising at all. Public practice is generally marked by decorum and a sense of good taste. However, there are exceptions, and they tend to get much negative attention from other CPAs and the public in general. The danger in bad advertising lies in creating the image of a profes- sional huckster, which may backfire on efforts to build a practice.

Solicitation generally refers to direct contact (e.g., in person, mail, telephone) with a specific potential client. In regard to solicitation, Rule 502 basically prohibits extreme bad behavior (coercion, overreaching, or harassing conduct). Many CPAs abhor solicita- tion, and many state boards of accountancy try to prohibit direct, uninvited approaches to prospective clients, especially when the client already has a CPA. Nevertheless, the U.S. Supreme Court has struck down state solicitation prohibitions, declaring them to be an infringement of personal and business rights to free speech and due process.

CPAs sometimes hire marketing firms to obtain clients. The AICPA permits such arrangements but warns that all such “practice development” activity is subject to the Advertising and Other Forms of Solicitation Rule because members cannot do through others things what they are prohibited from doing themselves.

Form of Organization and Name Rule A member may practice public accounting only in a form of organization permitted by law or regulation whose characteristics conform to resolutions of Council. A member shall not practice public accounting under a firm name that is misleading. Names of one or more past owners may be included in the firm name of a successor organization. A firm may not designate itself as “Member of the American Institute of Certified Public Accountants” unless all of its CPA owners are members of the Institute. (1.800.001)

The Form of Organization and Name Rule allows CPAs to practice public accounting in any form of organization permitted by a state board of accountancy and authorized by law. Organization forms include sole proprietorship, partnership, limited partnership, limited liability partnership (LLP), professional corporation (PC), limited liability corpo- ration (LLC), and ordinary corporation (Inc.). You may have noticed that the large inter- national accounting firms now place LLP after their firm names. Many small accounting firms include PC in their names.

CPAs in public practice cannot use misleading firm names. For example, suppose CPAs Stone and Thompson, who are not in partnership, agree to share expenses for office sup- port, advertising, and continuing education. They cannot put up a sign that states “Stone & Thompson CPAs” because this name suggests a partnership where there is none.

A member who practices public accounting also can participate in the operation of another business organization (e.g., a consulting or tax preparation firm) that offers profes- sional services of the types offered by public accounting firms. If this business is permit- ted to practice public accounting under state law, the member also is considered to be in the practice of public accounting in it and must observe all rules of conduct. CPAs who work in alternative practice structures occupy an odd position. They can prepare compiled

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(unaudited) financial statements, which is considered a form of public accounting practice. In such a case, CPA employees of the alternative practice structure (e.g., “PublicCo”) must take final responsibility for the accountants’ compilation report and must sign it with their own personal names (not the name of PublicCo).

The last paragraph of the Form of Organization and Name Rule permits a mixed accounting organization consisting of CPA and non-CPA owners to designate itself “Members of the AICPA” if all of the CPA owners are actually AICPA members. However, the AICPA Council limits this privilege of organizational form by expressing certain requirements for ownership and control, especially regarding non-CPAs who have ownership interests in an organization that practices public accounting. (See the Council Resolution provisions in the feature “Form of Organization and Name.” The purpose of the Council Resolution is to conform the operations of an accounting organization as closely as possible to the traditional accounting firm and to ensure control of professional services in the hands of CPAs.)

REVIEW CHECKPOINTS B.12 What ethical responsibilities do members of the AICPA have for acts of nonmembers who are

under their supervision (e.g., recent college graduates who are not yet CPAs)? B.13 What rules of conduct apply specifically to members in government and industry? B.14 What provisions of the AICPA Council Resolution on form of organization place control of accounting

services in the hands of CPAs? B.15 What is the primary difference between commissions and referrals?

The characteristics of an accounting organization under the “Form of Organization and Name” rule are as follows:

• A majority (50 percent or more) ownership and voting rights must belong to CPAs.

• Non-CPA owners must be active in the firm, not passive investors. • A CPA must have ultimate responsibility for the firm’s services. • Non-CPA owners can use titles such as “principal, owner, officer, mem-

ber, and shareholder” but cannot hold out to be a CPA.

• Non-CPA owners must abide by the AICPA Code of Professional Conduct. • Non-CPA owners must hold a bachelor’s degree, and after the year

2010, must have 150 semester hours of college education. • Non-CPA owners must complete the same continuing education

requirements as CPAs who are members of the AICPA. • Non-CPA owners are not eligible to be members of the AICPA.

Form of Organization and Name

CONSEQUENCES OF VIOLATING THE CODE OF PROFESSIONAL CONDUCT

Public accounting firms and responsible professional accountants understand the impor- tance of ethics to the profession and seek to ensure that the organization and all employees are acting in an ethical manner. Unethical behavior by an auditor can have financial implications (e.g., fines, lawsuits) and reputation implications that may be difficult to remedy. Quality control practices and disciplinary proceedings provide the mechanisms of self-regulation. Self-regulation refers to the quality control reviews and disciplinary actions conducted by fellow CPAs—professional peers.

LO B-6 Explain the types of penalties that can be imposed on accountants.

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Self-Regulatory Discipline Individual persons (not accounting firms) are subject to the rules of conduct of state CPA societies and the AICPA only if they choose to join these organizations. The AICPA and most of the state societies have entered into a Joint Ethics Enforcement Program through which the AICPA can refer complaints against CPAs to state soci- eties or state societies can refer them to the AICPA. Both organizations have ethics committees to hear complaints. They can (1) acquit an accused CPA, (2) find the CPA in violation of rules and issue a letter of required corrective action, or (3) refer seri- ous cases to an AICPA trial board. The letter of required corrective action ordinarily admonishes the CPA and requires specific continuing education courses to bring the CPA up to date in technical areas.

The trial board panel has the power to (1) acquit the CPA, (2) admonish the CPA, (3) suspend the CPA’s membership in the state society and the AICPA for up to two years, or (4) expel the CPA from the state society and the AICPA. The AICPA bylaws (not the Code of Professional Conduct) provide for automatic expulsion of CPAs judged to have committed a felony, failed to file their tax returns, or aided in the preparation of a false and fraudulent income tax return. The trial board panels are required to publish the names of the CPAs disciplined in their proceedings.

The expulsion penalty, while severe, does not prevent a CPA from continuing to practice accounting. Membership in the AICPA and state societies, while beneficial, is not required. However, a CPA must have a valid state license in order to practice. Most state boards of accountancy are the agencies that can suspend or revoke the license to practice.

The following is the AICPA’s report on cases investigated and their resolutions for 2017 and 2016 cases:

Source: AICPA website (www.aicpa.org).

The AICPA Joint Trial Board in ActionAUDITING INSIGHT

2017 2016

Total cases at beginning of period (including 122 and 120, respectively, deferred due to pending litigation)

1,029 982

Cases opened during period 533 703

Cases completed during period (565) (583)

Total cases at end of period (including 119 and 122, respectively, deferred due to pending litigation)

     997 1,102

Summary of Disposition of Completed Cases

Expelled or suspended 149 162

Admonished 48 33

Corrective action required 96 149

No violation/dismissed 78 43

No further action 136 152

Subsequent monitoring completed satisfactorily 39 30

Other 19 14

     565       583

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Public Regulation Discipline State boards of accountancy are government agencies consisting of CPA and non-CPA office- holders. In most states, the state board of accountancy issues licenses to practice accounting in their jurisdictions. Most state laws require a license to use the designation CPA or certified public accountant and limit the attest (audit) function to license holders only.

State boards have rules of conduct and trial board panels. They can admonish a license holder; perhaps more importantly, most can suspend or revoke the license to practice. Sus- pension and revocation are severe penalties because a person no longer can use the CPA title and cannot sign auditors’ reports. When candidates have successfully passed the CPA exam- ination and are ready to become CPAs, some state boards administer an ethics examination or require taking an ethics course intended to familiarize new CPAs with the state rules.

The SEC and the PCAOB also conduct public disciplinary actions. Their authority comes from their rules of practice, of which Rule 102(e) provides that the SEC can deny, temporarily or permanently, the privilege of practice before the SEC to any person found to have engaged in unethical or improper professional conduct. When conducting a “Rule 102(e) proceeding,” the SEC acts in a quasi-judicial role as an administrative agency.

The SEC penalty bars an accountant from signing any documents filed by an SEC- registered company. The penalty effectively stops the accountant’s SEC practice. In a few severe cases, Rule 102(e) proceedings have resulted in settlements barring not only the individual accountant but also her or his accounting firm or certain of its practice offices from accepting new SEC clients for a period of time.

The PCAOB’s Division of Enforcement and Investigations (DEI) handles disciplinary actions involving accountants (and their firms) who are engaged to audit public compa- nies (also known as “issuers”). The DEI’s role is to identify matters (often from tips) for further investigation, conduct an investigation, and recommend disciplinary proceedings (if considered necessary). Common investigations include violations of the PCAOB’s Auditing Standards, independence violations, and failures to cooperate with inspections/ investigations. If violations are found, the DEI makes recommendations for sanctions to the Board. The Board may decide to suspend or permanently bar an accountant from auditing any public companies, suspend or revoke an accounting firm’s registration, appoint a moni- tor to oversee a firm’s practice, impose monetary penalties, require additional continuing professional education, or impose other sanctions permitted under PCAOB rules.

Different countries have different penalties for accountants caught not honoring the public trust. In China, the death sentences for Zhou Limin, the former head of the China Construction Bank, and Liu Yibing, an accountant, were upheld by China’s State Supreme Court. The pair

was found guilty of stealing more than $60 million by offering fake accounts with high interest rates.

Source: “Accountant Gets Death Penalty,” CFO.com, December 14, 2006.

What Do Other Countries Do?AUDITING INSIGHT

In 2018, three partners from the Deloitte Mexico affiliate firm were barred, fined, and censured by the PCAOB. The reason? They failed to do their jobs and then misrepresented to Deloitte U.S. that the work had been performed. The partners did not evaluate the operating effectiveness of certain internal controls over financial reporting (ICFR), nor did they properly evaluate the loan reserves in 2013 and

2014 of a subsidiary of Texas-based EZCORP which was based in Mexico. The result? All three partners are barred from being associated persons of a registered public accounting firm for two years and have been fined in excess of $30,000 each.

Sources: https://pcaobus.org/News/Releases/Pages/PCAOB-Sanctions-Deloitte- Mexico-Partners.aspx

Do Your JobAUDITING INSIGHT

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REVIEW CHECKPOINTS B.16 What penalties can be imposed by the AICPA and the state societies on CPAs in their “self-regulation”

of ethics code violators? B.17 What penalties can the SEC and PCAOB impose on CPAs who violate rules of conduct?

This module begins with philosophers’ considerations of moral philosophy, explains the AICPA Code of Professional Conduct as well as the SEC and PCAOB rules related to auditors’ independence, provides an overview of the IESBA Code of Ethics, and ends with a review of enforcement actions against those CPAs who choose not to follow the rules. It is important to remember that accounting is the only business discipline that is considered a profession as are medicine and the law. As a result, professional ethics for accountants is not simply a matter covered by a few rules in a formal code of profes- sional conduct. Concepts of proper professional conduct permeate all areas of practice. Ethics and accompanying sanctions for ethical failures provide the foundation for public accountants’ value in the marketplace.

The spirit of the AICPA Code of Professional Conduct is that, although independence is required for audit and attest services, integrity and objectivity are required in connec- tion with all professional services. In this context, integrity and objectivity are the larger concepts and “independence” is a special condition largely defined by the matters of appearance specified in the interpretations of the Independence Rule. The ethics rules may appear to be restrictive, but they are intended to benefit the public, protect the pro- fession, and allow for sanctions to those CPAs choosing not to comply with the rules. The AICPA Code of Professional Conduct was recently reorganized to address situations faced by accountants in varying business environments; the following graphic illustrates how the different rules affect the varying roles that accountants play, whether in public practice, in business, or in other situations (e.g., between jobs).

Summary

CPAs in Public Pratice

Applicability of the AICPA Code of Professional Conduct to CPAs

CPAs in Business

(including those unemployed and retired) Acts Discreditable

Integrity and Objectivity General Standards Compliance with Standards Accounting Principles

Independence Fees and Other Types of Remuneration Advertising and Other Forms of Solicitation Confidential Information Form of Organization and Name

All CPAs

Specific rules in the AICPA Code of Professional Conduct may not necessarily be clas- sified under one of the ethics principles. Decisions based on a rule may involve impera- tive, utilitarian, or personal virtue considerations, or elements of all three. The rules have the form of imperatives because that is the nature of a code. However, elements of utili- tarianism and generalization seem to be apparent in the underlying rationale for most of the rules. If this perception is accurate, auditors may use these two principles in difficult

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decision problems for which adherence to a rule could produce an undesirable result. Your knowledge of philosophical principles in ethics—the imperative, utilitarian, and virtue theories—will help you make decisions about the AICPA, SEC, and PCAOB rules. This structured approach to thoughtful decisions is important not only when you are employed in public accounting but also when you work in government, industry, and education.

Public accountants must be careful in all areas of practice. As an accountant, you must not lose sight of the nonaccountants’ perspective. No matter how complex or technical a decision may be, a simplified view of it always tends to cut away the details of special technical issues to get directly to the heart of the matter. A sense of professionalism coupled with sensitivity to the effect of decisions on other people is invaluable in the practice of accounting and auditing. Remember that when you face an ethical dilemma, you are not alone. The AICPA, other professional organizations, and most accounting firms have anonymous hotlines for you to ask questions, and you always have your colleagues, friends, and family members to talk to.

act-utilitarianism: The emphasis on an individual act as it is affected by the specific circumstances of a situation, 637 categorical imperative: Kant’s specification of an unconditional obligation to act as one thinks others should act regardless of circumstances, 636 commission: A percentage fee charged for professional services in connection with executing a transaction or performing some other business activity, 659 contingent fee: A type of compensation established for the performance of any service in an arrangement in which no amount will be charged unless a specific finding or result is attained or the fee otherwise depends on the result, 658 covered member: Broadly defined, any individual who might be in a position to compromise the integrity of an audit. In the AICPA Code of Professional Conduct, the term is defined as any individual, among others, who is (1) on the audit engagement team, (2) in a position to influence the audit engagement, (3) a partner or manager of a nonaudit client service team, or (4) a partner from the local office of the public accounting firm, 643 generalization argument: A judicious combination of the imperative and utilitarian principles; to act as one thinks others should act in a similar circumstance, 637 independence: A mental attitude and the appearance that the auditor is not influenced by others in judgments and decisions, 643 referral fee: The (1) compensation that a CPA receives for recommending another CPA’s services and (2) that a CPA pays to obtain a client; may or may not be based on a percentage of the amount of any transaction, 659 rule-utilitarianism: The emphasis on the centrality of rules for ethical behavior while still maintaining the criterion of the greatest universal good, 637 self-regulation: The quality control reviews and disciplinary actions conducted by fellow CPAS—professional peers, 662 virtue ethics: The focus on the role of one’s character in the decision-making process, 637

Key Terms

B.18 Auditors are interested in having independence in appearance because a. They want to impress the public with their independence in fact. b. They want the public at large to have confidence in the profession. c. They need to comply with the fundamental principles of GAAS. d. Audits should be planned and properly supervised.

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All applicable questions are available with Connect.

Multiple-Choice Questions for Practice and Review

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B.19 Under Sarbanes–Oxley and PCAOB rules, ensuring that the auditor is independent in appearance is the responsibility of a. The public accounting firm. b. Senior management. c. The audit committee. d. The PCAOB.

B.20 If a public accounting firm says it always follows the rule that requires adherence to FASB pronouncements in order to give a standard unmodified auditors’ report, it is following a philosophy characterized by a. The imperative principle. b. The utilitarian principle. c. Virtue ethics. d. Reliance on members’ collective conscience.

B.21 Which of the following agencies issues independence rules for the auditors of public companies? a. Financial Accounting Standards Board (FASB). b. Government Accountability Office (GAO). c. Public Company Accounting Oversight Board (PCAOB) d. AICPA Accounting and Review Services Committee (ARSC).

B.22 Audit independence in fact is most clearly lost when a. A public accounting firm audits competitor companies in the same industry (e.g., Coca-

Cola and Pepsi). b. An auditor agrees to the argument made by the client’s financial vice president that

deferring losses on debt refinancing is in accordance with generally accepted accounting principles.

c. An audit team fails to discover the client’s misleading omission of disclosure about per- manent impairment of asset values.

d. A public accounting firm issues a standard unmodified report, but the reviewing partner fails to notice that the assistant’s observation of inventory was woefully incomplete.

B.23 The audit committee’s responsibility for auditor independence concerns a. Ensuring that partners of the public accounting firm are not stockholders in the company. b. Ensuring that nonaudit services provided by the auditor do not impair independence. c. Reporting on auditor independence to the PCAOB. d. Ensuring that all nonaudit services are provided by auditors who do not perform the

financial statement audit.

B.24 AICPA members who work in industry and government must always uphold which two of the following AICPA rules of conduct? a. The Independence Rule. b. The Integrity and Objectivity Rule. c. The Confidential Client Information Rule. d. The Acts Discreditable Rule.

B.25 A public accounting firm’s independence is not impaired when members of the audit engagement team does which of the following for a public company audit client? a. Prepares special purchase orders for active plutonium in secure national defense

installations. b. Completes operational internal audit assignments under the directions of the client’s

director of internal auditing. c. Prepares outsourced internal audit work on the client’s financial accounting control

monitoring. d. Prepares actuarial assumptions used by the client’s actuaries for life insurance actuarial

liability determination. e. All of the above would impair the public accounting firm’s independence.

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B.26 When a public accounting firm audits FUND-A in a mutual fund complex that has sister funds FUND-B and FUND-C, independence for the audit of FUND-A is not impaired when a. Managerial-level professionals located in the office where the engagement audit partner

is located but who are not on the engagement team own shares in FUND-B, which is not an audit client.

b. The wife of the FUND-A audit engagement partner owns shares in FUND-C (an audit client of another of the firm’s offices), and these shares are held through the wife’s employee benefit plan funded by her employer, the AllSteelFence Company.

c. Both (a) and (b). d. Neither (a) nor (b).

B.27 Which of the following is considered a close relative (but not an immediate family member) as defined by the AICPA? a. Spouse b. Spousal equivalent c. Parent d. Uncle

B.28 Which of the following is true if an auditor performs nonaudit services for a government entity? a. The scope of the audit must be reduced so that the auditor does not audit the area for

which the nonaudit work was performed. b. The auditor is prohibited from providing nonaudit work in areas directly related to the

production of accounting information. c. The senior members of the government entity must document their review of the

nonaudit service and indicate why it is appropriate for the auditors to perform this service.

d. The scope of the audit cannot be reduced because the nonaudit work was performed by the public accounting firm.

B.29 Which of the following is true? a. Members of an audit engagement team cannot speak with audit client officers about mat-

ters outside the scope of the audit while the audit engagement is in progress. b. Audit team members who leave the public accounting firm for employment with audit

clients can provide audit efficiencies (next year) because they are very familiar with the firm’s audit plans.

c. Audit team partners who leave the public accounting firm for employment with audit clients can retain variable annuity retirement accounts established in the person’s former firm retirement plan.

d. The public accounting firm must discuss with the audit client’s board or its audit commit- tee the independence implications of the client’s having hired the audit engagement team manager as its financial vice president.

B.30 Which of the following “bodies designated by Council” have been authorized to promul- gate general standards enforceable under the General Standards Rule of the AICPA Code of Professional Conduct? a. AICPA Division of Professional Ethics. b. Financial Accounting Standards Board. c. Government Accounting Standards Board. d. Accounting and Review Services Committee.

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B.31 Which of the following “bodies designated by Council” have been authorized to promulgate accounting principles enforceable under the Accounting Principles Rule of the AICPA Code of Professional Conduct? a. Auditing Standards Board. b. Federal Accounting Standards Advisory Board. c. Consulting Services Executive Committee. d. Accounting and Review Services Committee.

B.32 Phil Greb has a thriving practice in which he assists attorneys in preparing litigation dealing with accounting and auditing matters. He is “practicing public accounting” if he a. Uses his CPA designation on his letterhead and business card. b. Is in partnership with another CPA. c. Practices in a professional corporation with other CPAs. d. Never lets his clients know that he is a CPA.

B.33 The AICPA removed its general prohibition of CPAs taking commissions and contingent fees because a. CPAs prefer more price competition to less. b. Commissions and contingent fees enhance audit independence. c. Nothing is inherently wrong about the form of fees charged to nonaudit clients. d. Objectivity is not always necessary in accounting and auditing services.

B.34 CPA Kara Rambo is the auditor of Ajax Corporation. Her audit independence will not be considered impaired if she a. Owns $1,000 worth of Ajax stock. b. Has a husband who owns $1,000 worth of Ajax stock. c. Has a sister who is the financial vice president of Ajax. d. Owns $1,000 worth of the stock of Pericles Corporation, which is controlled by Ajax as

a result of Ajax’s ownership of 40 percent of Pericles’ stock, and Pericles contributes 3 percent of its total assets and income in Ajax’s financial statements.

B.35 When a client’s financial statements contain a material departure from an FASB Statement on Accounting Standards and the public accounting firm believes the departure is necessary to ensure that the statements are not misleading, a. The public accounting firm must qualify the auditors’ report for a departure from GAAP. b. The public accounting firm can explain why the departure is necessary and then give an

unmodified opinion paragraph in the auditors’ report. c. The public accounting firm must give an adverse auditors’ report. d. The public accounting firm can give the standard unmodified auditors’ report with an

unmodified opinion paragraph.

B.36 Which of the following would not be considered confidential information obtained in the course of an engagement for which the client’s consent would be needed for disclosure? a. Information about whether a consulting client has paid the CPA’s fees on time. b. The actuarial assumptions used by a tax client in calculating pension expense. c. Management’s strategic plan for next year’s labor negotiations. d. Information about material contingent liabilities relevant for audited financial statements.

B.37 Which of the following would probably not be considered an “act discreditable to the profession”? a. Numerous moving traffic violations. b. Failing to file the CPA’s own tax return. c. Filing a fraudulent tax return for a client in a severe financial difficulty. d. Refusing to hire Asian Americans in an accounting practice.

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B.38 According to the AICPA Code of Professional Conduct, which of the following acts is generally forbidden to CPAs in public practice? a. Purchasing bookkeeping software from a high-tech development company and reselling

it to tax clients. b. Being the author of a “TaxAid” newsletter promoted and sold by a publishing company. c. Having a commission arrangement with an accounting software developer to receive

4 percent of the price of programs recommended and sold to audit clients. d. Engaging a marketing firm to obtain new financial planning clients for a fixed fee of

$1,000 for each successful contact. B.39 A CPA’s legal license to practice public accounting can be revoked by the

a. American Institute of Certified Public Accountants. b. State society of CPAs. c. Auditing Standard Board. d. State board of accountancy.

B.40 According to the Acts Discreditable Rule for accountants in public practice, which of the following is not a “discreditable act”? a. Withholding a client’s sales records. b. Failing to file or remit tax payments. c. Failing to follow requirements of the PCAOB during the audit of an SEC client. d. Advertising that indicated the firm can reduce IRS penalties.

B.41 An auditor’s independence would not be considered impaired if she or he had a. Owned common stock of the audit client but sold it before the company became a client. b. Sold short the common stock of an audit client while working on the audit engagement. c. Served as the company’s treasurer for six months during the year covered by the audit but

resigned before the company became a client. d. Performed the bookkeeping and financial statement preparation for the company, which

had no accounting personnel and for which the president had no understanding of accounting principles.

B.42 When a CPA knows that a tax client has skimmed cash receipts and not reported the income in the federal income tax return but signs the return as a CPA who prepared the return, the CPA has violated which of the following AICPA rules of conduct? a. The Confidential Client Information Rule. b. The Integrity and Objectivity Rule. c. The Independence Rule. d. The Accounting Principles Rule.

B.43 An accountant recommends a local computer company to a client that is trying to upgrade its computerized sales records. The client purchases $25,000 worth of equipment and sends a check to the accountant for 5 percent of the total sales. This is an example of a a. Commission. b. Contingent fee. c. Referral fee. d. Nonaudit fee.

B.44 Which of the following ownership situations is permissible for a public accounting firm? a. A partner of the firm is responsible for fraud issues related to audits and audit clients.

He owns 20 percent of the firm and is not a CPA. b. Because the firm now specializes in fraud auditing and fraud investigation, the managing part-

ner of the firm has a background in law enforcement and fraud investigation but is not a CPA. c. A partner of the firm who owns 50 shares of stock in an audit client of the firm is respon-

sible for fraud issues related to audits and audit clients. d. A partner of the firm who has 20 years of experience in law enforcement and fraud investiga-

tion is responsible for fraud issues related to audits and audit clients. The partner’s career began as a police officer after receiving a law enforcement degree from a local community college.

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All applicable questions are available with Connect.

Exercises and Problems

B.45 SEC Independence Rules. Is independence impaired for the individual or the public accounting firm on these SEC filing audits according to SEC independence rules? a. CPA Yolanda is the Best & Co engagement partner on the Casa Construction Company (CCC)

audit supervised from the Santa Fe office of the firm. Yolanda owns 100 shares of CCC. b. CPA Yolanda sold the 100 CCC shares to CPA Javier, who is another partner in the Santa

Fe office but who is not involved in the CCC audit. c. CPA Javier transferred ownership of the 100 CCC shares to his wife. d. CPA Javier’s wife gave the shares to their 12-year-old son. e. CPA Javier’s son sold the shares to Javier’s father. f. CPA Javier’s father was happy to combine the 100 CCC shares with shares he already

owned because now he owns 25 percent of CCC and can control many decisions of the board of directors.

g. CPA Javier’s father declared personal bankruptcy and sold his CCC stock. CCC then hired him to fill the newly created position of director of financial reporting.

B.46 SEC Independence and Nonaudit Services. Is independence impaired on these SEC filing audits according to SEC independence rules regarding nonaudit services? a. CPA Dakota Tidrick is a staff assistant II auditor on the Section Co. audit. Upon the

audit completion date in January, Tidrick drafted the balance sheet, income statement, comprehensive income statement, statement of cash flows, and notes for review by the engagement partner before the auditors’ report was finalized.

b. CPA Mel Carnes is a manager in the firm’s consulting division. He spent 100 hours with the Section Co. audit client on an accounts payable information system study, which involved selecting the preferred software and supervising Section Co.’s employees in startup operations.

c. CPA Nicky Webber, working in the public accounting firm’s asset valuation consult- ing division located in Chicago, prepared for Section Co. an appraisal of the fair value of assets purchased in Section’s merger with the Group Co. These valuations were then audited by the engagement team located in Dallas in connection with the purchase accounting for the merger.

d. CPA Fran Young is the engagement partner on the Section Co. audit and is an actuarial consultant in the firm’s consulting division. Young personally audited the client’s pos- temployment benefits calculations, which had been prepared by Section’s actuaries.

e. Section Co. appointed its own employee, certified internal auditor (CIA) Pat Mumta, to be director of internal auditing with complete responsibility for planning, management, and review of all internal audit work. Mumta engaged Section Co.’s independent public accounting firm to supply staff to perform all operational audit studies of efficiency and effectiveness in Section’s domestic subsidiary companies. The public accounting firm used half of these same staff professionals to work on the audit of Section’s financial statement audit.

f. CPA Dale Churyk is the partner in charge of the Dallas office where the Section Co. audit is managed (by engagement partner Jack). Churyk has no direct role on the audit engagement team. However, Section relies on Churyk to prepare the confidential papers for the board of directors’ stock options and sign the release forms for option grants.

g. CPA Robin Mantzke works in the executive search department of the public account- ing firm’s consulting division, located in New York City. In connection with Section Co.’s hiring of its new vice president for marketing, Mantzke checked the references on the lead candidate Smith and performed a thorough background investigation that led to the firm’s advice that Smith was the best person for the appointment. Section Co. board members investigated other candidates and hired Smith in Dallas without further interac- tion with Mantzke.

h. Section Co. completed a private placement of long-term bonds during the year under audit. The bonds were distributed to 40 qualified-exempt investors through the brokerage

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firm of Amalgamated Exchange Inc., which is 50 percent owned by the public account- ing firm and 50 percent owned by Lynch Merrill Investment Corporation.

i. The public accounting firm’s tax consulting division prepared Section Co.’s export- import tax reports, which involved numerous interpretations of complicated export- import tax law provisions.

B.47 Independence, Integrity, and Objectivity Cases. Read the following cases.

Required: For each case, state whether the action or situation shows a violation of the AICPA Code of Professional Conduct, explain why if it does, and cite the relevant rule.

a. CPA Ellen Stout performs the audit of the local symphony society. Because of her good work, she was elected an honorary member of the board of directors.

b. CPA Darcy Wolfe practices management consulting in the area of computerized informa- tion systems under the firm name of Wolfe & Associates. The “associates” are not CPAs, and the firm is not an accounting firm. However, Wolfe shows “CPA” on business cards and uses these credentials when dealing with clients.

c. CPA Alex Goodwin performs significant day-to-day bookkeeping services for Harper Corporation and supervises the work of the one part-time bookkeeper employed by Had- ley Harper. This year, Harper wants to engage CPA Goodwin to perform an audit.

d. CPA H. Poirot bought a home in 1989 and financed it with a mortgage loan from Far- raway Savings and Loan. Farraway was merged into Nearby S&L, and Poirot became the manager in charge of the Nearby audit.

e. Poirot inherited a large sum of money from old Mr. Giraud in 2000. Poirot sold his house, paid off the loan to Nearby S&L, and purchased a much larger estate. Nearby S&L pro- vided the financing.

f. Poirot and Mala Lemon (a local real estate broker) formed a partnership to develop apart- ment buildings. Lemon is a 20 percent owner and managing partner. Poirot and three partners in the accounting firm are limited partners. They own the remaining 80 percent of the partnership but have no voice in everyday management. Lemon obtained perma- nent real estate financing from Nearby S&L.

g. Lemon won the lottery and purchased part of the limited partners’ interests. She now owns 90 percent of the partnership and remains general partner while the CPAs remain limited partners with 10 percent interest.

h. CPA Justin Shultz purchased a variable annuity insurance contract that offered the option to choose the companies in which this contract will invest. As directed, the insurance company purchased common stock in one of Shultz’s audit clients.

B.48 Independence, Integrity, and Objectivity Cases. Read the following cases.

Required: For each separate case, state whether the action or situation shows a violation of the AICPA Code of Professional Conduct; if so, explain why and cite the relevant rule or interpretation. a. Your client, Contrary Corporation, is very upset over the fact that your audit last year

failed to detect an $800,000 inventory overstatement caused by employee theft and fal- sification of the records. The board discussed the matter and authorized its attorneys to explore the possibility of a lawsuit for damages.

b. Contrary Corporation filed a lawsuit alleging negligent audit work, seeking $1 million in damages.

c. In response to the lawsuit by Contrary, you decided to bring litigation against certain offi- cers of the company alleging management fraud and deceit. You are asking for a damage judgment of $500,000.

d. The Allright Insurance Company paid Contrary Corporation $700,000 under a fidelity bond covering an inventory theft by employees. Allright is suing your public accounting firm for damages on the grounds of negligent performance of the audit, claiming that a proper audit would have uncovered the theft sooner and the amount of loss would have been considerably less.

e. Your audit client, Science Tech Inc., installed a cost accounting system devised by the con- sulting services department of your firm. The system failed to account properly for certain

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product costs (according to management), and the system had to be discontinued. Science Tech management was very dissatisfied and filed a lawsuit demanding return of the $10,000 consulting fee. The audit fee is normally about $50,000, and $10,000 is not an especially large amount for your firm. However, you believe that Science Tech management operated the system improperly. You are willing to do further consulting work at a reduced rate to make the system operate, but you are unwilling to return the entire $10,000 fee.

f. A group of dissident shareholders filed a class-action lawsuit against both you and your client, Amalgamated Inc., for $30 million. They allege there was a conspiracy to present misleading financial statements in connection with a recent merger.

g. CPA Ellis Lisa, a shareholder in the firm of Eden, Benjamin, and Block, P.C. (a profes- sional accounting corporation), owns 25 percent of the common stock of Dove Corpora- tion (not a client of Eden, Benjamin, and Block). This year, Dove purchased a 32 percent interest in Tale Company and is accounting for the investment using the equity method of accounting. The investment amounts to 11 percent of Dove’s consolidated net assets. Tale Company has been an audit client of Eden, Benjamin, and Block for 12 years.

h. CPAs Mark and Ben Saliba are the father-and-son partners of Queens, LLP. They have a 12 percent joint private investment in ownership of the voting common stock of Hydra Corporation, which is not an audit client of Queens, LLP. However, the firm’s audit cli- ent, Howard Company, owns 46 percent of Hydra, and this investment accounts for 20 percent of Howard’s assets (using the equity method of accounting).

i. Drew Francie and Madison Brian, CPAs, regularly perform the audit of the First National Bank, and the firm is preparing for the audit of the financial statements for the year ended December 31, 2020. (1) Two directors of the First National Bank became partners in Francie and Brian,

CPAs, on July 1, 2020, resigning their directorship on that date. They will not partici- pate in the audit.

(2) During 2020, the former controller of the First National Bank, now a partner in Fran- cie and Brian, was frequently called on for assistance regarding loan approvals and the bank’s minimum checking account policy. In addition, the former controller con- ducted a computer feasibility study for First National.

j. The Cather Corporation is indebted to a CPA for unpaid fees and has offered to give the CPA unsecured interest-bearing notes. Alternatively, Cather Corporation offered to give the CPA two shares of its common stock, after which 10,002 shares would be outstanding.

k. May Debra is not yet a CPA but is doing quite well in her first employment with a large public accounting firm. She has been on the job two years and has become an “experi- enced assistant.” If she passes the CPA exam this year, she will be promoted to senior accountant. This month, during the audit of Row Lumber Company, Debra told the con- troller that she is remodeling an old house. The controller likes Debra and had a load of needed materials delivered to the house, billing Debra at a 70 percent discount—a sav- ings over the normal cash discount of about $300. Debra paid the bill and was happy to have the materials that she otherwise could not afford on her meager salary.

l. Groaner Corporation is in financial difficulty. You are about to sign the report on the cur- rent audit when your firm’s office manager informs you the audit fee for last year has not yet been paid.

m. CPA Aubrey Rowan prepared Goodwin’s tax return this year. Last year, Goodwin pre- pared the return and paid too much income tax because the tax return erroneously con- tained “income” in the amount of $300,000 from an inheritance received when dear Aunt Martha died. This year, Goodwin sold the inherited property for $500,000. Goodwin argued with Rowan, who agreed to omit the sale of the property and the $200,000 gain this year on the grounds that Goodwin had already overpaid tax last year and this omis- sion would make things even.

n. CPA Sage Watson is employed by Baker Street Company as its chief accountant. Lee Lestrade, also a CPA and the financial vice president of Baker, owns a trucking com- pany that provides shipping services to Baker in a four-state area. The trucking com- pany needs to buy 14 new trailers, and Lestrade authorized a payment to finance the purchase in the amount of $750,000. The related document cited repayment in terms of reduced trucking charges for the next seven years. Lestrade created the journal entry for this arrangement, charging the $750,000 to prepaid expenses. Watson and Lestrade

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signed the representation letter to Baker’s external auditors and stated that Baker had no related-party transactions that were not disclosed to the auditors.

B.49 Integrity and Objectivity. Back in 1997, a disagreement arose between Livent Inc. and its auditor, Deloitte and Touche. Livent, which operated several theaters for live stage produc- tion, had sold the naming rights to one of its theaters to AT&T for $12.5 million. The agree- ment was oral, and one of the theaters was under construction. The auditors for Deloitte believed that only a portion of the deal should be included in revenue, but Livent wanted to book the entire $12.5 million. Livent retained Ernst & Young (EY) to provide an opinion on the transaction. EY’s report indicated that all $12.5 million could be recorded as revenue. Deloitte hired Price Waterhouse (currently PricewaterhouseCoopers) to review the trans- action. Price Waterhouse agreed with EY and Livent, and Deloitte allowed Livent to book the $12.5 million. In 1998, Livent issued a series of press releases indicating the discovery of significant account irregularities and, later in 1998, declared bankruptcy.

Required: Comment on the decision to engage EY and Price Waterhouse concerning the $12.5 million transaction. What would your position be on the need for other opinions? What would your position be for the disposition of the transaction?

B.50 General and Technical Rule Cases. Read the following cases. For each, state whether the action or situation shows a violation of the AICPA Code of Professional Conduct; if so, explain why and cite the relevant rule. a. CPA Jerry Cheese became the new auditor for Python Insurance Company. Cheese knew

a great deal about insurance accounting but had never conducted an audit of an insurance company. Consequently, Cheese hired CPA Tate Gilliam, who had six years of expe- rience with the State Department of Insurance Audit. Gilliam managed the audit, and Cheese was the partner in charge.

b. CPA Mackenzie Palin practices public accounting and is a director of Comedy Company. Palin’s firm performs consulting and tax services for Comedy. Palin prepared unaudited financial statements on Comedy’s letterhead and submitted them to First National Bank in support of a loan application. Palin’s accounting firm received a fee for this service.

c. CPA Ellery Idle audited the financial statements of Monty Corporation and gave an unmodified report. Monty is not a public company, so the financial statements did not contain the SEC-required reconciliation of deferred income taxes.

d. CPA Gwyn Chapman audited the financial statement of BTV Ltd. These financial statements contain capitalized leases that do not meet FASB criteria for capitaliza- tion. They resemble more closely the criteria for operating leases. The effect is mate- rial, adding $4 million to assets and $3.5 million to liabilities. However, BTV has a long experience with acquiring such property as its own assets after the “lease” terms end. Chapman and BTV management believe the financial statements should reflect the operating policy of the management instead of the technical requirements of the FASB. Consequently, the auditors’ report explains the accounting and gives an unmodified opinion.

B.51 Responsibilities to Clients’ Cases. Read the following cases. For each case, state whether the action or situation shows a violation or potential for violation of the AICPA Code of Professional Conduct, explain why, and cite the relevant rule. a. CPA Sal Colt has discovered a way to eliminate most of the boring work of processing

routine accounts receivable confirmations by contracting with the Cohen Mail Service. After the auditor has prepared the confirmations, Cohen stuffs them in envelopes, mails them, receives the return replies, opens the replies, and returns them to Colt.

b. Cadentoe Corporation, without consulting Jora Cramer, its CPA, has changed its account- ing so that it is not in conformity with GAAP. During the regular audit engagement, Cra- mer discovers that the statements based on the accounts are so grossly misleading that they might be considered fraudulent. Cramer resigns the engagement after a heated argu- ment. Cramer knows that the statements will be given to Sandy Panzer, a friend at the Last National Bank, and that Panzer is not a very astute reader of complicated financial statements. Two days later, Panzer calls Cramer and asks some general questions about Cadentoe’s statements and remarks favorably on the very thing that is misrepresented. Cramer corrects the erroneous analysis and Panzer is very much surprised.

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c. A CPA who had reached retirement age arranged to sell the practice to another certified public accountant. Their agreement called for the review of all audit documentation and business correspondence by the accountant purchasing the practice.

d. Martha Jacoby, CPA, withdrew from the audit of Harvard Company after discover- ing irregularities in Harvard’s income tax returns. One week later, Jacoby received a phone call from Jake Henry, CPA, who explained that he had just been retained by Har- vard Company to replace her. Henry asked Jacoby why she withdrew from the Harvard engagement, and she told him.

e. CPA Chen Wallace has two audit clients: Willingham Corporation owned by Jayden Willingham and Ward Corporation owned by Bailey Ward. Willingham Corp. sells a large proportion of its products to Ward Corp., which amounts to 60 percent of Ward Corp.’s purchases in most years. Willingham and Ward are also Wallace’s tax clients as individuals. This year, while preparing Ward’s tax return, Wallace discovered informa- tion that suggested Ward Corporation is in a failing financial position. In consideration of the fact that the companies and individuals are mutual clients, Wallace discussed Ward Corporation’s financial difficulties with Willingham.

f. Ashley Fiddle, CPA, prepared an uncontested claim for a tax refund on Faddle Corpora- tion’s amended tax return. The fee for the service was 30 percent of the amount the IRS rules to be a proper refund. The claim was for $300,000.

g. After Faddle had won a $200,000 refund and Fiddle collected the $60,000 fee, Jordan Faddle, the president, invited Fiddle to be the auditor for Faddle Corporation.

h. Burgess Company engaged CPA Kim Philby to audit Maclean Corporation in connection with a possible initial public offering (IPO) of stock registered with the SEC. Burgess Company established a holding company named Cairncross Inc. and asked Philby to issue an engagement letter addressed to Cairncross stating that Cairncross would receive the auditors’ report. Cairncross has no assets, and Philby agreed to charge a fee for the audit of Maclean only if the IPO is successful.

B.52 Other Responsibilities and Practices Cases. Read the following cases. For each, state whether the action or situation shows a violation or potential for violation of the AICPA Code of Professional Conduct; if so, explain why, and cite the relevant rule.

a. CPA Ron Stout completed a review of the unaudited financial statements of Wolfe Gifts. Arvida Wolfe was very displeased with the report. An argument ensued, and she told Stout never to darken her door again. Two days later, she telephoned Stout and demanded that he return (1) Wolfe’s cash disbursement journal, (2) Stout’s documentation schedule of adjust- ing journal entries, (3) Stout’s inventory analysis documentation, and (4) all other documen- tation prepared by Stout. Wolfe had not yet paid her bill, so Stout replied that state law gave him a lien on all of the records and he would return them as soon as she paid his fee.

b. CPA O’Dell May teaches a CPA review course at the university. He needs problem and question material for students’ practice, but the CPA examination questions and answers are no longer published. He pays $5 to students who take the exam for each question they can “remember” after taking the examination.

c. CPA Kelsey Blitz has been invited to conduct a course in effective tax planning for the City Chamber of Commerce. The chamber’s president said a brochure would be mailed to members giving the name of Blitz’s firm, Blitz’s educational background and degrees held, professional society affiliations, and testimonials from participants in the course held last year comparing Blitz’s excellent performance with other CPAs who have offered competing courses in the city.

d. CPA Reece Philby is a member of the state bar whose practice is a combination of law and accounting and is heavily involved in estate planning engagements. Philby’s letter- head has the following: Member, State Bar of Illinois, and Member, AICPA.

e. The public accounting firm of Burgess & Maclean (B&M) has made a deal with Brit & Company, a firm of management consulting specialists, for mutual business advantage. B&M agreed to recommend Brit to clients who need management consulting services. Brit agreed to recommend B&M to clients who need improvements in their accounting systems. During the year, both firms would keep records of fees obtained by these mutual referrals. At the end of the year, Brit and B&M would settle the net differences based on a referral rate of 5 percent of fees.

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f. Jack Robinson and Archie Robertson (both CPAs) are not partners, but they have the same office, the same employees, and a joint bank account and work together on audits. A letterhead they use shows both their names and the description “Members, AICPA.”

g. CPA Lou Dewey retired from the two-person firm of Dewey & Cheatham (D&C). One year later, D&C merged practices with Howe & Company to form a regional firm under the name of Dewey, Cheatham, & Howe Company.

B.53 AICPA Independence and Other Services. The Independence Rule of the AICPA Code of Conduct cites several “other services” that do and do not impair audit independence.

Required: Go to the AICPA website (www.aicpa.org), access the Code of Professional Conduct (ET 1.295) and find whether the following items impair independence (Yes) or do not impair independence (No) when performed for audit clients.

a. Post the client-approved entries to a client’s trial balance. b. Authorize the client’s customer credit applications. c. Use CPA’s information-processing facilities to prepare the client’s payroll. d. Use CPA’s information-processing facilities to generate checks for the client treasurer’s

signature. e. Advise client management about the application or financial effect of provisions in an

employee benefit plan contract. f. Have emergency signature authority to cosign cash disbursement checks in connection

with a client’s hospital benefit plan. g. As an investment advisory service, provide analyses of a client’s investments in compari-

son to benchmarks produced by unrelated third parties. h. Take temporary custody of a client’s investment assets each time a purchase is made as a

device to reduce cash float expense.

B.54 General Ethics. Is there any moral difference between a disapproved action in which you are caught and the same action that never becomes known to anyone else? Do many persons in business and professional society make a distinction between these two circumstances? If you respond that you do (or do not) perceive a difference while persons in business and professional society do not (or do), how do you explain the differences in attitudes?

B.55 Competition and Audit Proposals. Accounting firms are often asked to present “proposals” to companies’ boards of directors. These proposals are comprehensive booklets, accompa- nied by oral presentations, telling about the firm’s personnel, technology, special qualifica- tions, and expertise in the hope of convincing the board to award the work to the firm.

Kourtney Dena has a new job as staff assistant to Selby Michael, chairman of the board of Granof Grain Company. The company has a policy of engaging new auditors every seven years. The board will hear oral proposals from 12 accounting firms. This is the second day of the three-day meeting. Dena’s job is to help evaluate the proposals. During the first day of meetings, the proposal presented by Eden, Benjamin, and Block was clearly the best.

At the end of the day, Dena sees Michael’s staff chief slip a copy of Eden, Benjamin, and Block’s written proposal into an envelope. He then tells Dena to take it to a friend who works for Hunt and Hunt, a public accounting firm scheduled to make its presentation tomorrow, saying, “I told him we’d let him glance at the best proposal.” Michael is absent from the meeting and will not return for two hours.

Required: What should Dena do? What should CPA Hunt do if he receives the Eden, Benjamin, and Block proposal, assuming he has time to modify the Hunt and Hunt proposal before tomor- row’s presentation?

B.56 Engagement Timekeeping Records. A time budget is always prepared for audit engage- ments. Numbers of hours are estimated for various segments of the work, for example, inter- nal control evaluation, cash, inventory, and report review. Audit supervisors expect the work segments to be completed “within budget” and evaluate staff accountants’ performance in part on the ability to perform audit work efficiently within budget. Jessica Sara is an audit manager who has worked hard to get promoted. She hopes to become a partner in two or three years. Finishing audits on time is heavily weighted on her performance evaluation. She

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assigned the cash audit work to Paul Ed, who has worked for the firm for 10 months. Ed hopes to get a promotion and salary raise this year. Twenty hours were budgeted for the cash work. Ed is efficient, but it took 30 hours to finish because the company had added seven new bank accounts. Ed was worried about his performance evaluation, so he recorded 20 hours for the cash work and put the other 10 hours under the internal control evaluation budget.

Required: What do you think about Ed’s resolution of his problem? Was his action a form of lying? What would you think of his action if the internal control evaluation work was presently under budget because it was not yet complete and another assistant was assigned to finish that work segment later?

B.57 Audit Overtime. The performance evaluation of all accountants is based in part on their ability to do audit work efficiently and within the time budget planned for the engagement. New staff accountants, in particular, usually have some early difficulty learning speedy work habits, which demand that no time be wasted. Cynthia Elizabeth started work for Julie and Jacob CPAs in September. After attending the staff training school, she was assigned to the Rising Sun Company audit. Her first work assignment was to complete the extensive recalculation of the inventory compilation using the audit test counts and audited unit prices for several hundred inventory items. Her time budget for the work was six hours. She started at 4 P.M. and was not finished when everyone left the office at 6 P.M. Not wanting to stay downtown alone, she took all necessary audit documentation home. She resumed work at 8 P.M. and finished at 3 A.M. The next day, she returned to the CPA offices, put the completed documentation in the file, and recorded six hours in the time budget/actual schedule. Her supervisor was pleased, especially about her diligence in taking the work home.

