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About the Author

Charles Hall is a practicing CPA and Certified Fraud Examiner. For the last thirty years, he has primarily audited governments, nonprofits, and small businesses.He is the author of The Little Book of Local Government Fraud Prevention and Preparation of Financial Statements & Compilation Engagements. He frequently speaks at continuing education events.Charles is the quality control partner for McNair, McLemore, Middlebrooks & Co. where he provides daily audit and accounting assistance to over 65 CPAs. In addition, he consults with other CPA firms, assisting them with auditing and accounting issues.

financial statements with GAAP departure
Jun 20

Financial Statements with a GAAP Departure (How to Issue)

By Charles Hall | Accounting and Auditing

Can CPAs intentionally issue financial statements with a GAAP departure? Yes. And sometimes it might be preferable. 

financial statements with GAAP departure

I received a phone call last week from a CPA asking if he could issue a balance sheet with a GAAP departure? His client's bank requested a GAAP balance sheet with an intentional departure (the bank wanted one number to be shown at fair value and GAAP calls for cost). 

I advised the CPA how to issue financial statements with an intentional GAAP departure. Watch the video to see how..

One caution in issuing financial statements with a GAAP departure: The AICPA Code of Conduct does not allow a CPA to issue financial statements that are intentionally misleading. So, always communicate the departure. Departures from reporting frameworks should never be hidden.

The video refers to selected disclosures. You can see information about selected disclosures here.

The video also discusses AR-C 70, Preparation of Financial Statements. You can see information about AR-C 70 here.

going concern
Jun 20

Going Concern: How to Understand the Accounting and Auditing Standards

By Charles Hall | Accounting , Auditing

Are you preparing financial statements and wondering whether you need to include going concern disclosures? Or maybe you’re the auditor, and you’re wondering if a going concern paragraph should be added to the audit opinion. You’ve heard there are new requirements for both management and auditors, but you’re not sure what they are.

This article summarizes (in one place) the new going concern accounting and auditing standards.

going concern

Going Concern Standards

For many years the going concern standards were housed in the audit standards–thus, the need for FASB to issue accounting guidance (ASU 2014-15). It makes sense that FASB created going concern disclosure guidance. After all, disclosures are an accounting issue. 

Accounting Standard

ASU 2014-15, Disclosure of Uncertainties about an Entity’s Ability to Continue as a Going Concern, provides guidance in preparing financial statements. This standard was effective for years ending after December 15, 2016.

GASB Statement 56, Codification of Accounting and Financial Reporting Guidance Contained in the AICPA Statements on Auditing Standards, is the relevant going concern standard for governments. GASB 56 was issued in March 2009. (GASB 56 requires financial statement preparers to evaluate whether there is substantial doubt about a governmental entity’s ability to continue as a going concern for 12 months beyond the date of the financial statements. As you will see below, this timeframe is different from the one called for under ASU 2014-15. This post focuses on ASU 2014-15 and SAS 132.)

Meanwhile, the Auditing Standards Board issued their own going concern standard in February 2017: SAS 132.

Auditing Standard

Auditors will use SAS 132, The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern, to make going concern decisions. This SAS is effective for audits of financial statements for periods ending on or after December 15, 2017. SAS 132 amends SAS 126The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern.

So, let’s take a look at how to apply ASU 2014-15 and SAS 132.

Two Stages of Going Concern Decisions

In the past, the going concern decisions were made by auditors in a single step. Now, it is helpful to think of going concern decisions in two stages:

  1. Management decisions concerning the preparation of financial statements 
  2. Auditor decisions concerning the audit of the financial statements

First, we’ll consider management’s decisions.

Stage 1. Management Decisions

 

ASU 2014-15 provides guidance concerning management’s determination of whether there is substantial doubt regarding the entity’s ability to continue as a going concern.

Going Concern

What is Substantial Doubt?

So, how does FASB define substantial doubt? 

Substantial doubt about the entity’s ability to continue as a going concern is considered to exist when aggregate conditions and events indicate that it is probable that the entity will be unable to meet obligations when due within one year of the date that the financial statements are issued or are available to be issued.

What is Probable?

So, how does management determine if “it is probable that the entity will be unable to meet obligations when due within one year”?

Probable means likely to occur

If for example, a company expects to miss a debt service payment in the coming year, then substantial doubt exists. This initial assessment is made without regard to management’s plans to alleviate going concern conditions. 

ASC 205-40-50-4 says:

The evaluation initially shall not take into consideration the potential mitigating effect of management’s plans that have not been fully implemented as of the date that the financial statements are issued (for example, plans to raise capital, borrow money, restructure debt, or dispose of an asset that have been approved but that have not been fully implemented as of the date that the financial statements are issued).

But what factors should management consider?

Factors to Consider

Management should consider the following factors when assessing going concern:

  • The reporting entity’s current financial condition, including the availability of liquid funds and access to credit
  • Obligations of the reporting entity due or new obligations anticipated within one year (regardless of whether they have been recognized in the financial statements)
  • The funds necessary to maintain operations considering the reporting entity’s current financial condition, obligations, and other expected cash flows
  • Other conditions or events that may affect the entity’s ability to meet its obligations

Moreover, management is to consider these factors for one year. But from what date?