Required: a. What do you think about Elizabeth’s diligence and her understatement of the time she

took to finish the work? b. What would you think of the case if she had received help at home from her husband Paul? c. What would you think of the case if she had been unable to finish and had left the work

at home for her husband to finish?

B.58 Conflict of Client’s Interests. Jon Williams, CPA, is in the middle of the real-life soap opera, Taxing Days of Our Lives.

The Cast of Characters Oneway Corporation is Williams’s audit and tax client. The three directors are the officers and the only three stockholders, each owning exactly one-third of the shares. President Raul Jack founded the company and is now nearing retirement. As an individual, he is also Williams’s tax client. Vice President Jana Jill manages the day-to-day operations. She has been instrumental in increasing the business and its profits. Jill’s individual tax work is done by CPA Corin Phil. Treasurer Chris Bill has been a long-term, loyal employee responsible for many innovative financial transactions and reports of great benefit to the business. He is Williams’s close personal friend and an individual tax client.

The Conflict President Jack discussed with CPA Williams the tax consequences to him as an individual of selling his one-third interest in Oneway Corporation to Vice President Jill. Later, meeting with Bill to discuss his individual tax problems, Williams learns that Bill fears that Jack and Jill will make a deal, put him in a minority position, and force him out of the company. Bill says, “Jon, we’ve been friends a long time. Please keep me informed about Jack’s plans, even rumors. My interest in Oneway Corporation represents my life savings and my resources for the kid’s college. Remember, you’re little Otto’s godfather.”

Thinking back, Williams realized that Vice President Jill has always been rather hostile. Chances are that Phil would get the Oneway engagement if Jill acquires Jack’s shares and controls the corporation. Nevertheless, Bill will probably suffer a great deal if he cannot learn about Jack’s plans, and Williams’s unwillingness to keep him informed will probably ruin their close friendship.

Later, on a Dark and Stormy Night Williams ponders the problem. “Oneway Corporation is my client, but a corporation is a fiction—only a form. The stockholders personify the real entity, so they are collectively my

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clients, and I can transmit information among them as though they were one person. Right? On the other hand, Jack and Bill engage me for individual tax work, and information about one’s personal affairs is really no business of the other. What to do? What to do?”

Required: Give Williams advice about alternative actions, considering the constraints of the AICPA Code of Professional Conduct.

B.59 AICPA Code of Professional Conduct. Reread the Module B introduction about Scott London, CPA.

Required: a. What code violations have occurred in this case? b. What is the range of penalties that the PCAOB could levy against London? By the

California State Board of Accountancy? c. What do you think is the appropriate penalty?

B.60 Disciplinary Action. Go to the PCAOB website (www.pcaobus.org) and find settled disci- plinary orders. Review the cases and the penalties indicated for various published cases.

Required: What did Richard Huff do to get in trouble, and what was his sanction from the PCAOB?

B.61 Ethics Case.11 Sandy Sally is a sole proprietor CPA who runs a successful practice with five employees. Several years ago, Sally purchased an office building and relocated the practice in about 20 percent of the space and rented out the remaining portion. Things went well for the first few months, but then two of Sally’s tenants ran into financial difficulties and had to vacate the building. Sally was unable to quickly find new tenants for the space.

Sally struggled to keep current with the mortgage payments for a few months, but the loss of tenant income combined with the expense of operating a building became a large burden. Cash flow became very tight, and Sally stopped remitting the employee payroll taxes withheld.

The IRS filed a lien for nonpayment of employee payroll taxes, which was published in a local newspaper. A concerned citizen filed an ethics complaint.

Investigation found that, although the company had been delinquent in remitting employee payroll taxes and a federal tax lien had been filed, Sally had brought the tax liabili- ties into current status and produced evidence that the IRS lien had been released.

Required: a. What code violation(s) have occurred in this case? b. What is the range of penalties that could be levied against Sally? c. What do you think is the appropriate penalty?

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11The following information was obtained from the Pennsylvania CPA Journal and is adopted from a case brought before the Pennsylvania Ethics Committee; see R. J. DePasquale and C. Williams, “The CPA’s Taxes and the Code of Ethics,” Pennsylvania CPA Journal, Winter 2004.

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Benjamin Disraeli, British prime minister and author (1804–1881)

When men are pure, laws are useless; when men are corrupt, laws

are broken.

Legal Liability

M O D U L E C

Professional Standards References

Topic AU-C/ISA Section AS Section

Audit Documentation 230 1215

Letters for Underwriters and Certain Other Requesting Parties 920 6101

Filings under the Securities Act of 1933 925 4101

LEARNING OBJECTIVES Module B on professional ethics dealt mainly with auditors’ self-regulation. This module focuses on public regulation enforced by the Securities and Exchange Commission (SEC) and state and federal court systems. The discussion will help you understand auditors’ legal liability for professional work.

Your objectives are to be able to:

LO C-1 Identify and describe auditors’ exposure to lawsuits and loss judgments.

LO C-2 Specify the characteristics of auditors’ liability under common law and cite specific case precedents.

LO C-3 Describe auditors’ liability to third parties under statutory law.

LO C-4 Specify the civil and criminal liability provisions of the Securities Act of 1933.

LO C-5 Specify the civil and criminal liability provisions of the Securities Exchange Act of 1934.

LO C-6 Understand recent developments that affect auditors’ liability to clients and third parties.

PricewaterhouseCoopers (PwC) is one of the largest of the Big Four accounting firms, with revenues of more than $41 billion in 2018. In 2018, a federal judge ruled PwC negligent in the audit of Colonial Bank, ordering the firm to pay $625 million to the Federal Deposit Insurance Corp. (FDIC) to offset some of the $5 billion the FDIC claims the bank’s failure cost them as the insurer.1

PwC served as the auditor for Colonial Bank in the early 2000s, up through the collapse and closure of the bank in 2009. The collapse of Colonial Bank was a direct result of the fraud occurring at Taylor, Bean & Whitaker. 1Ben Lane, “PwC reaches $335 million settlement with FDIC over Taylor, Bean, and Whitaker/Colonial Bank audits,” Housing Wire, March 18, 2019, www.housingwire.com/articles/print/48456-pwc-reaches-335-million-settlement-with-fdic-over-taylor-bean- whitakercolonial-bank-audits; Francine McKenna, “PwC faces largest ever auditor malpractice damages verdict,” MarketWatch, April 7, 2018, www.marketwatch.com/story/pwc-faces-largest-ever-auditor-malpractice-damages-verdict-2018-04-05)

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Taylor Bean & Whitaker (TBW) was a top mortgage lending firm in the early 2000s; they were the largest privately held mortgage company in the country employing more than 2,000 people. The problem was TBW had recorded hundreds of millions of dollars in mortgages that did not exist. Colonial Bank bought many of those non- existent mortgages from TBW. By 2009, Colonial Bank had purchased and recorded more than $500 million in nonexistent loans. According the presiding judge in the 2018 proceedings, PwC was found negligent in part due to their failure to inspect the TBW loan files at Colonial for several years and their failure to inspect the supposed collateral backing of the loans.

In March 2019, the FDIC and PwC reached a settlement where, instead of $625 million, PwC would pay the FDIC $335 million, without admitting auditor negligence. The FDIC agreed to the settlement but noticeably without the support of former FDIC Chair and current board member Martin Gruenberg. According to Mr. Gruenberg, “The settlement announced. . .did not include a written admission of liability by PwC. Given PwC’s pro- fessional negligence.  .  .  .  . I voted against authorizing the settlement without a written admission of liability by PwC.”2

This is the second settlement PwC has made related to the Colonial Bank collapse. In 2016, the trustee of the TBW Bankruptcy Plan brought suit against PwC, seeking $5.5 billion in damages. Three weeks into the trial, the case was settled for an undis- closed amount.

Legal liability continues to be an important consideration and extremely costly for not just PwC, but for all auditors and accounting firms. Below is just a small sample of some of the larger settlements firms have made:3

∙ Deloitte & Touche (Deloitte): Adelphia Communications ($167.5 million in 2007), Delphi ($38 million in 2008), Fortress Re ($250 million in 2006), General Motors ($26 million in 2008), Parmalat, SpA ($159 million in 2007).

∙ EY: Bank of New England ($84 million in 2005), Cendant ($335 million in 1999), HealthSouth ($143 million in 2009), Lehman Brothers ($99 million in 2013).

∙ KPMG: Countrywide ($24 million in 2010), Xerox ($80 million in 2008), New Century ($44.8 million in 2010).

∙ PricewaterhouseCoopers (PwC): American International Group (AIG) ($97.5 million in 2008), Amerco ($50 million in 2004), Safety-Kleen ($48 million in 2005), Tyco ($225 million in 2007), MF Global ($65 million in 2015).

∙ BDO: Le-Nature’s Inc. ($285 million in 2012), Grand Court Lifestyles ($91 million in 2011).

∙ Grant Thornton: Parmalat (6.5 million in 2009).

2Ben Lane, “PwC reaches $335 million settlement with FDIC over Taylor, Bean, and Whitaker/Colonial Bank audits,” Housing Wire, March 18, 2019 (available at: www.housingwire.com/articles/print/48456-pwc-reaches-335-million-settlement-with-fdic-over-taylor- bean-whitakercolonial-bank-audits); Francine McKenna, “PwC faces largest ever auditor malpractice damages verdict,” Market Watch, April 7, 2018, (available at: www.marketwatch.com/story/pwc-faces-largest-ever-auditor-malpractice-damages-verdict- 2018-04-05) 3“Deloitte to Be Latest to Settle in Accounting Scandals,” The Wall Street Journal, April 26, 2005, p. B1; “Deloitte Pays Insurers More than $200 Million,” The Wall Street Journal, January 6, 2006, p. C3; “Big Accounting Firms Still Pay for Scandals,” The Wall Street Journal, January 13, 2007, p. B5; “PwC Sets Accord in Tyco Case,” The Wall Street Journal, July 7–8, 2007, p. A3; “Deloitte to Pay $167.5M in Adelphia Case,” CFO.com, August 6, 2007; “Deloitte to Pay $38 Million in Delphi Case,” CFO.com, January 2, 2008; “PwC Zapped in $97.5 Million Settlement,” CFO.com, October 6, 2008; “GM Reaches Settlement in Securities-Fraud Case,” The Wall Street Journal, August 9, 2008, p. B5; “Xerox to Pay $670 Million to Settle Securities Suit,” The Wall Street Journal, March 28, 2008, p. B3; “N.Y. Funds Reach Settlement with Countrywide, KPMG,” The Wall Street Journal (Online), May 7, 2010;“$91M BDO Seidman Verdict Highlights Malpractice Lawsuits,” South Florida Business Journal, February 4, 2011; “BDO Seidman Settles New York Lawsuit Over Le-Nature’s Loan,” Bloomberg News, April 5, 2012; ”Ex-Parmalat Auditors Settle US Investor Lawsuit,” Reuters, November 19, 2009; “Judge OKs $125 Mln New Century Lawsuit Settlement,” Reuters, August 10, 2010. “Ernst & Young Settles Lehman Investor Lawsuit for $99 Million,” Accounting Today, December 2, 2013; “Ernst & Young will pay $10 Million to End N.Y. Lehman Suit,” Accounting Today, April 15, 2015; “PwC Settles MF Global Lawsuit for $65 Million,” Accounting Today, April 20, 2015.

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THE LEGAL ENVIRONMENT How does legal liability arise? Consider the following schematic that summarizes the relationship between auditors and two key parties: the client and third-party users. As the graphic here shows, auditors owe clients a responsibility to conduct an audit in accor- dance with generally accepted auditing standards (GAAS) consistent with the terms in the engagement letter that serves as a contract between auditors and their clients.

Clients may suffer losses related to these responsibilities for two reasons:

1. A breach of contract between auditors and the client (e.g., auditors’ failure to com- plete the engagement by a specified deadline) may cause economic losses to the client resulting from delays, such as failing to receive funding through loans or investments, issuing its shares through a public offering at a less favorable price, or paying fines or penalties for missed deadlines.

2. Clients may suffer economic losses from acts of fraud or other misappropriation of assets by employees that a GAAS audit should have identified.

In either case, whether the client’s loss is caused by the breach of contract or failure to exercise the appropriate level of professional care (substandard performance) by auditors, the client may seek legal action.

LO C-1 Identify and describe auditors’ exposure to lawsuits and loss judgments.

Legal ramifications for audit firms is not just an issue in the United States and from the looks of it, there may be a lot more on the line than just a hefty fine.

As a result of recent high profile accounting scandals in the UK, including the collapse of building contractor Carillion Plc and bakery chain Patisserie Valerie Holdings Ltd, UK lawmakers are demanding a drastic change in the landscape of the Big 4 accounting firms. In a report issued in early 2019 by the Business, Energy, and Industrial Strategy Committee of the UK Parliament, the committee claims they are “not confident in relying solely on the integrity of auditors to do the right thing in the face of conflicting interest.”

Among the many recommendations in the report, the one that will have the biggest and most lasting impact is the recommendation that the Big 4 audit firms make a “full legal separation” of their auditing and consulting work. Implementing this recommendation significantly changes the business model for the Big 4 firms in the UK.

Sources: Thomas Beardsworth and Jonathan Browning, “U.K. lawmakers demand breakup of Big Four accounting firms,” Accounting Today, April 3, 2019, https://www.accountingtoday.com/articles/uk-lawmakers-demand-breakup-of- big-four-accounting-firms

Not Just a US Issue. . .AUDITING INSIGHT

Auditors

Client

• Rely on Financial Statements in Economic Decisions

• Issue Auditors’ Report

• Perform Services in Accordance with Contract • Conduct a GAAS Audit

Third-Party User of Financial Statements

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With respect to third-party users, auditors are responsible for issuing a report based on a GAAS audit that provides reasonable assurance that the financial statements on which these users base their economic decisions (lending decisions and investment deci- sions) are presented according to generally accepted accounting principles (GAAP). For third-party users, economic losses are either related to the client’s inability to repay loans or other obligations or to a decline in the value of the user’s investment in the client (in the form of a partnership interest or publicly traded shares of stock). If the user’s loss is caused by reliance on financial statements and those financial statements were not presented according to GAAP, users may seek legal action against auditors.

The main defense for auditors is that they followed GAAS and performed their audits with due professional care. In many cases, lawsuits are brought against auditors not because they are necessarily at fault, but in the case of client failure, they are the only party with resources against which recovery can be made (the “deep pockets” theory). As Bill Thompson, president of CPA Mutual Insurance Company of America, noted, auditors are “.  .  . the last men standing—and they carry insurance, which, to the attorneys, equals deep pockets.”4

Many users of auditors’ reports expect auditors to detect and report fraud, theft, and illegal acts despite the fact that a GAAS audit cannot be expected to identify all items of this nature. Some financial statement users’ expectations are very high; for this reason, an expectation gap often exists between the diligence that users expect and the diligence that auditors are able (and required) to provide. For example, in performing an audit on a multibillion-dollar corporation, auditors may choose to exclude testing transactions of $50,000, $100,000, $500,000, or more as immaterial. Certainly, a $1 million error in the financial statements of Apple Inc. (2018 revenues of $265.6 billion) would be immaterial to auditors. However, it would be difficult to convince an individual investor with $25,000 of retirement money invested that $1 million is not a significant amount of money. Clearly, many financial statement users believe auditors are looking at most, if not every, transaction; are evaluating each transaction, event, person, and department for fraud; and are certifying that financial statements are accurate. No auditors would, how- ever, accept an engagement for which any of these objectives was required.

When auditors do not meet the expectations of clients or financial statement users, they may be held liable under common law or statutory law, depending on the nature of the action and relationship of the party to the auditors. Common law uses legal precedent to identify the fault and responsibility of parties when there is no violation of a written law or statute. When no legal precedent can be found, the judge follows a sense of justice or morality, considering the prevailing customs and moral standards. Common law liability against auditors is available to clients and nonshareholder third parties; the jurisdiction for common law actions is typically a court in the state in which the alleged action occurred.

Statutory law is based on laws passed by legislative bodies and compiled in federal, state, and municipal codes. In a statutory case, the primary basis for a decision is whether the party’s actions have violated the law as written in the code. A lawsuit claiming that auditors did not perform the audit in an appropriate manner is a common law action. The primary statutory laws relevant to the audit of financial statements are laws governing the purchase and sale of securities; as a result, auditors’ liability under statutory law is primarily to third-party shareholders for securities issued by public entities. The Securities Act of 1933 and Securities and Exchange Act of 1934 (discussed later in this module) provide U.S. district courts with jurisdiction for violations of these acts.

4“Target: CPAS,” Accounting Today, July 1, 2011, p. 53.

REVIEW CHECKPOINTS C.1 Identify the general responsibilities auditors owe to clients and third parties. C.2 Distinguish between common law liability and statutory law liability. Which parties generally bring

suit against auditors under common law and under statutory law liability?

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LIABILITY UNDER COMMON LAW Under common law, lawsuits may be brought against auditors based on the law of contracts or as tort actions for failure to exercise the appropriate level of professional care.

∙ Breach of contract is a claim that accounting or auditing services were not performed in the manner described in the contract. Although auditors may have contractual relation- ships with third parties, cases involving breach of contract are most frequently brought against auditors by their clients.

∙ Tort actions cover other civil complaints (e.g., fraud, deceit, injury) arising from auditors’ failure to exercise the appropriate level of professional care (substandard perfor- mance). Clients or users of financial statements can bring tort actions against auditors.

Suits for damages under common law usually result when someone suffers a financial loss after relying on financial statements later found to be materially misstated. The popular press calls such unfortunate events audit failures. Plaintiffs in legal actions involving auditors (clients or third-party users of financial statements) generally assert all possible causes of action, including breach of contract, tort, deceit, fraud, and whatever else may be relevant to the claim.

Liability to Clients Clients may bring a lawsuit for breach of contract and other tort actions. The relationship of direct involvement between parties to a contract is known as privity of contract. When privity exists, plaintiffs must demonstrate all of the following: 1. They suffered an economic loss. 2. Auditors did not perform in accordance with the terms of the contract (for breach of contract). 3. Auditors failed to exercise the appropriate level of professional care (for tort actions). 4. The breach of contract or failure to exercise the appropriate level of professional care

caused the loss. The first case in the United States involving an auditor and client dispute (Smith v.

London Assurance Corp.) established auditors’ obligation for breach of contract.

LO C-2 Specify the characteristics of auditors’ liability under common law, and cite specific case precedents.

In addition to breach of contract, auditors may be liable to clients for tort liability. Three levels of substandard performance that may lead to tort liability include (listed from least severe to most severe): 1. Ordinary negligence: The unintentional breach of duty owed to another party because of

a lack of reasonable care. 2. Gross negligence: The breach of duty owed to another party because of a lack of

minimal care. 3. Fraud: The misrepresentation of facts that the individual knows to be false with the

intention to deceive. Because of the very close relationship between auditors and their clients, auditors have

a high level of responsibility to their clients. This responsibility is to conduct an audit in accordance with GAAS; if auditors exhibit ordinary negligence, clients will typically

SMITH V. LONDON ASSURANCE CORP. (1905) This was the first U.S. case involving auditors. Smith, the auditor, sued the cli- ent (London Assurance Corp.) for an unpaid fee. In a countersuit, London Assurance Corp. brought suit against Smith for losses resulting from employee embezzlement, which London claimed would not have occurred except for the

auditors’ breach of contract. The evidence indicated that Smith had indeed failed to audit the cash accounts at one branch office as stipulated in an engagement contract. The court recognized auditors as skilled profession- als and held Smith liable for the embezzlement losses that could have been prevented by appropriate performance under the terms of the contract.

Legal Precedent

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prevail in their legal actions against auditors. (Auditors are also liable to their clients for gross negligence and fraud.)

Auditors’ Defenses for Client Claims Auditors may attempt to mitigate clients’ claims by using one of the following three defenses:

1. Auditors exercised the appropriate level of professional care (tort) or performed the engagement in accordance with terms of the contract (breach of contract).

2. The client’s economic loss was caused by a factor other than auditors’ failure to exercise appropriate levels of professional care or breach of contract (the causation defense).

3. Actions on the part of the client were, in part, responsible for the loss (for example, failure of the client to establish effective internal control to prevent embezzlement losses). This is referred to as contributory negligence and is available to auditors in certain jurisdictions.

Liability to Third Parties In the early part of the 20th century, parties other than clients had difficulty succeeding in lawsuits against auditors. Parties not in privity of contract have no cause of action for breach of contract. However, these parties can bring lawsuits against auditors for failure to exercise appropriate levels of professional care (tort action). In these cases, third parties suffer an economic loss because they relied on the audited financial statements and auditors’ reports on those statements. Recall that the three levels of failure to exercise the appropriate level of professional care that have emerged through various cases are ordinary negligence (lack of reasonable care), gross negligence (lack of minimal care), and fraud (intention to deceive).

It has been well established that auditors are liable to all third parties for levels of perfor- mance representing gross negligence and fraud. However, auditors’ liability to various third parties for ordinary negligence has been debated and has changed significantly over time. Furthermore, the extent of liability for ordinary negligence to third parties varies by juris- diction (state in which the action is brought). As a result, both auditors and third-party users carefully monitor the evolution of auditors’ liability to third parties for ordinary negligence through common law precedents. This is particularly important because it is relatively easier for third parties to demonstrate ordinary negligence compared to either gross negligence or fraud.

To bring a suit against auditors under common law, third parties must demonstrate all of the following:

1. They suffered an economic loss (normally, a decline in the value of an investment or failure to be repaid for a loan or other obligation).

2. The auditors failed to exercise the appropriate level of professional care (ordinary negligence, gross negligence, or fraud).

3. The financial statements contained a material misstatement. 4. The loss was caused by reliance on the materially misstated financial statements.

One early and important case involving auditors’ liability to third parties is known as Ultramares. The Ultramares Corp. v. Touche opinion (discussed in detail in the Legal Precedent) expressed the view that, if auditors’ failures to exercise the appropriate level of professional care were so great as to constitute gross negligence, grounds might exist for concluding that auditors had engaged in constructive fraud, which is characterized by reckless disregard for the truth. The significance of Ultramares is that it established an obligation to third parties and others not in privity with auditors for gross negligence and fraud. Ultramares has been cited in numerous third-party common law cases against auditors.

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ULTRAMARES CORP. V. TOUCHE (1931) In 1924, Touche, Niven & Co. was engaged to audit the 1923 balance sheet of Fred Stern & Co., a rubber importer. Based on the audited balance sheet, Ultramares Corp., a factoring business, made numerous loans to Stern & Co. In January 1925, Stern & Co. went bankrupt and was unable to repay these loans to Ultramares (this represented the economic loss), and Ultramares brought suit against Touche for negligent performance. Although the New York court of appeals denied Ultramares’ negligence claim, the court did not assert that privity of contract was a requirement for third parties to sue auditors. As a result, this case recognized auditors’ potential liability to third parties and the right of third parties to bring suits against auditors.

In part, the court’s decision established criteria for auditors’ liability to third parties for constructive fraud. To do so, third parties must prove all of the following:

1. There was a misrepresentation of a material fact (usually in the finan- cial statements).

2. The misrepresentation was made consciously or without adequate knowledge to determine whether it was true.

3. There was knowledge (scienter) and intent to induce action in reliance on the information.

4. The damaged party justifiably relied on the misrepresentation. 5. There was resulting damage.

The court held that auditors could be liable when they did not have sufficient information (audit evidence) to lead to an opinion. Therefore, the auditors’ opinion is deceitful when auditors claim to have knowledge that they do not possess. The court also wrote that when the degree of negligence is gross, it may amount to a constructive fraud, and auditors could be liable to a third-party user.

Case conclusion: Ultramares contributed to the development of com- mon law liability to third parties by establishing that

1. Third parties not in privity with auditors can bring suit against auditors. 2. Auditors may be liable to parties who are not in privity in cases repre-

senting constructive fraud (gross negligence) or fraud. 3. Auditors are generally not liable for ordinary negligence to parties

who are not in privity.

Legal Precedent

The Ultramares decision was upheld in State Street Trust Co. v. Ernst, in which the courts identified auditors’ liability to third parties for gross negligence in the following opinion:

[Auditors], however, may be liable to third parties, even where there is lacking deliberate or active fraud. . . . A representation certified as true to the knowledge of the accountants when knowledge there is none, a reckless misstatement, or an opinion based upon grounds so flimsy, . . . In other words, heedlessness and reckless disregard of consequence may take the place of deliberate intention.5

Although the Ultramares case opened the door for lawsuits by third parties in which fraud or constructive fraud was present, for many years only parties that had privity of con- tract (typically, the client) could bring legal action against auditors for ordinary negligence. Primary beneficiaries are third parties known by name to the auditors for whose primary benefit the audit or other accounting service is performed (also referred to as near privity). In some legal jurisdictions, a beneficiary must be named in the contract; in other jurisdic- tions, the beneficiary need only be identified to auditors prior to or during the engagement. For example, an accounting firm may be informed that the report is needed for a bank loan application at the First National Bank; in this case, First National Bank is a primary benefi- ciary because it is known by name to auditors. Many cases (for example, CIT v. Glover) indi- cate that proving ordinary negligence may be sufficient to hold auditors liable for damages to primary beneficiaries. Credit Alliance v. Arthur Andersen identified specific criteria that must be met for primary beneficiaries to prevail against auditors for ordinary negligence.

In many jurisdictions, auditors also may be liable for ordinary negligence to foreseen parties. In these jurisdictions, the restatement of torts doctrine specifies that auditors are liable if they are aware that the auditors’ opinion and financial statements are to be used by some third party. Auditors need not know the exact identity of the third party but are pre- sumed to owe a duty to persons who could reasonably be expected to rely on the auditors’ work. For example, if a client informs auditors that it will be using audited financial state- ments to obtain financing but does not identify any specific banks, under the doctrine of restatement of torts, any bank that uses the audited financial statements in making lending decisions may have legal standing to sue auditors for ordinary negligence. Rusch Factors v. Levin concluded that auditors were liable to a lender (Rusch Factors) because the auditors were aware that the financial statements were to be shown to potential lenders despite the

5 State Street Trust C. v. Ernst, I278N.Y. 105, 15 N.E. 2d 415 (1938)

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fact that the auditors were not aware of their actual identity. Fleet National Bank v. Gloucester Co. affirmed auditors’ obligation to third parties who are foreseen parties but are not known by name to auditors (and, therefore, do not qualify as primary beneficiaries).

FLEET NATIONAL BANK V. GLOUCESTER CO. (1994) Fleet Bank relied on financial statements audited by Tonneson when making loans to Gloucester. Upon Gloucester’s default (the economic loss), Fleet brought suit against Tonneson, alleging that the audited financial statements were the basis for making the loans. Fleet made the following allegations: (1) Tonneson knew about Fleet Bank’s loans to Gloucester, (2) Tonneson reviewed the loan agreements between Gloucester and Fleet Bank, (3) Tonneson knew the loan agreements required submission of audited financial

statements, and (4) Tonneson believed and expected Gloucester would provide the audited financial statements to Fleet Bank. The U.S. District Court in Massachusetts found in favor of Fleet, adopting the restatement of torts approach.

Case conclusion: Auditors may be liable to third parties for ordinary negligence even if the third party is not named in the engagement con- tract. If auditors have knowledge that financial statements will be provided to third parties for the purpose of making a decision, in some jurisdiction auditors may be liable to such a third party.

Legal Precedent

Finally, in other jurisdictions, auditors may be liable to reasonably foreseeable parties. These parties (sometimes referred to as members of an unlimited class) include creditors, investors, or potential investors whose decisions normally rely on audited financial state- ments and opinions on those financial statements. If auditors are reasonably able to foresee a limited class of potential users (e.g., local banks, regular suppliers) of their reports, liability may be imposed for ordinary negligence. This, however, is an uncertain area, and liability in a particular case depends entirely on the unique facts and circumstances of the case and the jurisdiction of the legal action. This is the most liberal interpretation of the third-party liability and is used in only two states: Mississippi and Wisconsin.6 Rosenblum Inc. v. Adler established auditors’ liability for ordinary negligence to individuals who are “reasonably foreseeable.”

It should be noted that these classes of third parties are based on legislation and legal prec- edents. For example, for primary beneficiaries, auditors know both the name of the party and the intended use of the financial statements; for foreseen parties, auditors know the financial statements will be used by a certain type of third party; for foreseeable parties, auditors should be aware that the financial statements could be used by third parties. For example, if Grand Bank is relying on audited financial statements to decide whether to provide a loan to Prize Company, Grand Bank’s classification as a third party could be as follows:

∙ Grand Bank would be a primary beneficiary if Prize Company informed the auditors that the audited financial statements would be used to obtain a loan from Grand Bank and Grand Bank was identified to the auditors by name.

6F. D. Greene, A. R. Petrocine, and R. C. FitzPatrick, “Holding Accountants Accountable: The Liability of Accountants to Third Parties,” Employee Responsibilities and Rights Journal, March 2003, p. 27.

Legal Precedent CREDIT ALLIANCE V. ARTHUR ANDERSEN (1985) In this landmark case, Credit Alliance (a financial services firm) provided financing for equipment to L.B. Smith Inc. In 1978, Credit Alliance advised Smith that any future extensions of credit would require audited financial statements, which Smith subsequently provided for fiscal years 1976 through 1979. In 1980, L.B. Smith filed for bankruptcy and was unable to repay Credit Alliance. (This represented the economic loss.) The New York court of appeals provided a three-pronged test for Credit Alliance’s right to sue:

1. Auditors were aware that a particular party intended to rely on the auditors’ opinion and financial statements.

2. The third party was specifically identified. 3. Some action by the auditors showed that they had acknowledged the

third-party’s identification and intent to rely on the opinion and finan- cial statements.

This test has been used as precedent in many cases in determining whether the third party was an intended beneficiary of the auditors’ work.

Case conclusion: In many jurisdictions, third parties may bring suit against auditors for ordinary negligence even if they are not in privity of the contract. However, they must meet the three-pronged test established by the New York court of appeals.

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∙ Grand Bank would be a foreseen party if Prize Company informed the auditors that the audited financial statements would be used to obtain a loan but did not specify the name of a third party.

∙ Grand Bank would be a foreseeable party in almost any situation because audited financial statements are commonly used to obtain financing.

In all jurisdictions, auditors are generally liable for acts of gross negligence and fraud; auditors’ liability to third parties for ordinary negligence depends upon the doctrine in effect in the jurisdiction in which auditors practice. Clearly, limiting auditors’ liability for acts of ordinary negligence to only primary beneficiaries is most advantageous to auditors, and exposing them to liability for ordinary negligence to foreseeable parties is most disad- vantageous to auditors. One study7 classified various jurisdictions (as of 2000) as follows:

∙ Privity or near privity. Arkansas, Idaho, Illinois, Kansas, Louisiana, Michigan, Montana, Nebraska, New Jersey, New York, Pennsylvania, Utah, Virginia, Wyoming.

∙ Restatement of torts (foreseen). Alabama, Alaska, Arizona, California, Colorado, Florida, Georgia, Hawaii, Iowa, Massachusetts, Missouri, New Hampshire, North Carolina, Ohio, South Carolina, Tennessee, Texas, Washington, West Virginia.

∙ Reasonably foreseeable. Mississippi, Wisconsin.

Auditors’ legal liability to third parties as established by these and other cases under common law is summarized in Exhibit C.1.

Auditors’ Defenses for Third-Party Claims Auditors can defend a common law action by presenting arguments and evidence to mitigate third-party plaintiffs’ claims and evidence. Assuming that the plaintiff has demonstrated an economic loss and materially misstated financial statements, defenses available to auditors against third parties include the following. (Note that these are similar to defenses available against clients, except for the unavailability of the contributory negligence defense in cases brought by third parties:)

1. The third party did not have appropriate standing to sue in that jurisdiction (for example, bringing suit for ordinary negligence if the appropriate relationship between auditors and third party does not exist). Recall that auditors’ liability to third parties for ordi- nary negligence differs significantly depending on the jurisdiction in which the action is brought.

7C.Pacini, M. J. Martin, and L. Hamilton, “At the Interface of Law and Accounting: An Examination of a Trend toward a Reduction in the Scope of Auditor Liability to Third Parties in the Common Law Countries,” American Business Law Journal, Winter 2000, pp. 171–225.

Legal Precedent ROSENBLUM INC. V. ADLER (1983) Giant Stores Corporation acquired the retail catalog showroom business owned by Rosenblum, giving stock in exchange for the business. Fifteen months after the acquisition, Giant Stores declared bankruptcy, significantly reducing the value of the shares received by Rosenblum in the acquisition (the economic loss). Adler had audited Giant Stores’ financial statements and issued unmodified opinions on those financial statements for several prior years. These financial statements were later revealed to be misstated as a result of a fraudulent scheme perpetrated by Giant Stores. Rosenblum subsequently brought suit against the auditor (Adler) to attempt to recover the loss resulting from the decline in the value of the shares.

In finding for Rosenblum on certain motions, the New Jersey Supreme Court held, “Independent auditors have a duty of care to all persons whom the auditor should reasonably foresee [emphasis added] as recipients of the statements from the company for proper business purposes, provided

that the recipients rely on those financial statements.  .  .  .  It is well rec- ognized that audited financial statements are made for the use of third parties who have no direct relationship with the auditor. . . . Auditors have responsibility not only to the client who pays the fee but also to investors, creditors, and others who rely on the audited financial statements.”

Case conclusion: In some jurisdictions, auditors may be liable for ordi- nary negligence to a large class of users that are reasonably foreseeable but may not be known to the auditor at the time of the audit.

Additional note: Although the opinion in the Rosenblum case is an excellent example of a court opinion that extends liability to foreseeable parties, it should be noted that subsequent legislation (1995) in New Jersey has moved that state to a near privity standard. However, the Rosenblum opinion has been used as precedent in other states. This is an example of how state law can change and how court decisions can provide an impetus to legislatures to enact new law.

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2. The third party’s loss was caused by events other than the financial statements and auditors’ examination (causation defense). For example, the failure of an entity (and losses incurred by parties providing capital to that entity) may result from poor business practices and decisions, not misstated financial statements.

3. Auditors’ work was performed in accordance with professional standards (e.g., GAAS for audits of financial statements), which is generally interpreted to mean that auditors were not negligent (ordinary negligence).

Liability for Compilation and Review Services People find it easy to think about common law liability in connection with audited financial statements. Do not forget, however, that accountants also render compilation and review services and are associated with the resultant unaudited financial informa- tion. Users expect public accountants to perform these services in accordance with professional standards, and courts can impose liability for accounting work found to be substandard. Accountants have been assessed damages for work on such statements, as shown in the 1136 Tenants’ Corporation v. Max Rothenberg & Co. case. In this case, the court concluded that accountants engaged to perform “write-up” (compilation) work had a duty to inform clients of indicators of fraud that were identified during the engagement.

One significant risk involved with compilation and review engagements is that the client may fail to understand the nature of the service being given. Accountants should have a discussion and use an engagement letter to explain clearly to the cli- ent that a compilation engagement (write-up) does not involve gathering sufficient appropriate evidence and is lesser in scope than a review engagement. Similarly, a review service should be explained in terms of being less extensive than an audit engagement conducted in accordance with GAAS. Clear understandings at the out- set (along with clearly worded engagement letters) can enable accountants and cli- ents to avoid later disagreements. In Iselin v. Landau (1992), the court decided that the lack of an opinion on reviewed financial statements precluded the third party (William Iselin & Company) from bringing a lawsuit against the auditors (Mann Judd Landau) because of losses suffered from the bankruptcy of one of Iselin’s customers. (Mann Judd Landau had performed a review engagement on the financial statements of Iselin’s customer.)

EXHIBIT C.1 Summary of Auditors’ Liability to Third Parties under Common Law

Ultramares: Liable for Gross Negligence and Fraud

Credit Alliance v. Arthur Andersen:

Liable to Primary Beneficiaries for Ordinary Negligence

Fleet National Bank v. Gloucester Co.:

Liable to Foreseen Third Parties for Ordinary Negligence (restatement of torts)

Rosenblum Inc. v. Adler:

Liable to Reasonably Foreseeable Third Parties for Ordinary Negligence

Less Exposure for Auditors More Exposure for Auditors

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REVIEW CHECKPOINTS C.3 For what type of actions can clients bring suit against auditors under common law? What must cli-

ents prove prior to bringing suit in each case? C.4 In terms of tort liability, what level of responsibility do auditors owe clients under common law? C.5 What must third parties prove in a common law action seeking recovery of damages from auditors? C.6 What legal theory is derived from the Ultramares decision? Can auditors rely on the Ultramares decision today? C.7 Define and explain privity, primary beneficiary, foreseen party, and foreseeable party in terms of the

degree of failure to exercise the appropriate level of professional care on the part of auditors that would trigger the liability.

C.8 What defenses are available to auditors against suits brought by clients under common law? Against suits brought by third parties under common law?

C.9 What additional defenses can accountants use in lawsuits related to compilation and review engagements?

LIABILITY UNDER STATUTORY LAW Auditors can be liable to individuals when they violate a specific law or statute when performing professional services; this is referred to as statutory liability. Several federal statutes provide sources of potential liability for auditors, including the Federal False Statements Statute, the Federal Mail Fraud Statute, the Federal Conspiracy Statute, the Securities Act of 1933 (Securities Act), the Securities Exchange Act of 1934 (Securities Exchange Act), and the Sarbanes–Oxley Act. Federal securities regulation in the United States was enacted in the 1930s not only as a reaction to the events of the early years of the Great Depression but also as a culmination of attempts at “blue-sky” regulation by states.8 The Securities Act and the Securities Exchange Act require registrants to disclose important financial and nonfinancial information required for making informed investment decisions. The securities acts and the SEC operate for the protection of investors and for the facili- tation of orderly capital markets. Even so, no federal government agency, including the SEC, rules on the quality of investments. The securities acts have been characterized as “truth-in-securities” law. Their spirit favors the otherwise uninformed investing public, and caveat vendor—let the seller beware of violations—is applied to the issuer.

As the following graphic shows, auditors are exposed to liability under the Securities Act and the Securities Exchange Act when investors purchase or sell securities ([1] in the graphic). If an economic loss is suffered [2] and if the financial statements contain a material misstatement [3], auditors may be held liable for failure to detect the material misstatement.

LO C-3 Describe auditors’ liability to third parties under statutory law.

8The term blue sky comes from a state judge’s remark during a securities fraud case: “These securities have no more substance than a piece of blue sky.”

Investors purchase/sell

securities

[1] [2] [3]

Investors su�er economic

loss

Financial statements contain

material misstatement

Because of the availability of class action litigation and the wide dissemination and use of financial information filed with the SEC, litigation against auditors under the Securities Act and Securities and Exchange Act is the highest growing area of concern for auditors. The following sections discuss auditors’ liability under these acts in more detail.

REVIEW CHECKPOINT C.10 How does auditors’ liability under statutory law arise?

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THE SECURITIES ACT OF 1933 (SECURITIES ACT) The Securities Act of 1933 regulates the initial issuance of securities by registrants to the investing public through a market (including initial public offerings [IPOs]). The Securities Act provides that no person may lawfully buy, sell, offer to buy, or offer to sell any security by means of interstate commerce unless a registration statement is effective (a legal term essentially meaning filed and accepted by the SEC). A registration statement is a set of docu- ments filed with the SEC prior to the offering of securities. An important component of the registration statement is a prospectus, which is a legal document offering securities for sale and includes significant information about the issuing entity, including its historical financial statements and other necessary disclosures. Certain exemptions exist for limited offerings, offerings by small investors, and offerings involving financially sophisticated investors; these exemptions can be found in section 3, section 4, and Regulation D of the Securities Act.

The general point concerning the Securities Act is that, with some minor exceptions, all issuances of securities to the public must be registered with the SEC. Importantly for the auditor, the Securities Act requires that the registration statement include financial statements and required disclosures that “. . . shall be certified by an independent public or certified accountant”; this language requires an audit examination. Auditors are required not only to audit the financial statements as of the most recent date of the financial state- ments but also to ensure that these statements are fairly stated up to the date the regis- tration statement becomes effective, which could possibly be up to one year beyond the date of the financial statements. This audit requirement provides the basis for auditors’ liability to investors under the Securities Act.

Section 11: Civil Liability Section 11 of the Securities Act is of great interest to auditors because of the duties and responsibilities it establishes. This section discusses the principal criteria defining civil liabilities under the statute.

LO C-4 Specify the civil and criminal liability provisions of the Securities Act of 1933.

The following excerpts from Section 11 are of particular importance in identifying the responsibilities of auditors under this Act.

Section 11(a): . . . any person acquiring such security [in a registered offering] . . . may sue:

• Every person who signed the registration statement. • Every person who was a director of . . . or partner in, the issuer. • Every accountant, engineer, or appraiser. • Every underwriter with respect to such security.

Section 11(b): Notwithstanding the provisions of subsection (a), no person, other than the issuer, shall be liable as provided therein who shall sustain the burden of proof that  .  .  .  as regards any part of the registration statement purporting to be made upon his authority as an expert . . . he had, after reasonable investigation, reasonable grounds to believe . . . that the statements therein were true and that there was no omission to state a material fact. . . .

Section 11. Securities Act of 1933

Although section 11(a) notes that a number of parties involved in the registration and sale process might be liable to persons acquiring securities, section 11(b) generally limits the liability to the issuers of securities with some exceptions. Because auditors are con- sidered to be the “experts” regarding the fairness of the financial statements and must perform a “reasonable investigation” (an audit in accordance with GAAS), section 11(b) is of great importance to auditors. This requirement imposes liability for auditors for acts representing ordinary negligence.

Auditors commonly provide assurance to underwriters, who act as intermediaries between the offering entity and investing public by purchasing securities for investment or resale. Auditors provide comfort letters to underwriters that address, among other information, the independence of auditors and the fairness of the registrant’s financial statements.

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Section 11 includes two other very important implications for auditors. First, reviewing the first two words in section 11(a), “any person” [emphasis added] may bring suit against auditors. Essentially, the Securities Act treats all persons as being reasonably foreseeable and holds auditors liable to these persons. In addition, section 11 shifts the major burden of proof from the plaintiff (investor) to the auditors; essentially, plaintiffs must prove each of the following:

1. They suffered an economic loss. 2. The financial statements contained a material misstatement.

Recall that under common law liability, plaintiffs had to also allege and prove some level of failure to exercise the appropriate level of professional care and that the loss was caused by reliance on the misstated financial statements. Thus, under the Securities Act, the plaintiff is not required to demonstrate that the misstated financial statements caused the loss; the burden of proof regarding professional care rests with auditors. Section 11 has the following major implications for auditors:

∙ Auditors are liable for ordinary negligence. ∙ Auditors have potential liability to a large class of parties (investors in securities). ∙ Auditors (not others) have the burden of proof, in this case, proving that a reasonable

investigation under section 11(b) was conducted.

The final implication is particularly important because it presumes that auditors are “guilty until proven innocent” and has increased auditors’ exposure to investors. However, section 11 was written with the protection of the investing public in mind, not the protection of the expert auditors. The first significant court case under section 11 was Escott v. BarChris Construction Corporation.

ESCOTT V. BARCHRIS CONSTRUCTION CORP. (1968) BarChris Construction Corporation built bowling alleys. In 1961, BarChris engaged in a public offering of convertible bonds that was subject to the provisions of the Securities Act. BarChris issued a registration statement that included financial statements audited by Peat, Marwick, Mitchell & Co. (now KPMG). The financial statements included material overstatements of revenues, current assets, gross profit, and backlog of sales orders and mate- rial understatements of contingent liabilities, loans to company officers, and potential liability for customer delinquencies. BarChris’s worsening financial condition resulted in a default on interest payments (the economic loss), and BarChris eventually declared bankruptcy. Investors sued BarChris’s executive officers, directors, and auditor (Peat, Marwick, Mitchell & Co.) under the provi- sions of the Securities Act, citing lack of appropriate level of professional care during the conduct of the audit.

The judge ruled that the auditors had failed to perform a diligent and reasonable investigation [section 11(b)]. The judge found that the auditor had spent “only” 20.5 hours on the subsequent events review, had read no important documents, and “He asked questions, he got answers that he considered satisfactory, and he did nothing to verify them. . . . He was too easily satisfied with glib answers to his inquiries.” The judge also said, “Accountants should not be held to a standard higher than that recognized in their profession. I do not do so here. The senior accountant’s review [of subsequent events] did not come up to that standard. He did not take some of the steps which [the] written program prescribed. He did not spend an adequate amount of time on a task of this magnitude.”

Case conclusion: The auditors’ failure to perform a reasonable inves- tigation of subsequent events did not satisfy section 11(b) and resulted in their liability to investors in BarChris’s bonds.

Legal Precedent

Auditors’ Defenses under the Securities Act Section 11 provides two possible defenses to auditors, assuming that purchasers of securities are able to demonstrate they suffered a loss and the financial statements are materially misstated. Note that these defenses are similar to two defenses available to auditors for actions brought by clients and third parties under common law:

1. The “due diligence” defense provides that auditors who can prove they conducted a “reasonable investigation” will not be held liable under the Securities Act. A reasonable investigation can ordinarily be shown by conducting an audit in accordance with GAAS.

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2. Under the causation defense, if auditors can prove that all or part of the plaintiffs’ losses were caused by something other than the materially misstated financial state- ments included in the registration statement, they are not required to pay all or part of the damages. This defense may create some imaginative “other reasons.” In the BarChris case, at least one plaintiff had purchased securities after the company had gone bankrupt. This claim was settled out of court.

Section 13: Statute of Limitations Section 13 of the Securities Act requires any suits to be brought within one year after discovery of the materially misstated statement or omission or within three years after the public offering. These limitations restrict auditors’ liability exposure to a determinable time span. In many cases, the statute of limitations is a viable defense available to audi- tors. Although Sarbanes–Oxley generally extended the statute of limitations to within two years of discovery and five years after the action for situations involving fraud, some questions exist as to whether these extended limitations apply to the Securities Act, par- ticularly in cases not involving fraud.

Section 17: Antifraud Section 17 of the Securities Act is the antifraud section. This section makes it unlawful to “use the mails or instruments of transportation in interstate commerce” in an effort to defraud others. As with section 11, plaintiffs are not required to demonstrate reliance on the fraudulent information or that the fraudulent information resulted in their loss. There- fore, the burden of proof still rests with auditors.

Section 24: Criminal Liability Section 24 sets forth the criminal penalties imposed by the Securities Act. Criminal penalties are characterized by monetary fines, prison terms, or both. The key words in section 24 are “willful” violation and “willfully” causing materially misstated statements to be filed. Thus, although auditors have civil liability to third parties under section 11 in cases in which ordinary negligence can be demonstrated (failure to conduct a GAAS audit), criminal penalties are possible under the 1933 Securities Act only for instances in which auditors act with knowledge of the materially misstated financial statements (fraud and, perhaps, gross negligence). Section 24 establishes these penal- ties for fines at $10,000 and imprisonment for up to five years. The United States v. Benjamin case is an example of how auditors may be found criminally liable under the Securities Act.

UNITED STATES V. BENJAMIN (1964) The judgment in this case resulted in the conviction of auditors for will- ingly conspiring by use of interstate commerce to sell unregistered securities and to defraud investors in the sale of securities in violation of section 24 of the Securities Act. The auditors had prepared pro forma balance sheets and claimed that use of the words pro forma absolved them of responsibility. The auditors also claimed they did not know their reports would be used in connection with securities sales. The court

found otherwise, showing that the auditors did in fact know about the use of their reports and that certain statements about asset values and acquisitions were materially misstated. The court made two significant findings: (1) The willfulness requirements of section 24 may be proved by showing that due diligence would have revealed the materially mis- stated statements, and (2) use of limiting words such as pro forma does not justify showing false ownership of assets in any kind of financial statements.

Legal Precedent

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THE SECURITIES EXCHANGE ACT OF 1934 (SECURITIES EXCHANGE ACT)

The Securities Exchange Act regulates daily trading of securities and requires most entities whose securities are traded in interstate commerce to register and file pertinent information with the SEC. Entities having total assets of $10 million or more and 500 or more stockholders are required to register under the Securities Exchange Act. The purpose of these size and share criteria is to define securities in which there is a significant public interest. (These criteria are subject to change by the SEC.) For auditors, the most significant aspect of the Securities Exchange Act is the requirement for registrants to file the following reports with the SEC:

∙ Form 10-K, also known as an annual report, that is filed annually within 60-90 days (depending on the entity’s size) days of the date of the entity’s financial statements. These reports include financial statements that are audited by independent auditors.

∙ Form 10-Q, which is filed quarterly within 40-45 days of the end of the each of the first three fiscal quarters (again depending on the entity size). The fourth quarter’s results are filed within Form 10-K. These reports include financial statements that are reviewed by independent auditors.

∙ Form 8-K, also known as a current events report, that is filed periodically upon the occurrence of major events (e.g., earnings releases, major asset sales, acquisitions, and auditor changes). Independent auditors may review these reports or otherwise assist in their preparation.

The form and content of 10-K and 10-Q filings are governed by the SEC through Regulation S-X (which covers the annual and interim financial statements) and Regulation S-K (which covers other supplementary disclosures). In addition to these two regulations, audi- tors must be familiar with Financial Reporting Releases (FRRs), which express new rules and policies about disclosure, and Staff Accounting Bulletins (SABs), which provide unofficial, but important, interpretations of Regulations S-X and S-K. Taken together, these four pronounce- ments provide the authoritative literature for information that must be filed with the SEC.

Section 10 and Rule 10(b)-5: Antifraud Section 10 of the Securities Exchange Act is used against auditors quite frequently. Like section 17 of the Securities Act, section 10 is a general antifraud section that makes it unlawful for persons to use “manipulative” or “deceptive” devices in connection with the purchase or sale of securities. Rule 10(b)-5, made by the SEC staff under their authority to create admin- istrative rules related to the statute, is more explicit than section 10 in identifying auditors’ specific responsibilities.

LO C-5 Specify the civil and criminal liability provisions of the Securities Exchange Act of 1934.

REVIEW CHECKPOINTS C.11 What type of transactions are governed by the Securities Act? C.12 What is a registration statement? How does the registration statement introduce potential liability

to auditors under the Securities Act? C.13 How is section 11 of the Securities Act different from the legal environment that exists under

common law? C.14 What must the plaintiff prove in a suit under section 11 of the Securities Act seeking recovery of

damages from auditors? What defenses are available to auditors in this situation? C.15 Describe the due diligence and causation defenses available to auditors under the Securities Act. C.16 What liability exposure for auditors is found in the Securities Act in (a) section 17 and (b) section 24? C.17 According to the BarChris decision, how did auditors violate generally accepted auditing standards?

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Rule 10(b)-5. Employment of Manipulative and Deceptive Devices. It shall be unlawful for any person, directly or indirectly, by the use of any means or instrumentality of interstate commerce, or of the mails, or of any facility of any national securities exchange,

1. To employ any device, scheme, or artifice to defraud. 2. To make any untrue statement of material fact or to omit to state a

material fact necessary in order to make the statements made,

in the light of the circumstances under which they were made, not misleading.

3. To engage in any act, practice, or course of business that operates or would operate as a fraud or deceit upon any person in connection with the purchase or sale of any security.

Rule 10(b)-5. Securities Exchange Act of 1934

An important point about Rule 10(b)-5 liability is that plaintiffs must prove scienter (a mental state embracing the intent to deceive, manipulate, or defraud) to impose liability under the rule. Mere failure to exercise the appropriate level of professional care is not enough cause for liability. Two cases (Ernst & Ernst v. Hochfelder and Denise L. Nappier et al. v. PricewaterhouseCoopers) illustrate the need for purchasers and sellers of securities to prove scienter on the part of auditors and confirm the inability for these parties to bring suit against auditors for ordinary negligence. The Hochfelder case was also significant in providing exposure for auditors in cases of gross negligence, even in the absence of scienter.

ERNST & ERNST V. HOCHFELDER (1976) In this case, Hochfelder represented investors in an escrow account with First Securities of Chicago; this account was maintained by Lester Nay (president of First Securities), who diverted funds for his own personal use through a fraudulent scheme that was revealed in a suicide note prepared by Nay. When the escrow accounts proved worthless (the eco- nomic loss), the investors (through Hochfelder) brought suit against the auditor (Ernst & Ernst), alleging that their negligence prevented them from uncovering the scheme and preventing their losses. Hochfelder specifically disclaimed any allegations of fraud or intentional misconduct on the part of Ernst & Ernst but wanted to sue for liability under section 10(b) imposed for ordinary negligence in the auditors’ failure to uncover the fraudulent scheme.

The Court reasoned that section 10(b) in its reference to “employment of any manipulative and deceptive device” meant that intention to deceive, manipulate, or defraud is necessary to support a private cause of action under section 10(b), and failure to exercise the appropriate level of profes- sional care is not sufficient. This decision is considered a landmark for audi- tors because it relieved them of liability for ordinary negligence under section 10(b) of the Securities Exchange Act and its companion SEC Rule 10(b)-5.

However, footnote 12 in this opinion noted that “[in] certain areas of the law recklessness is considered to be a form of intentional conduct for purposes of imposing liability for some act. We need not address here the

question whether, in some circumstances, reckless behavior is sufficient for civil liability under 10(b) and Rule 10(b)-5.”

Case conclusion: This case established precedent for the plaintiff’s need to prove scienter to impose section 10(b) liability under the Secu- rities Exchange Act. In addition, the reference to “recklessness” in the footnote to the opinion provides potential exposure to auditors for gross negligence under the Securities Exchange Act.

DENISE L. NAPPIER ET AL. V. PRICEWATERHOUSECOOPERS (2002) Denise L. Nappier (treasurer of the State of Connecticut) successfully brought suit on behalf of shareholders (including Connecticut Retirement Plans and Trust Funds) against Campbell Soup Company and its directors for losses incurred upon declines in Campbell’s stock price (the economic loss). In this suit, Nappier demonstrated that the purchase of these shares was influenced by audited financial statements that were shown to contain material misstatements. The shareholders then attempted to assert an addi- tional claim against Campbell’s auditor (Pricewaterhouse Coopers), alleg- ing that it violated the provisions of the Securities Exchange Act by being a party to the preparation and certification of fraudulent financial statements.

Case conclusion: The case was dismissed when the shareholders could not prove the allegation that PricewaterhouseCoopers operated with scienter in conducting its audits of Campbell’s financial statements.

Legal Precedent

Section 18: Civil Liability Section 18 sets forth the pertinent civil liability under the Securities Exchange Act. Under Rule 10(b)-5 and section 18, plaintiffs have the same burden of proof as under common law. (That is, they must demonstrate that the loss was caused by reliance on the materi- ally misstated financial statements and that the auditors failed to exercise the appropriate level of professional care.) However, under the Securities Exchange Act, plaintiffs must

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demonstrate scienter on the part of auditors. Thus, plaintiffs must demonstrate all of the following: 1. They suffered an economic loss. 2. The financial statements contained a material misstatement. 3. The loss was caused by reliance on the materially misstated financial statements. 4. Auditors were aware that the financial statements contained a material misstatement.

(Recall that, under Hochfelder, auditors may be held liable for gross negligence.) Of note, two key differences in liability under the Securities Exchange Act and Securities

Act are that, under the former (1) plaintiffs have the burden of proof and (2) auditors cannot be held liable for ordinary negligence. Clearly, the shift of burden of proof from auditors (in the Securities Act) to plaintiffs (in the Securities Exchange Act) is an important distinction and determinant in plaintiffs’ ability to successfully prevail in securities actions.

Section 18 of the Securities Exchange Act establishes a statute of limitations of one year after discovery of the violation of the Act or within three years after the violation of the Act itself; for cases involving fraud, Sarbanes–Oxley extends these dates to two and five years, respectively.

Auditors’ Defenses under the Securities Exchange Act As a defense, auditors can attempt to demonstrate that they acted in “good faith” and had no knowledge of the material misstatement. (Causation is not a defense because it is presumed that the plaintiff has already demonstrated this in bringing suit.) Although this would seem to imply that auditors are liable only for fraudulent actions under the Securities Exchange Act (by demonstrating they had no knowledge of the material misstatement), the Hochfelder decision has resulted in some uncertainty as to auditors’ liability in the absence of scienter (specifically, for acts that may be considered to represent gross negli- gence). Importantly, in contrast to the Securities Act, auditors are not liable to shareholders for actions representing ordinary negligence under the Securities Exchange Act.

Section 32: Criminal Liability Section 32 states the criminal penalties for violation of the Securities Exchange Act. Like that pertaining to section 24 of the Securities Act, the critical test is whether the violator acted “will- fully and knowingly.” Therefore, to be subject to criminal liability, auditors must be shown to be guilty of fraud. Sarbanes–Oxley markedly increased the criminal penalties for violating the Securities Exchange Act; currently, violators may be fined up to $5 million and imprisoned for up to 20 years. In addition, Sarbanes–Oxley provides that if the “person” was not a natural per- son (for example, an accounting firm), fines of up to $25 million can be assessed. The United States v. Natelli (better known as the “National Student Marketing” case) illustrates potential criminal liability for auditors charged with violations of section 32. (It is important to note that this case occurred prior to the increased liability imposed by Sarbanes–Oxley.)

According to a recent academic study, from 1996 through 2016 the number of lawsuits against auditors decreased, the number of dis- missals in auditor litigation cases increased, and the settlement pay- ments, both in dollar value and as a percentage of payment by all defendants, decreased. In the study, the authors examine whether the decline in the auditor’s liability is at least partially attributable to the Supreme Court case rulings in Tellabs v. Makor (2007) and Janus v. First Derivative (2011), both of which provide more standardized, and quite possibly more narrow, guidance on what is required to prove

scienter under Rule 10(b)-5. Plantiffs must prove scienter on the part of the audit firms to be successful in litigation. By looking at changes in auditor settlements and court rulings on dismissals in the 10 year period, the authors conclude that decision in Janus v. First Derivative did indeed reduce liability exposure for auditors. Sources: Honigsberg, Colleen and Rajgopal, Shivaram and Srinivasan, Suraj, “The Changing Landscape of Auditor Litigation” (April 2019). Stanford Law and Economics Olin Working Paper No. 512; Columbia Business School Research Paper No. 17-110. Available at SSRN: https://ssrn.com/abstract=3074923 or http://dx.doi.org/10.2139/ssrn.3074923

Has Rule 10(b)-5 Lost Some of it’s Sting for Auditors?AUDITING INSIGHT

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Foreign Corrupt Practices Act (FCPA) In 1977, Congress passed the FCPA, which

∙ Made it illegal for corporations or their officers to knowingly bribe foreign officials or participate in bribery schemes involving foreign officials to obtain or retain business.

∙ Required entities to develop and maintain effective internal controls.

In 1988, the FCPA became codified as an amendment to the Securities Exchange Act. As a result, auditors may be liable for violations of this act if they should have identified these violations during their examination. In a 2018 settlement, Brazil’s Petrobras agreed to pay $853.2 million in penalties to settle bribery investigations involving payment to foreign government officials. In total, Petrobras was assessed a whooping $1.78 billion in penalties and disgorgement related to the FCPA violations.9 More recent settlements related to FCPA violations involve large, well known companies such as Anheuser-Busch InBev, who agreed in 2016 to pay $6 million related to improper payments to India government officials and silencing a whistleblower, and Panasonic, who agreed to pay $143 million in 2018 related to fees paid to a foreign government employee in an effort to obtain and retain more business.10 The following Audit Insight highlights recent increased enforcement by the US Department of Justice for FCPA violations.

9Richard Cassin, “Petobras reaches $1.78 billion FCPA resolution,” The FCPA Blog, September 28, 2018, http://www.fcpablog.com/ blog/2018/9/27/petrobras-reaches-178-billion-fcpa-resolution.html 10“SEC Enforcement Actions: FCPA Cases,” https://www.sec.gov/spotlight/fcpa/fcpa-cases.shtml

Legal Precedent UNITED STATES V. NATELLI (“NATIONAL STUDENT MARKETING” CASE) (1975) In this case, two auditors were convicted because of their involvement with materially misstated financial statements included in the proxy state- ment of National Student Marketing Corporation. These financial state- ments failed to reveal a $1 million write-off of “sales” (about 20 percent of the amount previously reported) and a corresponding large adjustment to National Student Marketing’s operating income. The court stated:

It is hard to probe the intent of a defendant. . . . When we deal with a defendant who is a professional accountant, it is even harder at

times to distinguish between simple errors of judgment and errors made with sufficient criminal intent to support a conviction, espe- cially when there is no financial gain to the accountant other than his legitimate fee.

Case conclusion: Both the audit partner in charge of the engagement (Anthony Natelli) and his supervisor were fined and received jail sentences of one year each. Although a federal appeals court reversed the super- visor’s conviction, it upheld Natelli’s conviction because of his apparent motive and action to conceal the effect of some accounting adjustments. Natelli’s sentence was eventually reduced to 60 days.

The U.S. Department of Justice is continuing to be aggressive in enforcing the FCPA, as evidenced by the following:

• All of the top 10 settlement amounts for FCPA violations have occurred since 2008, with settlement amounts in excess of $300 million for each company.

• Since 2007, DOJ enforcement actions have ranged from a low of 10 (2015) to a high of 48 (2010). There were 29 DOJ enforcement actions in 2017.

• Total combined monetary resolutions companies have had to pay related to FCPA violations has been on the rise since 2004, with a

peak at over $2 billion in 2016. Resolutions were over $1 billion in 2017.

• From 1978–2017, China leads for the most violations per country, with a total 89 violations. Nigeria is second with 75.

Sources: “FCPA Violations: Still a Big Deal in 2018,” Insights: Woodruff Sawyer, June 12, 2018, available at: https://woodruffsawyer.com/do-notebook/ fcpa-violations-2018/; “The Top Ten List of Corporate FCPA Settlements,” FCPA Professor, September 22, 2017, available at: http://fcpaprofessor.com/ top-ten-list-corporate-fcpa-settlements/

FCPA Violations: A Big and Costly DealAUDITING INSIGHT

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SUMMARY OF AUDITORS’ LIABILITY TO CLIENTS AND THIRD PARTIES Thus far, we have discussed auditors’ potential liability to clients and third parties under both common law and statutory law (Securities Act of 1933 and Securities Exchange Act of 1934, respectively). Exhibit C.2 summarizes various elements of this liability, including (1) the level of professional care (performance) owed to various parties by auditors, (2) the burden of proof, and (3) various defenses available to auditors. Most noteworthy in Exhibit C.2 is the fact that plaintiffs have the burden of proving that auditors’ failure to exercise the appropriate level of professional care caused the loss (“burden of proof”) under common law and the Securities Exchange Act of 1934; however, the burden of proof is with auditors under the Securities Act of 1933. See Exhibit C.3 for a summary of important cases that have either developed auditor liability (common law) or clarified various provisions of the Securities Acts.

Source of Liability Party(ies) Involved Plaintiff Proof Type of Offense Auditors’ Defenses Common law Client • Economic loss

• Auditors’ breach of contract or failure to exercise the appropriate level of professional care

• Loss caused by breach of contract or failure to exercise appropriate level of professional care

• Breach of contract • Ordinary negligence • Gross negligence • Fraud

• No breach of contract or no failure to exercise the appropriate level of professional care

• Economic loss caused by other factors (causation)

• Clients partially responsible for loss (contributory negligence)

Third parties • Economic loss • Auditors’ failure to

exercise the appropriate level of professional care

• Material misstatements in financial statements

• Loss caused by reliance on materially misstated financial statements

• Ordinary negligence (depends on jurisdiction and standing of party)

• Gross negligence • Fraud

• Lack of appropriate standing (relationship) between third party and auditors

• Loss caused by factors other than financial statements and auditors’ examination

• Work performed in accordance with GAAS or other professional standards

EXHIBIT C.2 Summary of Auditors’ Liability

REVIEW CHECKPOINTS C.18 Identify the contents of Form 10-K, Form 10-Q, and Form 8-K. How are auditors involved with

the information in these filings? C.19 What are (a) Regulation S-X, (b) Regulation S-K, (c) Financial Reporting Releases, and (d) Staff

Accounting Bulletins? C.20 Who may bring suit against auditors under the Securities Exchange Act? What must these parties

demonstrate in order to bring suit? C.21 What defenses are available to auditors under the Securities Exchange Act? C.22 What are the criminal penalties associated with violations of the Securities Exchange Act? C.23 What is scienter? How do the findings in Ernst & Ernst v. Hochfelder and Denise L. Nappier et al.

v. PricewaterhouseCoopers relate to scienter? C.24 What are the major differences in auditors’ liability under the Securities Act of 1933 and the

Securities Exchange Act of 1934?

(Continued)

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It is important to note that auditors’ liability will continue to evolve over time. In a 2007 case (Tellabs Inc. v. Makor Issues & Rights Ltd.), the U.S. Supreme Court held that trial courts must consider all plausible inferences of scienter and that cases should be permitted to proceed only if the possibility of scienter is “cogent and at least as compelling as any opposing inference.”11 Some cases have been dismissed using this standard, but other cases have taken the view that the burden of proof regarding scienter still remains with the defendant. Future cases and rulings will likely provide further clarification as to the relative burden of proof in cases involving accusations of scienter.

THE CHANGING LANDSCAPE OF AUDITORS’ LIABILITY The preceding discussion identifies the significant exposure of auditors to legal liability for their actions to various parties. Most people would argue that auditors performing substandard work should be held liable for that work, but a number of factors contribute to auditors’ exposure to litigation brought by plaintiffs, including

∙ Pressure to hold auditors accountable in light of a number of highly publicized audit failures and the significant losses of billions of dollars to investors as a result.

11Tellabs Inc. v. Makor Issues & Rights Ltd., 127 S. Ct. 2499 (2007).

LO C-6 Understand recent developments that affect auditors’ liability to clients and third parties.

Smith v. London Assurance Corp. (1905) • Established auditors’ liability to clients for breach of contract Ultramares Corp. v. Touche (1931) • Established rights of third parties not in privity with auditors to bring legal action

• Concluded that auditors are generally not liable to third parties not in privity for ordinary negligence but could be liable for gross negligence

Credit Alliance v. Arthur Andersen (1985) • Established auditors’ liability to primary beneficiaries for ordinary negligence Rusch Factors v. Levin (1968); Fleet National Bank v. Gloucester Co. (1994)

• Established auditors’ liability to foreseen parties for ordinary negligence (restatement of torts doctrine)

Rosenblum Inc. v. Adler (1983) • Established auditors’ liability to foreseeable parties for ordinary negligence Escott v. BarChris Construction Corp. (1968) • Confirmed auditor liability for ordinary negligence to investors under the Securities Act

• Established importance of auditors’ review of subsequent events Ernst & Ernst v. Hochfelder (1976) • Confirmed auditors’ liability to shareholders under the Securities Exchange Act if scienter is

demonstrated • Provided potential exposure to auditors for gross negligence even in absence of scienter

EXHIBIT C.3 Significant Cases Affecting Auditors’ Liability

Source of Liability Party(ies) Involved Plaintiff Proof Type of Offense Auditors’ Defenses Securities Act of 1933 Purchasers of

securities in an initial registration

• Economic loss • Material misstatements in

financial statements

• Ordinary negligence • Gross negligence • Fraud

• Due diligence (auditors conducted a GAAS audit)

• Loss caused by factors other than financial statements and auditors’ examination

Securities Exchange Act of 1934

Purchasers and sellers of securities through subsequent transactions

• Economic loss • Material misstatements in

financial statements • Loss caused by reliance

on materially misstated financial statements

• Auditors were aware of material misstatements and acted with intent (scienter)

• Gross negligence • Fraud

• Auditors acted in good faith • Auditors had no knowledge

of material misstatements

EXHIBIT C.2 Summary of Auditors’ Liability (Continued)

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∙ Awareness of litigation against auditors as an avenue to recover losses, regardless of the actual reason for and cause of those losses.

∙ Highly complex accounting standards and difficulty in interpreting and evaluating financial statements prepared under those standards.

∙ The doctrine of joint and several liability, which may expose auditors to extensive and unreasonable losses when they are only partially at fault.

∙ The availability of class action suits, which makes it attractive for a small number of individuals to bring suit on behalf of a larger number of others.

The auditing profession considers the U.S. tort liability system a crisis of expanding liability exposure in need of reform. Some important reforms that have been implemented or are currently being discussed in response to these damages are summarized in the remainder of this section. Some of these reforms influence auditors’ liability under common law and statutory law described in the preceding sections.

Sarbanes–Oxley The U.S. Public Company Reform and Investor Protection Act of 2002, better known as the Sarbanes–Oxley Act, seeks to strengthen corporate accountability and governance of public entities. Although the more publicized aspects of Sarbanes–Oxley affect cor- porate officers and directors, some of its provisions affect auditors’ statutory liability under the securities acts by increasing the penalties for auditors’ involvement in financial statement fraud. Many of the aspects of Sarbanes–Oxley that affect auditors’ planning, implementation, and reporting processes are discussed in other chapters in this book. Sarbanes–Oxley has impacted auditors’ liability as follows:

∙ Extended the statute of limitations for bringing suit under the Securities Exchange Act to the earlier of (1) two years after the discovery of facts relating to violations of the act or (2) five years following the violation of the act. In addition, as noted earlier, the penalties for securities fraud have been increased to provide for fines of up to $5 million and imprisonment of up to 20 years for violations of the Securities Exchange Act.

∙ Increased penalties for mail fraud and wire fraud from 5 years to 20 years of imprisonment.

∙ Addressed the destruction, alteration, or falsification of records in federal investi- gations and bankruptcies. Firms and individuals found to have altered or destroyed documents with the intent to impede an investigation may be subject to fines and imprisonment for up to 20 years. In addition, under PCAOB standards, accountants performing an audit of a public company must maintain all engagement documenta- tion for a period of seven years. Firms that do not comply with the record-retention provision are subject to fines and imprisonment of individual violators within the firm for up to 10 years.

In addition to the number of factors listed above that impact auditors’ exposure to litigation brought by plaintiffs, the following additional factors have also contributed to the increase in auditor exposure for liability claims:

• A reduced likelihood of judges dismissing charges against auditors. • The availability of insurance, which makes auditors a desirable tar-

get for attorneys for recovery.

• Mergers of smaller firms and larger firms and difficulties during the transition period of these mergers because of the lack of effective risk management practices for smaller firms.

• Clients’ increased interest in pursuing professional liability claims to recoup losses during the economic downturn.

Source: “Target CPAs,” Accounting Today, July 1, 2011, pp. 1, 53.

Are CPAs a Target?AUDITING INSIGHT

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In addition to the preceding items, Sarbanes–Oxley amended federal sentencing guidelines that increase financial and criminal penalties when securities fraud, obstruction of justice, and criminal fraud exist. This means not only that auditors face a higher liability risk but also that Sarbanes–Oxley may influence the courts in decisions regarding awards in civil cases. These provisions are considered a setback for the accounting profession’s initiative to reduce auditors’ liability.

Racketeer Influenced and Corrupt Organizations Act The Racketeer Influenced and Corrupt Organizations Act (RICO) was enacted to combat organized crime in businesses and other organizations by providing for extended criminal penalties and civil courses of action for various offenses. RICO targeted members of organized crime, but an unintended consequence of this legislation was exposure of its provisions to auditors, whom attorneys threatened to classify as “racketeers” and impose the threat of penalties for treble (triple) damages under the law. In 1988, Laventhol & Horwath (at the time, the seventh-largest accounting firm) became the first firm to lose a jury trial under RICO statutes related to its role in a cattle-breeding venture in which almost 3,000 investors lost more than $20 million. (Laventhol & Horwath subsequently filed for bankruptcy in 1990.)12

In 1993, the U.S. Supreme Court (in Reeves v. Arthur Young) ruled that auditors are not subject to RICO complaints unless they “actively participate” in the management or operation of a corrupt business. Thus, failure to exercise the appropriate level of professional care (i.e., ordinary negligence) is not sufficient to use the provisions of RICO in a lawsuit against auditors.

Aiding and Abetting Under the legal doctrine of aiding and abetting, plaintiffs have the ability to include parties in legal actions who were indirectly involved with particular offenses. In the past, share- holders argued that auditors’ failure to exercise the appropriate level of professional care exposed them to liability through this legal doctrine. In Central Bank v. First Interstate Bank (1994), the U.S. Supreme Court severely limited the extent to which the aiding and abetting doctrine could be used against auditors. In Stoneridge Investment Partners v. Scientific-Atlanta (2008), the Supreme Court ruled that investors who suffer losses because

12“Laventhol to Pay $15 Million in Suit,” http://articles.philly.com/1988-05-10/business/26262663_1_laventhol-horwath-rico-suits- rico-statute.

In early 2017, PricewaterhouseCoopers (PwC) found itself in the mid- dle of a lawsuit that challenged the line between auditor’s responsibil- ity and management’s responsibility for financial statements. Former client and now defunct brokerage firm MF Global was suing PwC, claiming the audit giant was to blame for the company’s bankruptcy. In particular, the lawsuit claimed PwC was negligent in their approval of certain complicated transactions.

It is management that is ultimately responsible for complying with generally accepted accounting principles (GAAP) when determining how to account for complex transactions. PwC’s responsibility, accord- ing to audit standards, is to obtain reasonable assurance that the financial statements are in accordance with GAAP. This includes evalu- ating judgments made by management. In this case, MF Global had researched and concluded their method for accounting for the com- plex transactions in question was in accordance with GAAP. MF Global then asked PwC to review their conclusion. PwC performed their own

research and analysis and determined the method MF Global used was in accordance with GAAP.

PwC ended up settling the case for an undisclosed amount in March 2017. According to former Securities and Exchange Commis- sion attorney Jacob Frenkel, “As a settled case, there is zero prec- edential value. Where there was a risk of extending unreasonably the role of an auditor, the law remains as is, meaning that auditors provide reasonable assurances about financial statements and are not audi- tors of business judgment.”

Source: Joshua Teitelbaum, “All auditors stand to lose if PwC is found responsible for MF Global Collapse,” Forbes.com, March 17, 2017, https:// www.forbes.com/sites/realspin/2017/03/17/all-auditors-stand-to-lose-if-pwc- is-found-responsible-for-mf-global-collapse/#24de1831dcd1; Daniel Fisher, “PwC settles with MF Global, Leaving question of auditor liability for a different case,” Forbes.com, March 23, 2017, https://www.forbes.com/sites/daniel- fisher/2017/03/23/pwc-settles-with-mf-global-leaving-question-of-auditor- liability-for-another-case/#1d0d82ea1900

Whose Responsibility Is It?AUDITING INSIGHT

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of corporate fraud can typically recover losses only from the entity, its officers, and its directors, not from others who are engaged in business with the corporation. Although Stoneridge did not directly address involvement of auditors, the court’s decision has been viewed as making it more difficult for plaintiffs to recover damages in civil actions from bankers, attorneys, and accountants under the so-called legal theory of scheme liability.13

Organization of Accounting Firms as Limited Liability Partnerships Almost all of the major accounting firms have names that end with the designation LLP (limited liability partnership). Prior to 1990, accounting firms were organized as partner- ships. One of the major disadvantages of the partnership form of organization is that the personal assets of all partners within the firm were at risk (i.e., were subject to loss via litiga- tion) for the actions of all others within the firm. In the early 1990s, decisions in New York and Hawaii to permit and recognize limited liability partnerships to practice within their juris- dictions led to accounting firms reorganizing themselves as limited liability partnerships.

A limited liability partnership combines the advantages of the traditional partnership form of organization (taxation of partnership income to the partners, limited ownership of partnership interests) with the liability protection afforded to corporations. Specifically, in a limited liability partnership, any claims against the partnership are limited to partner- ship assets unless an individual partner directly participated in the action giving rise to the claim. It is important to note that organization of a firm as a limited liability partner- ship does not affect the firm’s legal liability but only the extent to which the individual partners’ assets were subject to loss via litigation.

Proportionate Liability One significant concern for auditors is the doctrine of joint and several liability, which allows a successful plaintiff to recover the full amount of a damage award from any defendant found to have failed to exercise the appropriate level of professional care regardless of the relative guilt of this defendant compared to other defendant(s). Stated another way, if both the audi- tors and the client are found to have been responsible for misstatements in the client’s finan- cial statements, plaintiffs can seek recovery from either or both parties. Often in cases of business failures, auditors are the only parties with “deep pockets” of financial resources to pay damages. Thus, when a group of defendants (auditors, management, and client) is found liable for damages, auditors may be required to pay the entire amount even though they may be only partially at fault. In contrast, under proportionate liability, a defendant is required to pay a proportionate share of the court’s damage award depending on the degree of fault determined by a judge and jury (e.g., 20 percent, 30 percent, but not 100 percent).

Proportionate liability was largely accomplished at the federal level in 1995 with the passage of the Private Securities Litigation Reform Act. Civil lawsuits for damages now are governed by these proportionate liability terms:

∙ The total responsibility for loss is divided among all parties responsible for the loss. ∙ If other defendant(s) are insolvent, a solvent defendant’s liability is extended to 50 percent

more than the proportion found at trial. (For example, if an accounting firm is found 20 percent responsible for a loss and the client and its managers are insolvent, the accounting firm will have to pay 30 percent of the loss but not 100 percent as before.)

∙ Only the defendants who knowingly committed a violation of securities laws remain jointly and severally liable for all of the plaintiffs’ damages. (This is the imposition of penalty for actively participating in an actual fraud.)

The Private Securities Litigation Reform Act includes an exception to these provisions to compensate smaller investors. If plaintiffs have a net worth of less than $200,000 and lost 10 percent or more of the net worth because of auditors’ failure to exercise appropriate levels of professional care, auditors remain jointly and severally liable. 13“You Can’t Sue the Bean Counters,” BusinessWeek, January 28, 2008, p. 30; “Can Shareholders Sue Third Parties?” The Wall Street Journal, October 6–7, 2007, p. A19.

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Class-Action Suits It is not unusual for shareholders or investors who have suffered losses to band together and bring legal action against entities or auditors. In a class action, a relatively small num- ber of aggrieved plaintiffs with small individual claims can bring suit for large damages in the name of an extended class. After a bankruptcy, for example, 50 bondholders who lost $40,000 might decide to sue and can do so on behalf of the entire class of bondholders for all of their alleged losses (say $40 million). Attorneys take these cases on a contingency fee basis (a percentage of the judgment, if any). The size of the claim and the zeal of the attorneys can make the class-action suit a serious matter.

In the past, most class-action lawsuits were adjudicated in state courts, and a great deal of “jurisdiction shopping” was performed to find a court that might be more sympathetic to the plaintiffs. Some of the large corporate failures have resulted in class-action lawsuits that have proven costly for defendants to defend and difficult for them to win. In February 2005, the Class Action Fairness Act was signed into law. This act is designed to expand federal jurisdiction over class-action lawsuits and is estimated to result in the movement of 40 percent of class-action lawsuits from various state courts to federal court. Federal courts are preferable venues for defendants in class-action lawsuits because

∙ Class-action lawsuits come under more scrutiny in federal court compared to state courts. ∙ Federal courts have more resources at their disposal in managing class-action cases

than state courts. ∙ State courts have been alleged to unfairly discriminate against defendants from other

jurisdictions. ∙ State court verdicts often affect plaintiffs in other jurisdictions (states). A verdict in federal

court is regarded as more appropriate when it is applied to multiple jurisdictions.

It is important to note that not all class-action lawsuits will come under federal juris- diction, and the rules for determining whether a state or federal court has jurisdiction over a case are complex.

In 2019, the current state of auditor liability was “not be too bad for auditors,” according to Michael Young, partner at international law firm Willkie Farr & Gallagher LLP. However, when it comes to litigation auditors need to be thinking 5 to 10 years ahead. Litigation against auditors does not occur soon after the audit’s end, but instead many years later. One thing auditors can do to help themselves now: care- ful and thorough documentation of work done and judgments made. According to Mr. Young, “Five years after the audit, you may be asked to talk about what judgments you made. And you have to be really,

really smart and have a really, really good recollection to be able to recreate from memory the kinds of tough judgment calls that you made. That’s where documentation comes in. . . . If you can show that something was a tough judgment call and you considered things on all sides and you came to the best judgment you could, that works. That is really hard to attack.”

Sources: “New litigation and regulatory risks,” The CPA Journal, February 2019, available at: https://www.cpajournal.com/2019/03/18/new-litigation-and- regulatory-risks/

Liability and Looking AheadAUDITING INSIGHT

In 2018, the number of class-action settlements decreased slightly from the previous year, from 81 settlements to 78. The total settle- ment dollars for 2018 was over $5 billion, a substantial increase over 2017 and the third highest total from the prior 10 years. The increase

in settlement dollars was due to five “mega” settlements ranging from $110 million to $3 billion.

Source: Securities Class Action Settlements—2018 Review and Analysis (Cornerstone Research, 2019).

How Big Is the Class?AUDITING INSIGHT

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In addition to the Class Action Fairness Act, Congress enacted the Securities Litigation Uniform Standards Act in 1998. The most significant provision of this legislation requires class-action lawsuits with 50 or more parties to be filed in the federal courts. As noted earlier, federal courts are generally more favorable venues for class-action lawsuits for the defendants (auditors).

Auditors’ Liability Caps A final development in the legal liability arena is related to various measures of limiting (or “capping”) auditors’ liability to both clients and third parties. In their engagement letters, auditors are attempting to limit their potential liability to clients through care- ful wording. Firms are doing this in a variety of ways, including requiring some type of alternative dispute resolution. This type of liability cap limits a company’s right to sue its auditor by requiring the company to seek arbitration or mediation in the event of a disagreement over the books. Although the effectiveness of this language in limiting auditors’ liability has not been legally tested, some opponents of the lan- guage contend that restrictions such as this can compromise auditor independence and performance.14

Other Developments Auditor liability continues to change along with the landscape of the auditing profession. In 2009, a U.S. judge denied Deloitte Touche Tohmatsu’s motion for a summary judg- ment that would relieve the firm of any liability for audits of Parmalat conducted by its Italian member firm (Deloitte & Touche SpA). This action clearly expands liability for international accounting firms in cases in which the firm itself provides little actual service

14“More Companies Are Disclosing Pacts with Auditors on Liability Caps,” The Wall Street Journal, June 22, 2006, p. C4.

Three recent studies have examined factors influencing litigation:

• Schmidt concluded that litigation against auditors related to financial statement misstatements is more likely when the mis- statement is associated with (1) financial fraud, (2) a regulatory investigation, (3) a large decline in stock price, and (4) a higher number of errors in applying GAAP. In addition, the results of this study showed that litigation against an auditor/firm resulted in that office’s demonstrating more conservative behavior with respect to other clients (such as lower levels of positive financial statement accruals and a longer time period for issuing the audit reports). In a follow-up study, Schmidt found that the perception that auditors’ independence has been impaired by the amount of nonaudit ser- vices provided also influences the auditor’s decision to settle and increases the amount of the settlement.

• Casterella et al. found that in comparison with smaller firms, larger accounting firms, firms experiencing significant growth, firms with a higher number of claims outstanding against them, and firms that have been investigated or disciplined by a professional over- sight body had higher levels of litigation risk.

• Boone et al. found that auditors involved with engagements hav- ing higher litigation risk were less likely than auditors with lower

risk to acquiesce to client earnings management behavior and that the Private Securities Litigation Reform Act reduced the risk of litigation against auditors.

• Anantharamen et al. examine if, and how, the varying legal liability standards across states influence auditors’ reporting decisions, in particular the decision to issue a going concern modification for dis- tressed companies. They find that auditors are significantly more likely to issue a going-concern opinion to clients from states where the stan- dard for third-party liability is more expansive and the joint and several liability rule for determining damages among defendants exists.

• Cassell et al. found that auditor litigation risk increases as the number of institutional investors owners increases, as do audit fees.

Sources: J. Schmidt, “Perceived Auditor Independence and Audit Litigation: The Role of Nonaudit Service Fees, The Accounting Review, May, 2012, pp. 1033–1065; J. R. Casterella, K. L. Jensen, and W. R. Knechel, “Litigation Risk and Audit Firm Characteristics,” Auditing: A Journal of Practice & Theory, November 2010, pp. 71–82.; J. P. Boone, I. K. Khurana, and K. K. Raman, “Litigation Risk and Abnormal Accruals,” Auditing: A Journal of Practice & Theory, May 2011, pp. 231–256; D. Anantharaman, J. A. Pittman, and N. Wans, “State Liability Regimes within the United States and Auditor Reporting,” The Accounting Review, November 2016, pp. 1545-1575; C. Cassell, M. Drake, and T. Dyer, “Auditor Litigation Risk and the Number of Institutional Investors,” Auditing: A Journal of Practice & Theory, August 2018, pp. 71-90.

What Affects Litigation?AUDITING INSIGHT

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to the client. Speaking on behalf of the plaintiffs, attorney Stuart Grant noted, “Judge Kaplan has finally made the law reflect reality. These accounting firms sell themselves as worldwide, seamless organizations. Now they are going to be held responsible in the same fashion. In essence, Judge Kaplan has said that the parent can’t hide from the misdeeds of its children.”15 In more recent auditor-friendly rulings, the concept of in pari delicto has been strengthened as an auditor defense. Basically, this legal concept means that the court should not intercede between two wrongdoers. To put this in context, a corporation whose officers committed fraud cannot later sue the auditors for not catching the fraud; note, how- ever, that innocent shareholders may still proceed with litigation against the auditors.16

15“A Parmalat Ruling May Broaden Liability,” The Wall Street Journal, January 29, 2009, p. C4; “Judge: OK to Sue Deloitte over Parmalat,” CFO.com, January 30, 2009. 16S. Benson, “Shielding the Auditor from Corporate Fraud Liability,” The CPA Journal, April, 2012, pp. 58–65.

REVIEW CHECKPOINTS C.25 List some of the major changes in auditors’ liability provided by Sarbanes–Oxley. C.26 What is the difference between joint and several liability and proportionate liability? C.27 What major changes did the Private Securities Litigation Reform Act provide? What major changes

did the Class Action Fairness Act provide? C.28 What requirement was enacted in the Securities Litigation Uniform Standards Act that affected

class-action lawsuits?

Summary This module summarizes the potential liability auditors have to clients and third parties who rely on their work. Auditors can be liable under either common law (based on prior legal decisions and precedents) or statutory law (violating a written law). Auditors’ liability to clients arises through an economic loss suffered because of failure to perform the engagement in accordance with the contract (breach of contract) or because of auditors’ failure to exercise the appropriate level of professional care (tort liability). Because of the close relationship between auditors and clients, auditors owe their clients a very high degree of performance and are liable when they commit ordinary negligence (lack of reasonable care), gross negligence (lack of minimal care), or fraud (knowledge and intent to deceive).

Auditors’ liability to third-party investors or creditors under common law arises because of economic decisions made by these parties using audited financial statements. Under common law, auditors are liable to all third-party users for levels of failure to exercise the appropriate level of professional care representing gross negligence or fraud. With respect to ordinary negligence, three separate approaches to liability are for third parties who are primary beneficiaries (Credit Alliance v. Arthur Andersen), foreseen third parties (restatement of torts doctrine, Fleet National Bank v. Gloucester Co.), or fore- seeable third parties (Rosenblum Inc. v. Adler). The legal precedent in the jurisdiction in which the action is brought determines auditors’ liability to third parties for ordinary negligence.

Under statutory liability, the Securities Act of 1933 and the Securities Exchange Act of 1934 dictate liability to investors in securities. These acts differ based on both the bur- den of proof and the level of failure to exercise the appropriate level of professional care required to bring suit. Under the Securities Act, the burden of proof is on auditors; purchas- ers of securities may bring suit for ordinary negligence, gross negligence, or fraud. Under the Securities Exchange Act, the burden of proof is on purchasers or sellers of securities,

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and suit can be brought only for gross negligence or fraud. Clearly, the Securities Act imposes the highest degree of care on auditors and the lowest barriers for plaintiffs to bring suits against auditors.

Although Sarbanes–Oxley has expanded the statute of limitations as well as the penalties to auditors under the Securities Exchange Act, other developments have reduced (or advocate a reduction in) auditors’ exposure to legal liability. These developments include the Private Securities Litigation Reform Act, the Class Action Fairness Act, and various calls for liability limitations (or caps).

breach of contract: A claim that accounting or auditing services were not performed in the manner described in the contract, 683 causation defense: An argument available to auditors who can show that a plaintiff’s economic loss was caused by a factor other than the auditors’ failure to exercise the appropriate level of professional care or breach of contract, 684 class action: A situation in which a group of plaintiffs comes together in a legal action against another party, 702 comfort letter: A letter issued by auditors to underwriters of securities that provides an opinion on the fairness of the issuers’ financial statements, 690 common law: The liability for injuries that is based on reasons other than violation of a written law or statute. Under common law, legal precedent is used in assessing the degree of responsibility or fault of the parties; auditors have common law liability to clients and nonshareholder third parties, 682 constructive fraud: A failure to provide any care in fulfilling a duty owed to another including a reckless disregard for the truth (similar to gross negligence), 684 contributory negligence: A legal defense theory in which the plaintiff’s own failure to perform with the appropriate level of professional care bars recovery from auditors, 684 “deep pockets” theory: The concept that lawsuits may be brought against auditors not because they are necessarily at fault but because they are the only party with resources against which recovery can be made, 682 expectation gap: The difference between the actual work and assurance required by GAAS and the expectation of that work by the general public, 682 Financial Reporting Releases (FRRs): Reports prepared by SEC staff that express new rules and policies about disclosure, 693 foreseeable party: The individuals or organizations whose decisions normally rely on audited financial statements and opinions on those financial statements, 685 foreseen party: A limited class of individuals or organizations that could be reasonably expected to rely on auditors’ work, 685 Form 8-K: The “current events” report filed periodically at the occurrence of major events, such as earnings releases, major asset sales, acquisitions, and auditor changes, 693 Form 10-K: The form to use for annual filing of financial statements and related disclosures by public companies with the SEC, 693 Form 10-Q: The form to use for quarterly filing of financial statements and related disclosures by public companies with the SEC, 693 fraud: The misrepresentation of facts that the individual knows to be false with the intention to deceive, 683 gross negligence: The breach of duty owed to another party because of a lack of minimal care (similar to constructive fraud), 683 initial public offering (IPO): The initial issuance of securities by a registrant entity to the investing public through a market that is subject to the provisions of the Securities Act of 1933, 690 joint and several liability: The legal doctrine that when multiple defendants are named, the full amount of a damage award may be collected from any of the defendants named in the lawsuit even though they may be only partially at fault, 701 limited liability partnership: A form of organization adopted by most large accounting firms that combines the advantages of a traditional partnership with the liability protection afforded to corporations, 701 ordinary negligence: The unintentional breach of duty owed to another as a result of a lack of reasonable care, 683

Key Terms

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plaintiff: The person or organization that initiates a lawsuit (client or third-party user of financial statements), 683 primary beneficiary: A person known by name to the auditor for whose primary benefit the audit or other accounting service is performed, 685 privity of contract: A situation in which parties have a contractual relationship, 683 proportionate liability: The legal doctrine that payment of a share of the court’s damage award be based on the extent (or proportion) of fault exhibited by a convicted defendant, 701 prospectus: A legal document offering securities for sale; includes significant information about the issuing entity, including its historical financial statements and other necessary disclosures, 690 registration statement: A set of documents, including a prospectus, that a company files with the SEC prior to an initial public offering, 690 Regulation S-K: The SEC requirements relating to all business, analytical, and supplementary financial disclosures other than financial statements themselves, 693 Regulation S-X: The SEC accounting requirements for annual and interim financial statements filed under both the Securities Act and the Securities Exchange Act, 693 scienter: A mental state embracing the intent to deceive, manipulate, or defraud prior to committing those actions (for example, auditors’ knowledge of a misstatement in the financial statements and the intentional failure to disclose this misstatement in their report), 694 Staff Accounting Bulletins (SABs): The unofficial but important interpretations of Regulation S-X and Regulation S-K by SEC staff, 693 statutory law: The legal rules affecting liability based on violations of written laws or statutes. Auditors have statutory liability to third-party investors under the securities acts, 683 tort: A civil complaint charging that the action of one person caused injury (personal or financial) to another; such action against auditors is normally initiated by users of financial statements, 683

All applicable questions are available with Connect.

Multiple-Choice Questions for Practice and Review

C.29 A lack of reasonable care that may be characterized by the failure of auditors to follow GAAS in the conduct of the audit is known as a. Constructive fraud. b. Fraud. c. Gross negligence. d. Ordinary negligence.

C.30 From the auditors’ point of view, if financial damages are to be imposed in a civil lawsuit, which of the following is a preferable method of allocation? a. Joint and several liability. b. Reasonably foreseeable users’ approach to privity. c. Foreseen third parties’ approach to privity. d. Proportionate liability.

C.31 Users of financial statements have a different perception concerning the nature of auditors’ services than the actual objectives of an audit. This difference is known as a. Diverse liability perception. b. Reasonable foreseeable third parties. c. Insurance hypothesis. d. Expectations gap.

C.32 Individuals who believe they relied on misstated financial statements to make a decision and have suffered losses as a result will issue an action known as a a. Breach of contract. b. Tort. c. Securities litigation. d. Constructive fraud.

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C.33 Assume that auditors lost a civil lawsuit for damages and the court found total losses of $5 million. If the auditors were determined to be 30 percent at fault and were the only solvent defendants, what is the auditors’ likely obligation under proportionate liability? a. $5,000,000 b. Zero c. $2,250,000 d. $1,500,000

C.34 Suppose that the auditors in the preceding question participated knowingly in commission of violations of securities laws (with managers and directors of the audit client). What is the auditors’ likely obligation? a. $5,000,000 b. Zero c. $2,250,000 d. $1,500,000

C.35 When a client sues an accountant for failure to perform consulting work properly, the accountants’ best defense is probably based on the doctrine of a. Lack of privity of contract. b. Contributory negligence on the part of the client. c. Lack of any measurable dollar amount of damages. d. No negligence on the part of the consultant.