Timeframe

The financial statement preparer (i.e., management or a party contracted by management) should assess going concern in light of one year from the date “the financial statements are issued or are available to be issued.”

So, if December 31, 2017, financial statements (for a nonpublic company) are available to be issued on March 15, 2017, the preparer looks forward one year from March 15, 2017. Then, the preparer asks, “Is it probable that the company will be unable to meet its obligations through March 15, 2018?” If yes, substantial doubt is present and disclosures are necessary. If no, then substantial doubt does not exist. As you would expect, the answer to this question determines whether going concern disclosures are to be made and what should be included.

Substantial Doubt Answer Determines Disclosures

If substantial doubt does not exist, then going concern disclosures are not necessary.

If substantial doubt exists, then the company needs to decide if management’s plans alleviate the going concern issue. This decision determines the disclosures to be made. The required disclosures are based upon whether:

  1. Management’s plans alleviate the going concern issue
  2. Management’s plans do not alleviate the going concern issue

1. What if Management’s Plans Alleviate the Going Concern Issue?

If conditions or events raise substantial doubt about an entity’s ability to continue as a going concern, but the substantial doubt is alleviated as a result of consideration of management’s plans, the entity should disclose information that enables users of the financial statements to understand all of the following (or refer to similar information disclosed elsewhere in the footnotes):

  1. Principal conditions or events that raised substantial doubt about the entity’s ability to continue as a going concern (before consideration of management’s plans)
  2. Management’s evaluation of the significance of those conditions or events in relation to the entity’s ability to meet its obligations
  3. Management’s plans that alleviated substantial doubt about the entity’s ability to continue as a going concern

Management’s plans should be considered only if is it probable that they will be effectively implemented. Also, it must be probable that management’s plans will be effective in alleviating substantial doubt.

So, if management’s plans are expected to work, does the company have to explicitly state that management’s plans will alleviate substantial doubt? No. 

When management’s plans alleviate substantial doubt, companies need not use the words going concern or substantial doubt in the disclosures. And as Sears discovered, it may not be wise to do so (their shares dropped 16% after using the term substantial doubt even though management had plans to alleviate the risk). Rather than using the term substantial doubt, consider describing conditions (e.g., cash flows are not sufficient to meet obligations) and management plans to alleviate substantial doubt.

Sample Note – Substantial Doubt Alleviated

An example note follows:

Note 2 – Company Conditions

The Company had losses of $4,525,123 in the year ending March 31, 2017. As of March 31, 2017, its accumulated deficit is $11,325,354. 

Management believes the Company’s present cash flows will not enable it to meet its obligations for twelve months from the date these financial statements are available to be issued. However, management is working to obtain new long-term financing. It is probable that management will obtain new sources of financing that will enable the Company to meet its obligations for the twelve-month period from the date the financial statements are available to be issued.

Notice this example does not use the words substantial doubt.

2. What if Management’s Plans Do Not Alleviate the Going Concern Issue?

If conditions or events raise substantial doubt about an entity’s ability to continue as a going concern, and substantial doubt is not alleviated after consideration of management’s plans, an entity should include a statement in the notes indicating that there is substantial doubt about the entity’s ability to continue as a going concern within one year after the date that the financial statements are available to be issued (or issued when applicable). Additionally, the entity should disclose information that enables users of the financial statements to understand all of the following:

  1. Principal conditions or events that raise substantial doubt about the entity’s ability to continue as a going concern
  2. Management’s evaluation of the significance of those conditions or events in relation to the entity’s ability to meet its obligations
  3. Management’s plans that are intended to mitigate the conditions or events that raise substantial doubt about the entity’s ability to continue as a going concern

Sample Disclosure – Substantial Doubt Not Alleviated

An example disclosure follows:

Note 2 – Going Concern
 
The financial statements have been prepared on a going concern basis which assumes the Company will be able to realize its assets and discharge its liabilities in the normal course of business for the foreseeable future.  The Company had losses of $1,232,555 in the current year. The Company has incurred accumulated losses of $2,891,727 as of March 31, 2017. Cash flows used in operations totaled $555,897 for the year ended March 31, 2017.
 
Management believes these conditions raise substantial doubt about the Company’s ability to continue as a going concern within the next twelve months from the date these financial statements are available to be issued. The ability to continue as a going concern is dependent upon profitable future operations, positive cash flows, and additional financing.
 
Management intends to finance operating costs over the next twelve months with existing cash on hand and loans from its directors. Management is also working to secure new bank financing. The Company’s ability to obtain the new financing is not known at this time.
 
Notice this note includes a statement that substantial doubt is present. Though management’s plans are disclosed, the probability of success is not provided.

ASU 2014-15 Summary

ASU 2014-15 focuses on management’s assessment regarding whether substantial doubt exists. If substantial doubt exists, then disclosures are required. Here’s a short video summarizing 2014-15:

Thus far, we’ve addressed the stage 1. management decisions. As you can see management’s considerations focus on disclosures. By contrast, auditors focus on the audit opinion. Now, let’s look at what auditors must do.

Stage 2. Auditor Decisions

 

SAS 132 provides guidance concerning the auditor’s consideration of an entity’s ability to continue as a going concern.