C.36 When creditors who relied on an entity’s audited financial statements suffer monetary losses after a customer (the auditors’ client) goes bankrupt, what must the plaintiff creditors in a lawsuit for damages show in a court that follows the doctrine in Credit Alliance? a. The auditors knew and specifically acknowledged identification of the creditors. b. The auditors could reasonably foresee them as beneficiaries of the audit because entities

such as this client use financial statements to obtain credit from vendors. c. The plaintiffs were foreseen users of the audited financial statements because they were

vendors of long standing. d. All of the above.

C.37 When accountants agree to perform a compilation or review of unaudited financial state- ments, the best way to avoid clients’ misunderstanding the nature of the work is to describe it completely in a. An engagement letter. b. The auditors’ opinion. c. A report to the clients’ board of directors at the close of the engagement. d. A management letter to the board of directors’ audit committee.

C.38 Entities desiring to issue equity or debt must provide a set of financial statements to any prospective purchaser. This set of financial statements and other information for prospective purchasers is known as a a. Prospectus. b. Review. c. Patron’s acquisition statement. d. Projected audited financial information.

C.39 The Securities Act of 1933 and Securities Exchange Act of 1934 contain a. Civil liability provisions applicable to auditors. b. Criminal liability provisions applicable to auditors. c. Neither a nor b. d. Both a and b.

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C.40 Which of the following third parties is known by name to auditors as the audit is conducted? a. Foreseeable third party b. Foreseen third party c. General third party d. Primary beneficiary

C.41 Which of the following would be the auditors’ most likely defense in an action brought under the Securities Exchange Act of 1934? a. The investor did not have privity with auditors. b. The investor did not suffer a loss based on the materially misstated financial statements. c. The auditors acted in good faith and were not aware of the materially misstated financial

statements. d. The financial statements were not filed with the Securities and Exchange Commission.

C.42 Which of the following statements regarding auditors’ liability under the Securities Act of 1933 is not true? a. The act relates to the initial issuance of securities to the public, normally through an initial

public offering. b. Auditors’ liability arises because of audited financial information filed with the SEC. c. Third parties must demonstrate that they relied on misstated financial statements that

were examined by auditors. d. Auditors may be liable if they are found to have engaged in ordinary negligence.

C.43 Under the Securities Exchange Act of 1934, entities are required to report to the public about changing auditors on a. Form 10-K. b. Form 1-SA. c. Form 10-Q. d. Form 8-K.

C.44 Section 11(b) of the Securities Act of 1933 provides that individuals can be sued and may be liable for investors’ losses in connection with a public securities offering under which of these circumstances? a. The chairman of the board of directors performed a reasonable investigation of facts in

connection with preparing the section in the registration statement concerning the speci- fication of the use of the proceeds of the offering.

b. A consulting engineer performed a reasonable investigation and reported in the registra- tion statement on the feasibility of construction of a roadway to be financed with the offering proceeds.

c. The president of the issuing entity had no reason to doubt the report of the consulting engi- neer, although the president did not perform a separate reasonable investigation of her own.

d. The officers of the issuing entity were relieved that the independent auditors did not make an issue about the excessive valuation of inventory held to support construction in progress.

C.45 In comparison to the burden of proof required of plaintiffs in civil lawsuits against indepen- dent auditors under common law, section 10(b) of the Securities Exchange Act of 1934 a. Is the same regarding plaintiffs’ need to prove damages or losses. b. Is the same regarding plaintiffs’ need to establish privity or a beneficiary relationship

with auditors. c. Does not require that plaintiffs prove their reliance on materially misstated financial statements. d. Does not require that plaintiffs prove that relying on the materially misstated financial

statements caused their losses.

C.46 Which of the following cases provides auditors the broadest exposure for liability to third parties for ordinary negligence under common law? a. Credit Alliance v. Arthur Andersen. b. Fleet National Bank v. Gloucester Co. c. Rosenblum Inc. v. Adler. d. Ultramares.

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C.47 Which of the following is a major difference in auditors’ liability under the Securities Act of 1933 and the Securities Exchange Act of 1934? a. The burden of proving reliance on misstated financial statements and the relationship

between these financial statements and the economic loss. b. The auditors’ required degree of professional care. c. Both of the above. d. Neither of the above.

C.48 When an entity registers a security offering under the Securities Act of 1933, the law pro- vides an investor a. An SEC guarantee that the information in the registration statement is true. b. Insurance against loss from the investment. c. Financial information examined by independent auditors. d. Inside information about the entity’s trade secrets.

C.49 A group of investors sued Anderson, Olds, and Watershed, CPAs (AOW) for alleged dam- ages suffered when the entity in which they held common stock went bankrupt. To avoid liability under the common law, AOW must demonstrate which of the following? a. The investors actually suffered a loss. b. The investors relied on the financial statements audited by AOW. c. The investors’ loss was a direct result of their reliance on the audited financial statements. d. The audit was conducted in accordance with generally accepted auditing standards and

with due professional care.

C.50 The Securities and Exchange Commission document that governs accounting in financial statements filed with the SEC is a. Regulation D. b. Form 8-K. c. Form SB-l. d. Regulation S-X.

C.51 Which of the following cases upheld the requirement that plaintiffs demonstrate scienter when bringing action under the Securities Exchange Act of 1934? a. Ernst & Ernst v. Hochfelder. b. Escott v. BarChris Construction Corp. c. Smith v. London Assurance Corp. d. Ultramares.

C.52 A public entity subject to the periodic reporting requirements of the Securities Exchange Act of 1934 must file an annual report with the SEC known as the a. Form 10-K. b. Form 10-Q. c. Form 8-K. d. Regulation S-X.

C.53 When investors sue auditors for damages under section 11 of the Securities Act of 1933, they must allege and prove a. Scienter on the part of auditors. b. The audited financial statements contained a material misstatement. c. They relied on the materially misstated financial statements. d. Their reliance on the materially misstated financial statements was the direct cause of their loss.

C.54 Which of the following is not part of Sarbanes–Oxley? a. An increased duty on the part of auditors to identify financial statement fraud. b. A requirement that the CEO and CFO certify the financial statements. c. Increased penalties for destruction of records in federal investigations. d. Increased penalties for mail fraud and criminal violations of the Securities Exchange Act

of 1934.

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C.55 If a CPA firm is being sued for common law fraud by a third party based upon materially false financial statements, which of the following is the best defense the auditors could assert? a. Lack of privity. b. Lack of reliance. c. A disclaimer contained in the engagement letter. d. Contributory negligence on the part of the client.

(AICPA adapted)

C.56 Locke, CPA, was engaged by Hall Inc. to audit Willow Company. Hall purchased Willow after receiving Willow’s audited financial statements, which included Locke’s unmodified auditors’ opinion. Locke was negligent in the performance of the Willow audit engage- ment; this negligence was caused by failure to perform the engagement in accordance with terms of the engagement letter. As a result of Locke’s negligence, Hall suffered damages of $75,000. Hall appears to have grounds to sue Locke for

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a. Yes Yes

b. Yes No

c. No Yes

d. No No

(AICPA adapted)

C.57 An investor seeking to recover stock market losses from a CPA firm associated with an initial offering of securities based on an unmodified opinion on financial statements that accompanied a registration statement must establish that a. The audited financial statements contain a false statement or omission of material fact. b. The investor relied on the financial statements. c. The CPA firm did not act in good faith. d. The CPA firm would have discovered the false statement or omission if it had exercised

due care in its examination. (AICPA adapted)

C.58 Donalds & Company, CPAs, audited the financial statements included in the annual report submitted by Markum Securities Inc. to the Securities and Exchange Commission. The audit was improper in several respects. Markum is now insolvent and unable to satisfy the claims of its customers. Customers have instituted legal action against Donalds based on Section 10(b) and Rule 10(b)-5 of the Securities Exchange Act of 1934. Which of the following is likely to be Donalds’ best defense? a. The firm did not intentionally certify the false financial statements. b. Section 10(b) does not apply to the case. c. The firm was not in privity of contract with the creditors. d. The engagement letter specifically disclaimed any liability to any party that resulted from

Markum’s fraudulent conduct. (AICPA adapted)

Problems C.59 and C.60 are based on the following information: West & Co., CPAs, rendered an unmodified opinion on the financial statements of Pride

Corp., which were included in Pride’s registration statement filed with the SEC. Subse- quently, Hex purchased 500 shares of Pride’s preferred stock as part of a public offering subject to the Securities Act of 1933. Hex has commenced an action against West based on the Securities Act of 1933 for losses resulting from misstatements of facts in the financial statements included in the registration statement.

C.59 Which of the following elements must Hex prove to hold West liable? a. West rendered its opinion with knowledge of material misstatements. b. West performed the audit negligently.

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C.61 Breach of Contract. Although large-dollar lawsuits brought by shareholders grab the head- lines, auditors are most often sued by the client for breach of contract.

Required: a. How can auditors be in breach of contract with a client? b. How can a client be in breach of contract with auditors? c. What are the best defenses for auditors against breach of contract lawsuits brought by

their clients?

C.62 Liability to Clients. Thomas, CPA, is a regional firm that provides a variety of services to its clients. The following summarizes some issues that it has encountered with three of its audit clients during the most recent year:

∙ Thomas was engaged by Brown Company to conduct an audit of its financial statements. Brown is a nonpublic entity that is seeking financing and is having the audit conducted because of user demand for audited financial statements. Because this was an initial audit, it took Thomas longer to conduct the audit than anticipated. During this time, economic conditions resulted in a general increase in interest rates, and Brown’s costs of obtaining financing were higher than it had anticipated.

∙ Green Stores has been an audit client of Thomas for more than 10 years. Following the most recent audit (which resulted in an unmodified opinion on Green’s financial statements), Green Stores learned that its treasurer had been engaged in a significant embezzlement scheme, resulting in Green’s losses in excess of $2 million. Throughout Thomas’s 10-year relationship with Green Stores, it had issued unmodified opinions on Green’s financial statements and had not identified any weaknesses in Green’s internal control or other evidence that suggested the existence of this defalcation scheme.

∙ Fuchsia Inc. has been an audit client of Thomas for the past five years. During the most recent audit, Thomas identified misstatements that understated Fuchsia’s liabilities; Thomas believed that these misstatements should be corrected in order to fairly present Fuchsia’s financial condition, results of operations, and cash flows in conformity with GAAP. Fuchsia refused to make these misstatements, and Thomas resigned from the engagement. Fuchsia has engaged another auditor, but the delays associated with this change in auditors may result in accelerated payments to Fuchsia’s lenders for failure to provide them audited financial statements on a timely basis.

Required: a. Without specific reference to any of the preceding situations, on what basis/general areas

of liability may clients bring suit against auditors? b. Without specific reference to any of the preceding situations, what facts must clients

demonstrate to bring suit against auditors?

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c. Hex relied on the financial statements included in the registration statement. d. The misstatements were material.

(AICPA adapted)

C.60 Which of the following defenses would be least helpful to West in avoiding liability to Hex? a. West was not in privity of contract with Hex. b. West conducted the audit in accordance with GAAS. c. Hex’s losses were caused by factors other than the misstatements. d. Hex knew of the misstatements when Hex acquired the preferred stock.

(AICPA adapted)

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c. Without specific reference to any of the preceding situations, what defenses might be available to auditors for suits brought against them by their clients?

d. For each of the preceding clients, identify the potential basis or bases for legal action that might be brought against Thomas.

e. In your opinion, is Thomas likely to be liable to these clients for its actions? What factors should be considered in assessing Thomas’ potential liability in these situations?

C.63 Common Law Responsibility for Errors and Fraud. Huffman & Whitman (H&W), a large regional accounting firm, was engaged by Ritter Tire Wholesale Company to audit its financial statements for the year ended January 31. H&W had a busy audit engagement schedule from December 31 through April 1 and decided to audit Ritter’s purchase vouch- ers and related cash disbursements on a sample basis. The firm instructed staff members to select a random sample of 130 purchase transactions and gave directions about important deviations, including missing receiving reports. Boyd, the assistant in charge, completed the audit documentation, properly documenting the fact that 13 of the purchases in the sample had been recorded and paid without including the receiving report (required by stated inter- nal control procedures) in the file of supporting documents. Whitman, the partner in direct charge of the audit, showed the findings to Lock, Ritter’s chief accountant. Lock appeared surprised but promised that the missing receiving reports would be inserted into the files before the audit was over. Whitman was satisfied, noted in the audit documentation that the problem had been solved, and did not say anything to Huffman about it.

Unfortunately, H&W did not discover the fact that Lock was involved in a fraudulent scheme in which he diverted shipments of tires to a warehouse leased in his name and sent the invoices to Ritter for payment. He then sold the tires for his own profit. Internal auditors discovered the scheme during a study of slow-moving inventory items. Ritter’s inventory was overstated by about $500,000 (20 percent), the amount Lock had diverted.

Required: a. Do you believe H&W has any further audit responsibility with respect to the missing

receiving reports? Explain. b. Do you believe H&W failed to exercise the appropriate level of professional care? Why

or why not?

C.64 Common Law Responsibility for Errors and Fraud. Herbert McCoy is the president of McCoy Forging Corporation. For the past several years, Donovan & Company, CPAs, has performed the company’s compilation and some other accounting and tax work. McCoy decided to have Donovan & Company conduct an audit. He had recently received a disturbing anonymous letter that stated, “Beware; you have a viper in your nest. The money is literally disappearing before your very eyes! Signed: A friend.” He told no one about the letter.

McCoy Forging engaged Donovan & Company, CPAs, to render an opinion on the financial statements for the year ended June 30. McCoy told Donovan he wanted to verify that the financial statements were “accurate and proper.” He did not mention the anony- mous letter. The usual engagement letter providing for an audit in accordance with gener- ally accepted auditing standards (GAAS) was drafted by Donovan & Company and signed by both parties.

The audit was performed in accordance with GAAS. The audit did not reveal a clever defalcation plan. Harper, the assistant treasurer, was siphoning off substantial amounts of McCoy Forging’s funds. The defalcations occurred both before and after the audit. Harper’s embezzlement was discovered by McCoy’s new internal auditor in October after Donovan had delivered the auditors’ opinion. Although the scheme was fairly sophisticated, it could have been detected if Donovan & Company had performed additional procedures. McCoy Forging demands reimbursement from Donovan for the entire amount of the embezzlement, some $40,000 of which occurred before the audit and $65,000 after. Donovan has denied any liability and refuses to pay.

Required: Discuss Donovan’s responsibility in this situation. Do you think McCoy Forging could prevail in whole or in part in a lawsuit against Donovan under common law? Explain your conclusions.

(AICPA adapted)

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C.65 Auditors’ Liability for Fraud. Auditors may be liable to third parties for fraud in several ways.

Required: a. Identify auditors’ liability for fraud to third parties. b. Distinguish between fraud and constructive fraud. c. What is auditors’ liability for constructive fraud to third parties? d. In your opinion, is auditors’ liability to third parties for fraud and constructive fraud

appropriate (or “fair”)?

C.66 Accusation of Fraud. (This exercise is based on the actual case of Health Management Inc.) During the audit of the Health Management’s 1995 financial statements, $1.8 million of inventory in transit was included on the entity’s balance sheet. The auditors never obtained evidence of the existence of this inventory even though several questions had been raised concerning the excessively large amount of inventory in transit at year-end. In 1996, Health Management announced that it had discovered a series of accounting irregularities.

Required: a. Do legal grounds exist to claim that the auditors committed fraud? b. What would be the auditors’ defense if such grounds exist?

C.67 Common Law Liability Exposure. An accounting firm was engaged to examine the financial statements of Martin Manufacturing Corporation for the year ending December 31. Martin needed cash to continue its operations and agreed to sell its common stock investment in a subsidiary through a private placement. The buyers insisted that the proceeds be placed in escrow because of the possibility of a major contingent tax liability that could result from a pending government claim against Martin’s subsidiary. The payment in escrow was com- pleted in late November. Martin’s president told the audit partner that the proceeds from the sale of the subsidiary’s common stock, held in escrow, should be shown on the balance sheet as an unrestricted current account receivable. The president held the opinion that the government’s claim was groundless and that Martin needed an “uncluttered” balance sheet and a “clean” auditors’ opinion to obtain additional working capital from lenders. The audit partner agreed with the president and issued an unmodified opinion on Martin’s financial statements, which did not refer to the contingent liability and did not properly describe the escrow arrangement.

The government’s claim proved to be valid, and pursuant to the agreement with the buyers, the purchase price of the subsidiary was reduced by $450,000. This adverse development forced Martin into bankruptcy. The accounting firm is being sued for deceit (fraud) by several of Martin’s unpaid creditors who extended credit in reliance on the accounting firm’s unmodified opinion on Martin’s financial statements.

Required: a. What deceit (fraud) do you believe the creditors are claiming? b. Is the lack of privity between the accounting firm and the creditors important in this

case? c. Do you believe the accounting firm is liable to the creditors? Explain.

(AICPA adapted)

C.68 Common Law Liability Exposure. Risk Capital Limited, a Delaware corporation, was considering the purchase of a substantial investment in Florida Sunshine Corporation, a closely held corporation. Initial discussions with the Florida Sunshine Corporation began late in 2020.

Wilson and Wyatt, Florida Sunshine’s auditor, regularly prepared quarterly and annual unaudited financial statements. The most recently prepared financial statements were for the year ended September 30, 2020.

On November 15, 2020, after extensive negotiations, Risk Capital agreed to purchase 100,000 shares of no par, class A capital stock of Florida Sunshine at $12.50 per share. However, Risk Capital insisted on audited statements for 2020. The contract that was made available to Wilson and Wyatt specifically provided that Risk Capital shall have the right to rescind the purchase of said stock if the audited financial statements of Florida Sunshine show a material adverse change in the financial condition of the corporation.

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The audited financial statements furnished to Florida Sunshine by Wilson and Wyatt showed no such material adverse change. Risk Capital relied on the audited statements and purchased the investment in Florida Sunshine. It was subsequently discovered that, as of the date of the financial statements, the audited statements were misstated and that in fact there had been a material adverse change in the corporation’s financial condition. Florida Sunshine is insolvent, and Risk Capital will lose virtually its entire investment.

Risk Capital seeks recovery against Wilson and Wyatt.

Required: Assuming that only ordinary negligence is proved, will Risk Capital prevail

a. Under a privity of contract standard? b. Under a primary beneficiary standard? c. Under a foreseen parties standard?

C.69 Common Law Liability Exposure. Smith, CPA, is the auditor for Juniper Manufactur- ing Corporation, a nonpublic entity that has a June 30 fiscal year. Juniper arranged for a substantial bank loan, which depended on the bank receiving audited financial state- ments showing a debt-to-equity ratio of no more than 2 to 1. The bank’s deadline for receiving these financial statements was September 30. On September 25, just before the auditors’ opinion was to be issued, Smith received an anonymous letter on Juniper’s letterhead indicating that Juniper’s five-year lease of a factory building that was clas- sified in the financial statements as an operating lease was in fact a capital lease. The letter stated that Juniper had a secret written agreement with the lessor modifying the lease and creating a capital lease.

Smith confronted the president of Juniper, who admitted that a secret agreement existed but said it was necessary to treat the lease as an operating lease to meet the debt-to-equity ratio requirement of the pending loan and that nobody would ever discover the secret agree- ment with the lessor. The president said that if Smith did not issue a report by September 30, Juniper would sue Smith for substantial damages that would result from not getting the loan. Under this pressure and because the audit documentation contained a copy of the five-year lease agreement supporting the operating lease treatment, Smith issued the report with an unmodified opinion on September 29. In spite of the fact that it received the loan, Juniper went bankrupt. The bank is suing Smith to recover its losses on the loan, and the lessor is suing Smith to recover uncollected rents.

Required: Answer the following, setting forth reasons for any conclusions stated.

a. Is Smith liable to the bank? b. Is Smith liable to the lessor? c. Was Smith independent?

(AICPA adapted)

C.70 Common Law Liability to Third Parties. Flacco, CPA, conducted the audit of Raven Company and issued an unmodified opinion that concluded that the financial statements presented its financial condition, results of operations, and cash flows according to GAAP. As part of the preaudit conference, Flacco was informed by Raven’s management that its audited financial statements would be presented to Baltimore National Bank to secure financing for a significant expansion opportunity.

Using these financial statements, as well as Flacco’s opinion on those statements, Raven obtained financing from the following parties: (1) Baltimore National Bank, (2) Regional State Bank, and (3) Maryland Equity Partners (a private equity firm). Each of these parties specifically requested audited financial statements and relied on these statements in provid- ing financing to Raven. Six months after obtaining financing, Raven’s financial condition worsened, and it declared bankruptcy, forcing Raven to default on its payments to Baltimore National Bank and Regional State Bank. In addition, Maryland Equity Partners’ investment in Raven became worthless.

After the bankruptcy, the parties that had provided financing to Raven determined that Raven had intentionally misstated its financial statements by recording fictitious revenues and accounts receivable. These parties decided to file suit against Flacco for failure to identify the fictitious revenues and accounts receivable.

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Required: a. Define the following type of third parties: (1) primary beneficiary, (2) foreseen third parties,

and (3) foreseeable third parties. b. Considering the three types of third parties identified in (a), how would you classify (1)

Baltimore National Bank, (2) Regional State Bank, and (3) Maryland Equity Partners? c. Assume that court proceedings concluded that Flacco failed to send confirmations to

Raven’s customers and simply mathematically verified the summary listing of accounts receivable provided to him by Raven. Which of the parties would be likely to prevail in its claim against Flacco?

C.71 Common Law Liability to Third Parties. Madeoff is a small, nonpublic retailer seeking capi- tal for expansion. To obtain necessary capital, Madeoff engaged Allen, CPAs to audit its annual financial statements. In discussing the engagement, Madeoff explicitly informed Allen that the purpose of the audit was to obtain additional financing for expansion into new markets.

Madeoff obtained $3 million from lenders. These lenders included the following:

∙ First Trust and Bank provided $2 million. When engaging Allen, Madeoff indicated that it would use the audited financial statements and Allen’s opinion on these statements to seek financing from First Trust and Bank; also, First Trust and Bank was specifically named in the engagement letter. Prior to committing the capital, First Trust and Bank had reviewed Madeoff’s financial statements and, based on the financial condition reflected in its balance sheet, deemed Madeoff to be a qualified loan candidate.

∙ MoonTrust Bank provided $800,000 of capital to Madeoff. Although not named in the engagement letter or identified to Allen, Madeoff had previous business dealings with MoonTrust and maintained several accounts at MoonTrust. Based primarily on its prior relationships with Madeoff, MoonTrust approved the additional financing to Madeoff prior to receiving the audited financial statements or Allen’s report on those financial statements.

∙ Alice Lay, a local philanthropist, provided $200,000 of capital to Madeoff. Although her decision was primarily motivated by Madeoff’s role in the community and its corpo- rate citizenship, she did request and review Madeoff’s audited financial statements and Allen’s report on those financial statements prior to providing funding. Alice had never entered into a loan agreement of this nature in the past but felt personal ties to Madeoff and was interested in its continued success.

Approximately six months following these loans, Madeoff declared bankruptcy. Following the bankruptcy, lenders discovered that Allen’s audit failed to disclose several material financial statement misstatements that, if corrected, would have presented a less favorable depiction of Madeoff’s financial condition, results of operations, and cash flows. These lenders are exploring potential litigation against Allen to recover the funds they provided to Madeoff.

Required: a. Would these third parties more likely pursue litigation against Madeoff under common

law or statutory law? b. How would each of the lenders likely be classified based on their relationship with Allen

and the potential use of Madeoff’s financial statements and Allen’s report? c. Assume that Allen’s audit did not comply with generally accepted auditing standards

but that it did not demonstrate a lack of minimum care or actual knowledge of the mis- statements. Given the circumstances noted, how would you assess each of these parties’ ability to prevail against Allen in a potential claim?

d. Repeat part (c), assuming that the parties could prove that Allen was aware that Madeoff’s financial statements contained a material misstatement.

C.72 Liability in a Review Engagement. Mason & Dilworth (M&D), CPAs, were auditors for Hotshot Company, a closely held corporation owned by 30 residents of the area. Hotshot had previously engaged M&D to perform some compilation and tax work. Bubba Crass, Hotshot’s president and holder of 15 percent of the stock, said he needed something more than these services. He told Mason, the partner in charge, that he wanted financial statements for internal use, primarily for management purposes but also to obtain short-term loans from

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financial institutions. Mason recommended a “review” of the financial statements and did not prepare an engagement letter.

During the review work, Mason had some reservations about the financial statements. Mason told Dilworth at various times he was “uneasy about certain figures and conclu- sions,” but he would “take Crass’s word about the validity of certain entries since the review was primarily for internal use in any event and was not an audit.”

M&D did not discover a material act of fraud committed by Crass. The fraud would have been detected had Mason not relied so much on the unsupported statements Crass made concerning the validity of the entries about which he had felt so uneasy.

Required: a. What potential liability might M&D have to Hotshot Company and other stockholders? b. What potential liability might M&D have to financial institutions that used the financial

statements in connection with making loans to Hotshot Company? (AICPA adapted)

C.73 Liability under the Securities Acts. Orange is a public entity whose shares are traded on a national exchange. A Public Company Accounting Oversight Board inspection revealed a deficiency in audits conducted by Orange’s auditor, LeGrow. LeGrow had failed to perform important auditing procedures; after performing these procedures in response to the inspection, LeGrow identified several material misstatements and requested that Orange restate its financial statements. These restatements had the effect of reducing Orange’s reported income and cash flow from operations and increasing its liabilities.

Upon the disclosure of these restatements, Orange’s stock price declined more than 40 percent. Angered over this decline, investors are contemplating bringing legal action against LeGrow for failing to detect the misstatements.

Required: a. Assume that investors are bringing suit under the Securities Act of 1933. What would

investors need to demonstrate to bring suit against LeGrow under this act? b. What is LeGrow’s potential liability to investors if LeGrow’s audit was characterized as

demonstrating (1) ordinary negligence, (2) gross negligence, or (3) fraud? c. Repeat parts (a) and (b), assuming that investors are bringing suit under the Securities

Exchange Act of 1934. d. What are the primary differences in LeGrow’s liability to investors under the Securities

Act of 1933 and the Securities Exchange Act of 1934?

C.74 Liability under the Securities Acts. Jones, CPA, audits a number of public companies. During the past year, some deficiencies with respect to audits conducted for two of Jones’s clients in the software industry (SoftWare and ExternalDrive) were identified. These deficiencies related to Jones’s audit procedures used to evaluate the revenue recognized by these clients. Some pertinent facts in each of these audits are summarized as follows:

SoftWare. In 2020, SoftWare issued securities to investors in an initial public offering with an average offering price of $50 per share. Jones audited the financial statements, which were later determined to have overstated revenues through premature revenue recognition. The net effect on SoftWare’s operations was an overstatement of revenue by 25 percent and an overstatement of net income by 63 percent. Following the issuance, the market value of SoftWare’s shares declined to $15 per share.

ExternalDrive. ExternalDrive has been a client of Jones for five years and has been pub- licly traded throughout that entire period. In 2020, ExternalDrive’s Form 10-K revealed rev- enues of $25 million, net income of $8.5 million, and earnings per share of $1.40, all of which exceeded prior-years’ results and analysts’ estimates. ExternalDrive’s financial state- ments were subsequently found to have overstated revenues by $2.25 million, which reduced reported revenues and earnings per share by 11 percent and 24 percent, respectively. Follow- ing the revelation of these misstatements, ExternalDrive’s stock price declined from $18 per share to $9 per share.

You have been asked to defend Jones in legal actions involving shareholders of both companies and have engaged an auditing expert to evaluate Jones’s performance. After reviewing the audit documentation and related professional literature, she concluded

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that Jones’s performance was likely in violation of generally accepted auditing stan- dards; however, it did not rise to the level of being considered “reckless,” and it does not appear that Jones was aware of the departures from GAAP. In addition, although unrelated to Jones’s audit, she observed that the market price of software companies had declined in a similar manner to that of SoftWare and ExternalDrive because of overall economic conditions.

Required: a. Which statute would govern Jones’s liability to shareholders of SoftWare? ExternalDrive? b. What would shareholders of SoftWare and ExternalDrive need to demonstrate prior to

bringing suit against Jones? c. Based on the case facts as described, what possible defense(s) would you recommend to

Jones in each of these situations? d. Assume that these two cases went to trial and Jones’s performance was deemed to be

“reckless” in nature and that Jones possessed scienter. How does this change the likelihood of a favorable outcome for Jones?

C.75 Class-Action Lawsuits. In the United States, it has become common to seek recovery of financial losses from other parties, often even if that other party is not at fault. Frequently, this occurs by means of a class-action lawsuit.

Required: a. What is a class-action lawsuit? b. What advantages does a class-action lawsuit have for the plaintiffs? c. What disadvantages does a class-action lawsuit have for the defendant? d. How has recent legislation affected class-action lawsuits? e. Perform an Internet search for information regarding class-action lawsuits against auditors.

What are the (1) particulars of the lawsuit and (2) auditors’ defenses?

C.76 Liability under Common Law and the Securities Act of 1933. Butler Manufacturing Corporation raised capital for a plant expansion by borrowing from a bank and making a stock offering. Butler engaged Weaver, CPA, to audit its December 2020 financial statements. Butler told Weaver that the financial statements would be given to Union Bank and certain other named banks and included in a registration statement for the stock offering.

In performing the audit, Weaver did not confirm accounts receivable and, therefore, failed to discover a material overstatement. Weaver also was aware of a pending class-action product liability lawsuit that was not disclosed in Butler’s financial statements. Despite being advised by Butler’s legal counsel that the entity’s potential liability under the lawsuit would result in material losses, Weaver issued an unmodified opinion on Butler’s financial statements.

In May 2021, Union Bank relied on the financial statements and Weaver’s opinion to grant Butler a $500,000 loan.

Butler raised additional funds in November 2021 with a $14,000,000 unregistered offering of preferred stock. This offering was sold directly by the entity to 40 nonaccredited private investors during a one-year period.

Shortly after obtaining the Union Bank loan, Butler experienced financial problems but was able to stay in business because of the money raised by the stock offering. Butler lost the product liability suit, resulting in a judgment that the entity could not pay. Butler also defaulted on the Union Bank loan and was involuntarily petitioned into bankruptcy. This caused Union Bank to sustain a loss, and Butler’s stockholders’ investments became worthless.

Union Bank sued Weaver for failure to provide the appropriate level of professional care and for common law fraud. The stockholders who purchased Butler’s stock through the offering sued Weaver, alleging fraud under section 17 of the Securities Act of 1933.

These transactions took place in a jurisdiction providing for auditors’ liability for ordinary negligence to known and intended users of financial statements.

Required: Answer the following questions and give the reasons for your conclusions.

a. Will Union Bank be successful in its suit against Weaver under common law for (1) ordinary negligence and (2) fraud?

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b. Will the stockholders who purchased Butler’s stock through the offering succeed against Weaver under the antifraud provisions of section 17 of the Securities Act of 1933?

(AICPA adapted)

C.77 Liability under the Securities Acts. One of your firm’s clients, Fancy Fashions Inc., is a highly successful, rapidly expanding entity. It is owned predominantly by the Munster family and key corporate officials. Although additional funds would be available on a short-term basis from its bankers, they would represent only a temporary solution of the entity’s need for capital to finance its expansion plans. In addition, the interest rates being charged are not appealing. Therefore, Chris Munster, Fancy’s chairman of the board, in consultation with the other shareholders, has decided to explore the possibility of raising additional equity capital of approximately $15 million to $16 million. This will be Fancy’s first public offering.

At a meeting of Fancy’s major shareholders, its attorneys and a member of your firm spoke about the advantages and disadvantages of “going public” and registering a stock offering. One of the shareholders suggested that Regulation D under the Securities Act of 1933 might be a preferable alternative.

Required: a. Assume that Fancy makes a public offering for $16 million and, as a result, more than

1,000 persons own shares of the entity. Following the public offering, what are the impli- cations with respect to the Securities Exchange Act of 1934? (Hint: You can identify the thresholds for being subject to the reporting requirements of the Securities Exchange Act of 1934 through reference to the SEC’s website, www.sec.gov.)

b. What federal civil and criminal liabilities under the Securities Act of 1933 could apply in the event that Fancy sells the securities without registration and a registration exemption is not available?

c. Using the SEC’s website (www.sec.gov) as a reference, define “accredited investor” and dis- cuss the exemption applicable to offerings made under Regulation D for accredited investors.

(AICPA adapted)

C.78 Section 11 of Securities Act of 1933: Liability Exposure. Chriswell Corporation decided to raise additional long-term capital by issuing $20 million of 12 percent subordinated debentures to the public. May, Clark & Company, CPAs, the company’s auditors, were engaged to examine the June 30, 2021, financial statements, which were included in the bond registration statement.

May, Clark & Company completed its examination and submitted an unmodified audi- tors’ report dated July 15, 2021. The registration statement was filed and became effective on September 1, 2021. On August 15, one of the partners of May, Clark & Company called on Chriswell Corporation and had lunch with the financial vice president and the control- ler. He questioned both officials on the company’s operations since June 30 and inquired whether there had been any material changes in the company’s financial position since that date. Both officers assured him that everything had proceeded normally and that the finan- cial condition of the company had not changed materially.

Unfortunately, the officers’ representation was not true. On July 30, a substantial debtor of the company failed to pay the $400,000 due on its account receivable and indicated to Chriswell that it would probably be forced into bankruptcy. This receivable was shown as a collateralized loan on the June 30 financial statements. It was secured by stock of the debtor corporation, which had a value in excess of the loan at the time the financial statements were prepared but was virtually worthless at the effective date of the registration statement. This $400,000 account receivable was material to the financial condition of Chriswell Corpora- tion, and the market price of the subordinated debentures decreased by nearly 50 percent after the foregoing facts were disclosed.

The debenture holders of Chriswell are seeking recovery of their loss against all parties connected with the debenture registration.

Required: Are May, Clark & Company liable to the Chriswell debenture holders under section 11 of the Securities Act of 1933? Explain. (Hint: Review the BarChris case in this chapter.)

(AICPA adapted)

LO C-4, C-5

LO C-4

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C.79 Rule 10(b)-5 Liability under the Securities Exchange Act of 1934. Gordon & Groton (G&G), CPAs, were auditors of Bank & Company, a brokerage firm and member of a national stock exchange. G&G examined and reported on the financial statements of Bank, which were filed with the Securities and Exchange Commission.

Several of Bank’s customers were swindled by a fraudulent scheme perpetrated by Bank’s president, who owned 90 percent of the voting stock of the company. The facts establish that G&G failed to perform the audit with the appropriate level of professional care but neither participated in the fraudulent scheme nor knew of its existence.

The customers are suing G&G under the antifraud provisions of section 10(b) and Rule 10b-5 of the Securities Exchange Act of 1934 for aiding and abetting the president’s fraudulent scheme. The customers’ suit for fraud is predicated exclusively on G&G’s failure to conduct a proper audit, thereby failing to discover the fraudulent scheme.

Required: Answer the following, setting forth reasons for any conclusions stated.

a. What is the probable outcome of the lawsuit? b. What might be the result if plaintiffs had sued under common law for ordinary negli-

gence? Explain. (AICPA adapted)

C.80 Independence and Securities Exchange Act of 1934. Anderson, Olds, and Water- shed (AOW) have been the independent auditors for Accord Corporation since 1990. Accord is a public entity obligated to file periodic reports under the Securities Exchange Act of 1934.

Beginning in January 2020, the AOW litigation support consulting division performed a special engagement for Accord. The work involved a lawsuit that Accord had filed against Civic Company for patent infringement on microchip manufacturing processes. AOW personnel compiled production statistics—costs and lost profits—under various volume assumptions and then testified in court about the losses to Accord that had resulted from Civic’s improper use of patented processes. The amounts at issue were very large, with claims of $50 million for lost profits and a plea for $150 million punitive damages. Accord won a court judgment for a total of $120 million, and Civic has appealed the damage award. The case remained pending throughout 2020 and into 2021. By March 1, 2021, AOW had billed Accord $265,000 for the litigation support work.

In November 2020, AOW started the audit work on Accord’s financial statements for the fiscal year ending December 31, 2020. During this work, AOW auditors found that Accord’s management and board of directors did not fully disclose the stage of the appeal of the Civic Company case, had improperly deferred a material loss on new product start- up costs as an element of its inventory, and had accrued sales revenue for promotional chip sales that carried an unconditional right of return. As partner in charge of the engagement, D. Ward agreed with the president that the accounting and disclosure were suitable to pro- tect Accord’s shareholders from adverse business developments, and he issued a standard unmodified opinion that was included in the entity’s 10-K annual report filed with the SEC and dated April 1, 2021.

On April 2, 2021, AOW then billed Accord for the $200,000 audit fee and sent a reminder for payment of the $265,000 consulting fee.

Required: a. Was AOW independent for the audit of Accord for the fiscal year ended December 31,

2017? Explain. b. Did Ward and AOW follow generally accepted auditing standards in the audit? Cite any

specific standards that might have been violated, and explain your reasoning. c. Did Ward and AOW violate any section(s) of the Securities Exchange Act of 1934?

Explain.

C.81 Auditors’ Liability under Securities Exchange Act of 1934. Adam, an Illinois resident, was interested in purchasing stock in Joshua Foods Inc. Joshua Foods has corporate head- quarters in Fond du Lac, Wisconsin, and is incorporated in Delaware. Adam accessed Joshua Foods’ 2020 annual report including the financial statements on its corporate website. Adam also reviewed several analysts’ opinions on the Internet, including the opinions provided from his Internet broker, Matthew & Co. ExpressTrade. Adam received the annual report

LO C-5

LO C-5

LO C-5

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in the mail. Based on the increasing revenues, the $8 million net income indicated on the financial statements, and the other information received from the analysts, Adam purchased $350,000 worth of stock.

Three months later, Joshua Foods announced that over the past three years, the company had included $25 million of fictitious revenue and had capitalized more than $30 million of charges that should have been expensed. These irregularities will result in a restatement of the fiscal 2020 financial statements, resulting in a $1,250,000 loss for fiscal 2020. The press release from the company says that it will likely declare bankruptcy in the next few weeks. In the following two weeks, the value of Adam’s holdings in the stock declined to $50,000.

Required: a. You are Adam’s attorney. List the various legal issues and precedents that you will use in

trying to recover the losses Adam sustained. b. You are the attorney for Joshua Foods’ auditors. It is apparent that Adam will try to recover

losses from your firm. List the defenses you would prepare to protect the auditors from liability.

c. How does Sarbanes–Oxley affect the position of either Adam’s attorney or the auditors’ attorney? You may find www.soxlaw.com helpful.

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LEARNING OBJECTIVES This module explores internal audits, governmental audits, and fraud examination. These fields differ in important respects from financial statement auditing practiced by independent accountants in public accounting. However, you will find that all fields of

auditing share many elements. Fraud examination can be very exciting. It has the aura of detective work—finding things people want to keep hidden. The explanations and examples in this module will help you understand the working environment, objectives, and procedures that characterize internal, governmental, and fraud examination.

You have a chance to really learn and improve the business. You

build relationships with the board and the major business leaders.

You can move internal audit to more value-added processes. And it

builds your ability to manage people and work with cross-functional

teams.

Internal Audits, Governmental Audits, and Fraud Examinations

M O D U L E D

Michael Fung, former CFO, Walmart North American stores division, on his four years spent in internal audit1

Topic AU-C/ISA Section AS Section

Consideration of Fraud in a Financial Statement Audit 240 2401

Consideration of Laws and Regulations 250 2405

Consideration of the Internal Audit Function in a Financial Statement Audit 610 2415

Compliance Auditing Considerations in Audits of Governmental Entities and Recipients of Governmental Financial Assistance

801 6110

    ET/AT Standard†

Compliance Attestation   AT-C 315

Independence, Integrity, and Objectivity   ET 101 - 191

    IIA Standards

International Standards for the Professional Practice of Internal Auditing   IIA 1000 - 6000 (all)

Professional Standards References

†ET indicates ethics standard.

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INTRODUCTION* On March 22, 2018, officials of the city of Atlanta announced that the city had been a vic- tim of cyberattack. The unleashing of the SamSam ransomware virus on the city’s computer system shut down many of the city’s services for several days, with some impacts stretching several weeks. A month after the attack, water and sewer bills still could not be paid online or over the phone, and business licences could only be obtained in person. Public Wi-Fi at Atlanta’s Hartsfield-Jackson International airport, the busiest airport in the nation, was not available for two weeks. Scheduling for traffic ticket hearings was shut down for almost a month and a significant amount of correspondence related to city council work was lost.

The worst part—the debacle may very well have been avoided had the city acted on the warning of the internal auditor. Months before the attack, the city auditor provided a 41-page audit report indicating that the IT system was susceptible to attacks and that there were no formal processes to manage risk. Specifically, the report stated that “the large number of severe and critical vulnerabilities identified has existed for so long the organi- zations responsible have essentially become complacent.” The report goes on to note that, “departments tasked with dealing with the vulnerabilities . . . do not have enough time or tools to properly analyze or treat the systems. This situation represents a significant level of preventable risk exposure to the city.” Had the city responded in a timely manner to the concerns of the internal auditors, Atlanta may have saved itself from the embarrassment and headaches caused by the attack, along with the $2.7 million spent in contracts with IT consultants and crisis management services to help the city recover.

INTERNAL AUDITS, GOVERNMENTAL AUDITS, AND FRAUD EXAMINATIONS

In today’s environment of increased public scrutiny, organizations are asking public accounting firms for more assistance. Public accounting firms are not able to provide internal audit services to their publicly traded audit clients. However, organizations that need assistance with internal audit, investigation, and other related services can turn to public accounting firms that do not serve as their financial statements auditor. One of the main segments in most large public accounting firms is outsourced and cosourced internal audit services, and this opportunity has led to several business ventures focused primarily on providing internal audit and other nonaudit services to clients (e.g., Protiviti Inc.).

Your objectives are to be able to:

LO D-1 Define internal auditing, describe internal audit institutions (e.g., the IIA), describe how internal auditors interact with independent auditors, explain internal auditors’ indepen- dence problems, and list features of internal audit reports.

LO D-2 Define governmental auditing, describe governmental audit institutions (e.g., the GAO), describe the three types of governmental audits, discuss the standards

and regulations that govern audits, list features of governmental audit reports, and understand the purpose of the Single Audit Act of 1984 and Amendments of 1996.

LO D-3 Define fraud examination and the differences in how external auditors and fraud examiners approach their work. Describe the main objectives of a fraud investigation, how a fraud case is built, and how fraud evidence is handled. Describe the ways CPAs can assist in prosecuting fraud perpetrators.

*The material in this introduction is based on the following articles, with the quoted material coming from the CBS article: Benja- min Freed, “Atlanta was not prepared to respond to a ransomware attack,” Statescoop, April 24, 2018, https://statescoop.com/ atlanta-was-not-prepared-to-respond-to-a-ransomware-attack/;“Atlanta was warned about vulnerabilities months before cyber- attack, report shows,” CBSNews, https://www.cbsnews.com/news/atlanta-warned-cyber-vulnerabilities-audit-shows/

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Many of the tasks and processes that internal auditors and governmental auditors per- form are similar to those that financial statement auditors perform. However, services performed by governmental and internal auditors do vary considerably. When internal and governmental auditors perform audits of financial information, the scope of the engagement typically is wider than the scope performed by an external auditor. Internal auditors and governmental auditors often have objectives that go beyond the fair presen- tation of the financial statements, such as the efficiency of the financial reporting process. Furthermore, government and internal auditors often perform audits of monthly financial statements or other internal financial reports to ensure that information for management decisions is reliable. In this module, we explore the services provided by internal auditors and governmental auditors and gain an understanding of the elements that help to define what is meant by a quality audit.

Also in this module, we explore services auditors can provide related to fraud and fraud investigations. External auditors, internal auditors, and governmental auditors all have some responsibilities related to the identification of suspected fraud. As discussed in Chapter 4, external auditors are required to assess the risk of material misstatement due to fraud and to design further procedures based off of that assessment. Internal auditors are often the ones to discover fraud within organizations. When fraud is suspected or discovered, a fraud examination, with the help of a certified fraud examiner will typically commence. Fraud examinations and other services CPAs can provide with relation to fraud investigations are discussed at the end of the module.

INTERNAL AUDITS Internal Auditing Defined In the past, internal auditors have been defined as auditors working for the organization they were auditing. Internal auditors were employed by an organization such as a bank, hospital, city government, or industrial company. However, in recent years, many profes- sional services firms are providing internal audit services to the business community. Therefore, internal auditors may now be employed by either the organization they are auditing or an independent professional services firm.2 Many corporations believe that they gain expertise and improve control over audit costs when the internal audit function is outsourced to an external audit firm. Conversely, other companies believe that an in- house internal audit function is better aligned with the company’s goals and objectives and auditors gain more experience and expertise with the company’s organization and business. Currently, we are seeing more firms implementing a co-sourcing strategy in

LO D-1 Define internal auditing, describe internal audit institutions (e.g., the IIA), describe how internal auditors interact with independent auditors, explain internal auditors’ independence problems, and list features of internal audit reports.

2Professional services firms include public accounting firms that offer a variety of auditing, accounting, and consulting services and some consulting firms that do not perform financial statement audit services but do provide other services including internal audit services (e.g., Protiviti).

The following is an excerpt from the Protiviti website: Protiviti is a global consulting firm that delivers deep expertise,

objective insights, a tailored approach and unparalleled collaboration to help leaders confidently face the future. Our consulting solutions span critical business problems in technology, business process, ana- lytics, risk, compliance, transactions and internal audit. We are commit- ted to attracting and developing a diverse workforce of professionals

that share the common value of collaboration. As an organization, we believe that by teaming together, with each other, and our clients, we can see beyond the surface of changes and problems organizations face in this fast changing world to discover opportunities others might miss and face the future with greater confidence.

Source: https://www.protiviti.com/US-en/about-us

Taking Care of BusinessAUDITING INSIGHT

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which the company retains an in-house internal audit department augmented by audi- tors from an outside firm. This strategy allows the company to have a core audit group dedicated to the company with specialized “institutional knowledge” in company policy, procedure, and strategy, yet the company can obtain expertise and audit knowledge from the professional services firm for specific engagements or projects.

The Institute of Internal Auditors (IIA), the organization that sets standards and governs the internal audit profession, defines internal auditing and states its objective as follows:

Internal auditing is an independent, objective, assurance and consulting activity designed to add value and improve an organization’s operations. It helps an organization accomplish its objectives by bringing a systematic, disciplined approach to evaluate and improve effec- tiveness of risk management, control, and governance processes.

Several key elements in this definition warrant further evaluation.

Independence You may be wondering how in-house internal auditors employed by the company being audited can classify themselves as independent and objective. Although internal auditors employed by the entity under audit cannot be disassociated from their employers in the eyes of the public, they seek organizational and individual independence. Internal auditors achieve independence during the audit process when they are free from direction or con- straint by the managers of the business unit under audit. To establish this organizational independence, many internal audit organizations report directly to the audit committees of the board of directors. Such a reporting relationship reduces management’s influence over the audit scope and reporting. The other key aspect of independence and objectivity con- cerns the attitude of the individuals engaged in the audit. An internal auditor must have an impartial, unbiased attitude in performing the audit. In addition, individual auditors must not have any conflicts of interests. Such conflicts may result when the same company employs family members or outside business interests appear to affect audit judgments.

An element that greatly assists the internal audit department in establishing an indepen- dent and objective organization is the audit charter. Many departments and organizations have charters, and it is particularly important for the internal audit department to have one. An internal audit charter approved by senior management and the board of directors provides

∙ A commitment from management to the establishment of an independent and objec- tive audit organization.

∙ A definition of the authority and responsibility of the audit department. ∙ A definition of the scope of the audit department’s activities. ∙ The department’s authorization to perform audits, request materials, and gather evidence. ∙ The performance and reporting requirements for the audit department.

These elements provide an essential foundation for building an independent department.

An internal audit charter is used to define the purpose, responsibility, and authority for the internal audit function in all types of organiza- tions, including universities. Georgetown University’s internal audit  charter outlines several important elements of their internal audit function, including its mission, responsibilities, objective, and  the independence and objectivity of the internal audit department. According to the charter, the mission of the internal audit func- tion at Georgetown is to “review accounting, financial and other operations  to determine for the President and Board of directors

that: (1) assets are safeguarded and their use properly accounted for. (2) Accurate financial and managerial controls exist and function properly. (3) Recommendations are made for improvement in con- trols. (4) Management plans, policies and procedures are carried out and executed efficiently and effectively.” One might interpret the mission of the internal audit function as a way to hold the University accountable. Source: Georgetown University Internal Audit Department Charter, https://internalaudit.georgetown.edu/charter.

Accountability at the University LevelAUDITING INSIGHT

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Add Value and Improve Operations The objectives of an internal audit and an external audit are vastly different. Generally speaking, internal auditors perform little of their work on the financial statements. In-house internal auditors audit their companies all year, often months removed from both the previ- ous or the subsequent issue of annual financial statements. Internal auditors are primarily concerned with affecting the company’s bottom line; hence, the definition of internal audit- ing includes the phrase to add value and improve an organization’s operations. Internal auditors add value to a company primarily by achieving the following four audit objectives:

1. Recognizing and analyzing industry, business, and operational risks. Internal auditors use their industry knowledge to recognize and evaluate how changes in the economy, business environment, technology, regulatory environment, and management impact risks. Internal audit will often take a proactive approach to reduce or eliminate the risks identified, therefore adding value to the company.

2. Improving the economy and efficiency of the operations. Over a period of a few years, an internal auditor will have evaluated almost every department and almost every aspect of a company’s business. This experience makes the auditor a valuable asset to the organization, as the internal auditor may be able to provide insight into which processes work best to improve the economy and efficiency of operations and how they could be implemented in other areas of the company.

3. Ensuring compliance with management directives. In fulfilling this objective, internal auditors are concerned with identifying any noncompliance with management direc- tives that (1) increases the risk faced by the company or (2) diminishes the efficiency or effectiveness of the company’s operations which might ultimately harm the com- pany’s likelihood of meeting its goals and objectives.

4. Serving as management’s representative. The complexities of managing a large orga- nization often prohibit senior management from visiting locations and departments critical to the success of the organization. Therefore, the reports from the internal audit department may serve as the only critical objective evaluations received by man- agement for certain key areas of the organization.

It should be evident that the four audit objectives discussed here are not mutually exclu- sive. For example, the evaluation of compliance with company policies and procedures includes elements of reducing risk, evaluating economy and efficiency, and being man- agement’s representative.

Types of Internal Audit Services As stated in the definition of internal auditing, the internal audit function “helps an organization accomplish its objectives.” To achieve this goal, internal auditors provide  a  variety of internal audit services including (1) financial audits of financial reports and accounting control systems; (2) compliance audits that ensure conformity with company policies, plans, and procedures and with laws and regulations; (3) opera- tional audits that evaluate the economy and efficiency of business process; (4) gover- nance audits to aid management decision making; and (5) other types of audits specific to the organization.

Financial Audits Internal auditors usually do not audit quarterly or year-end financial statements in the same manner as external auditors. However, internal auditors may evaluate areas that management believes could be of concern to the external auditors, such as areas that were found to have problems in the prior audit. Such a preliminary evaluation may allow for correction of errors prior to the arrival of the external auditors.

Internal auditors perform audits of financial reports for internal use. This type of audit provides managers assurance that the information they are using in the decision-making process is relevant and reliable. Such an assurance function reduces management’s risk

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in making daily operating decisions or in determining appropriate action to address a unique problem. This type of auditing is similar to the auditing described elsewhere in this textbook.

Compliance Audits In many functional areas, management’s primary concern is compliance with policies, procedures, laws, and regulations—thus, the definition of compliance audits. The degree of management’s concern for such audits may vary by industry or by functional area. For example, compliance with laws will be of more concern in the banking, insurance, and health care industries as compared with a company in the retail industry. Also, in an audit of the human resources department, the main audit objective may be compliance with policies and procedures designed to ensure conformity with laws regarding fair hiring and proper dismissals of employees.

Operational Audits Operational auditing refers to auditors’ study of business operations for the purpose of mak- ing recommendations about economic and efficient use of resources, effective achievement of business objectives, and compliance with company policies. The goal of operational auditing is to help managers perform their management responsibilities and improve prof- itability. Internal auditors consider operational auditing as an integral part of internal audit- ing. The AICPA defines operational auditing performed by independent public accounting firms as a distinct type of consulting service having the goal of helping a client improve the use of its capabilities and resources to achieve its objectives. Therefore public account- ing firms could perform operational audits as a consulting service for nonattest clients.

Jim Burton, new to internal audit at Smith Construction Inc. (SCI), was performing what was supposed to be the most routine part of internal auditing. He and his supervisor, in accordance with company policy, were evaluating critical general ledger accounts following the departure of a high-level employee, in this case, the company’s chief financial officer (CFO) Paul Fournier. Jim was assigned to look over the company’s liability accounts.

What Jim discovered, however, was not so routine. He noticed a $30,000 payable made each month to a Boston law firm. After digging, Jim and his supervisor discovered that SCI had not had dealings with the

law firm for several years, and that the checks were in fact not being sent to the firm at all. Fournier had accessed the vendor master file and had changed the mailing address to one in Canada. With no formal review of vendor changes, the switch was simple. He then forged invoices to the law firm and submitted them for payment. The checks were mailed to his Canadian address, where he cashed the checks on his own behalf. In total, the former CFO stole $1.1 million from SCI. He was eventually convicted of fraud and sentenced to 18 months in a U.S. federal prison.

Source: “The CFO Check Scam,” Internal Auditor, June 2018.

A Not So Routine Financial AuditAUDITING INSIGHT

Internal auditors at Kinross Gold, a Canadian based gold mining com- pany, tried to warn management. In April of 2018, Kinross was hit with charges from the Securities and Exchange Commission (SEC) for not complying with the Foreign Corrupt Practices Act (FCPA)’s books and records and internal control provision. The violations occurred within two African subsidiaries, of which Kinross had purchased in 2010. In 2011, the Kinross internal audit department examined the two sub- sidiaries and found that “the internal accounting controls surrounding

vendor selection and disbursement for goods and services  .  .  . were not adequate to meaningfully assess transactions for accuracy or com- pliance with the FCPA.” Despite these warnings, the violations went unfixed for three years which then triggered an SEC investigation. Kinross settled the case by agreeing to pay close to a $1 million fine.

Source: Joseph McCafferty, “Ignored Internal Audit Reports Lead to FCPA Vio- lation at Gold Miner,” Internal Audit 360°, April 5, 2018, https://internalaudit360. com/ignored-internal-audit-reports-lead-to-fcpa-violation-at-gold-miner/.

Internal Audit Told Them SoAUDITING INSIGHT

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Governance Audits The definition of internal auditing includes evaluating the governance process. Internal auditors do this through the performance of governance audits. Governance audits are designed to help provide management with high-quality information for making gover- nance decision. They ensure that senior management receives accurate and timely infor- mation concerning management and leadership throughout the organization as well as the proper implementation and execution of company strategy and plans. This function of internal audit is continuing to grow in both scope and importance. When evaluating the governance process, the auditor could report on a wide variety of critical information. It is essential that management understands the risks that the business and industry are fac- ing. It is also imperative that management receives objective, timely feedback concerning corporate strategies and initiatives in order to effectively guide the corporation and fulfill their fiduciary responsibilities.

Other Audits Internal auditors may perform audits that are specific to the nature of the business they serve.

Quality Control Audits Auditors who work with manufacturing companies may pro- vide quality control audits designed specifically to determine whether the product meets the standards established by management. Customer service departments also may be subject to a quality audit to ensure that customers are being served in the manner pre- scribed by the company. The auditors are not a substitute for the quality control depart- ment, but they can review the work of quality control, quality control reports, and the responses of management to issues raised by quality control.

Environmental Audit Another type of audit performed in some organizations is an environmental audit.3 Many organizations deal with materials that must be handled in manners prescribed by law (e.g., what does Walmart do with those old batteries, tires, and oil?). Auditors can review procedures, record keeping, liability issues, and compliance as they relate to the organization’s environmental issues. In addition, auditors can make rec- ommendations for reducing waste (e.g., reusable shipping containers) and making prod- ucts that are more environmentally friendly (e.g., recyclable packaging materials).

Sustainability Audits In Module A, we have discussed sustainability as an assurance service. That is, management may report on sustainability issues such as carbon emissions and instruct the auditors to attest to the validity of the numbers in the report provided. However, as sustainability accounting and reporting gain more acceptance, especially in the United States, internal auditors are being asked to provide sustainability service beyond an assurance of numbers. Many organizations need audit assistance in establish- ing a sustainability program, measurement criteria, reporting standards, and other issues that require the internal auditor’s knowledge of the company and sustainability issues.

The IIA includes sustainability under a broad context of corporate social responsibility (CSR). In this context, auditors assist management in areas of

∙ Governance. ∙ Ethics. ∙ Environment issues. ∙ Health, safety, and security. ∙ Human rights and work conditions.

Clearly, we have seen the impact on corporate image and reputation as well as the questioning of the social morality of corporations whose products have been reported as having been manufactured in facilities with substandard conditions. According to the IIA

3Many organizations are engaged in sustainability accounting that includes an environmental component. However, due to the highly technical nature of environmental laws and policy, most organizations that have significant exposure have an environmen- tal audit function.

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Internal auditors should understand the risks and controls related to CSR objectives. Where appropriate, the CAE [chief audit executive] should plan to audit, facilitate control self-assessments, verify results, and/or consult on the various subjects. Internal auditors should maintain the skills and knowledge necessary to understand and evaluate the gover- nance, risks, and controls of CSR strategies.4

Because of the newness of sustainability, many companies have found that this area is best served through outsourced internal audit services. At this time, most large CPA firms have more expertise than some of their clients (especially when they can rely on knowledge transferred from European offices that have been working on sustainability issues for a long period of time). Over time, it is expected that an in-house internal audit department will gain sufficient expertise to service more of the sustainability issues within the company.

4Institute of Internal Auditors, Practice Guide, Evaluating Corporate Social Responsibility/Sustainable Development, p. 1; www.theiia.org/bookstore/product/evaluating-corporate-social-responsibilitysustainable-development-practice-guide-download- pdf-1483.cfm.

Internal Audit Standards The IIA is the international organization that governs the standards, continuing educa- tion, and general rules of conduct for internal auditors as a profession. The IIA issues International Standards for the Professional Practice of Internal Auditing (IIA Stan- dards). (See the IIA website at www.theiia.org.) The IIA standards are classified in three major categories:

1. Attribute standards. 2. Performance standards. 3. Implementation standards.

Aptly named, the attribute standards address the characteristics of internal auditors (e.g., independence, objectivity) and organizations performing internal audit activities. Performance standards relate to conducting internal audit activities and provide a mea- sure of quality against which the performance of internal audit activities can be mea- sured. The attribute and the performance standards apply to internal audit services in general. Implementation standards, on the other hand, are specific applications of the attribute and performance standards to specific types of engagements (e.g., assurance or consulting engagements).

Internal auditors are expected to comply with the IIA’s standards of professional con- duct. IIA audit standards are recommended and encouraged, but compliance with them

Companies wanting to report on sustainability initiatives have three options for standards of reporting: they can report following no stan- dards at all, following the Global Reporting Initiative Standards, or following the Sustainability Accounting Standards Board (SASB) stan- dards. The SASB announced in November 2018 the publication of the “world’s first set of industry-specific sustainability standards covering financially material issues.” Covering 77 industries, the standards had been in the making for six years.

In 2015, Appalachian Mountain Brewery (AMB), a local brewery in Boone, North Carolina, heard about the SASB standards. Later that year, with the help of the local university, AMB became one of the first

companies to issue a sustainability report using the SASB standards. Today, SASB reporting standards are used by well-known established companies such as Kellogg’s, GM, Etsy, and JetBlue.

Sources: Ken Tysiac, “SASB publishes industry specific sustainability account- ing standards,” Journal of Accountancy, November 7, 2018, https://www. journalofaccountancy.com/news/2018/nov/sasb-sustainability-accounting- standard-201820089.html; “AMB sustainability report is not only one of the first of its kind, but also features faculty-student collaboration from the Walker College,” https://business.appstate.edu/news/amb-sustainability-report- not-only-one-first-its-kind-also-features-faculty-student; SASB website, https:// www.sasb.org/company-use/

Bottoms Up! Local Brewery One of the First to Issue Sustainability Report Using SASB Standards

AUDITING INSIGHT

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depends on their acceptance, adoption, and implementation by practicing internal audi- tors. Many internal audit organizations include compliance with IIA standards in their department charters and in their audit reports.

The IIA also issues practice advisories. Because of the diversity of entities serviced by internal auditors, guidance from practice advisories is not mandatory. They suggest “best practices” in internal audit, and internal audit organizations are encouraged to implement those practices that are applicable to the business and industry they serve.

The IIA also administers the certified internal auditor (CIA) program. This certifica- tion is a mark of professional achievement that has gained international acceptance. To become a CIA, a candidate must hold a college degree and pass an examination on inter- nal auditing and related subjects. The exam has three parts:

∙ Part 1—Internal audit basics. ∙ Part 2—Internal audit practice. ∙ Part 3—Internal audit knowledge elements.

Candidates also must have two years of audit experience (internal audit or public accounting audit) obtained before or after passing the examination. Holders of master’s degrees need only one year of experience. You can sit for the CIA exam prior to completion of your bachelor’s degree. For more details, consult the IIA’s website (www.theiia.org).

Internal Audit Reports Internal audit reports are not as standardized as external auditors’ reports on financial statements. Each report is different because internal auditors need to communicate find- ings on a variety of assignments and audit objectives. The key criterion for an internal audit report is clear and concise communication of findings and recommendations.

The reporting stage is the internal auditors’ opportunity to capture management’s undivided attention. To be effective, a report cannot be unduly long, tedious, technical, or laden with minutiae. It must be accurate, concise, clear, and timely. It must speak directly to the risks the auditors evaluated. Most quality audit reports ensure that signifi- cant issues are described by five elements:

1. The condition the auditor identified. 2. The criteria that renders the condition inappropriate. 3. The cause of the condition. 4. The effect the condition may have on the company. 5. The recommendation that may eliminate or mitigate the condition.

Generally, internal auditors meet with the business unit’s management team to review the audit report before it is distributed to senior management. This meeting is called the exit conference. Its purpose is to inform the business unit’s management of the audit results, reach an agreement on the correctness of the findings, and learn of the correc- tive action management plans. If there are disagreements between the internal auditors and the business unit’s management, auditors may include management’s reasons for dis- agreement in the audit report, in the interest of fair and complete disclosure.

Internal audit reports are sent to the highest level of management in the organization, often including the CEO and the audit committee. Usually the senior manager overseeing a business unit (e.g., the vice president of materials management for distribution centers and purchasing) would receive audit reports and respond to senior management and the audit committee regarding which recommendations will be implemented. The manager also must explain why certain recommendations will not be implemented.

Once senior management agrees with acceptance or rejection of audit recommenda- tions, the business unit is obligated to implement the accepted recommendations. The IIA standards include a requirement for a follow-up to ascertain that appropriate action is being taken on accepted recommendations. Only after the follow-up is completed is the audit considered closed.

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GOVERNMENTAL AUDITS Governmental Auditing Defined Government officials and recipients of federal monies are responsible for carrying out public functions efficiently, economically, effectively, and ethically while achieving desired public objectives.5 Governmental auditing refers to a variety of services per- formed in an effort to hold the government accountable and transparent to the public regarding the linking of resources to related program results.

Many federal agencies (e.g., Army, Navy, Department of Transportation) have govern- mental auditors who are charged with ensuring compliance with agency and department policies and procedures. The accounting, auditing, and investigative agency of the federal government is the Government Accountability Office (GAO). It audits the departments, agencies, and programs of the federal government (even if they are subject to audits by their own internal audit staffs) to determine whether the laws passed by the U.S. Congress are followed and to determine whether programs are being implemented with economy and efficiency and are achieving desired results. The U.S. Congress always receives cop- ies of GAO reports.

LO D-2 Define governmental auditing, describe governmental audit institutions (e.g., the GAO), describe the three types of governmental audits, discuss the standards and regulations that govern audits, list features of governmental audit reports, and understand the purpose of the Single Audit Act of 1984 and Amendments of 1996.

5Government Auditing Standards 2018 Revision, July 2018, p. 3.

REVIEW CHECKPOINTS D.1 How does internal auditing help a company accomplish its objectives? D.2 How can internal auditors achieve practical independence? D.3 What four audit objectives do auditors try to achieve to add value to a company? D.4 What auditing services do internal auditors provide? D.5 What are the standards that govern internal auditing? D.6 What special professional certification is available for internal auditors? D.7 Who is responsible for enforcing compliance with laws and regulations in the business?

• “Concerned that the IRS whistleblower program does not process awards in a timely fashion, Senate Finance Committee Leaders are asking the Government Accountability Office to look into the IRS pro- cesses and resources devoted to administrator the program.”

• A spokesman for Oregon Sen. Ron Wyden says the senator will ask the GAO to investigate a monitoring and maintenance program for under- ground waste tanks at the nation’s most contaminated nuclear site. The request follows news Friday that six tanks at the Hanford Nuclear Reservation are leaking.

• The Senate has passed a bill that would direct the GAO to examine the economic benefits large banks receive for being “too big to fail.”

• Several senators have requested that the GAO look for ways to coordi- nate the efforts of law enforcement and public health agencies at various levels and nonprofit organizations to address prescription drug abuse.

• Senate Homeland Security and Governmental Affairs Ranking Member Tom Coburn, M.D. (R-OK), Chairman Tom Carper (D-DE), Financial and

Contracting Oversight Subcommittee Chairwoman Claire McCaskill (D-MO), Senator Susan Collins (R-ME), and House Committee on Over- sight and Government Reform Chairman Darrell Issa highlighted a report from the GAO entitled Federal Employees’ Compensation Act: Case Examples Illustrate Vulnerabilities That Could Result in Improper Payments of Overlapping Benefits. The report examines improper and overlapping payments in the Federal Employees Compensation Act (FECA) and unemployment insurance programs. In its report, the GAO outlined steps to lower the risk of improper payments, including actions by the Department of Labor, as well as necessary action by Congress to allow the Department of Labor and state governments to perform more effective oversight and payment controls.

• Senators Orrin Hatch (R-Utah), Chuck Grassley (R-Iowa) and Tom Cotton (R-Ark) asked the GAO to investigate abuses of the Orphan Drug Act, in response to high prescription drug pricing. The Orphan Drug Act grants tax incentives and seven years of exclusive drug mar- keting rights to drugs needed by fewer than 200,000 patients in the

Congress Relies on the GAO

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US. The exclusivity rights allow drug companies to set drug pricing without concerns of competitors, which some contend contributes to high drug pricing.

• Senator Tom Carper (D-Del) asked the GAO to look into how climate change is threatening humans and the environment.

Source: Sarah Tribble and Sydney Lupkin, “GOP Senators Ask GAO To Investigate High Prices for Orphan Drugs,” NPR, March 7, 2017, https://www.npr.org/sections/ health-shots/2017/03/07/518980280/gop-senators-ask-gao-to-investigate-high- prices-for-orphan-drugs; Miranda Green, “Top Democrat calls for GAO to investigate

climate threat,” The Hill, May 13, 2019, https://thehill.com/regulation/energy- environment/443449-top-democrat-calls-for-government-watchdog-to-investigate “Wyden and Hatch Ask GAO to Look into IRS Whistleblower Program,” Taxanalysts, June 24, 2014. “U.S. Senators Johnson and Lankford Call on GAO to Review Adminis- tration’s Executive Actions,” WDI News and Opinion, March 30, 2015 “Oregon Sena- tor to Ask for GAO Probe of Hanford,” The Washington Times, February 22, 2013

k“Senators Encourage GAO to Investigate Ways to Collaborate on Prescrip- tion Drug Abuse,” Drug Store News, March 5, 2013; “GAO Report Outlines Improper Federal Employees Compensation Payments,” May 6, 2013, Tom Coburn, U.S. Senate press release.

The U.S. Comptroller General heads the GAO. In one sense, GAO auditors are the highest level of internal auditors for the federal government. State and federal agencies and other local government units use the GAO’s generally accepted government auditing standards (GAGAS) to guide their audits. These standards are published in a book with a yellow cover, referred to as the Yellow Book.

Many states also have audit agencies similar to the GAO. They answer to state legis- latures and perform the same types of work described here as GAO auditing. In another sense, the GAO and many state agencies are really external auditors with respect to gov- ernment agencies they audit because they are organizationally independent.

Many government agencies have their own internal auditors and inspectors general. Well-managed local governments also have internal audit departments. For example, most federal agencies (e.g., Department of Defense, Department of the Interior), state agencies (e.g., education, welfare, controller), and local governments (e.g., cities, counties, tax districts) have internal audit staffs. Governmental auditors are charged with looking for projects that do not spend the taxpayers’ money wisely. If you were a governmental audi- tor looking at the project in the following Auditing Insight, would you raise any issues?

Types of Governmental Audits The GAO shares with internal auditors many of the same elements of expanded-scope services. The GAO, however, emphasizes the accountability of public officials for the efficient, eco- nomical, and effective use of public funds and other resources. The GAO defines and describes expanded-scope governmental auditing in terms of three types of governmental audits:

1. Financial statement audits. 2. Attestation engagements. 3. Performance audits.

Financial Statement Audits Financial statement audits determine whether the financial statements of an audited entity present fairly the financial position, results of operations, and cash flows in conformity

In 2015 the Department of Defense spent $2 million to hire a team of researchers and musicians to develop robotic music computers to perform a trumpet solo with human musicians. The lead on the proj- ect, jazz musician and academic Kelland Thomas, says his goal is to be able to hook the computer system to robots that can play instruments with humans “in ways we recognize as improvisational and adaptive.”

Source: Eric Pianin, “7 Unbelievable Ways the Government Wasted Your Money in 2015,” The Fiscal Times, December 22, 2015, available at: http://www.thefiscaltimes.com/2015/12/22/7-Unbelievable-Ways- Government-Wasted-Your-Money-2015

Jazzy RobotsAUDITING INSIGHT

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with generally accepted accounting principles. In addition, financial audits can have other objectives, including

∙ Issuing special reports for specified elements, accounts, or items of a financial statement. ∙ Reviewing interim financial statements. ∙ Issuing letters for underwriters. ∙ Reporting on the processing of transactions by service organizations. ∙ Auditing compliance with regulations relating to federal award expenditures and other

governmental financial assistance.

Attestation Engagements Attestation engagements involve providing an opinion on subject matter or an assertion about the subject matter that is the responsibility of another party. The subject matter of an attestation engagement may take many forms, including historical or prospective per- formance or condition, physical characteristics, historical events, analyses, systems and processes, or behavior. Examples of such engagements include reporting on

∙ Internal control over financial reporting or compliance with specified requirements. ∙ Compliance with requirements of specified laws, regulations, rules, contracts, or grants. ∙ Management’s discussion and analysis presentation. ∙ Prospective or pro forma financial information. ∙ The reliability of performance measures. ∙ The reasonableness and allowability of proposed contract amounts. ∙ Performance of specified procedures on a subject matter.

Performance Audits Performance audits provide objective analysis so that management and those charged with governance and oversight can rely on information to improve program performance and operations, reduce costs, facilitate decision making by corrective action, and contribute to public accountability.6

Performance audits may be requested by management or a legislative body or may be mandated by the law, grant, or contract under which an agency or company is operating or receiving money. Performance audits provide an objective and systematic examination of evidence of the performance and management of a program against objective criteria. Perfor- mance audits provide information to improve program operations and facilitate decision mak- ing by those with oversight responsibility. Examples of performance audits include assessing

∙ The extent to which legislative, regulatory, or organizational goals and objectives are being achieved.

∙ The relative ability of alternative approaches to provide better program performance or eliminate factors that inhibit program effectiveness.

∙ The relative cost and benefits or cost effectiveness of program performance. ∙ The degree to which, if at all, a program produced the intended results. ∙ The degree to which, if at all, a program produced unintended effects. ∙ The extent to which programs duplicate, overlap, or conflict with other related programs. ∙ The degree to which, if at all, the audited entity is using sound procurement practices. ∙ The validity and reliability of performance measures or financial information related

to the program.

Audit Procedures for Performance Audits The general evidence-gathering procedures used during the audit of financial statements in governmental audits are basically the same as the ones used by external auditors.

6Government Auditing Standards, January 2011.

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However, performance audits, which provide assurance on economy, efficiency, and pro- gram results, require special consideration.

Governmental and internal auditors must be as objective as possible when developing conclusions about efficiency, economy, and program results. This objectivity is achieved by (1) finding standards for evaluation, (2) determining the actual results of the program, and (3) comparing the actual results to the standards. Finding standards and deciding on relevant measurements is often very difficult.

When dealing with standards, measurements, and comparisons, auditors must keep inputs and outputs in perspective. For financial statement audits, evidence about inputs— personnel hours and cost, material quantities and costs, asset investment—is most important in connection with reaching conclusions. For performance audits, output mea- surements are most important. Management has the responsibility for devising information systems to measure output. Such measurements should correspond to program objectives set forth in laws, regulations, administrative policies, legislative reports, or other such sources. Auditors need to realize that output measurements are usually not expressed in financial terms. Output measurements could include things such as water quality improve- ment, educational progress, weapons effectiveness, materials-inspection time delays, etc. Auditors also need to recognize that program activity does not necessarily indicate pro- gram success, rather success is contingent on the program results, i.e., the output.

Kinerville has instituted a new program in its school system. The program provides a healthy balanced breakfast for underprivileged students in grades K–12. You have been asked to audit the program’s effectiveness. In planning this audit, the following issues must be resolved:

First, what is the goal of the program? If you said, “to feed hungry chil- dren,” you would be only partially correct. The actual goal of school break- fast programs is based on the assumption that children do better in school when they have a good breakfast. Therefore, the main purpose of the pro- gram is to improve the educational experience for underprivileged children.

Second, by what standard would you measure success? A comparison to other students in the school who are not in the program? If these stu- dents are not “underprivileged,” is this a fair measure? Should Kinerville’s school district withhold breakfasts from some underprivileged children so there is a comparison group? Is there a moral issue with this type of evalu- ation? (This is an ethical question that the medical profession wrestles

with on a regular basis because in studies of a new medicine, placebos are given to ill patients.) Would a comparison with other schools in other districts be appropriate? Maybe, but the comparison group would have to be carefully selected and matched on many demographic factors.

Third, what is the measure that will be used for comparison? Increased grades? Higher standardized test scores? What are the problems with these measures? Will teachers change their teaching methods and focus exclusively on test preparation? Can there be other reasons for an increase in test scores?

Lastly, how large an improvement is required for the program to be successful?

You may want answers to all of these questions, but real concrete answers do not exist. Most of these issues can be resolved with tests and measures that have some positive aspects and some negative aspects, and the audit team may need to have several measures and make many difficult judgments.

An Example of Setting Performance Audit Criteria

GAO Government Auditing Standards The GAO establishes GAGAS that guide all audits for federal government agencies and facilities and all audits of entities receiving federal funds. Note that these standards must be adhered to even if an accounting firm is engaged to perform one of these audits. (Rule 501 of the AICPA Code of Conduct makes the failure to follow government standards during a government audit an act discreditable; see Module B.) In addition, many state and local governments have adopted GAGAS as the audit standards for agencies, munici- palities, and government districts (e.g., school districts).

In many areas, GAGAS are similar to the AICPA Statements on Auditing Standards. However, GAGAS go beyond the AICPA standards in several respects. Government auditing standards impose additional rules and regulations about handling government funds and accounts.7 A sample of this literature includes the following: 7Extensive government audit literature can be found at three important websites: (1) the OMB website (www.whitehouse.gov/omb), (2) the AICPA website (www.aicpa.org/InterestAreas/GovernmentalAuditQuality/Pages/GaQC.aspx), and (3) the GAO website (www.gao.gov).

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∙ Single Audit Act of 1984. This is the federal law that established uniform require- ments for audits of federal financial assistance provided to state and local governments (discussed later in the module).

∙ OMB Uniform Administrative Requirements, Cost Principles, and Audit Require- ments for Federal Awards (Uniform Guidance)

∙ AICPA Audit and Accounting Guide, “Audits of State and Local Governments.”

Because most governmental programs are created by grants and operate under laws and regulations, GAGAS explicitly require review and testing for compliance with appli- cable laws and regulations. Governmental auditors must be especially diligent when noncompliance with laws and regulations could result in errors or frauds that could be material to the financial statements.

GAGAS have more elaborate specifications for audit documentation and reporting than GAAS require. The GAO standards require the following written reports in financial statement audits:

1. An audit report on financial statements. 2. A report on the auditee’s compliance with applicable laws and regulations, including

a report of irregularities, frauds, illegal acts, material noncompliance, and internal control deficiencies.

3. A report on the auditee’s internal control and the control risk assessment.

GAGAS also contain an elaborate set of guidelines for reports on performance audits. These audits cover such a wide range of subjects (from food programs to military con- tracts) that no “standard” report is possible. The details of these standards can be found on the GAO website (www.gao.gov). These GAO standards are good guides for internal audit reports and for operational audit reports (consulting services engagements) pre- pared by CPAs in public practice.

GAO Audit Reports GAGAS have three sets of reporting standards: one for financial audits, one for attesta- tion engagements, and another for performance audits.

Financial audit reports start with an audit report similar to the external auditors’ stan- dard report except that the description of the audit in the scope paragraph must include a reference to GAGAS. The report on financial statements contains an opinion regarding conformity with GAAP, just as the reports that independent auditors in public practice give on nongovernmental organizations. In addition, GAGAS require reports on internal control, fraud, illegal acts, violations of provisions of contracts, grant agreements, abuse of government assets, and tests of compliance with laws and regulations as part of the financial reporting requirements.

Governmental auditors, like their public accounting firm counterparts, may be asked to perform attestation engagements. Attestation engagements provide an opinion or con- clusion concerning a specific subject or an assertion about a subject. It is important when reporting on attestation engagements to clearly specify the subject matter or assertion, the conclusions, and any significant reservations concerning the subject matter or assertion addressed in the report.

Both attestation engagement reports and performance audit reports are completely dif- ferent from financial audit reports. Like that for internal audit reports, the GAO objective is clear communication for the purpose of making recommendations and improving oper- ations. Hence, the Yellow Book’s performance audit reporting standards require timely, well-written communications of findings and recommendations for action. The managers of an audited entity are expected to respond to the report, and this response is usually included in the final version of the report. Unlike internal audit reports, most GAO reports are available to the public and can be requested from the Government Printing Office.

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However, performance audits have another side. GAGAS require the reports to relate illegal acts, abuse of public money and property, noncompliance with laws and regula- tions, and internal control weaknesses. These matters reflect negatively on an organiza- tion’s management.

Single Audit Act of 1984 and Amendments of 1996 The federal government requires audits of state and local governments that receive federal financial assistance through appropriations, grants, contracts, cooperative agreements, loans, loan guarantees, property, interest subsidies, and insurance. When a state or local government, university, or community organization receives federal financial assistance from several federal agencies, the Single Audit Act of 1984, as amended in 1996, (the Act) allows for that organization to obtain a single audit on which all of the agencies can rely.

The Act established an annual audit requirement for all governments, agencies, and nonprofit organizations that expend $750.000 or more of federal funds. A single audit, conducted in accordance with GAGAS, covering financial statements, compliance with laws and regulations, and internal control is required. The Act does not require expanded scope audits of economy, efficiency, or program results. However, federal agencies may require, and pay for, additional audits of economy, efficiency, and program results to monitor the benefits of federal fund expenditures.

The auditors can be from public accounting firms or from state and local agencies pro- vided they meet the GAO independence and proficiency requirements. In a single audit, the auditors are expected to determine and report whether

1. The financial statements present fairly the financial position and results of operations in accordance with GAAP.

2. The organization has internal controls to provide reasonable assurance that it is man- aging federal financial assistance programs in compliance with applicable laws and regulations.

3. The organization has complied with laws and regulations that may have a material effect on its financial statements and on each major federal assistance program.

Government audits under the Yellow Book and the Single Audit Act Amendments of 1996 (including OMB Uniform Guidance) are difficult and time consuming. The GAO requires auditors to have 24 hours of continuing education within a two-year period in topics directly related to the government environment, governmental auditing, or the spe- cific environment the in which the audited entity operates to qualify for planning an audit, conducting fieldwork, and preparing reports.8 The GAO also imposes requirements for overall continuing education and participation in a peer review program.9

Governmental audits require more work on compliance and reporting on internal control than external auditors normally perform in an audit of financial statements of a private business. The reason is the federal government’s concern for laws, regulations, and control of expenditures. More than $650 billion of federal funds are used by state and local governments for various programs 10, so the stakes are high. See Exhibit D.1 for  the Single Audit Report for the Louisville Metro Council for the fiscal year ended June 30, 2018.

8https://www.gao.gov/assets/80/76894.pdf It is a document titled “Government Auditing Standards - Guidance on GAGAS Requirements for Continuing Professional Education”, published in 2005 by the GAO (US Government Accountability Office) 9Most CPAs in public practice have similar continuing education and peer review requirements in connection with their state licenses and voluntary membership in the AICPA but not specific to governmental auditing. However, the GAO makes the require- ments even for CPAs who do not have similar demands from their state boards or who choose not to belong to the AICPA. In this manner, the GAO exercises its own control over government audit quality. 10https://fas.org/sgp/crs/misc/R40638.pdf. Please add footnote indicating. Name of report: Federal Grants to State and Local Gov- ernments: A Historical Perspective on Contemporary Issues; updated May 22, 2019; Congressional Research Service.

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EXHIBIT D.1 Single Audit Report for the Louisville Metro Council Fiscal Year Ended June 30, 2018

INDEPENDENT AUDITOR’S REPORT ON INTERNAL CONTROL OVER FINANCIAL REPORTING AND ON

COMPLIANCE AND OTHER MATTERS BASED ON AN AUDIT OF FINANCIAL STATEMENTS PERFORMED IN

ACCORDANCE WITH GOVERNMENT AUDITING STANDARDS

Honorable Mayor Greg Fischer and The Louisville Metro Council Louisville, Kentucky

Louisville, Kentucky December 14, 2012

Crowe Horwath LLP

Internal Control over Financial Reporting

Compliance and Other Matters

Purpose of this Report

We have audited the financial statements of the governmental activities, the aggregate discretely presented component units, each major fund, and the aggregate remaining fund information of Louisville/Je�erson Country Metro Government (“Metro Government”) as of and for the year ended June 30, 2012, which collec- tively comprise Metro Government’s basic financial statements and have issued our report thereon dated December 14, 2012, which cited reliance on the reports of other auditors. We conducted our audit in accord- ance with auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards, issued by the Comptroller General of the United States.

Management of Metro Government is responsible for establishing and maintaining e�ective internal control over financial reporting. In planning and performing our audit, we considered Metro Government’s internal control over financial reporting as a basis for designing our auditing procedures for the purpose of express- ing our opinion on the financial statements, but not for the purpose of expressing an opinion on the e�ective- ness of Metro Government’s internal control over financial reporting. Accordingly, we do not express an opinion on the e�ectiveness of Metro Government’s internal control over financial reporting.

A deficiency in internal control exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal control such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or detected and corrected on a timely basis.

Our consideration of the internal control over financial reporting was for the limited purpose described in the first paragraph and was not designed to identify all deficiencies in internal control that might be deficiencies, significant deficiencies, or material weaknesses. We did not identify any deficiencies in internal control over financial reporting that we consider to be material weaknesses, as defined above.

As part of obtaining reasonable assurance about whether Metro Government’s financial statements are free of material misstatement, we performed tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements; noncompliance with which could have a direct and material e�ect on the determination of financial statement amounts. However, providing an opinion on compliance with those provisions was not an objective of our audit and accordingly, we do not express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards.

The purpose of this report is solely to describe the scope of our testing of internal control over financial report- ing and compliance and the results of that testing, and not to provide an opinion on the e�ectiveness of the entity’s internal control or on compliance. This report is an integral part of an audit performed in accordance with Government Auditing Standards in considering the entity’s internal control and compliance. Accordingly, this communication is not suitable for any other purpose.

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Compliance and Other Matters

Purpose of this Report

Louisville, Kentucky December 21, 2013

Crowe Horwath LLP

As part of obtaining reasonable assurance about whether Metro Government’s financial statements are free of material misstatement, we performed tests of its compliance with certain provisions of laws, regula- tions, contracts, and grant agreements, noncompliance with which could have a direct and material e�ect on the determination of financial statement amounts. However, providing an opinion on compliance with those provisions was not an objective of our audit, and accordingly, we do not express such an opinion. The results of our tests disclosed no instances of noncompliance or other matters that are required to be reported under Government Auditing Standards.

The purpose of this reportis solely to describe the scope of our testing of internal control over financial reporting and compliance and the results of that testing, and not to provide an opinion on the e�ectiveness of the entity’s internal control or on compliance. This report is an integral part of an audit performed in accordance with Government Auditing Standards in considering the entity’s internal control and compliance. Accordingly, this communication is not suitable for any other purpose.

REVIEW CHECKPOINTS D.8 What is governmental auditing? D.9 What is the GAO and what do they do? D.10 What three types of auditing services do governmental auditors provide? D.11 How can governmental and internal auditors try to achieve objectivity when developing

conclusions about economy, efficiency, or program results? D.12 Why do GAGAS require a review for compliance with laws and regulations in conjunction with

financial audits? D.13 What are the major differences between independent auditors’ reports on financial statements

and internal and governmental reports on efficiency, economy, and program results audits? D.14 What was the purpose of the Single Audit Act of 1984?

FRAUD EXAMINATIONS The responsibilities of external auditors, internal auditors, and governmental auditors often  require the identification of suspected fraud. External auditors responsibilities regarding errors, fraud, and illegal acts are sprinkled throughout several sections of the

A report from the GAO states that the Environmental Protection Agency (EPA)’s Integrated Risk Information System (IRIS) unit has had their work delayed by EPA leadership. The IRIS unit is respon- sible for identifying and evaluating the dangers of chemicals in items like  paint  and  pesticides. According to the report issued in January 2019, “the IRIS program has been unable to release any work since June 2018 while waiting for feedback from the Administrator’s office.” The investigation came on the heels of lawmaker demands

for the release of a report examining whether formaldehyde exposure increases the risk of leukemia. The GAO investigation revealed the report had been “drafted and ready to be released for public com- ment” when the assessment into formaldehyde was dropped as a result of leadership putting a limit on the number of chemicals IRIS was studying.

Source: Heidi Vogt, “EPA’s Top Leaders Stymied Research Unit, Report Finds,” Dow Jones Institutional News, February 14, 2019.

Stalling at the EPA?AUDITING INSIGHT

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auditing standards. AU-C 240 specifically requires external auditors to use information obtained during the planning and performance of the audit to identify risks that may result in a material misstatement due to fraud. In addition, auditors need to be aware of the various types of frauds, their signs (red flags), and the need to follow up to determine whether a suspicion is justified. If justified, auditors need to alert management and call in the experts.

Internal auditors also have responsibilities related to fraud. According to the IIA, the mission of internal auditors is “to enhance and protect organizational value by providing risk-based and objective assurance, advice, and insight.” In doing so, internal auditors must consider and evaluate exposure to all types of risk, including the risk of fraud. The IIA standards specifically reference the need for internal audit to evaluate the potential for fraud within an organization and how that fraud risk is managed.

For governmental auditors, the basic requirements are to know the applicable laws and regulations, to design the audit to detect abuse and illegal acts, and to report their findings to the proper level of authority. All governmental auditors are required to prepare a writ- ten report on their tests of compliance with applicable laws and regulations, including all material instances of noncompliance and all instances or indications of illegal acts that could result in criminal prosecution. Reports are directed to the top official of an organi- zation and, in some cases, to an appropriate oversight body, including other government agencies and audit committees. Persons receiving the audit reports are responsible for reporting to law enforcement agencies.

As illustrated in Exhibit D.2, internal auditors are much more likely to discover fraud than external auditors-internal auditors discover about 15 percent of frauds as opposed to only 4 percent discovery by external auditors. By far the most common way fraud is

LO D-3 Define fraud examination and the differences in how external auditors and fraud examiners approach their work. Describe the main objectives of a fraud investigation, how a fraud case is built, and how fraud evidence is handled. Describe the ways CPAs can assist in prosecuting fraud perpetrators.

EXHIBIT D.2  Finding Fraud

Initial Detection of Occupational Frauds

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discovered is through anonymous tips (40 percent).11 Once a fraud is suspected, a fraud examiner may be called to investigate further. Although it is technically correct to call these engagements fraud investigations or examinations, many firms and companies use the term fraud audit.

The Art of Fraud Examinations Auditors are required to provide reasonable assurance that financial statements are free of material misstatements due to fraud. During an audit, auditors may uncover facts or circumstances indicating that fraud may exist. At this point, a fraud examination may commence and may require the assistance of a certified fraud examiner (CFE).12

Fraud examinations combine the expertise of auditors and criminal investigators. Fraud examiners are fond of saying that their successes are the result of accident, hunches, or luck. Nothing can be further from reality. Successes come from experience, logic, and the ability to see things that are not obvious. (As for Sherlock Holmes, famous detective of literature, sometimes it is “the dog that did not bark” that is the clue.) Fraud examinations, broadly

11Association of Certified Fraud Examiners, Report to the Nation: 2018 Global Study on Occupational Fraud and Abuse. 12The CFE designation is offered by the Association of Certified Fraud Examiners. Information concerning the designation and requirements can be found on its website (www.acfe.com).

Quite by accident, Frank Benford made an interesting discovery about num- bers. When consulting logarithm tables for his work, he realized that the first few pages of his logarithm table books, which contained logs of num- bers that start with lower digits, were more worn that the last few pages. He surmised that he was looking up logs of numbers with low digits more frequently because there were more numbers that began with a lower first digit. The first digit of a number is the leftmost - for example, the first digit of 23,015 is 2. He tested his theory by looking at number lists from a variety of sources, including demographic, geographic, and scientific data. He found that in naturally occurring numbers, approximately 31 percent of numbers had a first digit of 1, 19 percent had a first digit of 2, and only 5 percent had a first digit of one. What resulted from his experiment is what is now known as Benford’s Law, a frequency distribution of the first digit in a number, with smaller chances of occurence as the first digit gets larger.

Not all data sets follow Benford’s law. Those data sets that most likely follow Benford’s law have the following characteristics: (1) The numbers describe the sizes of similar phenomena (e.g., market values of corpo- rations); (2) the numbers do not contain a built-in maximum or minimum value (such as deductible IRA contributions or hourly wage rates); and (3) assigned numbers, such as Social Security numbers, zip codes, or bank account numbers, will not conform to Benford’s law.

Benford’s law has been applied to many sets of financial data, includ- ing income tax or stock exchange data, corporate disbursements and sales figures, demographics, and scientific data. Since the 1940s, more than 150 academic papers on Benford’s law have been published by mathema- ticians, statisticians, engineers, physicists, and—recently—accountants.

Accountants could have used Benford’s law to find problems such as these:

• Fraudulent checks. A fraudulent check scheme by a manager in the office of the Arizona State Treasury could have easily been discovered by a CPA familiar with Benford’s Law. The manager wrote checks just

below $100,000, a likely control threshold, to try to conceal his fraud. The result was that the digit patterns of the check amounts were almost opposite to those of Benford’s law. More than 90 percent had 7, 8, or 9 as a first digit combination. Among the first two digits of the invented amounts, 87, 88, 93, and 96 were all used twice. For the last two digits, 16, 67, and 83 were duplicated. The numbers appear to have been chosen at random, by a fraudster not aware that some digits do appear more frequently than others, and it is not 7, 8, or 9!

• Biases in corporate data. In one company’s accounts payable data, there was a large first-two-digit spike (excess of actual over expected) at 24. An analysis showed that the amount $24.50 occurred abnor- mally often. The audit revealed that these were claims for travel expenses and that the company had a $25 voucher requirement. Employees were apparently biased toward claiming $24.50.

• Ducking authorization levels. Sometimes managers concentrate their purchases just below their authorization levels so their choices won’t be scrutinized. Managers with $3,000 purchasing levels might have a lot of invoices for $2,800 to $2,999, which would show up in data analysis by spikes at 28 and 29. During one bank audit, the auditors analyzed the first two digits of credit card balances written off as uncollectible. The graph showed a large spike at 49. An analysis of the related dollar amounts (i.e., from $480 to $499 and from $4,800 to $4,999) showed that the spike was caused mainly by amounts between $4,800 and $4,999, and that one officer was responsible for the bulk of these write-offs. The write-off limit for internal personnel was $5,000. It turned out that the officer was operating with a circle of friends who would apply for credit cards. After they ran up balances of just under $5,000, he would write the debts off.

Source: Mark J. Nigrini, “I’ve Got Your Number,” Journal of Accountancy 187, no. 5 (May 1999), pp. 79–83.

Benford’s Law

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speaking, involve familiarity with many elements: the human factor, organizational behav- ior, common fraud schemes, evidence and its sources, standards of proof, and red flags.

Independent auditors of financial statements and fraud examiners approach their work differently. Some of the most important differences are as follows:

∙ Financial statement auditors follow a program/procedural approach designed to accomplish a fairly standard job; fraud examiners work in unique and unusual situa- tions in which little is standard.

∙ Financial statement auditors note errors and omissions; fraud examiners also focus on exceptions, but they must be aware of peculiarities and patterns of conduct as well.

∙ Financial statement auditors assess control risk to design audit procedures; fraud examiners habitually “think like a crook” to imagine ways controls could be subverted for fraudulent purposes.

∙ Financial statement auditors use the concept of materiality (dollar size large enough to matter). Most fraud examiners believe that “immaterial fraud” is an oxymoron. Fraud is often larger than it appears, fraud left unchecked tends to grow, and fraud indicates a lack of integrity on the part of the person or persons involved. For these reasons, fraud examiners often pursue even small frauds.

∙ Financial statement audits are based on theories of financial accounting and auditing logic; fraud examination is grounded in a theory of behavioral motive, opportunity, and rationalization.

Financial statement auditors often use inductive reasoning—that is, they sample accounting data, derive audit findings, and project (“induct”) the finding to a conclusion about the population of data sampled. Fraud examiners often enjoy the expensive luxury of using deductive reasoning—that is, after being tipped off that a certain type of loss occurred or probably occurred, they can identify the suspects, make clinical observations (e.g., stakeouts), conduct interviews and interrogations, eliminate dead-end results, and establish a legal case against the alleged fraudster. They can conduct covert activities that usually are not used in the financial audit. The “expensive luxury” of the deductive approach involves surveying a wide array of information and information sources, elimi- nating the extraneous, and retaining the selection that proves the fraud.