Going Concern

Objectives of the Auditor

SAS 132, paragraph 10, states the objectives of the auditor are as follows:

  • Obtain sufficient appropriate audit evidence regarding, and to conclude on, the appropriateness of management’s use of the going concern basis of accounting, when relevant, in the preparation of the financial statements
  • Conclude, based on the audit evidence obtained, whether substantial doubt about an entity’s ability to continue as a going concern for a reasonable period of time exists
  • Evaluate the possible financial statement effects, including the adequacy of disclosure regarding the entity’s ability to continue as a going concern for a reasonable period of time
  • Report in accordance with this SAS

These objectives can be summarized as follows:

  1. Conclude about whether the going concern basis of accounting is appropriate
  2. Determine whether substantial doubt is present
  3. Determine whether the going concern disclosures are adequate
  4. Issue an appropriate opinion 

In light of these objectives, certain audit procedures are necessary.

Risk Assessment Procedures

In the risk assessment phase of an audit, the auditor should consider whether conditions or events raise substantial doubt. In doing so, the auditor should examine any preliminary management evaluation of going concern. If such an evaluation was performed, the auditor should review it with management. If no evaluation has occurred, then the auditor should discuss with management the appropriateness of using the going concern basis of accounting (the liquidation basis of accounting is required by ASC 205-30 when the entity’s liquidation is imminent) and whether there are conditions or events that raise substantial doubt. 

The auditor is to consider conditions and events that raise substantial doubt about an entity’s ability to continue as a going concern for a reasonable period of time. What is a reasonable period of time? It is the period of time required by the applicable financial reporting framework or, if no such requirement exists, within one year after the date that the financial statements are issued (or within one year after the date that the financial statements are available to be issued, when applicable). The governmental accounting standards require an evaluation period of “12 months beyond the date of the financial statements.”

Auditors should consider negative financial trends or factors such as:

  • Working capital deficiencies
  • Negative cash flows from operating activities
  • Default on loans
  • A denial of trade credit from suppliers
  • Need to restructure debt
  • Need to dispose of assets
  • Work stoppages or other labor problems
  • Need to significantly revise operations
  • Legal problems
  • Loss of key customers or suppliers
  • Uninsured catastrophes
  • The need for new capital

The risk assessment procedures are a part of planning an audit. You may obtain new information as you perform the engagement.

Remaining Alert Throughout the Audit

The auditor should remain alert throughout the audit for conditions or events that raise substantial doubt. So, after the initial review of going concern issues in the planning stage, the auditor considers the impact of new information gained during the subsequent stages of the engagement.

Audit Procedures When Substantial Doubt is Present

If events or conditions do give rise to substantial doubt, then the audit procedures should include the following (SAS 132, paragraph 16.):

  1. Requesting management to make an evaluation when management has not yet performed an evaluation
  2. Evaluating management’s plans in relation to its going concern evaluation, with regard to whether it is probable that: 
    1. management’s plans can be effectively implemented and 
    2. the plans would mitigate the relevant conditions or events that raise substantial doubt about the entity’s ability to continue as a going concern for a reasonable period of time
  3. When the entity has prepared a cash flow forecast, and analysis of the forecast is a significant factor in evaluating management’s plans: 
    1. evaluating the reliability of the underlying data generated to prepare the forecast and 
    2. determining whether there is adequate support for the assumptions underlying the forecast, which includes considering contradictory audit evidence
  4. Considering whether any additional facts or information have become available since the date on which management made its evaluation

Sometimes management’s plans to alleviate substantial doubt include financial support by third parties or owner-managers (usually referred to as supporting parties). 

Financial Support by Supporting Parties

When financial support is necessary to mitigate substantial doubt, the auditor should obtain audit evidence about the following:

  1. The intent of such supporting parties to provide the necessary financial support, including written evidence of such intent, and
  2. The ability of such supporting parties to provide the necessary financial support

If the evidence in a. is not obtained, then “management’s plans are insufficient to alleviate the determination that substantial doubt exists.”

Intent of Supporting Parties

The intent of supporting parties may be evidenced by either of the following:

  1. Obtaining from management written evidence of a commitment from the supporting party to provide or maintain the necessary financial support (sometimes called a “support letter”)
  2. Confirming directly with the supporting parties (confirmation may be needed if management only has oral evidence of such financial support)

If the auditor receives a support letter, he can still request a written confirmation from the supporting parties. For instance, the auditor may desire to check the validity of the support letter.

If the support comes from an owner-manager, then the written evidence can be a support letter or a written representation.

Support Letter

An example of a third party support letter (when the applicable reporting framework is FASB ASC) is as follows:

(Supporting party name) will, and has the ability to, fully support the operating, investing, and financing activities of (entity name) through at least one year and a day beyond [insert date] (the date the financial statements are issued or available for issuance, when applicable). 

You can specify a date in the support letter that is later than the expected date. That way if there is a delay, you may be able to avoid updating the letter.

The auditor should not only consider the intent of the supporting parties but the ability as well.

Ability of Supporting Parties

The ability of supporting parties to provide support can be evidenced by information such as:

  • Proof of past funding by the supporting party
  • Audited financial statements of the supporting party
  • Bank statements and valuations of assets held by a supporting party

After examining the intent and ability of supporting parties regarding the one-year period, you might identify potential going concern problems that will occur more than one year out.