Successfully identifying and catching fraud perpetrators often depends on the audi- tors’ awareness. The identification of evidence that may indicate a fraud, the handling of that evidence, and the timely involvement of the fraud examiner may mean the difference between stopping a fraud and recovering stolen assets or continuing the expansion of fraud in the client’s business.

A government fraud examiner uncovered a fraud while driving into the parking lot of the city hall of a small town. The auditor always parked in the employee lot (saving the customer parking for residents conduct- ing business with city hall). In the parking lot, along with the Fords and Chevrolets, was a candy-apple red Porsche. After parking his car, the auditor went over to the Porsche and began to look the car over. When someone from city hall came out, the auditor began a conversation.

Auditor: This is certainly a beautiful car!

City hall employee: Yes, it is.

Auditor: Do you know how much horsepower it has?

City hall employee: Not a clue. The car belongs to Bob. I’m cer- tain he’d tell you.

Auditor: Great. I would love to find out more about this car. Where would I find Bob?

City hall employee: Oh. Bob’s a city inspector. You’ll find him in the inspector’s office.

Auditor: Thanks!

Further investigation revealed that Bob had been taking kickbacks.

Source: Story told by a government fraud examiner at an Association of Certi- fied Fraud Examiners seminar.

What Car Are You Driving?AUDITING INSIGHT

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Fraud Examiner Responsibilities When a fraud examiner is called, fraud is strongly suspected or already recognized. The Association of Certified Fraud Examiners (ACFE) indicates that assignments are initi- ated only with predication, which means a reason to believe fraud may have occurred.13

Fraud examiners’ attitudes and responsibilities differ from those of other auditors in two additional respects: internal control and materiality. Fraud examiners’ interest in internal control policies and procedures involves less evaluation of strengths and more evaluation of weaknesses. Fraud examiners “think like crooks” to imagine fraud schemes that get around an organization’s internal controls.

Fraud examiners have four main objectives in performing an investigation. First, they must determine whether a fraud does exist. Second, once fraud examiners determine that a fraud does exist, they must determine the scope of the fraud. For organizations that received an external audit, the median fraud, when discovered, had been in operation for more than 18 months.14 Therefore, fraud examiners must attempt to determine when the fraud started and what assets have been misappropriated. Third, fraud examiners must identify the perpetrators. They must take great care not to falsely accuse employees and not to solicit help from management personnel who might be involved in the fraud. Finally, examiners must determine how the fraud occurred and whether changes in con- trols or policy can eliminate this type of fraud in the future.

Fraud examiners’ attitude about materiality differs from that of auditors. Auditors have a large-dollar amount as a criterion for an error that is big enough to matter, but fraud examiners have a much lower threshold, and many operate under the theory that there is no such thing as an immaterial fraud. In fact, fraud is sometimes compared to an iceberg in the sense that most of it is hidden and only a small part may be visible. A fraud loss of $20,000 this year may not be material to an external auditor, but $20,000 each year for a 15-year fraud career amounts to $300,000 in the fraud examiner’s eyes—and it is big enough to matter!

13The Professional Standards and Practices for Certified Fraud Examiners can be found on the association’s website at www.acfe.com. 14Association of Certified Fraud Examiners, 2012 Report to the Nation: Occupational Fraud and Abuse.

Alice, a fraud examiner, has been called into Bulldog Corporation because an accounts payable fraud is suspected. Several vendor invoices were paid to Longhorn Enterprises, a vendor not on the approved vendor list. Although this may indicate a fictitious vendor set up by someone in the company as a fraud, it also may be an indication of someone not following procedure. It is possible that the purchases from this vendor were valid, but the vendor was not put on the approved vendor list. The fraud examiner must determine whether this is a fraud or just a case of not following procedure. The fraud examiner may take several steps to identify whether Longhorn Enterprises exists.

DOES FRAUD EXIST? Alice has called the secretary of state’s office, checked the telephone directory, and searched the Internet but has not found any indication of a company called Longhorn Enterprises. In addition, the invoices from Long- horn Enterprises have no telephone number and only a post office box as an address. Finally, there are no creases on the invoices in the file, indicat- ing they were probably not mailed to the company.

HOW LARGE IS THE FRAUD? Convinced that Longhorn Enterprises does not exist, Alice sets out to determine the extent of the fraud and searches the cash disbursements

journal and accounts payable records looking for checks paid to Longhorn Enterprises. After finding 32 invoices paid over the last two years, Alice has Bulldog obtain copies of the canceled checks, front and back. Alice makes copies of all of the invoices and places the originals in a plastic bag. (They are evidence and may have fingerprints or other forensic infor- mation.) All the originals are locked up for safekeeping. The total of the checks is $67,245.

WHO COMMITTED THE FRAUD? Alice notices that the checks are endorsed by hand (most companies endorse checks with a stamp) and that the checks are deposited in Small- time Regional Bank. Because Bulldog pays its employees through direct deposit, Alice can compare the banks used by employees with the bank used to deposit Longhorn Enterprises’ checks. Alice compares that list with the list of employees who are involved in the purchasing and pay- ables process and finds three purchasing and payable employees who use the Smalltime Regional Bank. Alice takes this information to an attor- ney, who assists in getting a subpoena for the bank records and postal information concerning the post office box. Alice finds that both the post office box and bank account are registered to Dallas Fry, an accounts

A Fraud Examination Example

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Protecting the Evidence While engaged in audit work, auditors should know how to preserve the chain of custody of evidence. The chain of custody is the crucial link of the evidence to the suspect, called the relevance of evidence by attorneys and judges. If documents are lost, mutilated, cof- fee soaked, or compromised (so a defense attorney can argue that they were altered to frame the suspect), they can lose their effectiveness for the prosecution. Auditors should learn to mark evidence, writing an identification of the location, condition, date, time, and circumstances as soon as it appears to be a signal of fraud. This marking may be on a separate tag or page, or the original may be marked in a manner that preserves the integrity of the document. The original document should be put in a protective envelope (plastic) for preservation, and investigative work should proceed with copies of the docu- ments instead of originals. A record should be made of the safekeeping and of all persons who used the original. Any eyewitness observations should be promptly recorded in a memorandum or on tape (audio or video) with corroboration of colleagues if possible. Other features of the chain of custody relate to interviews, interrogations, confessions, documents obtained by subpoena, and other matters, but auditors usually do not conduct these activities.

Obtaining Litigation Support Independent CPAs often accept engagements for litigation support and expert witnessing. This work is often referred to as forensic accounting, which means applying accounting and auditing evidence to legal problems, both civil and criminal. Litigation support can take several forms, but it usually amounts to consulting in the capacity of helping attor- neys document cases and determine damages. Expert witness work involves testifying to

Building a Fraud Case Building a case against a fraudster is a task for trained investigators who know how to conduct interviews and interrogations, perform surveillance, use informants, and obtain usable confessions. In almost all cases, the postdiscovery activity proceeds with a spe- cial prosecutorial attitude and with management cooperation or leadership. The district attorney and police officials also may be involved. Prosecution of fraudsters is advisable because, if left unpunished, they often go on to steal again. In addition, failure to pros- ecute sends a negative message to other potential fraudsters in the organization.

payable clerk who uses Smalltime Regional Bank for payroll deposits. The bank records also show transfers of money from the bank account, listed as LE Inc., to Fry’s personal bank account.

Next, Alice talks with other employees in the accounts payable area and discovers that Fry has purchased a new car and took an expensive vacation last year. Alice is now ready to confront Fry with the evidence and obtain a confession.

HOW COULD THIS FRAUD HAPPEN? Finally, from Fry’s confession, Alice determines that the assistant trea- surer  routinely approves small payments without scrutinizing the sup- porting documentation. Fry inserted fictitious invoices in stacks of other invoices for the assistant treasurer to sign. Alice’s final report included the fact that the assistant treasurer’s failure to follow procedure allowed the fraud to occur.

Computer Assisted Audit Techniques (CAATs) can be used in a vari- ety of ways to search for fraudulent activities. For example, lists of vendor addresses can be compared to employee address files to see whether employees are paying invoices to companies that they own

or operate. Duplicate payments can be found by sorting payments by invoice number and amount paid. Telephone records can be quickly sorted and scanned to ensure that employees are not misusing com- pany telephones.

Using Computer Assisted Audit Techniques to find Fraud

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findings determined during litigation support and testifying about accounting principles and auditing standards applications. The AICPA, ACFE, and IIA conduct continuing education courses for auditors who want to become experts in these fields.

REVIEW CHECKPOINTS D.15 Compare and contrast the type of work performed by external auditors (auditing financial state-

ments to render an opinion) and fraud examiners. D.16 Internal auditors have one of the highest incidents of fraud detection (higher then external audi-

tors). Why might this be true? To what extent would you think internal auditors include fraud detection responsibility in their normal audit assignments?

D.17 In fraud examiners’ terminology, what is predication? D.18 Why might fraud examiners’ attitudes about control systems and materiality differ from that of

other auditors? D.19 Why is prosecution of fraud perpetrators generally a good idea? D.20 Why do fraud examiners handle information in a different manner than auditors? Why is this

important?

Governmental and internal auditing standards include the essence of the AICPA’s gener- ally accepted auditing standards (GAAS) but also include standards for audits of economy, efficiency, and program results. In addition, the internal auditing standards contain guid- ance for the management of an internal audit department within a company. The auditor’s responsibilities, professional organizations, and standards are summarized in Exhibit D.3.

All auditors hold independence as a primary goal, but internal auditors must establish an internal organizational independence from the managers and executives whose areas they audit. Governmental auditors must be concerned about factual independence with regard to social, political, and level-of-government influences.

Summary

Auditor Primary Functions Standards Professional Organization Certification

Internal auditor Evaluate departments and functions (1) to determine operational efficiency and effectiveness and compliance with laws, regulations, policies, and procedures and (2) to provide consulting services to management.

International Standards for the Professional Practice of Internal Auditing

Institute of Internal Auditors www.theiia.org

Certified Internal Auditor (CIA) Various specialty certifications such as certified financial services auditor (CFSA)

Governmental auditor

Evaluate government entities to (1) determine compliance with laws, regulations, and policies as well as efficiency and effectiveness in the performance of programs and (2) investigate government operations as mandated or directed by government oversight bodies.

Government auditing standards (The Yellow Book)

Association of Government Accountants www.agacgfm.org

The certified government financial manager (CGFM) and certified government auditing professional (CGAP) (offered through the IIA)

Fraud auditor Provide investigative services to auditors and management when the predication of fraud exists.

CFE Code of Professional Standards

Association of Certified Fraud Examiners www. acfe.com

Certified fraud examiner (CFE)

EXHIBIT D.3 Summary of Auditor Information

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audit charter: The internal audit charter is a formal document that defines the internal audit activity’s purpose, authority, and responsibility. The internal audit charter establishes the internal audit activity’s position within the organization, including the nature of the chief audit executive’s functional reporting relationship with the board; authorizes access to records, personnel, and physical properties relevant to the performance of engagements; and defines the scope of internal audit activities, 724 compliance audit: An examination designed to ensure that an organization is following applicable laws, regulations, and management directives; usually performed by internal auditors but may be performed by governmental or external auditors as well, 726 environmental audit: An examination designed to ensure that an organization is following environmental standards established by laws, regulations, and management directives; may recommend methods of reducing environmental problems by reducing or reusing waste or by- products of an organization’s processes, 727 exit conference: A meeting that occurs at the end of an internal audit between the auditors and management of the organization being audited in many external audits and is a required part of an internal audit, 729 follow-up: A process required of internal auditors to ensure that significant audit findings have been addressed by the auditee in accordance with the agreement between the auditor and management, 729 forensic accounting: The application of accounting and auditing evidence to resolve legal issues in civil and criminal law, 742 governance audit: An examination designed to provide management the information required to make governance decisions or to ensure that high-quality information is provided for these decisions, 727 internal auditing: A professional service provided to a company to assist the company in meeting its corporate goals and objectives in part by evaluating and recommending risk management, control, and governance processes, 724 operational auditing: An examination designed to evaluate the processes and procedures of an organization or an area within an organization to ensure the process or area is operating efficiently and effectively, 726 performance audit: An examination designed to ensure that the resources of an organization are being used appropriately and that its objectives are being met, 732

Key Terms

Governmental auditing is complicated by the special context of audit assignments intended to accomplish accountability by agencies that handle federal funds—grants, sub- sidies, entitlement programs, and the like. The requirements of the GAO standards and the Single Audit Act of 1984, as amended in 1996, impose on the audit function the responsi- bility for compliance audit work designed to determine agencies’ observance of laws and regulations, of which there are many. Auditors must report not only on financial statements but also on internal control, violations of laws and regulations, fraud, abuse, and illegal acts. These elements are all part of the federal oversight of federal spending facilitated by auditors.

Governmental and internal audit reports are not standardized as are the GAAS reports on audited financial statements. Auditors must be very careful that their reports commu- nicate their conclusions and recommendations in a clear and concise manner. The variety of assignments and the challenge of reporting in such a free-form setting contribute to making governmental auditing, internal auditing, and consulting services exciting fields for career opportunities.

Auditors must have knowledge of the types of errors, frauds, and illegal acts that can be perpetrated in any audit. External, internal, and governmental auditors all have stan- dards for care, planning, detection, and reporting of errors, frauds, and illegal acts. Fraud examiners, on the other hand, have little in the way of standard programs or materiality guidelines because of the unlimited nature of frauds. However, auditors must exercise technical and personal care because accusations of fraud are always taken very seriously. For this reason, after preliminary findings indicate fraud possibilities, auditors should enlist the support of management and assist fraud examination professionals in bringing an investigation to a conclusion.

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predication: A suspicion that a fraud may have occurred, 741 quality control audit: An examination designed to ensure that an organization is meeting its quality control standards; usually involves determining that personnel responsible for performing quality control are meeting the goals and objectives established and that quality information is being reported to appropriate members of management, 727 single audit: A governmental examination standard that allows an entity to receive one audit of its financial statements, compliance with laws and regulations, and internal control that will be utilized by multiple agencies granting money to the entity, 735 Yellow Book: The common name used to refer to the generally accepted government auditing standards (GAGAS), 731

Multiple-Choice Questions for Practice and Review

All applicable Exercises and Problems are available with Connect.

D.21 Which of the following would be considered in determining whether an internal audit department is independent? a. The organizational level of the chief audit officer and the objectivity of the audit staff. b. A requirement for the auditors to report to the audit committee and for the composition of

that committee. c. The organizational status of the audit committee and the individual independence of

internal auditors in the department. d. The nature of the audit charter and the objectivity of the audit staff.

D.22 Which of the following would be considered the most significant problem for internal audit if the chief audit executive reports to the controller? a. The controller would amend the audit schedule so more audit time was spent on account-

ing issues. b. The controller may have no training as an internal auditor. c. During times when the budget needs to be cut, internal audit would likely be the first to

lose funding. d. The controller can control the scope of audits and censor audit reports before being sent

to management and the audit committee. D.23 Which of the following is not an internal audit objective designed to add value to a purchas-

ing department? a. A review of the bidding process indicates that a vendor company may be operating under

two different names; therefore, purchasing is not getting the three independent bids required by policy.

b. The purchasing process is causing unnecessary delays in ordering product. c. The purchasing department is not following a new human resource policy requiring a six-

month performance review for new employees. d. The director of purchasing is new to the organization and has made several decisions

regarding vendor approvals with which the auditor does not agree. D.24 In an internal auditor’s report, audit findings would include all of the following except

a. The effect of audit finding on the auditee or the company. b. The cause of the audit finding. c. The relevance of the audit finding on the audit. d. The recommendation to correct the audit finding.

D.25 Governmental auditors’ independence and objectivity are enhanced when they report the results of an audit assignment directly to a. Managers of the government agency under audit and in which the auditors are employed. b. The audit committee of directors of the agency under audit. c. Political action committees of which they are members. d. The congressional committee that ordered the audit.

LO D-1

LO D-1

LO D-1

LO D-1

LO D-2

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D.26 In all audits of governmental units performed according to GAGAS, the most important work is a. Compliance auditing. b. Obtaining a sufficient understanding of internal control. c. Documentation of the audit. d. Exit interviews with managers in the governmental unit.

D.27 Which of the following is considered different and more limited in objectives than the others? a. Operational auditing b. Performance auditing c. Management auditing d. Financial statement auditing

D.28 A typical objective of an operational audit is for the auditor to a. Determine whether the financial statements fairly present the company’s operations. b. Evaluate the feasibility of attaining the company’s operational objectives. c. Make recommendations for achieving company objectives. d. Report on the company’s relative success in attaining profit maximization.

D.29 A governmental auditor assigned to audit the financial statements of the state highway department would not be considered independent if the auditor a. Also held a position as a project manager in the highway department. b. Was the state audit official elected in a general statewide election with responsibility to

report to the legislature. c. Normally works as a state auditor employed in the department of human services. d. Was appointed by the state governor with responsibility to report to the legislature.

D.30 Governmental auditing can extend beyond audits of financial statements to include audits of an agency’s efficient and economical use of resources and a. Constitutionality of laws and regulations governing the agency. b. Evaluation of the personal managerial skills shown by the agency’s leaders. c. Correspondence of the agency’s performance with public opinion regarding the social

worth of its mission. d. Evaluations concerning the agency’s achievements of the goals set by the legislature for

the agency’s activities.

D.31 Which of the following best describes how the detailed audit plan of a financial statement auditor compares with the audit client’s comprehensive internal audit plan? a. The comprehensive internal audit plan covers areas that an external auditor would nor-

mally not review. b. The comprehensive internal audit plan is more detailed, although it covers fewer areas

than an external audit would normally cover. c. The comprehensive internal audit plan is substantially identical to the audit plan used by

an external auditor because both review substantially identical areas. d. The comprehensive internal audit plan is less detailed and covers fewer areas than an

external auditor would normally review.

D.32 Which of the following is usually not part of an internal audit department’s audit charter? a. A commitment from management to ensure the independence of the internal audit

department. b. A definition of the scope of the audit department’s activities. c. The organizational structure of the internal audit department. d. The reporting requirements of the internal audit department.

D.33 Which of the following would you not expect to see in an auditor’s report(s) on the financial statements of an independent government agency? a. A statement that the audit was conducted in accordance with generally accepted govern-

ment audit standards. b. A report on the agency’s compliance with applicable laws and regulations.

LO D-2

LO D-1

LO D-1

LO D-2

LO D-2

LO D-1

LO D-1

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Module D Internal Audits, Governmental Audits, and Fraud Examinations 747

c. Commentary by the agency’s managers on the audit findings and recommendations. d. A report on the agency’s internal controls.

D.34 The federal Single Audit Act of 1984 as amended in 1996 requires auditors to determine and report several things about state and local governments that receive federal funds. Which of the following is not normally required to be reported? a. An opinion on the fair presentation of the financial statements in accordance with gener-

ally accepted accounting principles. b. A report on the government’s internal control related to federal funds. c. The government’s performance in meeting goals set in enabling legislation. d. A report on the government’s compliance with applicable laws and regulations.

D.35 The Government Accountability Office (GAO) describes expanded-scope governmental auditing to include all of the following except a. Financial statement audits. b. Attestation engagements. c. Compliance audits. d. Performance audits.

D.36 In government and internal performance auditing, which of the following is the least impor- tant consideration when performing the fieldwork? a. Determining the applicable generally accepted government accounting principles pro-

nounced by the GASB. b. Defining problem areas or opportunities for improvement and defining program goals. c. Selecting and performing procedures designed to obtain evidence about operational

problems and production output. d. Evaluating evidence in terms of economy, efficiency, and achievement of program goals.

D.37 Which of the following is the least important consideration for a governmental auditor who needs to be objective when auditing and reporting on an agency’s achievement of program goals? a. Measure the actual output results of agency activities. b. Compare the agency’s actual output results to quantitative goal standards. c. Perform a comprehensive review of management controls. d. Determine quantitative standards that describe goals the agency was supposed to achieve.

D.38 Compliance auditing performed under the Single Audit Act of 1984, as amended in 1996, in accordance with GAGAS is necessary for an auditor’s a. Report on the auditee’s internal control, including reportable conditions and material

weaknesses. b. Opinion on the auditee’s observance, or lack thereof, of applicable laws and regulations. c. Opinion on the auditee’s financial statements. d. Report of a supplementary schedule of federal assistance programs and amounts.

D.39 Which two of the following characterize the work of fraud examiners? a. Analysis of control weaknesses for determination of acceptable fraud risk. b. Analysis of control strengths as a basis for planning other audit procedures. c. Determination of a materiality amount that represents a significant misstatement of the

financial statements. d. Consideration of a materiality amount in cumulative terms—that is, becoming large over

a number of years.

D.40 When auditing with “fraud awareness,” auditors should especially notice and review employee activities under which of these conditions? a. The company always estimates the inventory but never takes a complete physical count. b. The petty cash box is always locked in the desk of the custodian. c. Management has published a company code of ethics and sends frequent communication

newsletters about it. d. The board of directors reviews and approves all investment transactions.

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D.41 The best way to enact a broad fraud prevention program is to a. Install airtight control systems of checks and supervision. b. Name an ethics officer who is responsible for receiving and acting upon fraud tips. c. Place dedicated hotline telephones on walls around the workplace with direct communi-

cation to the company ethics officer. d. Establish a corporate culture conducive to ethical behavior in the workplace.

D.42 A reason to believe that a fraud has occurred is called a. Deliberation. b. Forensics. c. Predication. d. Restitution.

D.43 In a fraud examination, original documents must be protected from damage and tampering to a. Establish motive. b. Develop documentation for employee dismissal. c. Protect the chain of custody. d. Ensure that suspects are unaware of an investigation in progress.

D.44 An environmental audit might include all of following except a. Determining that proper tracking of waste material is being maintained by the organization. b. Reviewing the liability account established for pending environmental claims against the

company. c. Reviewing the environmental history of another company that the internal auditor’s orga-

nization is interested in purchasing. d. All of the above are appropriate issues for an environmental audit.

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All applicable questions are available with Connect.

D.45 Identification of Audits and Auditors. Audits may be characterized as (a) financial state- ment audits, (b) compliance audits, (c) economy and efficiency audits, and (d) program audits. The work can be done by independent (external) auditors, internal auditors, or gov- ernmental auditors (including IRS auditors and federal bank examiners). Following is a list of the purpose or products of various audit engagements. [Students may need to refer to Chapter 1.]

a. Analyze proprietary schools’ spending to train students for oversupplied occupations. b. Determine the fair presentation in conformity with GAAP of an advertising agency’s

financial statements. c. Study the Department of Defense’s expendable launch vehicle program. d. Determine costs of municipal garbage pickup services compared to comparable service

subcontracted to a private business. e. Audit tax shelter partnership financing terms. f. Study a private aircraft manufacturer’s test pilot performance in reporting on the results

of test flights. g. Periodically have U.S. comptroller of currency examine a national bank for solvency. h. Evaluate the promptness of materials inspection in a manufacturer’s receiving department. i. Report on the need for the states to consider reporting requirements for chemical use data. j. Render a public report on the assumptions and compilation of a revenue forecast by

sports stadium/racetrack complex.

Required: Prepare a three-column schedule showing (1) each of the engagements listed, (2) the type of audit (financial statement, compliance, economy and efficiency, or program), and (3) the kind of auditors you would expect to be involved.

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D.46 Organizing a Risk Analysis. You are the director of internal auditing of a large municipal hospital. You receive monthly financial reports prepared by the accounting department, and your review of them has shown that total accounts receivable from patients has steadily and rapidly increased over the past eight months.

Other information in the reports shows the following conditions:

∙ The number of available hospital beds has not changed. ∙ The bed occupancy rate has not changed. ∙ Hospital billing rates have not changed significantly. ∙ The hospitalization insurance contracts have not changed since the last modification 12

months ago. Your internal audit department audited the accounts receivable 10 months ago. The audit

documentation file for that assignment contains financial information, a record of the risk analysis, documentation of the study and evaluation of management and internal risk mitiga- tion controls, documentation of the evidence-gathering procedures used to produce evidence about the validity and collectability of the accounts, and a copy of your report, which com- mented favorably on the controls and collectability of the receivables. However, the current increase in receivables has alerted you to a need for another audit so any existing problem will not get out of hand. You remember news stories last year about the manager of the city water system who got into big trouble because his accounting department double-billed all residential customers for three months.

Required: You plan to perform a risk analysis to understand the problem if indeed one exists. Write a memo to your senior auditor listing at least eight questions to use to guide and direct the risk analysis. (Hint: The questions used last year were organized under these headings: (1) Who does the accounts receivable accounting? (2) What data processing procedures and policies are in effect? and (3) How is the accounts receivable accounting done? This time, you will add a fourth category: (4) What financial or economic events have occurred in the last 10 months?)

(CIA adapted)

D.47 Study and Evaluation of Management Control. The study and evaluation of management risk control in a governmental or internal audit is not easy. First, auditors must determine the risks and the controls subject to audit. Then they must find a standard by which performance of the control can be evaluated. Next they must specify procedures to obtain the evidence on which an evaluation can be based. Insofar as possible, the standards and related evidence must be quantified.

Students working on this case usually do not have the experience or theoretical back- ground to determine control standards and audit procedures, so the following scenario gives certain information (in italics) that internal auditors would know about or be able to learn on their own. Fulfilling the requirement thus amounts to taking some information from the scenario and learning other things by using accountants’ and auditors’ common sense.

The Scenario Ace Corporation ships building materials to more than a thousand wholesale and retail cus- tomers in a five-state region. The company’s normal credit terms are net/30 days; it offers no cash discounts. Jerry Clark is the chief financial officer and is concerned about risks related to maintaining control over customer credit. In particular, Clark has stated two management control principles for this purpose:

1. Sales are to be billed to customers accurately and promptly. Clark knows that errors will occur but thinks company personnel should be able to hold quantity, unit price, and arith- metic errors down to 3 percent of the sales invoices. Clark considers an invoice error of $1 or less not to matter and believes that prompt billing is important because customers are expected to pay within 30 days. Clark is very strict in thinking that a bill should be sent to the customer one day after shipment and believes the billing department is staffed well enough to be able to handle this workload. The relevant company records consist of an accounts receivable control account, a subsidiary ledger of customers’ accounts in which charges are entered by billing (invoice) date and credits are entered by date of payment receipts, a sales journal that lists invoices in chronological order, and a file of shipping documents cross- referenced by the number on the related sales invoice copy kept on file in numerical order.

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2. Accounts receivable are to be aged and followed up to ensure prompt collection. Clark has told the accounts receivable department to classify all customer accounts in categories of (a) current, (b) 31–59 days overdue, (c) 60–90 days overdue, and (d) more than 90 days overdue. Clark wants this trial balance to be complete and to be transmitted to the credit department within five days after each month-end. In the credit department, prompt fol- low-up means sending a different (stronger) collection letter to each category, cutting off credit to customers that are more than 60 days past due (putting them on cash basis), and giving the over-90-days accounts to an outside collection agency. These actions are sup- posed to be taken within five days after receipt of the aged trial balance. The relevant com- pany records, in addition to the ones listed, consist of the aged trial balance, copies of the letters sent to customers, copies of notices of credit cutoff, copies of correspondence with the outside collection agent, and reports of results—statistics of subsequent collections.

Required: Take the role of a senior internal auditor. You are to write a memo to the internal audit staff to inform them about comparison standards for the study and evaluation of these two manage- ment control policies. You also need to specify two or three procedures for gathering evidence about performance of the controls. The body of your memo should be structured as follows:

1. Control: Sales are billed to customers accurately and promptly. a. Accuracy.

(1) Policy standard . . . (2) Audit procedures . . .

b. Promptness. (1) Policy standard . . . (2) Audit procedures . . .

2. Control: Accounts receivable are aged and followed up to ensure prompt collection. a. Accounts receivable aging.

(1) Policy standard . . . (2) Audit procedures . . .

b. Follow-up prompt collection. (1) Policy standard . . . (2) Audit procedures . . .

D.48 Quality Control Audit of a University. In a quality audit, defining the measurement crite- ria is often difficult and time consuming. You have been a student at a college or university for several years and should have a basic understanding of its academic operations. You have been engaged to perform a quality audit of your university.

Required: a. How would you measure quality in a university environment? What departments are

responsible for measuring quality? b. What audit evidence would you look for in performing the quality audit?

D.49 Internal Audit of Inventory. External auditors usually calculate inventory turnover (cost of goods sold for the year divided by average inventory) and use the ratio as a broad indication of inventory age, obsolescence, or overstocking. External auditors are interested in evidence relating to the material accuracy of the financial statements taken as a whole. Internal audi- tors, on the other hand, calculate turnover by categories and classes of inventory to detect problem areas that might otherwise be overlooked. This kind of detailed analytical audit might point to conditions of buying errors, obsolescence, overstocking, and other matters that could be changed to save money.

The data shown in the following exhibit are for turnover, cost of sales, and inventory investment for a series of four historical years and the current year. In each of the years, the external auditors did not recommend any adjustments to the inventory valuations.

Required: Calculate the current-year inventory turnover ratios. Interpret the ratio trends and identify what conditions might exist. As an internal auditor, write a memo to the vice president for production explaining your findings, possible causes related to problems, and additional investigation that should be conducted.

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D.50 Internal Auditors in the Fast-Food Industry. Internal auditors perform risk-based audits that go beyond the risks of the financial statements. Assume you are on the internal audit staff of McDonald’s.

Required: a. Identify the risks in the fast-food industry associated with

I. Competition. II. Customer preference. III. The economy. IV. Technology. V. Regulation. VI. Other risks.

b. Explain how each of the risks you identified could affect McDonald’s. c. Explain how these risks might affect the internal audits performed by the internal audit

staff for McDonald’s.

D.51 CPA Involvement in an Expanded-Scope Audit. A public accounting firm has been engaged to audit a local food distribution program funded by the U.S. Department of Agri- culture. The engagement is to encompass both financial and performance audits that consti- tute the expanded scope of a GAGAS audit and is to be conducted in accordance with the audit standards published by the Government Accountability Office (GAO).

Required: a. The accountants should perform sufficient audit work to satisfy the financial and com-

pliance element of GAGAS. What is the objective of such audit work? (Hint: Go to the Generally Accepted Government Auditing Standards at www.gao.gov.)

b. The accountants should be aware of general and specific kinds of uneconomical or inef- ficient practices in such a program. What are some examples?

c. What might be some standards and sources of standards for judging program results?

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Additional Information Current Year ($000)

Transfers Sales Cost of Goods Sold Gross Profit Compared to Prior Year

Materials and parts $3,970* NA NA NA Work-in-process 7,988† NA NA NA Computer games 2,320‡ $2,000 $2,200 $<200> Sales volume declined 60%§

Flash drives 2,236‡ 3,000 2,000 1,000 Sales volume increased 35% Semiconductor parts 2,720‡ 4,000 2,400 1,600 Sales volume increased 40% Chargers and cables   712‡ 1,000   800 200 Sales volume declined 3%

NA means not applicable. *Cost of materials transferred to Work-in-Process. †Cost of materials, labor, and overhead transferred to Finished Goods. ‡Cost of goods transferred from Work-in-Process to Finished Product Inventories. §Selling prices also were reduced and the gross margin declined.

Inventory Current-Year Inventory ($000)

2017 2018 2019 2020 Beginning Ending

Total inventory 2.1 2.0 2.1 2.1 $3,000 $2,917 Materials and parts 4.0 4.1 4.3 4.5 1,365 620 Work-in-process 12.0 12.5 11.5 11.7 623 697 Finished products:

Computer games 6.0 7.0 10.0 24.0 380 500 Flash drives 8.0 7.2 7.7 8.5 64 300 Semiconductor parts 4.0 3.5 4.5 7.0 80 400 Chargers and cables 3.0 2.5 2.0 1.9 488 400

Inventory Data

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D.52 Selection of Effective Extended Procedures. The following lettered items are some “suspi- cions,” and you have been requested to select some effective procedures designed to confirm or repudiate the suspicions.

a. The custodian of the petty cash fund may be removing cash on Friday afternoon to pay for weekend activities.

b. A manager noticed that eight new vendors had been added to the purchasing depart- ment’s approved list after the assistant purchasing agent was promoted to purchasing manager three weeks ago. The manager suspects all or some of them might be fictitious companies set up by the new purchasing manager.

c. The payroll supervisor may be stealing unclaimed paychecks of people who quit work and do not pick up the last check.

d. Although no customers have complained, cash collections on accounts receivable are down. The counter clerks may have stolen customers’ payments.

e. The cashier may have “borrowed” money, covered it by holding each day’s deposit until cash from the next day(s)’s collection is enough to make up the shortage from an earlier day, and then send the deposit to the bank.

Required: Write the suggested procedures for each case in definite terms so another person will know what to do.

D.53 Internet Exercise: Audit Charters. Most universities have internal audit departments, and most of them have audit charters that are available on the university website (although you may need to hunt to find it). Go to the website of your college or university and find the internal audit department. Find and print the audit charter or its equivalent. If you are having trouble finding it, call or e-mail the internal audit department and ask whether someone can provide a copy of the audit charter. If your university does not have an internal audit depart- ment or does not make its charter available, check the website of one of the larger public universities in your state.

Required: As described in the audit charter:

a. What are the responsibilities of the internal audit department? b. What authority does the internal audit department have? c. To whom does the internal audit department report? d. When the internal audit department issues a report, who gets it? e. Are there any items described in the audit charter that you find surprising or interesting?

D.54 Internet Exercise: Governmental Audit Reports. Go to the website of the town where you reside and find the Comprehensive Annual Financial Report (CAFR). Find and print the auditor’s report. Warning: Be careful! CAFRs can be more than 100 pages, so make certain you’re printing only the auditor’s report.

Required: a. Who audited the financial statements in the CAFR? b. How does the auditor’s report compare to the three-paragraph standard report used when

auditing for-profit companies’ financial statements? c. What additional paragraphs were added to the report?

D.55 Collecting Evidence in a Fraud Examination. A fraud examiner was called into a business because of a suspicion of fraud. An assistant manager in a bookstore is taking books off the shelf, bringing them to the return book area, completing a customer return form, and pocket- ing the money. This is done late in the day when few other employees are in the store and are involved in closing activities that occupy them in other areas.

Required: a. What are the objectives of the fraud examiner in performing a fraud examination? b. What evidence could the fraud examiner obtain that would help reach the objectives of

the audit? c. How should the fraud examiner handle the evidence obtained?

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D.56 Auditing the Effectiveness of a Loan Program. The following problem is based on an actual program and situation.

The Office of Economic Opportunity (OEO) designed special programs to have a major impact on unemployment, dependency, and community tensions in urban areas with large concentrations of low-income residents or in rural areas having substantial migration to such urban areas. The purpose of these experimental programs—combining business, commu- nity, and personnel development—is to offer poor people an opportunity to become self- supporting through the free enterprise system. The programs are intended to create training and job opportunities, improve the living environment, and encourage development of local entrepreneurial skills.

Assume that the OEO has identified Mayville as a participant in the special impact pro- gram. The Mayville program received more than $50 million in federal funds and obtained another $10 million from private foundations.

Problems Mayville is a three-square-mile section of Mega City with a population of approximately 200,000. This area has serious problems of unemployment and underemployment and inad- equate housing.

Mayville’s problems are deeply seated and have resisted rapid solution. They stem pri- marily from the fact that local residents, to a considerable degree, lack the education and training required for the jobs available elsewhere in the city and from the lack of jobs in the area. Unemployment and underemployment, in turn, reduce buying power, which has a depressing effect on the area’s economy.

The magnitude of the Mayville problems is indicated by the following data disclosed by the U.S. census:

1. Of the total civilian labor force, 8.9 percent was unemployed compared with unemploy- ment rates of 7.1 percent for Mega City and 6.8 percent for the standard metropolitan statistical area (SMSA).

2. Per capita income was $14,106, compared with $22,720 for New York City and $29,909 for the SMSA.

3. Families below the poverty level made up 27.8 percent of the population, compared with 12.4 percent in New York and 9.2 percent in the SMSA.

4. Families receiving public assistance made up 25.4 percent of the population, compared with 9.6 percent in New York and 7.5 percent in the SMSA. A number of factors aggravate the area’s economic problems and make them more dif-

ficult to solve. Some of these are

∙ A reluctance of industry to move into Mega City. ∙ A net outflow of industry from Mega City. ∙ High city taxes and a high crime rate. ∙ A dearth of local residents possessing business managerial experience.

The area’s housing problems resulted from the widespread deterioration of exist- ing housing and are, in part, a by-product of below-average income levels resulting from unemployment and underemployment. These problems were aggravated by a shortage of mortgage capital for residential housing associated with a lack of confidence in the area on the part of financial institutions, which, as discussed later, seems to have been somewhat overcome.

Mayville was the target of several special impact programs. Included were programs designed to stimulate private business, to improve housing, to establish community facili- ties, and to train residents in marketable skills. There were two programs to stimulate private business: a program to loan funds to local businesses and a program to attract outside busi- nesses to the area.

Under the business loan program begun five years ago, the sponsors proposed to create jobs and stimulate business ownership by local residents. At first, investments in local busi- nesses were made only in the form of loans. Later, the sponsors adopted a policy of mak- ing equity investments in selected companies to obtain the sponsors’ voice in management. Equity investments totaling about $159,000 were made in four companies.

Loans were to be repaid in installments over periods of up to 10 years, usually with a moratorium on repayment for six months or longer. Repayment was to be made in cash or

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by applying subsidies allowed by the sponsors for providing on-the-job training to unskilled workers. Loans made during the first two years of the program were interest free. Later, the sponsors revised the policy to one of charging below-market interest rates. Rates charged were from 2 to 5 percent. This policy change was made to (1) emphasize to borrowers their obligations to repay the loan and (2) help the sponsors monitor borrowers’ progress toward profitability.

Prospective borrowers learned of the loan program through (1) information disseminated at neighborhood centers, (2) advertisements on radio and television and in a local newspa- per, and (3) word of mouth. Those who wished to apply for loans were required to complete application forms providing information relating to their education, business and work expe- rience, and personal financial statements and references. The sponsors set up a management assistance division, which employed consultants to supplement its internal marketing assis- tance efforts and to provide management, accounting, marketing, legal, and other assistance to borrowers.

The sponsors proposed to create at least 1,700 jobs during the first four years of the loan program by making loans to some 73 new and existing businesses.

Required: Put yourself in the position of the GAO manager in charge of all audits pertaining to the Office of Economic Opportunity. The Mega City field office has been assigned to conduct a detailed review of the special impact program described here. Prepare a memo to the Mega City field office in which you indicate, in as much detail as is possible from the information provided, the specific steps the field office should perform in evaluating the effectiveness of the special impact loan program.

D.57 Operational Audit: Customer Complaints. Danny Deck, the director of internal auditing for Rice Department Stores, was working in his office one Thursday when Chris McMurray, president of the company, burst in to tell Deck about a problem. According to McMurray, “Customer complaints about delays in getting credit for merchandise returns are driving Sally Godwin up the wall! She doesn’t know what to do because she has no control over the processing of credit memos.”

Godwin is the manager in charge of customer relations and tries to keep everybody happy. Upon her recommendation, the company had adopted an advertising motto: “Satisfaction Guaranteed and Prompt Credit When You Change Your Mind.” The motto is featured in newspaper ads and on large banners in each store.

Deck performed a preliminary review and found the following: 1. Godwin believes customers will be satisfied if they receive a refund check or notice of

credit on account within five working days. 2. The chief accountant described the credit memo processing procedure as follows: When

a customer returns merchandise, the sales clerks give a smile, a “returned merchandise receipt,” and a promise to send a check or a notice within five days. The store copy of the receipt and the merchandise are sent to the purchasing department, where buyers exam- ine the merchandise for quality or damage to decide whether to put it back on the shelves, return it to the vendor, or hold it for the annual rummage sale. The buyers then prepare a brief report and send it with the returned merchandise receipt to the customer relations department for approval. The buyer’s report is filed for reference and the receipt, marked for approval in Godwin’s department, is sent to the accounting department. The account- ing department sorts the receipts in numerical order, checking the numerical sequence, and files them in preparation for the weekly batch processing of transactions other than sales and cash receipts. When the customer has requested a cash refund, the checks and canceled returned merchandise receipts are approved by the treasurer, who signs and mails the check. When the credit is on a customer’s charge account, it is shown on the next monthly statement sent to the customer.

3. The processing in each department takes two or three days.

Required: a. Analyze the problem. How much time does it take the company to process the merchan-

dise returns? b. Formulate a recommendation to solve the problem. Write a brief report explaining your

recommendation.

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D.58 GAO Auditor Independence. The GAO reporting standards for performance audits state that each report should include “recommendations for action to correct the problem areas and to improve operations.” For example, an audit of the Washington Metropolitan Area Transit Authority found management decision deficiencies affecting some $230 million in federal funds. The GAO auditors recommended that the transit authority could improve its management control over rail car procurement through better enforcement of contract requirements and development of a master plan to test cars.

Suppose the transit authority accepted and implemented specific recommendations made by the GAO auditors.

Required: Do you believe these events would be enough to impair the independence of the GAO audi- tors in a subsequent audit of the transit authority? Explain and tell whether it makes any difference to you that the same or different person performs both the first and subsequent audits.

D.59 Efficiency Standards. The U.S. Postal Service (USPS) advertises prompt delivery sched- ules for express mail (overnight delivery) and priority mail (two-to–three-day delivery). The USPS knows various risks that may arise to thwart a timely (as advertised) delivery but believes that systems and controls are in place and operating to mitigate the risks. The USPS advertised that 94 percent of express mail and 87 percent of priority mail was delivered on time from the time the mail was postmarked to the time it reached the destination post office. However, a consulting firm studied the USPS operations and determined that the express mail arrived at the recipients’ addresses on time 81 percent of the time (not 94 percent) and the priority mail arrived timely 75 percent of the time (not 87 percent).

Required: What can account for the difference in these performance statistics between the USPS deliv- ery rates and the consultant’s rates? (Hint: Think in terms of orientation to customers and standards for measuring performance.)

D.60 The Perfect Crime. Consider the following story of a real embezzlement. The embezzler hired a print shop to print a private stock of Ajax Company checks in the

company’s numerical sequence. In his job as an accounts payable clerk, he intercepted legit- imate checks written by the accounts payable department and signed by the Ajax treasurer and then destroyed them. He substituted the same-numbered check from the private stock, made it payable to himself in the same amount as the legitimate check, and “signed” it with a rubber stamp that looked enough like the Ajax Company treasurer’s signature to fool the paying bank. He deposited the money in his own bank account.

The bank statement reconciler (a different person) was able to agree the check numbers and amounts listed in the cleared items in the bank statement to the recorded cash disburse- ment (check number and amount) and thus did not notice the trick. The embezzler was able to process the vendor’s “past due” notice and next month statement with complete docu- mentation, enabling the Ajax treasurer to sign another check the next month paying both the past due balance and current charges. The embezzler was careful to scatter the double- expense payments among numerous accounts (telephone, office supplies, inventory, etc.) so the double-paid expenses did not distort accounts very much. As time passed, the embezzler was able to recommend budget figures that allowed a large enough budget so his double- paid expenses in various categories did not often pop up as large variances from the budget.

Required: List and explain the ways and means you believe someone might detect this fraud scheme. Think first about the ordinary everyday control procedures. Then think about extensive detection efforts assuming a tip or indication of a possible fraud has been received. Is this a “perfect crime”?

D.61 Impact of Changing Rules. Many companies outsource their internal audit function to CPA firms.

Required: a. What benefits might be gained from having a CPA firm provide its internal audit services? b. What benefits might be gained from having an in-house internal audit department? c. What concerns might arise from having a CPA firm provide its internal audit services?

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D.62 Looking for Evidence of Fraud. Wen-Li is an internal auditor for Main Electrical Supply in Springfield, Illinois. During her audit, she came across the invoice shown in the follow- ing exhibit. The invoice is in almost pristine condition with few marks and no creases. The invoice was properly filed in a vendor folder marked Best Office Supply, which is on the approved vendor list, but the vendor review sheet, which is required to place a vendor on the approved vendor list, is missing from the file.

Three other invoices were in the file:

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Vendor Invoice

Product

Best O�ce Supply Company P.O. Box 1934

Springfield, Illinois 62705

September 15, 2019

Bill to: Main Electrical Supply 506 Commerce Avenue Springfield, IL 62707 217-555-2230

Payment is due immediately upon receipt

Invoice #0089

10 boxes

15 cases 8 units

$3.65 $36.50 $236.40 $180.48

$453.38

$15.76 $22.56

Copy paper Pens

Total

Toner cartridges

Quantity Price per Unit Total Cost

June 14, 2019 Invoice 0076 $238.99 July 17, 2019 Invoice 0081 324.55 August 16, 2019 Invoice 0085 386.82

Required: a. Is this a legitimate invoice? What information might lead you to suspect that this invoice

may indicate a fraud? b. What type(s) of fraud might this indicate?

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LEARNING OBJECTIVES Module E provides a comprehensive example of the use of attributes sampling in the audit team’s study of internal control.

Your objectives are to be able to:

LO E-1 Identify the objectives of attributes sam- pling, define deviation conditions, and define the population for an attributes sam- pling application.

LO E-2 Understand how various factors influence the size of an attributes sample and how to determine the sample size for an attributes sampling application.

LO E-3 Identify various methods of selecting an attributes sample.

LO E-4 Evaluate the results of an attributes sampling application by determining the upper limit rate of deviation.

LO E-5 Understand how to use sequential sampling, discovery sampling, and nonstatistical sam- pling in attributes testing. 

Stephen K. Tagg, marketing faculty member, University of Strathclyde

There are five kinds of lies: lies, damned lies, statistics, politicians

quoting statistics, and novelists quoting politicians on statistics.

Attributes Sampling

M O D U L E E

Professional Standards References

Topic AU-C/ISA Section

PCAOB Reference

Consideration of Internal Control in an Integrated Audit 265 2201

Identifying and Assessing the Risks of Material Misstatement 315 2110

Auditors’ Responses to Risks of Material Misstatement 330 2301

Audit Sampling 530 2315

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INTRODUCTION During election seasons, the concept of sampling (drawing a conclusion about a population by examining a subset, or sample from that population) draws significant attention. Poll- sters attempt to predict the outcome of elections based on various methods of identifying voter sentiment; however, despite their best efforts, polling is far from an accurate science.

In the 2017 United Kingdom “snap” election, pollsters predicted the Labour party would receive 36% of the vote, allowing then prime minister Theresa May to have a majority in Parliament. In a surprising result, the Labour party received 40% of the vote, gained 40 seats, and denied Ms. May a majority.1 Similar surprises occurred in the 2016 United States presidential election (in which Donald Trump defeated Hillary Clinton) and in the 2016 Brexit vote (which saw a majority of voters support the withdrawal of the United Kingdom from the European Union). In all three cases, polling leading up to the elections would not have correctly predicted the final outcome.

These results demonstrate the potential disadvantage of using sampling: the decisions based on a sample (voters contacted or whose sentiments were otherwise assessed) may differ from decisions based on the population (the voters who actually participated in the election process). This possibility is referred to as sampling risk, and is present whenever sampling is used. Assuming that voters accurately revealed their preferences to pollsters and pollsters accurately recorded these preferences, the major cause of these outcomes is a nonrepresentative sample. For example, in the 2016 U.S. presidential election, the reluc- tance of working-class white voters (who were generally supportive of Trump) to respond to phone calls from pollsters understated Trump’s level of support among the electorate.2

The two primary areas in which sampling is used in the audit examination are: 1. Performing tests of controls to determine the operating effectiveness of internal con-

trol and assess control risk. In this case, the population of interest is instances in which client personnel were required to perform a control activity. Using sampling in this manner is referred to as attributes sampling.

2. Performing substantive tests of details to provide the necessary level of detection risk and evaluate the fairness of an account balance or class of transactions. In this case, the population of interest is transactions or components underlying the account bal- ance. Using sampling in this manner is referred to as variables sampling. Auditors apply sampling for tests of controls on almost every engagement. As you

read in Chapter 5, the Sarbanes–Oxley Act requires auditors of public companies to test the effectiveness of internal controls. Moreover, auditors of all entities should test the operating effectiveness of controls where control risk is less than 100 percent and the audit team is relying on them to reduce substantive procedures. This module focuses on the use of attributes sampling in conducting tests of controls to assess control risk, con- trol the audit team’s overall exposure to audit risk, and meet the objectives of the audit.

The importance of attributes sampling is evidenced by the following deficiencies noted by PCAOB inspection teams when reviewing tests of controls conducted by large auditing firms:3

∙ As a result of the deficiencies in the Firm’s testing of ITGCs [information technology general controls] that are described above, . . . the Firm’s testing of certain application controls using a sample of one instance of the control’s operation was not sufficient. . .

∙ The Firm identified and tested a control consisting of the monitoring of customer com- plaints related to retail deposit accounts. The Firm failed to determine whether all rel- evant customer complaints were covered by this control. In addition, to test this control, the Firm selected a sample of complaints from a population that excluded a category of complaints that constituted the majority of complaints, without having a basis to do so.

3PCAOB Report on the 2015 Inspection of KPMG LLP (November 9, 2016); PCAOB Report on 2017 Inspection of EY LLP ( September 12, 2019).

2“Epic Fail,” The Economist, November 12, 2016, pp. 29–30. 1“Democracy’s Whipping Boys,” The Economist, June 17, 2017, pp. 54-56.

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PLANNING (STEPS 1-3) Attributes sampling is used to determine the extent to which some attribute (or character- istic) exists within a population of interest. In tests of controls, that attribute is whether a specific control was properly applied by client personnel and is appropriately functioning to prevent or detect material financial statement misstatements.

The following seven-step procedure serves as the basis for our illustration of attributes sampling:

LO E-1 Identify the objectives of attributes sampling, define deviation conditions, and define the population for an attributes sampling application.

Evaluating

Performing

Planning 1. Determine the objective of sampling. 2. Define the characteristic of interest. 3. Define the population.

4. Determine the sample size. 5. Select the sample items. 6. Measure the sample items.

7. Evaluate the sample results.

D o c u m e n t a t i o n

To illustrate the application of the process, we focus on the audit team’s study and evaluation of important controls for the revenue cycle of AirCon Company, a manufac- turer of high-technology products.

Step 1: Determine the Objective of Sampling The first step in the attributes sampling process is to identify the objective of attributes sampling, which is related to examining key controls corresponding to the management assertions of interest to the audit team. For the examination of AirCon’s revenue cycle, the two major assertions of interest are occurrence (does the recorded sale represent an actual sale made to a customer?) and accuracy (has the sale been recorded at the proper dollar amount?). Once the relevant assertions have been determined, the audit team then specifies one or more controls that, if functioning, allow the client to meet the recording objectives related to these assertions. The following is a summary of the assertions and one relevant control that will be tested.4

Assertion Control

Occurrence Sales invoices are supported by a valid shipping document5 

Accuracy Sales invoices are initialed by client personnel as evidence of verification of mathematical accuracy

Step 2: Define the Characteristic of Interest Once the specific controls have been identified, the audit team must next define the char- acteristic of interest; in an attributes sampling context, this is a deviation condition. The word deviation (commonly referred to as exception) refers to instances in which the client or its personnel do not follow prescribed controls; in other words, deviations are instances

5Of course, the possibility exists that the shipping document was fraudulently prepared in an effort to increase sales. However, this possibility is beyond the scope of our discussion of attributes sampling.

4In practice, a greater number of controls would pertain to the occurrence and accuracy assertions. We limit the number of con- trols examined by the audit team to focus on the application of attributes sampling.

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in which controls are not functioning as intended. Defining the deviation conditions at the outset is important because deviation conditions provide the audit team evidence regarding the operating effectiveness of the client’s internal control.

AirCon’s control activities indicate that authorized client personnel should write their initials in a preprinted “verified by” space on the invoice after mathematically verifying the accuracy of each sales invoice. For the control activity that a sales invoice must be supported by a valid shipping document, a deviation would be a situation in which a ship- ping document does not exist to support a sales invoice. The deviation conditions defined by the audit team are as follows:

Assertion Control Example of Deviation

Occurrence Sales invoices are supported by a valid shipping document

Instance in which sales invoice is not accompanied by a valid shipping document

Accuracy Sales invoices are initialed by client personnel as evidence of verification of mathematical accuracy

Lack of authorized employee initials on sales invoice or mathematically incorrect invoice

A deviation does not necessarily indicate that an error in processing a transaction has occurred. For example, an employee could have mathematically verified a sales invoice but forgotten to record his or her initials on the sales invoice. In addition, the invoice could be correctly calculated regardless of whether the invoice was verified. However, the failure of client employees to document their performance of key controls represents a deviation from that control activity and should be investigated. Further, the documenta- tion may be initialed, but not by an authorized employee.

Step 3: Define the Population The population is the set of all items about which a conclusion is desired. In attributes sam- pling, the population represents all potential occurrences of the control activity of interest. Population definition is important because audit conclusions can be made only about the population from which the sample was selected. For example, consider the following rela- tionships between the sales invoice and shipping document in the revenue cycle:

Shipping Document (transaction occurred)

Sales Invoice (transaction is recorded)

Have all sales been recorded?

(Completeness)

Are all recorded sales valid?

(Occurrence)

Tracing

Vouching

Notice that, by defining the population as sales invoices, the audit team is examining only transactions that have been recorded. As a result, this population cannot be used to provide evidence for the completeness assertion. However, this population is appropriate if the audit team is interested in verifying that all recorded sales invoices represent valid transactions (as evidenced by the presence of shipping documents), which corresponds to the occurrence assertion. As a result, the population should be defined as all sales invoices prepared by AirCon during the period under audit.

When defining the population, the audit team also needs to determine the physical representation of the population. The physical representation is the frame of reference that the audit team uses in selecting the sample, also referred to as the source of the sample.

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That is, the audit team will select the sample from the physical representation. Some pos- sible physical representations for selecting a sample of sales invoices include

∙ A journal list of recorded sales invoices. ∙ Copies of sales invoices contained in a file. ∙ A computerized list of sales invoices.

The primary concerns about the physical representation are that it is complete and corresponds with the actual population. If tests of controls are performed at an interim date, the audit team should extend tests from the interim date to the date of the financial statements and ensure that the final population includes all transactions (and possible applications of controls) for the period under audit. This can be done by footing a sales journal and agreeing the total of sales to the general ledger.

AirCon Company has a computerized list of all sales invoices prepared during the year. It can be sorted by date, customer, or dollar amount. The audit team will use this listing to select the sample.

The first three steps in the sampling process for AirCon Company are summarized next.

PERFORMING (STEPS 4-6) Step 4: Determine the Sample Size The sample size represents the number of items that the audit team examines within a population of interest. Four main factors influence the sample size in an attributes sam- pling application:

1. Tolerable rate of deviation. 2. Sampling risk (risk of overreliance, or risk of assessing control risk too low). 3. Expected population deviation rate. 4. Population size.

LO E-2 Understand how various factors influence the size of an attributes sample and how to determine the sample size for an attributes sampling application.

REVIEW CHECKPOINTS E.1 Define attributes sampling. In what stage of the audit would it be used? E.2 How do the management assertions relate to the objectives of attributes sampling? E.3 Define deviation condition. Why are deviation conditions so important in an attributes sampling

application? E.4 Why is appropriately defining the population of interest so important in an attributes sampling

application?

Step 1 The audit team’s objective in sampling is to evaluate the operating effectiveness of controls related to the occurrence and accuracy assertions.

Step 2 The audit team defined deviation conditions as (a) lack of employee initials on sales invoices or mathematical error on a sales invoice (accuracy) and (b) a sales invoice that is not accompanied by a shipping docu- ment (occurrence).

Step 3 The audit team defined the population as a computerized list of all sales invoices prepared during the year and verified the completeness and accuracy of the listing.

Summary: Steps 1–3 in the Sampling Process for AirCon Company

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Tolerable Rate of Deviation Because of human involvement and error, audit teams cannot expect controls to be func- tioning 100 percent of the time. In evaluating whether controls are functioning effect- ively, the question does remain about the extent to which deviations are permissible while still allowing the audit team to appropriately rely on the control.

The tolerable rate of deviation is the maximum rate of deviations permissible by the audit team without modifying the planned assessed level of control risk. In determining the tolerable rate of deviation, the audit team should consider (1) the planned assessed level of control risk and (2) the degree of assurance desired by the audit evidence in the sample. Generally, if a control is judged to be more important and would result in a more significant reduction in substantive testing, the tolerable rate of deviation should be established at lower levels.

Exhibit E.1 illustrates how the tolerable rate of deviation can be related to control risk assessments. Although control risk is rarely assessed numerically in practice, note that lower levels of control risk are associated with lower tolerable rates of deviation (and vice versa). Using Exhibit E.1, if the audit team established a low acceptable control risk (between 0.10 and 0.30), the corresponding tolerable rate of deviation would range from 3 to 7 percent.

Assume that AirCon Company’s control risk was assessed at a low level (0.30) for the occurrence assertion and a moderate level (0.50) for the accuracy assertion. Using the matrix in Exhibit E.1, the audit team translated these assessments into tolerable rate of deviation of 6 percent and 10 percent for the controls related to the occurrence and accur- acy assertions, respectively.

Sampling Risk Sampling risk is the likelihood that the decision made based on the sample differs from the decision that would have been made had the entire population been examined. There are two types of sampling risks for attributes sampling applications: the risk of underreliance and the risk of overreliance (sometimes referred to as the risk of assessing control risk too high and the risk of assessing control risk too low, respectively). Exhibit E.2 summarizes some of the key characteristics of these risks.

Because the risk of overreliance results in the audit team’s failure to reduce audit risk to acceptable levels (an effectiveness loss), controlling exposure to this risk is of primary importance. Although the risk of underreliance is also a form of sampling risk, this risk will actually result in the audit team achieving a lower level of audit risk than planned. Therefore, in an attributes sampling plan, the audit team will typically control only the exposure to the risk of overreliance in determining the appropriate sample size.

The appropriate risk of overreliance is based on the planned level of control risk; as the audit team wishes to place a greater degree of reliance on internal controls (lower control risk), the risk of overreliance must be controlled to lower levels. Refer to Exhibit E.1 and recall that the audit team has decided to assess control risk at low levels (0.30) for the occurrence assertion and moderate levels (0.50) for the accuracy assertion. Based on the relationships in Exhibit E.1, these assessments of control risk are translated into 5 percent and 10 percent risks of overreliance for the controls related to the occurrence and accur- acy assertions, respectively.6

6Exhibit F.1 reflects the common practice of selecting one of two levels of the risk of overreliance (5 percent and 10 percent).

Control Risk (Qualitative) Control Risk

(Quantitative) Tolerable Rate of

Deviation Risk of

Overreliance

Low 0.10–0.30 3%–7% 5%

Moderate 0.40–0.60 6%–12% 5%–10%

Slightly below maximum 0.70–0.90 11%–20% 10%

Maximum 1.00           Not applicable Not applicable

EXHIBIT E.1 Effect of Control Risk Assessments on Tolerable Rate of Deviation and Risk of Overreliance

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Expected Population Deviation Rate Audit teams usually know or suspect that some level of deviation occurs in the client’s internal control activities; this rate is referred to as the expected population deviation rate. The concept of reasonable assurance suggests that the client’s internal control activities will not function perfectly (i.e., a zero rate of deviation). Thus, some level of deviations is typically observed and is incorporated into the determination of sample size.

How is the expected population deviation rate determined? If the client represents a recurring engagement, the audit team has some knowledge of rate of deviations from prior engagements. These rates might need to be adjusted if changes in the client’s con- trols have occurred since the prior audit, but previous-year rates serve as a reasonable starting point. For example, if the observed rate of deviation from prior audits was 4 percent but the audit team is aware of improvement in controls, the current-year rate of deviation could be estimated at a lower level (say, 3 percent). If, on the other hand, the engagement is a first-year engagement, the audit team might use a small sample (referred to as a pilot sample) to estimate the rate of deviations.

Based on their previous experience in examining the operating effectiveness of these controls for AirCon Company, the audit team assessed the expected population deviation rate at 2 percent and 3.5 percent for the controls related to the occurrence and accuracy assertions, respectively.

Population Size Common sense probably tells you that samples should be larger for larger populations (a direct relationship). Strictly speaking, your common sense is accurate; clearly, the sample size for a population of 10 items would be smaller than for a population of 1,000 items. However, once a population reaches a certain size, any increase has a minimal effect on sample size. As a result, unless the population size is very small (which is not common for most attributes sampling applications), the audit team does not consider population size in determining sample size to a great extent.

To illustrate, the AICPA Audit Guide Auditing Sampling provides the following sam- ple sizes for different populations for the same level of the risk of overreliance, expected population deviation rate, and tolerable rate of deviation:

Population Size Sample Size

   100 33

   200 35

   500 37

1,000 37

1,500 38

2,000 38

EXHIBIT E.2 Sampling Risks Associated with Attributes Sampling

Sampling Risk Sample Results Unknown State of the Population Loss

Risk of underreliance (risk of assessing control risk too high)

Adjusted sample rate of deviation > Tolerable rate of deviation Conclusion: Control is not functioning effectively

Population rate of deviation ≤ Tolerable rate of deviation Conclusion: Control is functioning effectively

Efficiency loss because additional substantive procedures will be performed

Risk of overreliance (risk of assessing control risk too low)

Adjusted sample rate of deviation ≤ Tolerable rate of deviation Conclusion: Control is functioning effectively

Population rate of deviation > Tolerable rate of deviation Conclusion: Control is not functioning effectively

Effectiveness loss because an insufficient level of substantive procedures will be performed

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The preceding illustrates that, once the population exceeds 500 items, the effect of population size on sample size is relatively limited. Because AirCon processes more than 20,000 sales invoices per year, the population is of sufficient size not to influence the audit team’s sample size. What about extremely small sample sizes? Often, controls such as bank reconciliations are only performed monthly or at some other interval; as such, this type of control has a population size of only 12 items in a given year. Exhibit  E.3 suggests the sample sizes in such circumstances.

Summary of Sample Size Factors Exhibit  E.4 summarizes the general relationships between the factors discussed in this section and sample size.

A survey of the sampling practices of six international accounting firms (including the Big Four) revealed the following levels of parameters used in practice (these parameters provided a range of sample sizes for the six firms from 22 items to 59 items:)7

∙ Risk of overreliance: Between 5 percent and 10 percent. ∙ Expected population deviation rate: Generally 0 percent. ∙ Tolerable rate of deviation: Between 5 percent and 10 percent.

Using AICPA Sampling Tables to Determine Sample Size How does the audit team use the preceding factors in determining sample size? The AICPA has developed sampling tables that specifically incorporate the (1) risk of over- reliance, (2) expected population deviation rate, and (3) tolerable rate of deviation. These tables also identify the number of deviations the audit team can find and still accept the control as operating effectively (number of expected deviations), which can give the audit team an idea of whether the sample size is realistic. In practice, computer programs are frequently used to determine sample size; these programs follow the logic of the

7B. E.Christensen, R.J. Elder, and S.M. Glover, “Behind the Numbers: Insights into Large Audit Firm Sampling Policies,” Accounting Horizons, March 2015, pp. 61–81.

EXHIBIT E.3 Sample Sizes for Small Audit Populations

Control Frequency and Population Size Sample Size

Quarterly (4) 2

Monthly (12) 2–4

Semimonthly (24) 3–8

Weekly (52) 5–9 Source: AICPA Audit Guide Audit Sampling.

EXHIBIT E.4 Factors Affecting Sample Size

Factor Determination Based On

Relationship with Sample Size

Level for AirCon

Tolerable rate of deviation Level of control risk Inverse 6% (occurrence) 10% (accuracy)

Sampling risk (risk of overreliance)

Level of control risk Inverse 5% (occurrence) 10% (accuracy)

Expected population deviation rate

Prior audits (for recurring engagements) or a pilot sample of controls (for first-year engagements)

Direct 2% (occurrence) 3.5% (accuracy)

Population size Number of applications of control to transactions

Direct Greater than 20,000 invoices

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statistical formulas that are used to construct the AICPA sampling tables. The AICPA tables are used as follows:

1. Based on the risk of overreliance, select the appropriate sample size table in Appendix  E.A. Tables for a 5 percent and 10 percent risk of overreliance are repro- duced as Exhibits E.A.1 and EA.2, respectively.

2. Identify the row of the table corresponding to the expected population deviation rate for the control being examined.

3. Identify the column of the table representing the assessed tolerable rate of deviation for the control being examined.

4. Determine the sample size by identifying the junction of the row from step 2 and the column from step 3.

Referring to the sample size table in Exhibit E.A.1 (5 percent risk of overreliance) and reading the sample size at the intersection of the 2 percent expected population deviation rate row and the 6 percent tolerable rate of deviation column reveals a sample size for the control related to the occurrence assertion of 127 items.

This can be seen using the following excerpt from Exhibit E.A.1:

361 195 129

127 88

66

7%6%5%

3.00%

2.00%

1.00%

Expected Population Deviation Rate

Tolerable Rate of Deviation

93 78

181

Using the sample size table in Exhibit  E.A.2 (10 percent risk of overreliance) and reading the sample size at the intersection of the 3.5 percent expected population devia- tion rate row and the 10 percent tolerable rate of deviation column reveals a sample size for the test of controls related to the accuracy assertion of 52 items.8

In practice, audit teams utilize software in performing sampling plans. Throughout this module, we illustrate the use of IDEA Data Analysis Software in various stages of the attributes sampling process.

Using IDEA to Determine Sample Size Using the Analysis>Sample>Attribute function and the Planning (Beta Risk Control) tab provides the following data entry screen for the control related to the occurrence assertion.9

9More detailed information on the use of IDEA in the attributes sampling process (including additional input and output screens and screens for the control relating to the accuracy assertion) can be found in Connect.

Step 4 Based on the acceptable risk of overreliance, expected population deviation rate, and tolerable rate of deviation, the audit team determined

sample sizes of 127 (for the control related to the occurrence assertion) and 52 (for the control related to the accuracy assertion).

Summary: Step 4 in the Sampling Process for AirCon Company

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Key elements in the above include (data input by audit team are shown in brackets):

∙ The tab “Planning (Beta Risk Control)” corresponds to controlling the risk of overreliance.  ∙ The audit team enters the “Population size” (number of transactions) (note that IDEA

will not accept entries with commas). [20000] ∙ The audit team enters the “% Tolerable deviation rate”, which corresponds to the tol-

erable rate of deviation(note that percentage signs are not entered for this and other parameters). [6.00]

∙ The audit team enters the “% Expected deviation rate”, which corresponds to the expected population deviation rate. [2.00]

∙ The audit team enters the “Confidence level (to control Beta Risk)”, which corres- ponds to 1 – the risk of overreliance. [95.00]

Based on these parameters, IDEA provides a sample size of 127 items. The “Critical number of deviations in sample” (3) is the number of deviations that can be observed without reducing reliance on controls. Note from the highlighted row in the table that, at 3 deviations, the “Achieved Confidence” is 95.11% (which corresponds to a risk of over- reliance of 4.89%). A fourth deviation would increase the risk of overreliance of 11.47% (100% - 88.53% = 11.47%).

REVIEW CHECKPOINTS E.5 Define the terms (a) sampling risk, (b) tolerable rate of deviation, and (c) expected population

deviation rate. How does the audit team assess or determine these factors? E.6 What two types of sampling risks could an audit team encounter when performing attributes sampling? E.7 In attributes sampling, why is the risk of overreliance more important than the risk of underreliance? E.8 What is the relationship between sample size and (a) sampling risk, (b) tolerable rate of deviation,

and (c) expected population deviation rate? E.9 Describe the general procedure used by the audit team to determine sample size using AICPA sam-

pling tables.

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Step 5: Select the Sample Items After determining the appropriate sample size, the audit team then selects sample items from the population. The audit team’s basic goal in selecting a sample is to increase the likelihood that it is representative of the population, thereby reducing sampling risk. For example, if the audit team is examining a sample of sales invoices, this sample should include sales invoices that

∙ Have been prepared throughout the year. ∙ Represent both large and small dollar amounts. ∙ Have been prepared by different individuals involved in the invoice preparation process. ∙ Represent different customers or geographic areas.

To illustrate, considering the first item, if sales invoices for only the month of November are examined, differences in the persons, processes, or other factors involved in the prep- aration or processing of sales invoices in the month of November can result in a nonrepre- sentative sample.

The audit team then selects the sample from the population. Two common methods used are unrestricted random selection and systematic random selection.

∙ When using  unrestricted random selection (also known as random selection), the audit team identifies a series of random numbers equal to the desired sample size and selects the numbered item in the corresponding population (for example, selecting the 120th, 268th, 341st, etc. sales invoices comprising AirCon’s population of sales invoices).

∙ When using  systematic random selection (commonly referred to as systematic selection), the audit team identifies a random starting point in the population and then bypasses (or “skips”) a fixed number of items (referred to as the sampling interval) and selects the corresponding items until the appropriate number of items has been selected. The sampling interval is determined by dividing the number of items in the population by the desired sample size. 

Two other methods of selecting samples are block selection (which involves the selec- tion of a series of contiguous or adjacent items) and haphazard selection (which selects items in an unstructured manner without intentional bias). A recent survey of the sam- pling practices of six international accounting firms (including the Big Four) concluded that unrestricted random selection and systematic random selection are generally pre- ferred, with haphazard selection being the least preferred method.10

LO E-3 Identify various methods of selecting an attributes sample.

10B.E.Christensen, R.J. Elder, and S.M. Glover, “Behind the Numbers: Insights into Large Audit Firm Sampling Policies,” Accounting Horizons, March 2015, pp. 61–81.

Selecting the Sample Using IDEA For populations maintained in electronic format, IDEA can be used to select samples using either unrestricted random selection or systematic random selection. More detailed information and sample input and output screens can be found in Connect.

Step 6: Measure the Sample Items Once the audit team has determined the sample size (step 4) and selected the sample items (step 5), they are ready to measure the sample items. When measuring the sample items in an attributes sampling application, the audit team determines whether the control

Step 5 The audit team determined the completeness and accuracy of the population and selected 127 invoices. The first 52 were examined for both the controls related to the accuracy and occurrence assertions

and the final 75 were examined for the control related to the occurrence assertion (recall that the sample sizes for the controls related to the accur- acy and occurrence assertions were 52 and 127, respectively.)

Summary: Step 5 in the Sampling Process for AirCon Company

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has been appropriately performed. It is important that the audit team not reperform the control activity but rather examine some form of evidence that client personnel performed it. If there is no evidence of the control being performed, the item will be classified as a deviation. The audit team examines evidence on the operating effectiveness of important controls by performing tests of controls.

Although measuring sample items is typically straightforward, one issue that could arise relates to missing items. For example, when evaluating a control related to a sales invoice that cannot be located, the audit team would classify this particular item as a devi- ation. The fact that the document is missing could indeed reflect the fact that a control was not applied in the intended manner and the related document has been intentionally destroyed or removed from the physical representation of the population.

Measuring sample items is the step in the sampling process when nonsampling risk can occur. Nonsampling risk is the risk that the audit team’s sample provides an incorrect conclusion for reasons other than the representativeness of the sample. For example, the audit team could make an unintentional error in evaluating evidence (such as classify- ing a deviation as a nondeviation or vice versa) or may fail to recognize that initials on a document are not those of an appropriate individual.

As noted earlier, the audit team’s tests of controls were to verify the existence of valid shipping documents to support sales invoices (control related to the occurrence assertion) and verify the initials of client employees indicating mathematical verification of sales invoices (control related to the accuracy assertion).

REVIEW CHECKPOINTS E.10 What are some important considerations for the audit team when selecting sample items? E.11 What are tests of controls? What is the audit team’s goal in performing them in an attributes sam-

pling application? E.12 When performing tests of controls, how would the audit team classify a situation when encounter-

ing a missing item?

EVALUATING SAMPLE RESULTS (STEP 7) Calculating the Upper Limit Rate of Deviation After measuring sample items, the audit team can calculate a sample rate of deviation, which represents the rate of deviations from key controls noted by the audit team mem- bers in their sample. The sample rate of deviation is calculated by dividing the number of deviations noted in the sample by the sample size. Thus, the sample rate of deviation for the controls related to the occurrence and accuracy assertions were 1.6 percent (2 devia- tions ÷ 127 invoices) and 7.7 percent (4 deviations ÷ 52 invoices), respectively. Because the tolerable rates of deviation for these controls are 6 percent and 10 percent, respect- ively, the audit team’s initial conclusion might be to rely on the controls as planned because the sample rate of deviation is less than the tolerable rate of deviation.

What is the fallacy with this approach? The audit team’s sample might not represent the population, and the sample rate of deviation may significantly understate the true population rate of deviation. Although audit teams never know the true population rate of

LO E-4 Evaluate the results of an attributes sampling application by determining the upper limit rate of deviation.

Step 6 The audit team’s tests of controls identified two deviations for the control related to the occurrence assertion and four deviations for the control related to the accuracy assertion.

Summary: Step 6 in the Sampling Process for AirCon Company

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deviation with any certainty, they can use sampling tables to “adjust” the sample rate of deviation to one that has a certain probability of equaling or exceeding the true rate of deviation. Simply stated, this adjusted rate (the upper limit rate of deviation, or ULRD) pro- vides a conservative estimate of the population rate of deviation that allows the audit team to control exposure to sampling risk to acceptable levels.

The ULRD provides the following information: ∙ There is a 1 − Risk of overreliance probability that the true population rate of devia-

tion is less than or equal to the ULRD. ∙ There is a risk of overreliance probability that the true population rate of deviation

exceeds the ULRD. Exhibits E.B.1 and E.B.2 in Appendix E.B allow the ULRD to be determined for an

acceptable risk of overreliance of 5 percent and 10 percent, as follows: 1. Based on the acceptable risk of overreliance, select the appropriate evaluation table. 2. Identify the row representing the appropriate sample size. 3. Identify the column corresponding to the number of deviations found by the audit team. 4. The ULRD is the value found at the intersection of the row in step 2 and the column

in step 3. To illustrate the use of sample evaluation tables, consider the findings for the control

activity related to the occurrence assertion for AirCon Company. Recall that the audit team examined a sample of 127 sales invoices for the potential functioning of this con- trol, found two deviations, and calculated a sample rate of deviation of 1.6 percent. Using Exhibit  E.B.1 (for a risk of overreliance of 5 percent), the audit team would locate the row corresponding to a sample size of 127 items and the column for two deviations. Note that Exhibit  E.B.1 contains a row for sample sizes of 125 and 150 but not 127. When choosing between two samples to use in this table, it is more conservative to use the smaller number. In this instance, the audit team can do one of the following: 1. Select an additional 23 items for examination for a sample size of 150 (the next highest

sample size in the sample evaluation table). 2. Evaluate the results of the sample using a smaller sample size of 125. This provides a

conservative (higher) measure of the ULRD because the same number of deviations will be attributed to a smaller number of sample items.

3. Interpolate the values in Exhibit E.B.1 and estimate a ULRD for a sample of 127 items. Because the original sample of 127 is very close to the sample size row of 125, assume

that the audit team evaluates the two deviations using a sample size of 125. Reading the value in the table at the intersection of this row and column reveals a ULRD of 5.0  percent, as shown in the following excerpt from Exhibit E.B.1.

2.0 3.2 4.2

3.8 5.0

6.2

210

150

125

100

Sample Size Actual Number of Deviations Found

3.0 4.7

2.4

The ULRD is composed of the following components:

∙ A sample rate of deviation of 1.6 percent (2 deviations ÷ 127 items = 1.6%).11

∙ An allowance for sampling risk of 3.4 percent (ULRD of 5.0% − Sample rate of devia- tion of 1.6% = 3.4%). The allowance for sampling risk represents the “adjustment” of the sample rate of deviation for the acceptable risk of overreliance.

11The fact that the audit team uses a sample size of 125 items to determine the ULRD does not affect the calculation of the sample rate of deviation using the original sample size (127 items).

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Now let us consider the results for the control related to the accuracy assertion. Using a risk of overreliance of 10 percent ( Exhibit E.B.2), note that a row for a sample of 52 items is not shown. Again, because this sample size is close to the row for a sample size of 50 and using 50 is more conservative than using 55 (the next available row in Exhibit E.B.2), the four deviations would be evaluated using a sample size of 50. Reading the ULRD at the intersection of the row for a sample size of 50 and the column for 4 deviations yields a ULRD of 15.4 percent. This ULRD is comprised of a sample rate of deviation of 7.7  percent12 and an allowance for sampling risk of 7.7 percent (15.4% − 7.7% = 7.7%). In this case, the ULRD of 15.4 percent exceeds the tolerable rate of deviation of 10 percent.

REVIEW CHECKPOINTS E.13 What is the sample rate of deviation? How does the audit team calculate it? E.14 What is the ULRD? What information does the ULRD provide to the audit team? E.15 What factors influence the determination of the ULRD? E.16 Describe the general process used to determine the ULRD using AICPA sampling tables. E.17 What options are available to the audit team for determining the ULRD if the audit team’s sample

size is not included in the AICPA sampling tables? E.18 If the audit team examines a sample of 100 items, finds six deviations, and calculates a ULRD of

10.3 percent, what is the allowance for sampling risk?

Making the Evaluation Decision The audit team’s decision rule after calculating the ULRD can be summarized as follows:

How would the audit team proceed from this point? Because the ULRD for the control related to the occurrence assertion (5.0 percent) is less than the tolerable rate of deviation (6.0 percent), it appears that the control for the occurrence assertion is functioning effect- ively. As a result, the audit team could decide to rely on internal control as planned and maintain the planned level of control risk as well as the planned level of detection risk.

For the control related to the accuracy assertion, since the ULRD (15.4 percent) exceeds the tolerable rate of deviation (10.0 percent), the audit team has one of two options. The first option is to reduce the planned degree of reliance on internal control, increase the planned level of control risk, and reduce the planned level of detection risk by performing more effective substantive procedures. Referring to Exhibit E.1, assume that a tolerable rate of deviation of 16 percent corresponds to a control risk assessment of 0.80 (slightly below maximum). Thus, without gathering any further evidence, the audit team could increase the assessment of control risk from 0.50 (moderate) to 0.80

12The fact that the audit team uses a sample size of 50 items to determine the ULRD does not affect the calculation of the sam- ple rate of deviation using the original sample size of 52 items (4 deviations ÷ 52 items = 7.7% sample rate of deviation).

ULRD

ULRD

Tolerable Rate of Deviation

Tolerable Rate of Deviation

• Reduce reliance on internal control and increase control risk • Expand sample size and perform additional tests of controls

>

≤ Rely on internal control as planned and maintain control risk at planned levels

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(slightly below maximum) and correspondingly decrease the necessary level of detection risk. This decrease in the necessary level of detection risk would require the audit team to perform more effective substantive procedures.

Alternatively, the audit team could attempt to reduce the ULRD to a level below the tolerable rate of deviation of 10 percent by examining an expanded sample of controls. The following excerpted rows from Exhibit  E.B.2 show the ULRDs corresponding to situations in which four deviations are identified (reflecting the deviations identified by the audit team). As shown, if a total of 80 items is examined and no additional deviations are noted, the ULRD is 9.8 percent. Therefore, one option available to the audit team is to examine an additional 28 items (80 items − original sample of 52 items). Because addi- tional deviations are likely to be identified, examining additional items is generally not an effective solution unless the ULRD is very close to the tolerable rate of deviation.13

ULRD calculated based on original sample

Sample Size Deviations = 4 40 19.0%

15.4 12.9 11. 1

9.8

50 60 70 80

Potential ULRD if additional items examined with no deviations

13The AICPA Audit Guide Audit Sampling recommends as a rule of thumb that if the audit team decides to test more items, then the team members increase the sample by at least the number of items in the original sample.

Which option would the audit team select? This decision depends on the relative costs of increasing the tests of controls versus the costs associated with performing more extensive substantive procedures. If the cost of examining additional items is relatively low and the likelihood of observing no additional deviations is high, the audit team would likely decide to extend the sample of controls. However, if the cost of selecting and evalu- ating additional items is relatively high and the audit team is likely to encounter addi- tional deviations, it could be more cost effective to perform more effective substantive procedures. Either approach will maintain audit risk at an acceptable level.

Qualitative Evaluation of Deviations The focus thus far has been on quantitative factors: sample sizes, numbers of deviations, tolerable rate of deviation, and ULRD. Regardless of the results of the attributes sam- pling application, the audit team should conduct a qualitative evaluation of deviations to determine their nature and cause. In some cases, deviations can truly represent an isolated incident on a specific transaction; in others, they can represent something far more serious.

A qualitative evaluation of deviations attempts to answer questions such as these with regard to observed deviations:

∙ Do deviations represent a pervasive error made consistently on all transactions or an isolated mistake made on a specific transaction?

∙ Are deviations intentional or unintentional in nature? ∙ Do deviations represent a misunderstanding of instructions or careless attention to duties? ∙ Do deviations have implications with regard to the effectiveness of other controls (for

example, information technology general controls or other Committee of Sponsoring Organizations of the Treadway Commission, or COSO, components)?

If any deviations appear to be pervasively occurring throughout the sample, to represent intentional actions on the part of client employees, to represent careless attention, or to have implications with respect to other controls, they have additional implications for the audit and should be discussed with the client and its audit committee. In addition, for public enti- ties, these deviations may reflect significant deficiencies or material weaknesses that must be disclosed in the audit team’s report on internal control over financial reporting.

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Using IDEA to Evaluate Sample Results Using IDEA to Evaluate Sample Results Using the Analysis>Sample>Attribute function and the Sample Evaluation tab pro- vides the following data entry screen for the control related to the occurrence assertion:

Key elements in the above include (data input by the audit team are shown in brackets): ∙ The tab “Sample Evaluation” is used to evaluate the results of the sample after per-

forming tests of controls. ∙ The audit team enters the “Population size” (number of transactions) (note that IDEA

will not accept entries with commas). [20000] ∙ The audit team enters the “Sample size”. [127] ∙ The audit team enters the “Number of deviations in the sample”. [2] ∙ The audit team enters the “% Desired confidence level”, which corresponds to 1 – the

risk of overreliance. [95.00%] Based on these parameters, IDEA calculates a sample deviation rate of 1.57% and a

“1-Sided Upper Limit” of 4.86% (which corresponds to the ULRD). The “Conclusion” indicates that, at a 95% confidence level (5% risk of overreliance), the population devi- ation rate is less than or equal to 4.86% (the ULRD). Since the ULRD is less than the tolerable rate of deviation, the audit team would conclude that the control is functioning correctly and can rely on control risk at planned levels.

Step 7 The audit team determined a ULRD of 5.0 percent and 15.4 per- cent for the controls related to the occurrence and accuracy assertions, respectively. Based on a comparison of the ULRD to the tolerable rate of deviation, the audit team would

• Conclude that the control related to the occurrence assertion is func- tioning effectively and rely on internal control as planned.

• Conclude that the control related to the accuracy assertion is not func- tioning  effectively and either (1) reduce reliance on internal control or (2) expand the sample to examine a larger number of items.

Summary: Step 7 in the Sampling Process for AirCon Company

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DOCUMENTING Exhibit E.5 summarizes the audit documentation related to the AirCon example discussed throughout this module. Note that it includes the following information:

∙ Parameters used to determine sample size (control risk, risk of overreliance, tolerable rate of deviation, expected population deviation rate)

∙ Description of method used to select sample ∙ Sample items selected ∙ Measurement of sample items (identification of deviations) ∙ ULRD ∙ Conclusions with respect to the operation of the occurrence and accuracy controls

EXHIBIT E.5 Sample Audit Documentation for AirCon Company Tests of Controls

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OTHER ATTRIBUTES SAMPLING METHODS Sequential sampling methods provide the audit team the opportunity to draw conclusions using a smaller sample than a traditional fixed sampling plan. It is sometimes called “stop-or-go” sampling because the plan allows the audit team to stop after examining a relatively small sample and evaluate the results. If the results are clearly acceptable or clearly unacceptable, the audit team can draw its conclusion; if the results are inconclu- sive, the audit team can go forward and examine additional items.

A significant advantage of sequential sampling methods is that they could allow the audit team to evaluate the operating effectiveness of controls more efficiently. One dis- advantage of these methods is that the allowable rate of deviations in the sample is lower than that in a fixed sampling plan (i.e., sequential sampling is more conservative). In addition, the audit team should be careful in continuing to extend the sample using a sequential sampling approach if the preliminary sample evidence does not support the planned level of control risk (in other words, once the audit team has determined that the control is not functioning effectively, there is no reason to expand testing).

Another variation of attributes sampling is discovery sampling, a form of attributes sampling that is used when deviations from controls are very critical yet are expected to occur at a relatively low rate. Discovery sampling should be used when a control is extremely important for the audit team’s examination or when the audit team suspects the existence of fraud. In this situation, the audit team uses sample sizes from Exhibits EA.1 and EA.2 corresponding to an expected population deviation rate of 0 percent. Then, if even one deviation is discovered, the audit team stops immediately and concludes that the control is not operating effectively.

Nonstatistical sampling methods are permissible under generally accepted auditing stan- dards and differ from the statistical methods discussed in this chapter as follows:

1. The audit team may judgmentally determine the sample size and is not required to quantify the various parameters (although the sample sizes under statistical and non- statistical methods should be comparable).

2. The audit team may use nonrandom methods in selecting sample items, such as block selection or haphazard selection.

3. The audit team may judgmentally evaluate sample results, based on the sample rate of deviation and tolerable rate of deviation.

A recent survey of the sampling practices of six international accounting firms (includ- ing the Big Four) found that the firms either explicitly require the use of statistical meth- ods or ensure that the sample sizes and sampling conclusions reached with nonstatistical methods are comparable to those if statistical methods were used, suggesting that nonsta- tistical methods are not frequently used in practice.14

LO E-5 Understand how to use sequential sampling, discovery sampling, and nonstatistical sampling in attributes testing.

14B.E.Christensen, R.J. Elder, and S.M. Glover, “Behind the Numbers: Insights into Large Audit Firm Sampling Policies,” Accounting Horizons, March 2015, pp. 61–81.

REVIEW CHECKPOINTS E.19 What is the audit team’s decision rule with respect to the relationship between the ULRD and the

tolerable rate of deviation? E.20 What options are available to the audit team if the ULRD is less than or equal to the tolerable rate

of deviation? E.21 What options are available to the audit team if the ULRD is greater than the tolerable rate of

deviation? E.22 What information does the audit team typically document in an attributes sampling application?

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REVIEW CHECKPOINTS E.23 What is sequential sampling? What are its advantages and disadvantages? E.24 Define discovery sampling. When is it typically used? E.25 In what steps of a sampling plan would the use of nonstatistical sampling differ from the use of

statistical sampling? E.26 How should an audit team using nonstatistical sampling for attributes testing evaluate the results

of the test?

The following excerpts from 2016–2018 PCAOB inspection reports of audits conducted by the Big Four firms (Deloitte, EY, KPMG, and PwC) illustrate issues identified in the attributes sampling applications con- ducted by these firms.

• The Firm failed to sufficiently test the operating effectiveness of a control that it selected for testing, which consisted of the updating and approval of loan data that the issuer used in the calculation of the Allowance for Loan Losses. Specifically, the Firm failed to test the completeness of the population from which it selected its sample of loans for testing this control.

• The Firm selected for testing a control over this revenue that con- sisted of (1) the comparison, by contract, of accrued revenue for the current month to both accrued revenue for the prior month and amounts invoiced during the current month and (2) the inves-

tigation of variances over an established threshold. . . The Firm’s testing of this control, however, was insufficient as the Firm failed to obtain sufficient evidence to conclude that the control operated effectively. Specifically, the Firm’s sample to test this control was too small in light of the frequency that the control operated.

• With respect to the subsidiary for which the Firm was instructed to perform certain procedures on the financial statements and [inter- nal control over financial reporting], the Firm tested a control that consisted of the preparation and review of the inventory allow- ance and deemed this control to be ineffective; the Firm did not identify and test any other controls that addressed the inventory allowance.

Source: PCAOB website, www.pcaobus.org/Inspections/Reports/Pages/ default.aspx.

PCAOB Findings for Attributes SamplingAUDITING INSIGHT

This module discusses attributes sampling, which the audit team uses to evaluate the operating effectiveness of internal control activities. When performing attributes sam- pling, the audit team’s primary objective is to assess the extent to which the client’s internal control activities are functioning effectively. As with any sampling application, the audit team is exposed to sampling risk (the risk that the decision made based on the sample differs from the decision that would have been made if the entire population had been examined). The audit team controls this sampling risk (referred to as the risk of overreliance or the risk of assessing control risk too low) in determining the appropriate sample size and evaluating the sample results.

After the sample is selected, the audit team performs tests of controls to determine whether the control is functioning as intended. A sample rate of deviation is determined by dividing the number of deviations by the sample size; this rate is adjusted to control for the acceptable exposure to the risk of overreliance to determine the upper limit rate of deviation (ULRD). The ULRD is a measure that has a 1 – Risk of overreliance probability of equaling or exceeding the true rate of deviation in the population.

Once calculated, the ULRD is compared to the tolerable rate of deviation. If the ULRD is less than the tolerable rate of deviation, the audit team can rely on internal control as planned and accept the planned level of control risk. If the ULRD is higher than the toler- able rate of deviation, the audit team can either increase the assessed level of control risk (which will increase the necessary level of substantive procedures) or expand the sample to attempt to provide a ULRD that is lower than the tolerable rate of deviation. Decisions regarding the assessed level of control risk should consider the costs of performing addi- tional tests of controls versus the cost savings from reduced substantive procedures.

Summary

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allowance for sampling risk: The difference between the upper limit rate of deviation and the sample rate of deviation; “adjusts” the sample rate of deviation to allow the audit team to control the exposure to the risk of overreliance, 769 attributes sampling: A form of sampling used to determine the extent to which some characteristic (attribute) exists within a population of interest; used by the audit team during tests of controls, 758, 759 block selection: A method of choosing sample items in which a series of contiguous (or adjacent) items is chosen from the population, 767 deviation: A condition that refers to instances in which client personnel do not follow prescribed controls and controls are not functioning as intended, 759 discovery sampling: A form of attributes sampling that audit teams use when deviations from controls are very critical but are expected to occur at a relatively low rate, 774 expected population deviation rate: The rate of variations anticipated by the audit team in the client’s internal control activities; based on prior experience or a pilot sample, 763 haphazard selection: The method of choosing sample items in an unstructured manner but without any intentional bias, 767 nonrepresentative sample: A sample that differs substantially from the population on one or more key characteristics of interest from which it is drawn, 758 Nonstatistical sampling methods: In attributes sampling, methods that do not control the audit team’s exposure to the risk of overreliance in determining sample size, selecting sample items, or evaluating sample results, 774 physical representation of the population: An audit team’s frame of reference for selecting a sample, 760 random selection: See unrestricted random selection, 767 risk of overreliance (risk of assessing control risk too low): The likelihood that the audit team will conclude that the client’s controls are functioning effectively when they are not functioning effectively, 762 risk of underreliance (risk of assessing control risk too high): The likelihood that the audit team will conclude that the client’s controls are not functioning effectively when they are functioning effectively, 762 sample: A subset of items drawn from a population of interest, 758 sample rate of deviation: The extent of variations found in the audit team’s sample; determined by dividing the number of deviations by the sample size, 768 sampling: The process of making a statement about a population of interest based on examining only a subset (or sample) of that population, 758 sampling interval: An interval determined by dividing the recorded amount of the population (account balance) by the sample size, 767 sampling risk: The likelihood that the decision made based on the sample will differ from the decision that would have been made if the entire population had been examined, 758 sequential sampling: A plan in which an initial sample is selected and the audit team (1) draws a final conclusion regarding the effectiveness of the control or (2) selects additional items before drawing a final conclusion regarding the effectiveness of the control; also referred to as stop- or-go sampling, 774 systematic random selection (systematic selection): The method of selecting sample items in which a starting point is determined and a fixed number of items are bypassed between selections, 767 systematic selection: See systematic random selection, 767 tolerable rate of deviation: The maximum rate of deviation permissible by the audit team without modifying the planned assessed level of control risk, 762 unrestricted random selection (random selection): A method of selecting items in which all items in the population are assigned a number and chosen based on random numbers, 767 upper limit rate of deviation (ULRD): A measure that adjusts the sample rate of deviation for the audit team’s acceptable level of sampling risk; the rate of deviation that has a (1–Risk of overreliance) probability of equaling or exceeding the true population rate of deviation, 769 variables sampling: A form of sampling used to examine a population to estimate the amount or value of some characteristic of that population; used by auditors during their substantive procedures, 758

Key Terms

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E.27 Which of the following major stages of the audit is most closely related to attributes sampling? a. Determining preliminary levels of materiality. b. Performing tests of controls. c. Performing substantive procedures. d. Searching for the possible occurrence of subsequent events.

E.28 Which of the following steps in attributes sampling is most closely related to identifying key controls corresponding to the relevant management assertions? a. Determine the objective of sampling. b. Define the deviation condition. c. Define the population. d. Determine the sample size.

E.29 Which of the following factors has a direct relationship with sample size in an attributes sampling application?

E.30 Which of the following sampling risks does the audit team control in an attributes sampling application (ROO = risk of overreliance, ROU = risk of underreliance)?

E.31 Why is the audit team more concerned with controlling the exposure to the risk of overreli- ance than with the risk of underreliance? a. Only the risk of overreliance results in an incorrect audit decision. b. The risk of underreliance is not related to the audit team’s study and evaluation of inter-

nal control. c. The risk of overreliance can ultimately result in the audit team’s failing to reduce audit

risk to acceptable levels. d. The risk of underreliance can be controlled by performing tests of controls during the

interim period. E.32 Which of the following would not result in the audit team’s selecting a larger sample of con-

trols for examination? a. A reduction in the risk of overreliance from 10 percent to 5 percent. b. An increase in the tolerable rate of deviation from 3 percent to 6 percent. c. An increase in the expected population deviation rate from 2 percent to 4 percent. d. All of the above would result in a larger sample of controls.