Conditions and Events After the Reasonable Period of Time

So, should an auditor inquire about conditions and events that may affect the entity’s ability to continue as a going concern beyond management’s period of evaluation (i.e., one year from the date the financial statements are available to be issued or issued, as applicable)? Yes.

Suppose an entity knows it will be unable to meet its November 15, 2018, debt balloon payment. The financial statements are available to be issued on June 15, 2017, so the reasonable period goes through June 15, 2018. But management knows it can’t make the balloon payment, and the bank has already advised that the loan will not be renewed. SAS 132 requires the auditor to inquire of management concerning their knowledge of such conditions or events. 

Why? Only to determine if any potential (additional) disclosures are needed. FASB only requires the evaluation for the year following the date the financial statements are issued (or available to be issued, as applicable). Events following this one year period have no bearing on the current year going concern decisions. Nevertheless, additional disclosures may be merited.

Thus far, the requirements to evaluate the use of the going concern basis of accounting and whether substantial doubt is present have been explained. Now, let’s see what the requirements are for:

  • Written representations from management
  • Communications with those charged with governance
  • Documentation

Written Representations When Substantial Doubt Exists

When substantial doubt exists, the auditor should request the following written representations from management:

  1. A description of management’s plans that are intended to mitigate substantial doubt and the probability that those plans can be effectively implemented
  2. That the financial statements disclose all the matters relevant to the entity’s ability to continue as a going concern including conditions and events and management’s plans

Communications with Those Charged with Governance

Remember that you may need to add additional language to your communication with those charged with governance.

When conditions and events raise substantial doubt about the entity’s ability to continue as a going concern for a reasonable period of time, the auditor should communicate the following (unless those charged with governance manage the entity):

  1. Whether the conditions or events, considered in the aggregate, that raise substantial doubt about an entity’s ability to continue as a going concern for a reasonable period of time constitute substantial doubt
  2. The auditor’s consideration of management’s plans
  3. Whether management’s use of the going concern basis of accounting, when relevant, is appropriate in the preparation of the financial statements
  4. The adequacy of related disclosures in the financial statements
  5. The implications for the auditor’s report

Documentation Requirements

When substantial doubt exists before consideration of management’s plans, the auditor should document the following (SAS 132, paragraph 32.):

  1. The conditions or events that led the auditor to believe that there is substantial doubt about the entity’s ability to continue as a going concern for a reasonable period of time.
  2. The elements of management’s plans that the auditor considered to be particularly significant to overcoming the conditions or events, considered in the aggregate, that raise substantial doubt about the entity’s ability to continue as a going concern, if applicable.
  3. The audit procedures performed to evaluate the significant elements of management’s plans and evidence obtained, if applicable.
  4. The auditor’s conclusion regarding whether substantial doubt about the entity’s ability to continue as a going concern for a reasonable period of time remains or is alleviated. If substantial doubt remains, the auditor should also document the possible effects of the conditions or events on the financial statements and the adequacy of the related disclosures. If substantial doubt is alleviated, the auditor should also document the auditor’s conclusion regarding the need for, and, if applicable, the adequacy of, disclosure of the principal conditions or events that initially caused the auditor to believe there was substantial doubt and management’s plans that alleviated the substantial doubt.
  5. The auditor’s conclusion with respect to the effects on the auditor’s report.

Opinion – Emphasis of Matter Regarding Going Concern

If the auditor concludes that there is substantial doubt concerning the company’s ability to continue as a going concern, an emphasis of a matter paragraph should be added to the opinion.

An example of a going concern paragraph is as follows:

The accompanying financial statements have been prepared assuming that the Company will continue as a going concern. As discussed in Note 2 to the financial statements, the Company has suffered recurring losses from operations, has a net capital deficiency, and has stated that substantial doubt exists about the company’s ability to continue as a going concern. Management’s evaluation of the events and conditions and management’s plans regarding these matters are also described in Note 2. The financial statements do not include any adjustments that might result from the outcome of this uncertainty. Our opinion is not modified with respect to this matter.

The auditor should not use conditional language regarding the existence of substantial doubt about the entity’s ability to continue as a going concern. 

Opinion – Inadequate Going Concern Disclosures

Paragraph 26. of SAS 132 states that an auditor should issue a qualified opinion or an adverse opinion, as appropriate, when going concern disclosures are not adequate.

SAS 132 Summary 

Now, let’s circle back to where we started and review the objectives of SAS 132.

The objectives are as follows:

  • Conclude about whether the going concern basis of accounting is appropriate
  • Determine whether substantial doubt is present
  • Determine whether the going concern disclosures are adequate
  • Issue an appropriate opinion 

Conclusion

As you can see ASU 2014-15 and SAS 132 are complex. So, make sure you are using the most recent updates to your disclosure checklists and audit forms and programs.

Finally, keep in mind that going concern is also relevant to compilation and review engagements.

Steal Like a Boss
Jun 18

Steal Like a Boss (and Feel Good About It)

By Charles Hall | Fraud

Can you steal like a boss? White collar crime takes special skills and thoughts. Do you have what it takes? Here’s my tongue-in-cheek look at how I would steal.

Steal Like a Boss

 

Six Steps to Steal Like a Boss

To steal, I need to:

  1. Be Believable
  2. Have a Cause
  3. Calm My Conscience
  4. Develop My Plan
  5. Execute My Plan
  6. If Caught, Settle Out of Court

1. Be Believable

Look trustworthy. The more age, experience, and education I have, the better. The longer I work for the organization, the more I am trusted.

And while I’m at it, I’ll do what I can to move to positions of higher authority which will provide me with greater opportunities. Being in authority enables me to steal like a boss.

If possible, I will gain the ability to authorize or initiate purchases. Kickbacks (paid to those who authorize payments) are difficult to detect, even by professional fraud examiners, and the dollars can be significant. Like taking candy from a baby.

But before I steal, I need motivation. 

2. Have a Cause

Any financial pressure will do–a gambling or drug habit, an affair, medical bills, or maybe I just want to appear more successful than I am. If I don’t have a need, I will create one. I am my own cause.

My unshareable need (cause) must not be known by others lest they suspect my need for cash. 

One problem I must take care of before I steal is my conscience.

3. Calm My Conscience

I hate when that little voice starts talking: “Charles, you can’t do this. You’ll embarrass your wife.” It takes skill and fortitude, but I must calm my conscience. All the more reason to have a cause (see point 2.). The nobler I can make my reasons, the better. Something like, “I’ve earned this. The company should realize my greatness and provide me with appropriate compensation. I have three kids in college, and they need my support. You know I want to be a good provider for my family.”

I may need to start stealing borrowing or compensating myself in small amounts and then build up. Such wise reasoning will make it easier to calm my conscience.

Thinking correctly is important. When that little voice speaks, I will rephrase the words. I know I can. After all, I’ve done so for years.

Now I need to develop a plan.

4. Develop My Plan

I will pay attention to control weaknesses.

Our auditors have told us for years that we lack appropriate segregation of duties in regard to purchasing. Opportunity awaits.

If I am going to steal be compensated appropriately, I need to make it worth my while. Be bold. Think big. I have noticed that one of our key vendors has been very kind to me, a free week-long trip to Vegas for the last three years.

A key contract renewal is coming up. The vendor should be more generous to me. Besides, last year the CFO received a nicer trip than I did (two weeks in Austria). And bribes gifts don’t hurt anyone; the vendor pays for them (though I have noticed the vendor’s pricing seems to be increasing…actually, exploding).

It’s game time. I need to “just do it.” But how?

5. Execute My Plan

Take I must compensate myself in a steady under-the-radar kind of way. Most folks get greedy. I must be diligent to work in a measured way, not taking receiving noticeable amounts. Greed is my enemy. Excess might land me on the front page of the paper.

Also, I think I can steal borrow money from the receipts cycle since I am in charge of daily deposits and all related accounting duties. This might cost me my vacation though. I need to be on the job to continue to hide perform my duties. But if the funds taken compensation is enough, it might be worth it.

But what if my actions become known to others?

6. If I Get Caught, Settle Out of Court

If I am discovered someone notices that I have borrowed funds, then I may have to beg for forgiveness and promise to pay it back. And, of course, I need to make sure the company understands my concern for its reputation. News like this does not support the company’s mission statement: Honesty and Compassion for Those We Serve.

I don’t need a criminal record, especially if I need to steal borrow funds from my next employer. It is comforting to know that in many cases companies don’t prosecute for fear of public embarrassment. 

More Fraud Information

You’ll find more information about fraud prevention in my book: The Little Book of Local Government Fraud Prevention.

See my series of fraud articles at White Collar Crime is Knocking at Your Door.

Key fraud findings
Jun 11

2018 ACFE Fraud Report to the Nations (Key Findings)

By Charles Hall | Fraud

Here are key findings from the 2018 ACFE Fraud Report. The survey is titled the 2018 Report to the Nations.

Key fraud findings

Every two years the Association of Certified Fraud Examiners (ACFE) issues a fraud report based on hundreds of actual fraud cases. The report provides great insights into how fraud occurs (the method), the persons stealing (the fraudster), and the damage (the amount of losses). 

If you are an auditor (internal or external), then you need to be familiar with the findings in this report. Understanding how theft occurs will enable you to detect and prevent it in the future.

Here are key points from the report.

2018 ACFE Fraud Report Findings

  • Organizations lose 5% of their revenues to fraud
  • check
    The median duration of a fraud was 16 months
  • The median loss per case was $130,000
  • The median loss per case when owners or executives were involved was $850,000
  • check
    Businesses with a 100 or fewer employees suffered a median loss per case of $200,000
  • check
    Businesses with more than 100 employees suffered a median loss per case of $104,000
  • check
    In 40% of the cases, tips were the initial detection method (53% of the tips came from employees of the organization; 32% of the tips came from vendors, customers, and competitors)
  • check
    Fraud losses were 50% smaller for organizations with fraud hotlines
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    Only 4% of the fraudsters had a prior fraud conviction
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    Occupational fraud was committed in the following categories: (1) asset misappropriation (89%), (2) corruption (38%), and (3) financial statement fraud (10%) -- in some cases, the fraudster used multiple schemes
  • check
    The median losses were (1) $114,ooo for asset misappropriation, (2) $250,000 for corruption, and (3) $800,000 for financial statement fraud
  • check
    70% of corruption cases were committed by someone in a position of authority
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    82% of corruption cases were committed by males
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    50% of corruption cases were detected by a tip
  • check
    Internal control weaknesses led to nearly half of the fraud
  • check
    Small businesses typically have fewer anti-fraud controls than larger organizations, leaving them more vulnerable
  • check
    Data monitoring/analysis and surprise audits were correlated with the largest reductions in fraud losses and duration (yet only 37% of victim organizations implemented these controls)
  • check
    A majority of the victim organizations recovered nothing
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    Fraudsters that were with the company for more than five years stole an average of $200,000
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    Fraudsters that were with a company for less than five years stole an average of $100,000
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    The industries with the highest levels of fraud were (1) Banking and Financial, (2) Manufacturing, (3) Governments, and (4) Health Care
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    The departments with the highest level of fraud were (1) Accounting (14%), (2) Operations (14%), (3) Sales (12%), and (4) Executive/upper management (11%)
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    69% of frauds were commented by males with a median loss of $156,000 (the median loss from female thefts was $89,000)
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    61% of the fraud cases involved someone with a university degree or postgraduate degree
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    When one fraudster was involved, the median loss was $74,000
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    When two fraudsters were involved, the median loss was $150,000
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    When three or more fraudsters were involved, the median loss was $339,000
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    Living beyond their means was the primary behavioral red flag (41% of cases) 
89%
of fraud from asset misappropriations