E.33 Baily Cox, an audit manager, judged that the test of controls of the company’s 50,000 purchase transactions should be based on a tolerable rate of deviation of 6 percent, a risk of overreliance of 5 percent, and an expected population deviation rate of 3 percent. Using

LO E-1

LO E-1

LO E-2

Tolerable Rate of Deviation

Expected Population Deviation Rate

a. Yes Yes

b. No Yes

c. Yes No

d. No No

LO E-2

  ROO ROU

a. Yes Yes

b. No Yes

c. Yes No

d. No No

LO E-2

LO E-2

LO E-2

All applicable Exercises and Problems are available with Connect.

Multiple-Choice Questions for Practice and Review

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AICPA sample size tables, Cox determined that the appropriate sample size in this situa- tion would be a. 49. b. 78. c. 132. d. 195.

E.34 Francona Madden, an audit manager, considered the control risk assessments listed in the left column of the following table in evaluating A. Cardinal’s internal control over sales transactions. The sample sizes for the substantive procedures of the customer accounts receivable are shown to the right of each control risk. What risk of overreliance (ROO) could be assigned for tests of controls at each control risk level?

a. From top to bottom: 5 percent, 10 percent, 1 percent. b. From top to bottom: 10 percent, 1 percent, 5 percent. c. From top to bottom: 1 percent, 10 percent, 5 percent. d. From top to bottom: 1 percent, 5 percent, 10 percent.

E.35 Assume that Dylan Lee found two deviations in a sample of 90 transactions. Using AICPA sample evaluation tables, Lee determined that the ULRD at a 5 percent risk of overreliance is a. 2.0 percent. b. 2.2 percent. c. 5.9 percent. d. 6.9 percent.

E.36 The interpretation of the ULRD in an attributes sampling application is a. The estimated rate of deviation in the population with probability equal to the risk of

overreliance that the population deviation rate is higher. b. The estimated rate of deviation in the population with probability equal to the risk of

overreliance that the actual rate of deviation is lower. c. The estimated rate of deviation in the population with certainty that the actual rate of

deviation is lower. d. The estimated rate of deviation in the population with certainty that the actual rate of

deviation is higher. E.37 If an audit team examined 100 transactions and found one deviation from an important con-

trol activity, the audit conclusion could be that control risk can be assessed at the associated control risk level when a. The tolerable rate of deviation is 2 percent. b. The tolerable rate of deviation is 3 percent. c. The tolerable rate of deviation is 4 percent. d. More information about decision criteria is available.

E.38 If an audit team calculated a ULRD of 5 percent when the tolerable rate of deviation was 4 percent, both at the same risk of overreliance, control risk should be a. Assessed at the level associated with the 4 percent tolerable rate of deviation. b. Increased and substantive procedures should be adjusted accordingly. c. Assessed at the maximum level (100 percent) because the company’s performance failed

the test. d. Decreased and substantive procedures should be adjusted accordingly.

E.39 In which of the following circumstances would the audit team most likely use attributes sampling? a. Selecting customer accounts receivable for confirmation. b. Selecting inventory items for verification of physical quantities. c. Selecting purchase orders for indication of proper authorization. d. Selecting additions to property, plant, and equipment during the year.

LO E-2

Control Risk Accounts Receivable Sample ROO 0.20 400 ? 0.50 390 ? 0.80 350 ? 0.90 190 10%

LO E-4

LO E-4

LO E-4

LO E-4

LO E-1

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E.40 Using AICPA sample evaluation tables, determine the conclusion from a statistical sample of internal controls when a sample of 125 documents indicates five deviations if the toler- able rate of deviation is 5 percent, the expected population deviation rate is 2 percent, and the allowance for sampling risk is 3 percent. a. Accept the evidence as support for assessing a low control risk because the tolerable rate

of deviation less the allowance for sampling risk is less than the expected population deviation rate.

b. Use the evidence to assess a higher control risk than planned because the sample rate of deviation plus the allowance for sampling risk exceeds the tolerable rate of deviation.

c. Use the evidence to assess a higher control risk than planned because the tolerable rate of deviation plus the allowance for sampling risk exceeds the expected population deviation rate.

d. Accept the evidence as support for assessing a low control risk because the sample rate of deviation plus the allowance for sampling risk exceeds the tolerable rate of deviation.

E.41 An audit team designed a sample that would provide a 10 percent risk of overreliance that not more than 7 percent of sales invoices lacked credit approval. From previous audits, the audit team expected that 3 percent of the sample invoices lacked proper approval. From the sample of 90 invoices, 7 were found to lack credit approval. Using AICPA sample evaluation tables, the audit team determined that the ULRD was a. 3.3 percent. b. 4.5 percent. c. 7.8 percent. d. 12.8 percent.

E.42 Based on the information in the preceding question, the audit team determined that the allowance for sampling risk was a. 2.2 percent. b. 5.0 percent. c. 7.8 percent. d. 10.0 percent.

E.43 If the _______ exceeds the _______, the audit team would decide to rely on internal control as planned and maintain control risk at planned levels. a. ULRD; tolerable rate of deviation. b. tolerable rate of deviation; ULRD. c. expected population deviation rate; tolerable rate of deviation. d. tolerable rate of deviation; expected population deviation rate.

E.44 If the sample evidence does not support the planned level of control risk, the audit team could a. Increase the assessed level of control risk. b. Perform additional substantive procedures, reducing the necessary level of detection risk. c. Expand the sample to achieve an observed ULRD less than the tolerable rate of deviation. d. All of the above are acceptable.

E.45 Which of the following best describes the method of determining the ULRD? a. Expected population deviation rate + Allowance for sampling risk. b. Risk of underreliance + Allowance for sampling risk. c. Sample rate of deviation + Allowance for sampling risk. d. Tolerable rate of deviation + Allowance for sampling risk.

E.46 Which of the following factors used to determine sample size is normally based on the extent to which the audit team expects to rely on the internal control being examined? a. Allowance for sampling risk. b. Expected population deviation rate. c. Sample rate of deviation. d. Tolerable rate of deviation.

E.47 A type of sampling application in which a relatively small initial sample is examined and deci- sions regarding expanding that sample are based on the results of this initial sample is known as a. Attributes sampling. b. Discovery sampling. c. Sequential sampling. d. Statistical sampling.

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E.48 Jerry Tim is examining an important internal control in the audit of Langly Company. In past audits, deviations from this control have been observed at a minimal rate (less than 0.1  percent); however, because the account balance affected by this control is highly suscep- tible to fraud, it is important that Tim obtain a high level of assurance that deviations occur at no higher than a predetermined (low) rate. Which of the following sampling methods would Tim most likely use to evaluate this control? a. Attributes sampling b. Discovery sampling c. Sequential sampling d. Statistical sampling

E.49 In which step of a sampling plan is nonstatistical sampling different from statistical sampling? a. Define the characteristic of interest. b. Define the population. c. Measure the sample items. d. Evaluate the sample results.

E.50 The primary benefit of using nonstatistical sampling is that a. It generally results in a smaller sample size. b. It removes the need to consider allowance for sampling risk. c. It is simpler to use. d. All of the above are true.

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E.51 Test of Controls Objectives and Deviations.

Required: Review each of the following controls. Identify (1) the objective of the audit team’s test of controls and (2) one example of a deviation from the control.

a. The credit department supervisor reviews each customer’s order and approves credit by making a notation on the order.

b. The billing department must receive written notice from the shipping department of actual shipment to a customer before a sale is recorded. The sales record date is supposed to be the shipment date.

c. Billing clerks carefully identify the correct catalog list prices for goods shipped and cal- culate and verify the amounts billed on invoices for the quantities of goods shipped.

d. Billing clerks review invoices for intercompany sales and mark each one with the code 9 so they will be posted to intercompany sales accounts.

E.52 General Attributes Sampling. Frazier Holyfield, a new staff accountant, is evaluating important controls over the revenue cycle and, more specifically, assessing the operating effectiveness of the control that all shipments made to customers by Top Rank Inc. have been properly invoiced.

Required: Comment on the following actions that Holyfield performed. You should evaluate each action independently of any other actions.

a. Holyfield decided to inspect documentary evidence that all shipments made by Top Rank have been invoiced by matching shipping documents with invoices. Accordingly, she has identified the population from which she intends to sample as all sales invoices. Top Rank has a computerized list of invoiced sales that she can use to select the appropriate sample.

b. Because Holyfield plans to place a high degree of reliance on this particular control, she assesses the risk of overreliance at 5 percent. In previous years, a 10 percent level was used, but consultation with the engagement manager (Mike Evander) and partner (Donna Arum) indicate that a higher degree of reliance is planned in the current audit.

c. Holyfield assessed the expected population deviation rate at 1 percent. Although the rate of deviation from prior audits has approximated 2 percent, Top Rank has made several improvements in its processing of sales invoices; as a result, she believes that a lower expected population deviation rate is appropriate.

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d. Based on the risk of overreliance (5 percent), the expected population deviation rate (1  percent), and the tolerable rate of deviation (4 percent), Holyfield uses sampling tables to calculate a sample size of 156. She then increases the sample size to 175 because the population of sales invoices is extremely large. (More than 30,000 sales invoices are pro- cessed per year.)

e. Based on her tests of controls, Holyfield determined a sample rate of deviation of 2  percent. Using this rate of deviation, along with the appropriate risk of overreliance, she determined an allowance for sampling risk of 2.5 percent. Because the sum of these two (4.5 percent) is less than the risk of overreliance, Holyfield concluded that the con- trol is operating effectively and decided to rely on this control as planned to reduce the scope of her substantive procedures.

E.53 Examples of Deviations. Dana Beckham, CPA, is performing an attributes sampling application for Posh Company. In doing so, Beckham is interested in determining whether quantities on sales invoices are verified by client personnel and agreed with those on the corresponding shipping documents. Per Posh Company’s instructions, client personnel are supposed to place checkmarks next to the quantities on the sales invoices to identify that these quantities have been verified.

During the tests of controls, Beckham selected a total of 100 invoices for examination. Of these invoices, 95 had checkmarks clearly indicated on them. Beckham’s examination of the remaining five invoices revealed the following:

1. On one invoice, checkmarks were not placed next to the quantities; however, the designa- tion “OK” was written next to them.

2. One of the invoices selected for examination could not be located. Posh Company indicated that invoices occasionally are discarded when customers return the merchandise for credit.

3. No marks or identification was noted next to the quantities on one of the invoices; how- ever, this invoice was marked “VOID.”

4. A checkmark was placed on an invoice; however, this checkmark was not adjacent to any of the quantities and could not easily be associated with specific quantities noted on the invoice.

5. One of the invoices contained 15 different types of items. However, only five checkmarks were placed on the invoice, all adjacent to items from the same location in the warehouse.

Required: a. For each of the five invoices noted, indicate whether you believe the item represents a

deviation. Please justify your treatment of the invoice. b. What is one fallacy associated with assuming that the internal controls related to the

95 remaining invoices are functioning effectively?

E.54 Examples of Deviations. Madison Perry, CPA, is conducting an audit of Parker Inc. In so doing, Perry is performing a study of Parker’s internal control and has identified a number of important controls related to purchases on which to rely. These controls are as follows:

1. There is segregation of duties between the individual authorizing the purchase, the indi- vidual preparing the purchase order, and the individual receiving goods and services being purchased.

2. Verification of approval of purchases is evidenced by having the individuals performing the verification place their initials on the purchase order.

3. On receipt of goods or services, invoices from vendors should be matched to purchase orders. This matching is evidenced by a handwritten notation of the purchase order num- ber on each invoice.

4. Mathematical verification of vendor invoices should be evidenced by having the individ- uals performing the verification place their initials on the invoice itself.

5. Payments should be made only for vendor invoices that have been matched to purchase orders and mathematically verified.

Required: a. For each of the five controls, describe one test of control that Perry could perform to ver-

ify the operating effectiveness of the control. b. For each of the five controls, provide an example of a deviation that Perry might identify. c. Assume that Perry encountered the following situation(s) during the tests of controls.

Discuss whether you believe these situations represent deviations from the controls.

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1. For a sample purchase, Perry could readily determine that different individuals author- ized the purchase and prepared the purchase order. However, because receiving personnel were on vacation, the individual authorizing the purchase initially received the goods and services being purchased. This is a one-time occurrence and happened only on the day when all receiving personnel were on vacation or otherwise absent from work.

2. For one purchase, the individual did not initial the purchase order to evidence verifi- cation but signed it at the bottom.

3. One vendor invoice did not have handwritten notation of the purchase order number; however, the notation “OK, approved” was written.

4. For one purchase, a vendor invoice could not be located. As a result, a substitute invoice was identified, and this invoice was properly verified by Parker’s personnel.

5. Perry identified a single cash disbursement to a vendor that was related to five separ- ate invoices; all five invoices were properly approved for payment. Parker commonly combines several invoices into a single check to save costs.

d. Once identified by Perry, how do deviations affect the conclusion made with respect to the operating effectiveness of Parker’s internal control?

E.55 Examples of Deviations. Cameron Jones, CPA, is verifying that all sales made by Hicks Company to customers on account are properly approved by credit personnel. Hicks has established the following control related to this objective:

On receipt of a purchase order, evaluate the customer’s creditworthiness. If the customer’s name is included on an approved customer list, issue a credit authorization and begin processing the sale.

Required: a. Define the word deviation. Provide an example of a deviation from this control. b. In what stages of an attributes sampling plan does the audit team consider deviations?

How do deviations influence the attributes sampling process? c. What test of control could Jones perform to detect deviations from this control? d. In addition to their effect on Jones’s ability to rely on this control, would the following

matters raise additional concerns? 1. The deviations were inadvertent mistakes and omissions made over a period of time

by a number of different employees. 2. The deviations were all related to the activities of a recently hired employee that

occurred during the person’s first month with Hicks Company and appeared to be inadvertent mistakes and omissions. Additional tests of controls revealed that no devi- ations were noted following this period.

3. The deviations were the result of intentional activity on the part of Hicks Company’s employees to increase reported sales to meet targeted earnings levels.

E.56 Timing of Test of Controls and Sample Selection. Susan Hill was examining controls for the authorization of cash disbursements. She selected cash disbursement entries made through- out the year and vouched them to paid invoices and canceled checks bearing the initials and signatures of employees authorized to approve the disbursements. She performed the work on September 30 when the company had issued checks numbered 43921 to 52920. Because 9,000 checks had been issued in nine months, she reasoned that 3,000 more could be issued in the three months before the December 31 year-end. About 12,000 checks had been issued last year. She wanted to take one sample of 100 disbursements for the entire year, so she selected 100 random numbers in the sequence 43921 to 55920. She audited the 80 checks in the sample that were issued before September 30, and she held the other 20  randomly selected check numbers for later use. She found no deviations in the sample of 80, a finding that, in the circumstances, would cause her to assign a low (20 percent) control risk to the probability that the system would permit improper charges to be recorded in expense and purchase/inventory accounts.

Required: Prepare a memorandum to the audit manager (dated October 1) describing the audit team’s options with respect to evaluating control performance for the period from October through December.

E.57 Sample Selection. Read each of the following cases. Explain for each case how you could select a sample having the best chance of being representative of the population using (1) unrestricted random selection and (2) systematic random selection.

a. You need to select a sample of recorded cash disbursements. The client used two bank accounts for general disbursements. Account 1 was used during January–August  and

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issued checks numbered 3633–6632. Account 2 was used during May–December and issued checks numbered 0001–6000.

b. You need to select a sample of purchase orders. The client issued prenumbered pur- chase orders in the sequence 9000–13999. You realize that if you select five-digit ran- dom  numbers from a table and look for numbers in this sequence, 95 percent of the random numbers you scan will be discards because a table has 100,000 different five- digit random numbers. (The computer is down today!) How can you alter this sequence to reduce the number of instances in which the numbers in the table do not correspond to numbers in the population?

c. You need to select a sample of 100 perpetual inventory records so you can count the quantities while the stock clerks take the physical inventory. The perpetual records have been printed in a control list showing location, item description, and quantity. You have a copy of the list. It is 75 pages long, with 50 lines to a page (40 lines on the last page).

E.58 Sample Selection. Robert Janice, CPA, is verifying a sample of controls related to the approval of vouchers for payment. His client, Fave Company, uses a prenumbered voucher system in which a voucher is prepared and approved for all receiving reports and the corres- ponding vendor’s invoice. Based on the prior audit, Janice has verified that the first receiving report number for the year is 12794 and the final receiving report prepared this year is 38121.

Required: Indicate how Janice could use (1) unrestricted random selection and (2) systematic random selection to select the sample for sample sizes of 50, 100, and 500.

E.59 Sample Selection. Hunter McNeal is studying and evaluating Branyon’s internal controls related to the mathematical verification of sales invoices. In this verification, Branyon’s con- trol activities require that employees perform the following procedures:

∙ Verify that sales invoices are prepared only for items actually shipped to customers. This activity is evidenced by requiring employees to place a checkmark next to quantities on the sales invoices.

∙ Verify that prices charged to customers are from approved price lists. This activity is evi- denced by requiring employees to place a checkmark next to prices on the sales invoice.

∙ Verify that extensions and footings on invoices are mathematically accurate. This activ- ity is evidenced by requiring employees to initial the bottom of the invoice in a section marked “Mathematically verified by.” To verify the operating effectiveness of these activities, McNeal established an expected

population deviation rate of 3 percent, a tolerable rate of deviation of 6 percent, and a risk of overreliance of 10 percent. Using these parameters, McNeal determined a necessary sample size of 132 invoices, is now ready to select invoices for examination, and is considering the use of systematic selection.

Required: a. McNeal wants to ensure the selection of a representative sample of sales invoices. What

are some of the characteristics that should be considered to ensure that the sample is rep- resentative of the population of sales invoices?

b. What issues does the use of systematic selection introduce with respect to McNeal’s abil- ity to select a representative sample of sales invoices from the population?

c. Identify any issues associated with the use of systematic selection in the following independent circumstances. 1. Branyon does not maintain invoices in a computerized format but maintains hard copy

by date. McNeal has full access to the files containing the invoices. 2. Branyon does not maintain invoices in a computerized format but maintains hard copy

according to customer classification (“A” represents high-volume customers; “B,” middle-volume customers; and “C,” low-volume customers). McNeal has full access to the files containing the invoices.

3. Branyon does not maintain invoices in a computerized format but maintains hard copy by date. Because they are maintained off-site, McNeal does not have full access to the files; however, Branyon has offered to pull invoices selected by McNeal and make them available for the tests of controls.

4. Branyon maintains invoices in a computerized format arranged alphabetically by cus- tomer name. This file can be sorted by date, amount of sale, customer number, cus- tomer classification, and zip code. McNeal has full access to the computerized files.

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E.60 Sample Size Determination. Jule Phillips is examining the internal control of Cowboy Company and has identified the mathematical verification of sales invoices as an important control and decided to test this control. Based on a discussion with Cowboy’s management, Phillips determined that Cowboy Company’s employees were required to indicate their com- pliance with this control by writing their initials in an appropriate place on the invoice copy.

Assume that Phillips established an acceptable risk of overreliance of 5 percent, an expected population deviation rate of 3 percent, and a tolerable rate of deviation of 9 percent.

Required: a. Using AICPA sample size tables, determine the appropriate sample size. b. Indicate how Phillips would assess the three parameters that are used to determine sam-

ple size (risk of overreliance, expected population deviation rate, and tolerable rate of deviation).

c. Use the original parameters but now assume that Phillips is willing to increase the accept- able risk of overreliance to 10 percent. Using AICPA sample size tables, determine the new sample size to examine.

d. Provide an explanation for the change in sample size noted in part (c). E.61 Sample Size Determination. Review each of the following independent sets of conditions.

Required: Use AICPA sample size tables to identify the appropriate sample size for use in a statistical sampling application (ROO = risk of overreliance, EPDR = expected population deviation rate, TRD = tolerable rate of deviation). What is your conclusion regarding the relationship of each of these factors to sample size based on comparing the sample sizes across different combinations of these factors?

a. ROO = 5%, EPDR = 0%, TRD = 7%. b. ROO = 5%, EPDR = 3%, TRD = 7%. c. ROO = 5%, EPDR = 3%, TRD = 6%. d. ROO = 10%, EPDR = 0%, TRD = 7%. E.62 Sample Size Determination. Review each of the following independent sets of

conditions.

Required: Use AICPA sample size tables to identify the appropriate sample size for use in a statistical sampling application (ROO = risk of overreliance, EPDR = expected population deviation rate, TRD = tolerable rate of deviation). What is your conclusion regarding the relationship of each of these factors to sample size based on comparing the sample sizes across different combinations of these factors?

a. ROO = 5%, EPDR = 1%, TRD = 4%. b. ROO = 5%, EPDR = 1.5%, TRD = 4%. c. ROO = 5%, EPDR = 1.5%, TRD = 6%. d. ROO = 10%, EPDR = 1.5%, TRD = 4%. E.63 Sample Size Determination. For each of the following independent cases, use AICPA sam-

ple size tables to identify the missing value(s).

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  1 2 3 4 Risk of overreliance 5.0% 5.0% 10.0% (d) Expected population deviation rate 1.25% 2.5% (c) 1.25% Tolerable rate of deviation 7.0% (b) 6.0% 6.0% Sample size (a) 68 153 78

E.64 Sample Size Determination. Grady Cambridge, CPA, is performing attributes sam- pling to determine whether all purchases on account are properly approved by the cli- ent. Because the client typically makes more than 2,000 purchases on account per year, Cambridge has decided to use sampling instead of examining the entire population of purchases. Based on past experience with this client, Cambridge anticipates a rate of deviation of 1 percent.

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Required: a. What factors should Cambridge consider in determining the necessary sample size? How

would the level of these factors be determined? b. Once the appropriate factors have been determined, describe the process that Cambridge

would use in determining the necessary sample size. c. Assume that Cambridge established a risk of overreliance of 10 percent and a tolerable

rate of deviation of 6 percent. Using AICPA sample size tables, determine the appropri- ate sample size to use in evaluating the controls over approval of purchases on account.

d. How would the following changes impact (a) the factors used to determine sample size and (b) the sample size examined by Cambridge? (Do not determine an exact sample size but indicate whether the sample size would be larger, smaller, or unchanged. Treat each of these changes in factors independently in providing your answers.) 1. Because of increased sales and new lines of business, the number of purchases made

by the client on account increased markedly from more than 2,000 to nearly 5,000 during the current year.

2. The client remediated some control deficiencies related to the purchasing function noted in Cambridge’s prior audits. One of these control deficiencies related specific- ally to the approval of purchases made by the client.

3. The client has had turnover in the purchasing function during the most recent year. This turnover resulted in a higher-than-normal number of deviations during the first few months of the new employees’ tenure. The deviation rate since then has decreased to historical levels.

4. Cambridge has decided that it would be cost beneficial to seek a reduction in control risk from moderate to low.

5. Cambridge has decided that it is no longer efficient to test controls at current levels and accordingly increased control risk from moderate levels to high levels.

6. Because some of its previous suppliers are no longer in business or no longer com- petitive with respect to price, the client has added a number of new vendors to its approved vendor listing.

e. What are the trade-offs Cambridge must make between increasing the reliance on inter- nal control and maintaining the current level of reliance on internal control?

f. What factors should Cambridge consider in deciding whether to increase the reliance on internal control?

E.65 Sample Results Evaluation. Jamie Plane is testing the effectiveness of an important control for Blackheart Inc. Plane is placing a high level of reliance on this control and has assessed a rela- tively low risk of overreliance (5 percent) and tolerable rate of deviation (6 percent). Based on the acceptable risk of overreliance, expected population deviation rate, and tolerable rate of devia- tion, Plane determined a sample size of 60 items. The tests of controls revealed three deviations.

Required: a. Calculate the sample rate of deviation. b. Using AICPA sample evaluation tables, calculate the ULRD and allowance for sampling risk. c. Why does the ULRD differ from the sample rate of deviation? d. What would Plane’s conclusion be with respect to the operating effectiveness of the con-

trol? What options are available at this time? e. Ignoring the effects on sample size, how would Plane’s decision to accept a higher risk

of overreliance (10 percent) affect the conclusions made with respect to the operating effectiveness of the control?

E.66 Sample Results Evaluation. Required:

Review each of the following independent sets of conditions. For each condition, calculate the (1) sample rate of deviation, (2) ULRD and (3) allowance for sampling risk (n = sample size, d = deviations, ROO = risk of overreliance). What is your conclusion regarding the relationship of each of these factors to the ULRD based on comparing the ULRD across dif- ferent combinations of these factors?

a. n = 60, d = 4, ROO = 5%. b. n = 60, d = 6, ROO = 5%. c. n = 60, d = 6, ROO = 10%.

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E.67 Sample Results Evaluation.

Required: Review each of the following independent sets of conditions. For each condition, calculate the (1) sample rate of deviation, (2) ULRD, and (3) allowance for sampling risk (n = sample size, d = deviations, ROO = risk of overreliance). What is your conclusion regarding the relationship of each of these factors to the ULRD based on comparing the ULRD across dif- ferent combinations of these factors?

a. n = 100, d = 8, ROO = 5%. b. n = 100, d = 4, ROO = 5%. c. n = 100, d = 8, ROO = 10%.

E.68 Sample Results Evaluation.

Required: For each of the following independent cases, use AICPA sample size and sample evaluation tables to identify the missing value(s).

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1 2 3 4 Sample size 30 (d) 200 50 Number of deviations 2 4 (g) 2 Sample rate of deviation (a) (e) 2.5% (i) Risk of overreliance 5.0% 5.0% 10.0% (j) ULRD (b) 12.6% (h) (k) Allowance for sampling risk (c) (f) 2.1% 8.1%

E.69 Sample Results Evaluation. Assume that you are working on the audit of a small company and are examining purchase invoices for the presence of a “received” stamp. The omission of the stamp is thus a deviation. The population is composed of approximately 4,000 invoices processed by the company during the current year.

You decide that a rate of deviation in the population as high as 5 percent would not require any extended audit procedures. However, if the population rate of deviation is more than 5 percent, you would want to assess a higher control risk and conduct more extensive substantive tests.

In each case, write the letter of the sample (A or B) that, in your judgment, provides the best evidence that the rate of deviation in the population is 5 percent or lower (using a risk of overreliance of 5 percent). Assume that each sample is selected at random. Refer to AICPA sample evaluation tables if necessary.

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Sample A B A B A B A B A B

Number of invoices examined 75 200 150 25 200 100 100 125 200 150

Number of deviations 1 4 2 0 6 2 1 3 8 4

Sample rate of deviation 1.3 2.0 1.3 0.0 3.0 2.0 1.0 2.4 4.0 2.7

E.70 Sample Results Evaluation. Kendall Jackson, CPA, is examining the operating effective- ness of the internal control of Town Mo, a large conglomerate in the music industry. As part of the evaluation, Jackson determined a necessary sample size of 93 items (based on a toler- able rate of deviation of 5 percent, an expected population deviation rate of 0.5 percent, and a risk of overreliance of 5 percent). After properly selecting the 93 items, Jackson found no deviations from the prescribed control activities.

Required: a. Based on Jackson’s sample, determine the sample rate of deviation and ULRD. (Because

the AICPA sample evaluation tables do not contain a row for a sample size of 93, round down and use a sample size of 90.)

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b. Explain the difference between the ULRD and the sample rate of deviation observed in part (a). How does this difference relate to the use of statistical sampling?

c. What would Jackson conclude with respect to the operating effectiveness of Town Mo’s internal control?

d. If Jackson found three deviations in the sample, calculate the sample rate of deviation and use AICPA sample evaluation tables to determine the ULRD. What would Jackson con- clude with respect to the operating effectiveness of Town Mo’s internal control in this case?

e. Using AICPA sample evaluation tables, determine the maximum number of deviations that Jackson could identify without reducing the reliance on Town Mo’s internal control.

f. Repeat part (e) using a 10 percent risk of overreliance. What is the explanation for any differences between this number of deviations and that in part (e)?

E.71 Evaluating a Sampling Application. Tom Barton, an assistant accountant with a local CPA firm, recently graduated from Other University. He studied statistical sampling for auditing in college and wants to impress his employers with his knowledge of modern auditing methods.

Barton decided to select a random sample of payroll checks for the test of controls using a tolerable rate of deviation of 5 percent and an acceptable risk of overreliance of 5  percent. The senior accountant told Barton that 2 percent of the checks audited last year had one or more errors in the calculation of net pay. He decided to audit 100 random checks. Because supervisory personnel had paychecks with higher amounts than production workers, he selected 60 of the supervisor checks and 40 checks of the others. He was very careful to see that the selections of 60 from the April payroll register and 40 from the August payroll register were random.

The audit of this sample yielded two deviations, exactly the 2 percent rate experienced last year. The first was the deduction of federal income taxes based on two exemptions for a supervisory employee whose W-4 form showed four exemptions. The other was payment to a production employee at a rate for a job classification one grade lower than it should have been. The worker had been promoted the week before, and Barton found that in the next payroll he was paid at the correct (higher) rate.

When he evaluated this evidence, Barton decided that these two findings were really not con- trol deviations at all. The withholding of too much tax did not affect the expense accounts, and the proper rate was paid the production worker as soon as the clerk caught up with the change orders. Barton decided that having found zero deviations in a sample of 100, the ULRD for a 5 percent risk of overreliance was 3 percent, which easily satisfied his predetermined criterion.

The senior accountant was impressed. Last year he had audited 15 checks from each month, and Barton’s work represented a significant time savings. The reviewing partner on the audit also was impressed because she had never thought that statistical sampling could be so efficient, and that was the reason she had never studied the method.

Required: Identify and explain the mistakes made by Barton.

E.72 Comprehensive Attributes Sampling. Audra Dodge, CPA, is performing an attributes sampling plan for her audit of Truck Company. In her audit of cash disbursements, she has identified preparing a voucher and marking it as “paid” prior to preparing and mailing a check to the vendor as an important control. Dodge defined any voucher that was not marked as “paid” as being a deviation.

In performing her sampling application, she established the following parameters:

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Expected population deviation rate 1.5%

Tolerable rate of deviation    4%

Required: Identify what factors Dodge considered in establishing the risk of overreliance, expected population deviation rate, and tolerable rate of deviation. Assume that Dodge wished to place additional reliance on this control. How would that affect the three parameters in part (a)? Based on the original parameters, use AICPA sample size tables to determine the appropri- ate sample size.

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If Dodge selected the sample size in part (c) and found four deviations, what is the sample rate of deviation? Using AICPA sample evaluation tables, determine the ULRD. (Note: If the sample size cannot be directly located on the sample evaluation table, round down to the next highest sample size.) What would Dodge’s conclusion be with respect to the functioning of this control?

E.73 Nonstatistical Attributes Sampling. Aubrey Marblehead is conducting tests of controls on the control that quantities on Rock’s receiving reports are appropriately verified. In so doing, Marblehead has inquired of Rock’s receiving personnel, who said that they place a mark near the quantities verified and sign the receiving report upon delivery. Marblehead has decided to use nonstatistical sampling for this engagement. Based on the importance of this control and the rate of deviation that has been observed in prior audits, Marblehead has established the following parameters.

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Risk of overreliance    5%

Expected population deviation rate 2.75%

Tolerable rate of deviation    7%

Based on the parameters established, Marblehead decides to use a sample of 100 receiv- ing reports.

Required: a. How would Marblehead define a deviation condition? b. How would Marblehead appropriately define the population? What steps should be taken

to ensure that it is complete? c. If Rock has a computerized list of all receiving reports, what are some options available

to Marblehead in selecting specific items for examination? What precautions should be taken before undertaking the selection of items?

d. For each of the following deviations, determine the sample rate of deviation and indicate Marblehead’s decision with respect to the functioning of the control. 1. 2 deviations. 2. 4 deviations. 3. 10 deviations.

E.74 Nonstatistical Attributes Sampling. Monroe Curtis is auditing the revenue cycle of Kentucky Distilleries and has elected to perform a nonstatistical test of controls. Kentucky Distilleries sells Old Horse Bourbon to wholesale distributors around the country. Because the sale of bour- bon is strictly controlled, Curtis does not expect deviations to be present in the system and has assessed control risk as low and selected a sample size of 50 sales. Curtis has defined a devia- tion as a recorded sale not being supported by a shipping document with a federal tax stamp.

Required: a. How does nonstatistical sampling differ from statistical sampling? b. Why would Curtis choose to perform nonstatistical sampling instead of statistical sampling? c. How should Curtis select the sample? d. What conclusion should Curtis make if one deviation is found? E.75 Comprehensive Attributes Sampling. The firm of Buy and Best, CPAs, is engaged to

conduct the audit of Radio Hut, a retailer of electronic and other high-technology products. Because of technological advances in Radio Hut’s inventory products, an important risk that it faces is that prices charged by suppliers reflect current industry prices (which tend to fluc- tuate relatively significantly, particularly as new technologies are introduced and as older technologies are discontinued). The nature of Radio Hut’s inventories is such that a small number of suppliers exist and each supplier has a similar pricing structure. This pricing struc- ture is reflected in an electronic industry pricing guide, which is updated on a daily basis.

You are a staff accountant with Buy and Best and have been asked to identify a potential audit approach to address this risk. In the past, your firm has decided to place relatively limited reliance on internal control activities related to Radio Hut’s purchasing function and has instead conducted relatively extensive substantive procedures related to its inven- tories. However, the new partner on the Radio Hut engagement has successfully reduced substantive procedures for the firm’s other clients in the retail industry by performing more

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extensive tests of controls. Because of previous experience in the industry as well as having used this audit approach successfully for other clients, the new partner asks you to evaluate the possibility of using more extensive tests of controls in the audit of Radio Hut.

The following controls are relevant to Radio Hut’s processing of vendor invoices:

∙ Similar to most retailers in the industry, Radio Hut has a highly automated inventory monitoring and control system. Based on anticipated product life, current sales, and existing inventory levels, Radio Hut generates an automatic purchase order when inven- tory levels reach predetermined thresholds.

∙ Once a purchase order has been generated, the store manager reviews it prior to transmit- ting it to the appropriate vendor. This review ensures that the vendor is from an approved list and that the proposed purchase is consistent with the store’s objectives and near-term plans (e.g., not purchasing a large number of laptop computers just prior to a major pro- motion for tablets).

∙ Upon receipt of the items, warehouse personnel prepare “blind” copies of a receiving report, noting the quantity of each item received.

∙ Purchasing personnel verify the vendors’ invoices by (1) comparing the invoice to a pur- chase order by referencing the purchase order number on the vendor invoice, (2) comparing quantities on the vendor invoice to quantities from the receiving report prepared by ware- house personnel, (3) comparing prices on the invoice for reasonableness through reference to industry pricing data, and (4) mathematically verifying the accuracy of the invoice.

These controls have been in place for a number of years, and Radio Hut has experi- enced relatively little turnover in its purchasing and related functions. You did not observe any remediation or major changes with respect to these controls or to Radio Hut’s control environment during the past year.

You reviewed the prior audit documentation, which was prepared by another staff accountant who has since left the firm. Based on your review, you prepared the follow- ing notes:

∙ The control activity tested by the staff accountant is the employee verification of the rea- sonableness of prices on the invoices by placing a checkmark or other notation adjacent to the price on the invoice.

∙ Using an expected population deviation rate of 1 percent, a tolerable rate of deviation of 7 percent, and a risk of overreliance of 10 percent, the staff accountant selected a sample of 55 invoices.

∙ Tests of controls revealed three misstatements; based on the sample size of 55 and a risk of overreliance of 10 percent, the ULRD was 11.8 percent. Because this exceeded the tolerable rate of deviation 7 percent, the other staff accountant reduced reliance on the control activity and conducted more extensive substantive procedures.

Required: a. Comment on the appropriateness of the work done in the prior audit with respect to test-

ing this control activity. b. Based on the results of tests of controls in the prior year, provide your initial thoughts regard-

ing the viability of increasing your reliance on this control activity in the current audit. c. How will your decision to increase the reliance on the control activity affect the sample

size in the current audit? What specific factors will be affected by this decision? d. Assume that you have established a risk of overreliance of 5 percent, a tolerable rate of

deviation of 6 percent, and an expected population deviation rate of 1 percent. Using AICPA sample size tables, determine the necessary sample size in the current audit. Is this sample size consistent with your expectations compared to that examined in the prior year?

e. Using AICPA sample size tables, determine what factor(s) resulted in the increased sam- ple size from the prior year. Can you determine the extent to which each factor contrib- uted to this increase? [Note: Requirements (f)–(h) are unrelated to (a)–(e).]

f. Refer to the AICPA sample evaluation tables. Assuming a sample size of 100 items, how many deviations would be permissible for you to rely on this control activity using a 5 percent risk of overreliance and a 6 percent tolerable rate of deviation?

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g. Repeat part (f), assuming that you decided to reduce your reliance on internal control and establish a risk of overreliance of 10 percent.

h. What does a comparison of your results in parts (f) and (g) tell you about the effect of the risk of overreliance on the ULRD?

E.76 General Attributes Sampling. You overheard the following dialogue between Joe Ashley (a staff assistant) and Monique Estrada (his supervisor).

Required: Referring to appropriate professional standards, comment on each of these statements.

a. “It’s unfortunate that generally accepted auditing standards don’t allow us to use non- statistical sampling for this control. I just don’t feel that the extra time and effort to use statistical sampling are worth the benefits.”

b. “I’m not sure what level of control risk we should plan to use. We need to determine the amount of substantive procedures that we will conduct and then assess control risk accordingly.”

c. “We really need to be careful to limit our exposure to the risk of overreliance. This risk could result in our failure to perform enough substantive procedures.”

d. “Separation of duties is such an important control that we should use statistical sampling to evaluate the extent to which the custody, recording, and approval functions for pur- chases are performed by different individuals.”

e. “Because we’re really relying heavily on this control, it’s important that it be operating very effectively. That’s why I set the tolerable rate of deviation at such a low level.”

f. “We found six deviations of the 120 items we examined. That’s a 5 percent rate of devi- ation. Because our tolerable rate of deviation is 8 percent, it looks like we can rely on internal control as planned.”

g. “A deviation is a deviation. Some of these problems were honest mistakes, but others looked like client employees intentionally ignored the controls. However, they all have the same effect on the ULRD.”

h. “Because our upper limit rate of deviation is lower than the tolerable rate of deviation, we don’t have to do anything with the deviations we found.”

E.77 Comprehensive Nonstatistical Attributes Sampling. Marty Alewine, a newly promoted senior at your firm, has been assigned as in charge of the audit of Doxey Electronics. Doxey has been a client of your firm for years. Controls are considered effective, and statistical attributes sampling to test sales transactions has been used for several years. Last year’s audit documentation revealed the following: risk of overreliance, 5 percent; expected population deviation rate, 2 percent; tolerable rate of deviation, 5 percent; sample size, 181; deviations found, three; and ULRD, 4.2 percent. Alewine’s conclusion from the documentation is that the controls were accepted as operating effectively.

Deciding to use nonstatistical sampling this year to reduce audit hours, Alewine selected 100  invoices from the December invoice files, reasoning that tests closer to year-end are more effective, by selecting every 10th invoice until 100 invoices had been identified. Two invoices differed in amount from the shipping document, and one invoice could not be located. Alewine decided to accept the controls as effective again this year, reasoning the sample rate of deviation was only 2 percent, which is much less than the tolerable rate of deviation used last year.

Required: As the manager of the Doxey Electronics audit, you have been reviewing the audit documen- tation. Prepare a list of reviewer comments to discuss with Alewine.

E.78 Discovery and Sequential Attributes Sampling. Sydney Siebenthaler, the audit manager for Jennifer’s Running Shirts Inc., has just returned from a continuing education class on audit sampling and now wants to use discovery sampling or sequential sampling on the Jennifer’s audit because the class instructor said that the sample sizes would be significantly smaller. “Talk about a no-brainer!” Siebenthaler exulted.

Jennifer’s has good controls, and the audit team has performed tests of controls over the payroll procedures in previous years to reduce substantive tests of payroll accounts to only analytical procedures. In the previous year, the audit team used the following parameters: risk of overreliance, 10 percent; expected population deviation rate, 2 percent; and tolerable rate of deviation, 10 percent, which resulted in a sample size of 38. The auditors increased

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(rounded) the sample size to 40 items, and one deviation was found. The resulting ULRD rate was 9.4 percent, and the control was accepted as operating effectively.

Required: a. Define discovery sampling. b. Do you agree that discovery sampling should be used on the audit of Jennifer’s? c. How would discovery sampling be used? d. Define sequential sampling. e. Do you agree that sequential sampling should be used on the audit of Jennifer’s? f. How would sequential sampling be used?

USING IDEA IN ATTRIBUTES SAMPLING Exercises E.79, E.80, and E.81 require the use of IDEA in an attributes sampling con- text. Elm Manufacturing Company (ELM) is a small manufacturer of backpacks located in Rochelle, Illinois. You are testing controls related to the authorization of sales made to customers on account and are interested in ensuring that goods are only shipped to customers following a formal credit approval. You have access to ELM’s electronic rec- ords in Connect. The appropriate file for these exercises is the Sales 2017–4th Q data set. Detailed information about ELM, instructions for accessing data sets, a data directory for data sets, and a detailed attributes sampling example (with IDEA screenshots) can be found in Connect. NOTE: The Sales 2017–4th Q data set contains a total of 410 transactions; because you are only examining the credit approval for goods that have been shipped, you would only exam- ine orders through No. 17383 (a total of 388 shipments).

E.79 Attributes Sampling with IDEA: Determining Sample Size, Selecting Sample Items, and Evaluating Sample Results. Your audit team has established the following parameters for the examination of ELM’s control over the authorization of sales:

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Population size 388 shipments

Risk of overreliance 10%

Expected population deviation rate 1%

Tolerable rate of deviation 6%

Required: Using IDEA, perform the following related to ELM’s control over credit approvals.

Determine the appropriate sample size. Based on the sample size and preceding param- eters, how many deviations could be observed without the audit team reducing their reliance on the authorization control?

Using systematic random selection, a random start of 23, as well as the sample size in part (a), select sample items from the population. What are the first five transactions that will be selected for examination?

After performing your tests of controls, you have identified three deviations in your  sample. What is the ULRD? What conclusion would you draw with respect to the functioning of ELM’s controls over the authorization of sales?

E.80 Attributes Sampling with IDEA: Determining Sample Size. Your audit team has estab- lished the following parameters for the examination of ELM’s control over the authorization of sales:

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Population size 388 shipments

Risk of overreliance 10%

Expected population deviation rate 1%

Tolerable rate of deviation 6%

Required: Use IDEA to determine the necessary sample size, given the preceding parameters.

Parts (b), (c), and (d) are independent scenarios that affect sample size. Assume the audit team has decided to increase its reliance on this control and reduce

control risk related to the authorization of sales on account. Accordingly, it has decided to

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reduce the risk of overreliance to 5 percent. What is the necessary sample size, holding all other factors constant?

Assume that in the past year the audit team noted a greater extent of deviations in the population and decided that an expected population deviation rate of 2 percent would be more appropriate. What is the necessary sample size, holding all other factors constant?

Assume that the audit team has decided to reduce its reliance on this control and is will- ing to increase the tolerable rate of deviation from 6 percent to 8 percent. What is the neces- sary sample size, holding all other factors constant?

How do the results in parts (b), (c), and (d) reflect the relationship between various par- ameters and sample size?

E.81 Attributes Sampling with IDEA: Evaluating Sample Results. Based on a population size of 388 shipments, a 10 percent desired risk of overreliance, an expected population devia- tion rate of 1 percent, and a tolerable rate of deviation of 6 percent, the audit team selected a sample of 58 items.

In performing tests of controls, your audit team identified three shipments that were not supported by an approved sales order and concluded that these represent deviations from the control activity.

Required: a. Use IDEA to determine the ULRD. What would the audit team’s conclusion be with

respect to the functioning of ELM’s control over the authorization of sales transactions? Part (b) is a set of independent scenarios that affect the evaluation of sample results.

b. For each of the following numbers of deviations, use IDEA to determine the ULRD and provide the audit team’s conclusion with respect to the functioning of ELM’s control over the authorization of sales transactions. 1. 0 deviations 2. 1 deviations 3. 2 deviations

c. How do the results in part (b) reflect the relationship between the number of deviations and the ULRD?

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AICPA Sample Size Tables

Appendix E.A

Note: This table assumes a large population. Sample sizes of more than 2,000 not shown. Source: AICPA Audit Guide Audit Sampling.

EXHIBIT E.A.1 Sample Size Table for 5 Percent Risk of Overreliance (Number of Expected Deviations)

Expected Population Deviation Rate

Tolerable Rate of Deviation

2% 3% 4% 5% 6% 7% 8% 9% 10% 15% 20%   0.00% 149 (0) 99 (0) 74 (0) 59 (0) 49 (0) 42 (0) 36 (0) 32 (0) 29 (0) 19 (0) 14 (0)   0.25 236 (1) 157 (1) 117 (1) 93 (1) 78 (1) 66 (1) 58 (1) 51 (1) 46 (1) 30 (1) 22 (1)   0.50 313 (2) 157 (1) 117 (1) 93 (1) 78 (1) 66 (1) 58 (1) 51 (1) 46 (1) 30 (1) 22 (1)   0.75 386 (3) 208 (2) 117 (1) 93 (1) 78 (1) 66 (1) 58 (1) 51 (1) 46 (1) 30 (1) 22 (1)   1.00 590 (6) 257 (3) 156 (2) 93 (1) 78 (1) 66 (1) 58 (1) 51 (1) 46 (1) 30 (1) 22 (1)   1.25 1,030 (13) 303 (4) 156 (2) 124 (2) 78 (1) 66 (1) 58 (1) 51 (1) 46 (1) 30 (1) 22 (1)   1.50   392 (6) 192 (3) 124 (2) 103 (2) 66 (1) 58 (1) 51 (1) 46 (1) 30 (1) 22 (1)   1.75   562 (10) 227 (4) 153 (3) 103 (2) 88 (2) 77 (2) 51 (1) 46 (1) 30 (1) 22 (1)   2.00   846 (17) 294 (6) 181 (4) 127 (3) 88 (2) 77 (2) 68 (2) 46 (1) 30 (1) 22 (1)   2.25   1,466 (33) 390 (9) 208 (5) 127 (3) 88 (2) 77 (2) 68 (2) 61 (2) 30 (1) 22 (1)   2.50     513 (13) 234 (6) 150 (4) 109 (3) 77 (2) 68 (2) 61 (2) 30 (1) 22 (1)   2.75     722 (20) 286 (8) 173 (5) 109 (3) 95 (3) 68 (2) 61 (2) 30 (1) 22 (1)   3.00     1,098 (33) 361 (11) 195 (6) 129 (4) 95 (3) 84 (3) 61 (2) 30 (1) 22 (1)   3.25     1,936 (63) 458 (15) 238 (8) 148 (5) 112 (4) 84 (3) 61 (2) 30 (1) 22 (1)   3.50       624 (22) 280 (10) 167 (6) 112 (4) 84 (3) 76 (3) 40 (2) 22 (1)   3.75       877 (33) 341 (13) 185 (7) 129 (5) 100 (4) 76 (3) 40 (2) 22 (1)   4.00       1,348 (54) 421 (17) 221 (9) 146 (6) 100 (4) 89 (4) 40 (2) 22 (1)   5.00         1,580 (79) 478 (24) 240 (12) 158 (8) 116 (6) 40 (2) 30 (2)   6.00     &nb