Get Your Free Copy of ACFE Report

Join the ACFE 

I have been a member of the Association of Certified Fraud Examiners since 2004. Why? Because I want to be a better auditor. And I have found that the ACFE has given me a much greater understanding of how fraud happens and how to prevent it. The organization has made me a much better auditor. Consider joining this organization. (You can join without becoming a Certified Fraud Examiner (CFE), though I recommend doing that as well. Learn more about becoming a CFE.) You'll be glad you did.

CPA Hall Talk Fraud Articles

For more information about fraud, see White Collar Crime is Knocking at Your Door. There you will see a list of fraud-related articles that I have written.

Fraud Prevention Book

Also check out my book on Amazon: The Little Book of Local Government Fraud Prevention. While the book focuses on governments, there is plenty of information relevant to all organizations.

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CPAHallTalk.com is now live
Jun 01

CPAHallTalk.com is Now Live

By Charles Hall | Accounting and Auditing

CPAHallTalk.com is now live!

CPAHallTalk.com is now live

My blog’s name was formerly CPAScribo.com. Now it’s CPAHallTalk.com. Why the change? To make it more recognizable and memorable. 

I started CPAScribo.com six years ago. At the time, I had no readers, and honestly, the blog was not very good. Still, it was my way of serving CPAs. Limited, yes, but over time, more effective and useful to you–my reader. 

And that’s what CPAHallTalk.com is all about–you. I want—in my own small way—to make you better. Someone in the know. Someone efficient. Someone effective.

Over time, the information in CPAScribo.com (now CPAHallTalk.com) has increased—numbering in the hundreds of articles. Also, the readership has grown. For 2018, I anticipate over 180,000 unique visitors. Additionally, over 1,500 subscribers receive my free periodic newsletters by email.

What’s my focus? To provide information to CPAs (mainly in the United States) concerning auditing, accounting, fraud, and technology

What’s my style? I try to write in a manner that feels like a chat, some Hall Talk if you will. My desire is to make the difficult easy (or at least easier).

What’s to come? I will provide more information to assist you in staying current. In what areas? Accounting and auditing standards, fraud prevention and detection, and the use of technology in your CPA firm. We are in a period of unprecedented change. Artificial intelligence. Data analytics. Blockchain. New accounting and auditing standards. New audit software. So, I want to help you keep up.

Your suggestions? If you have suggestions for future posts, please email me or include them in the comment box below.

Here at CPAHallTalk.com I look forward to serving you and building an even stronger relationship. Cheers.

10 Steps to Make Work Papers Sparkle
May 22

10 Steps to Make Work Papers Sparkle

By Charles Hall | Accounting and Auditing , SSARS

In this post, I provide ten steps to make work papers sparkle.

Have you ever been insulted by a work paper review note?

Your tickmarks look like something created by my child.

Rather than providing guidance, the comment feels like an assault.

Or maybe you are the reviewer–you stare at a work paper for several minutes–and you’re thinking, “what the heck is this?” Your stomach tightens and you say out loud, “I don’t have time for this.”

There are ways to create greater clarity in your work papers.

Make Work Papers Sparkle

Make Work Papers Sparkle

Here are ten steps to make your work papers sparkle.

  1. Timely review work papers. The longer the in-charge waits to review work papers, the harder it is for the staff person to remember what they did and, if needed, to make corrections. Also, consider that the staff person may be reassigned to another job. Therefore, he may not be available to clear the review notes.
  2. Communicate the work paper’s purpose.

a.  An unclear work paper is like a stone wall. It blocks communication.

b.  State the purpose of the work paper; for example:

Purpose of Work Paper – To search for unrecorded liabilities as of December 31, 2018. Payments greater than $30,000 made from January 1, 2019, through March 5, 2019, were examined for potential inclusion in accounts payable.

Or:

Purpose of Work Paper – To provide a detail of accounts receivable that agrees with the trial balance; all amounts greater than $20,000 agreed to subsequent receipt.

If the person creating the work paper can’t state the purpose, then maybe there is none. It’s possible that the staff person is trying to copy a work paper from the prior year that (also) had no purpose.

Click Purpose Notation Explanation for brief audio comment.

c.  All work papers should satisfy a part of the audit program (plan). No corresponding audit program step? Then the audit program should be updated to include the step—or maybe the work paper isn’t needed at all.

3.  The preparer should sign off on each work paper  (so it’s clear who created it).

4. Audit program steps should be signed off as the work is performed (not at the end of the audit–just before review). The audit program should drive the audit process—not the prior year work papers.

5.  Define tickmarks.

6.  Reference work papers. (If you are paperless, use electronic links.)

7.  Communicate the reason for each journal entry.

The following explanation would not be appropriate:

To adjust to actual.

A better explanation:

To reverse client-prepared journal entry 63 that was made to accrue the September 10, 2018, Carter Hardware invoice for $10,233.

8.   When in doubt, leave it out.

Far too many documents are placed in the audit file simply because the client provided them. Moreover, once the work paper makes its way into the file, auditors get “remove-a-phobia“–that dreaded sense that if the auditor removes the work paper, he may need it later.

If you place those unneeded documents in your audit file and do nothing with them, they may create potential legal issues. I can hear the attorney saying, “Mr. Hall, here is an invoice from your audit file that reflects fraud.”

Again, does the work paper have a purpose?

My suggestion for those in-limbo work papers: Place them in a “file 13” stack until you are completely done. Then–once done–destroy them. I place these work papers in a recycle bin at the bottom of my work paper tree. 

9.  Complete forms. Blanks should not appear in completed forms (use N/A where necessary).

10. Always be respectful in providing feedback to staff. It’s too easy to get frustrated and say or write things we shouldn’t. For instance, your audit team is more receptive to:

Consider providing additional detail for your tickmark: For instance–Agreed invoice to cleared check payee and dollar amount.

This goes over better than:

You failed to define your tickmark–again?

Last Remarks

What other ways do you make your work papers sparkle? Comment below.

You may also be interested in a related post: 7 Steps to Effectively Review Financial Statements. Also, see If It’s Not Documented, It’s Not Done.

The Exciting (and Scary) Future Changes in Accounting
May 21

The Exciting (and Scary) Future Changes in Accounting

By Charles Hall | Technology

Are you ready for the exciting (and scary) future changes in accounting?

I have spent the last two days talking to and listening to CPAs talk about the coming changes in accounting and auditing. What’s the cause of the changes? In a word: Technology.

The Exciting (and Scary) Future Changes in Accounting

The Coming Changes in Public Accounting

Specifically, we will see changes from artificial intelligence, blockchain, big data, and audit tools. The big four have already spent hundreds of millions of dollars in developing (and embracing) these technologies.

The expectation, so I am hearing, is for CPA firms to reduce the employment of traditional positions (e.g., auditing and tax) and increase the use of other disciplines (e.g., data analytics, leveraging AI and other technologies).

When these changes occur (and yes, I believe they are coming), CPAs can get hurt. Or we can embrace the changes and continue to be profitable. Ignoring these dynamics (or saying they are overstated) will—I believe—leave one blind-sided. 

Could I be wrong? Well, yes. And it would not be the first time. But based on what I am reading and hearing, it appears we will see more change in the next five years than we have in the last twenty-five (that’s a pure guess).

Examples of Emerging Accounting and Audit Software

Firms will need to make investments in emerging technologies and new software products such as Onpoint (a compilation and review product developed by the AICPA and CaseWare).

One platform, Mindbridge, offers audit technology with artificial intelligence. (Mindbridge works with standard accounting software packages such as QuickBooks and Intaact.)

An interesting platform for bookkeeping is AutoEntry. This package automates the entry of information into QuickBooks (it works with the online and desktop versions). Hector Garcia provides a nice YouTube video demonstrating how this software works.

Onpoint, Mindbridge, and AutoEntry are examples of technologies that will transform accounting as we know it. Anybody feel like we’re watching the accounting version of the Jetsons?

Advisory Services: An Opportunity

Interestingly, one of the fastest growing areas in public accounting is advisory services. So, smaller CPA firms should expect more demand from bookkeeping clients in terms of providing business advice: strategic planning, how and when to borrow money, where to invest excess funds, etc. This makes sense. The newer technologies are providing accountants with more time. And with that time, we can become better advisors.

May 15

Fraudulent Payments Without Being on the Signature Card

By Charles Hall | Asset Misappropriation

Today I show you how bookkeepers can make fraudulent payments without being on the signature card.

Auditors often focus on authorized check signers when considering who can fraudulently disburse funds. But might it be possible to make payments without being on the bank’s signature card? The answer is yes. 

fraudulent payments without being on the signature card

Courtesy of a DollarPhoto.com

Fraudulent Payments without Being on the Signature Card

Here are a few ways to disburse funds without being on a signature card:

  1. Forgery
  2. Unsigned checks
  3. Wire transfer 
  4. Electronic bill pay 
  5. Signing checks with accounting software 
  6. Use of a signature stamp

1. Forgery

Since banks don’t usually inspect checks as they clear, a forged check will normally clear the bank.

2. Unsigned Checks

Again, since banks don’t normally inspect checks as they are processed, an unsigned check can clear the bank. (I saw one just last month.)

3. Wire Transfer

Many times–at the client’s direction–banks wire money with just one person’s approval. One nonprofit administrator stole $6.9 million in less than an hour because of this control weakness. 

I have also seen small-town business bookkeepers drop by a local bank and ask them to wire money. Banks, desiring to help their client, sometimes do.

Businesses should use the controls offered by banks. Otherwise, they might be on the hook for fraudulent wires.

4. Electronic Bill Pay

Anyone with the right passwords can make electronic bill payments to themselves or anyone else.

5. Signing Checks with Accounting Software

This one scares me the most.

Many businesses, in an effort to expedite the disbursement process, have authorized signatures embedded in the payables software, enabling the payables clerk to make a payment to anyone. If the payables clerk has access to check stock (and they usually do), watch out. Even if a second person is normally involved in processing checks with automatic signatures, how easy is it for the clerk to go by in the evenings and make fraudulent payments? This danger increases if the payables clerk also reconciles the bank account. Why? No second person is reviewing the cleared checks.

6. Use of a Signature Stamp

I cringe every time I see a signature stamp. Why not just ask the authorized signer to just sign plenty of blank checks? (Yes, I am being facetious.)

Just last year I worked on a case where the bookkeeper wrote manual checks to herself but entered payments in the general ledger to legitimate vendors for the same amounts. Why? To mask the payments.

Recipe for Disbursement Fraud

Give anyone (1) the ability to sign checks, (2) access to blank check stock, and (3) the ability to make the bookkeeping entry, and you have the recipe for theft–particularly if that same person reconciles the bank statement or if the person reconciling the bank statement does not examine the payee on cleared checks. If you can’t segregate duties (there are too few employees), here’s how to lessen segregation of duties problems in two easy steps

How to Audit Accounts Payable

Click here for detailed information about how to audit accounts payable and expenses.

CPAHallTalk.com
May 14

CPAHallTalk.com is My New Blog Name (June 1)

By Charles Hall | Accounting and Auditing

CPA-Scribo.com is about to become CPAHallTalk.com.

CPAHallTalk.com

Last week I decided to change the name of my blog. So, I reached out to my regular subscribers and asked for their assistance. I offered a $200 Amazon gift card to the winner. I couldn’t believe the response.

How many suggestions did I receive? Over 200! I was blown away.

And who is the winner? Sara Laidlaw (Www.asbinc.net) from Savannah, Georgia.

Thanks, Sara, for the new name.

If you key in CPA-Scribo.com after the change on June 1, you’ll automatically redirect to the new URL: CPAHallTalk.com.

Thanks much to everyone that participated! My subscribers are the best. At present, the blog has over 1,500 subscribers. So, come on and join the party. You can subscribe below.

The blog is on track to have over 180,000 visitors this year

corporate account takeover
May 02

Corporate Account Takeover (the Importance of Using Bank Security Procedures)

By Charles Hall | Accounting and Auditing , Fraud , Local Governments

Some thieves gain control of company bank accounts using a corporate account takeover scheme. And with that control, they steal money. Below you’ll see how this type of theft occurs.

On March 17, 2010, cyber thieves hacked into the computers of Choice Escrow and stole the login ID and password to their online banking account. With that information, the thieves were able to submit a $440,000 wire transfer from Choice Escrow’s bank account to an account in Cyprus.

Corporate account takeover

Courtesy of istockphoto.com

When Choice Escrow and the bank were unable to resolve their differences, Choice Escrow filed suit. The back-and-forth legal battle lasted until March 18, 2013, when a court ruled the loss was the responsibility of Choice Escrow. A major determining factor in the decision was Choice Escrow’s refusal of the dual control security mechanism offered by Bancorpsouth Bank. According to Article 4A of the Uniform Commercial Code, if an institution offers a reasonable security procedure to a commercial customer and that customer turns down that security procedure, then the customer is liable in the event of a loss.

Bancorpsouth Bank offered dual control to Choice Escrow twice. Not only did the bank offer this security feature to Choice Escrow, but Bancorpsouth also documented the customer’s refusal to use the security feature. The documentation of the customer’s refusal of the security features was a determining factor in this case. From a bank’s perspective, this case underscores the importance of a written agreement with commercial online banking customers and, more importantly, the importance of documenting the security procedures offered to those customers. From a user’s perspective, the case highlights the need to use the security procedures offered.

Corporate Account Takeover

Corporate account takeover is a term which has become more prevalent over recent years. Generally speaking, corporate account takeover occurs when an unauthorized person or entity gains access or control over another entity’s finances or bank accounts. This usually results in the theft of money in the form of fraudulent wire transfers or ACH transactions.

These fraud schemes first began to be noticed in 2005 but have since become much more widespread and frequent. Recent statistics have revealed that the fraudsters carrying out these schemes are actually becoming less successful in getting money out of a bank account. This reduction is due to both increased efforts on the part of the financial institutions, as well as better education of the customer to help them avoid becoming a target.

Usually, the financial institutions themselves are not the targets of the attack but rather the corporate customers of the institution. Using malware, social engineering, and various other methods, the fraudster obtains information about the customer’s online banking credentials. Once the online banking credentials have been obtained, a request for wire or ACH transfers is placed by the thief. Any business may be targeted for these types of attacks, but those at risk mostly are small businesses, governments, and nonprofits who have limited resources to protect against such threats.

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