All Posts by Charles Hall

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About the Author

Charles Hall is a practicing CPA and Certified Fraud Examiner. For the last thirty-five years, he has primarily audited governments, nonprofits, and small businesses. He is the author of The Little Book of Local Government Fraud Prevention, The Why and How of Auditing, Audit Risk Assessment Made Easy, and Preparation of Financial Statements & Compilation Engagements. He frequently speaks at continuing education events. Charles consults with other CPA firms, assisting them with auditing and accounting issues.

Ways Fraud Happens
Jul 13

25 Ways Fraud Happens: Audit Brainstorming

By Charles Hall | Fraud

As auditors perform their fraud brainstorming, it helps to have ideas to consider. So today I provide you with 25 ways fraud happens. 

Ways Fraud Happens

25 Ways Fraud Happens

Here’s a list of common company thefts:

  1. Collection clerk steals cash prior to recording it
  2. Collection clerk steals cash after recording a customer receipt; he voids the receipt and adjusts (writes down) the customer’s account
  3. Collection clerk places a personal check (for $5,000) in the cash drawer and takes an equivalent amount of cash; the clerk leaves the check in the drawer for months—in effect the clerk has an unauthorized loan
  4. The cash collections supervisor steals cash after receiving funds from collection clerks but before the money is deposited; she adjusts the related bank reconciliation by the amount stolen
  5. The person opening the mail steals checks before they are receipted; these amounts had not previously been recorded as a receivable
  6. Employees steal capital assets (knowing that no one performs periodic inventories)
  7. Employees use company credit cards for personal purchases but code the transactions as company expenses
  8. Accounts payable clerks cut checks to themselves (or to an accomplice) but record the check as company expenses; the check signatures are forged
  9. Accounts payable clerks establish fictitious vendors using their own addresses, a P.O. Box, or that of an accomplice; payments are made to the fictitious vendor and covered up with fictitious invoices; the checks are signed electronically as they are printed
  10. Accounts payable employee intentionally double-pays an invoice, then requests that the vendor refund the extra payment (with the refund going directly to the payable clerk)—check is converted to personal use
  11. Payroll personnel increase the pay rate—in the master pay rate file—for themselves or for friends working in the company
  12. Payroll personnel pay themselves (or friends) twice for each payroll
  13. Payroll personnel purposefully overpay withholding taxes and inflate the withholding amount on their own W-2, resulting a tax refund that includes the excess payments
  14. Purchasing department personnel are bribed by a vendor; the vendor recoups the bribe costs by inflating its subsequent invoices
  15. State, city, county elected officials are bribed; the vendor recoups the bribe costs by inflating its subsequent invoices
  16. Vendors give favors (e.g., free vacations) to those with the power to buy—commonly called a gratuity; vendor recoups the cost of the favors by inflating its subsequent invoices
  17. CEO orders accounts payable staff to make payments to himself (with an implied threat); payments are coded in a manner that hides the payment
  18. Money is wired by the CFO to the CFO but is recorded as a legitimate expense using a journal entry
  19. Money is wired to the CFO who then leaves the country without trying to cover up the theft
  20. The CEO or CFO makes payments to someone who is threatening their life or is blackmailing them; the expense is coded as legitimate
  21. A secret bank account is opened in the name of the business by the CFO but the sole authorized check signer is the CFO; checks are made from a legitimate business bank account to the secret bank account; the CFO writes checks to himself from the secret account
  22. A sales person steals rebate checks that belong to the company; she deposits the checks into her personal bank account by writing “pay to the order of…” on the back of the check
  23. The payables clerk writes a manual check to himself and then records the check with a journal entry that reflects a legitimate vendor
  24. The CFO inflates revenue at year-end with fictitious journal entries; stock prices go up; the CFO sells personally-owned company stock, then the CFO reverses the year-end accruals
  25. The inventory clerk steals stock and covers the theft by altering the inventory records

Fraud Brainstorming for Auditors

In performing your fraud brainstorming, consider printing out this list and seeing if any of these thefts are relevant to your audit.

How to prevent payroll fraud
Jul 06

How to Prevent Payroll Fraud

By Charles Hall | Fraud

Do you know how to prevent payroll fraud? Today we take a look at how you can protect your business.

Direct deposit of payroll checks can open the door to theft. Also when one person is in control of payroll processes, danger lurks.

prevent payroll fraud

Picture is courtesy of DollarPhotoClub.com

I was teaching a fraud prevention class this past Friday, and one of the participants, a school payroll clerk named Dawn, asked me to address how fraud might occur in her department. So I asked her a series of questions.

“Does your school use direct deposit?” She answered yes.

“Do you fully control the issuance of W-2s?” Dawn said yes.

“Who adds the direct deposit information to your payroll software?” She answered, “I do.”

“Can anyone else change the direct deposit file?” Her answer was no.

“Who controls the master pay rate file?” Here again, she was the only one who had rights to this payroll function.

Then I asked Dawn if she reconciles the bank statement. She said that Randy, a gentleman sitting in front of her, reconciles the account. I was also told that they have hundreds of employees.

How Can Dawn Steal?

I told the class that a person in Dawn’s position could steal in multiple ways. Here are a few:

  • She can leave a terminated employee on the payroll and change that person’s bank account number to her own, allowing her to receive all payroll payments for the discontinued staff member. Then, she can also alter the related W-2s to cover her tracks.
  • She can change the master pay rate of any employee, including herself.
  • She can inflate the hours worked for any employee.

Prevent Payroll Fraud

After pointing out the flaws in internal control, I asked the class how they would reduce these threats. Angela (another student) sang out: “Create transparency by allowing another person to review or see what the payroll clerk is doing.” (This made me smile since I had been preaching this idea all morning.)

To lessen the threat of fraud, always ask, “how can I create transparency?” The answer will almost always involve allowing another individual to monitor the work of the primary persons in the process. And I am not proposing that this observing person be present 24/7—just that she periodically review the activity of the primary person (e.g., payroll clerk). 

The monitoring person can be someone that works with the entity or someone from the outside (e.g., external CPA). Here are sample fraud prevention measures for the above-described threats:

  • Download all the payroll records, including each employee and direct deposit bank account number; sort for identical bank account numbers (a same bank account number may mean that a terminated employee was left on the payroll, and their deposits are being routed to another person such as the payroll clerk)
  • Have someone (other than the payroll clerk) pull the payroll personnel files for twenty employees and then compare the authorized pay rates (in the personnel file) to the payroll master file (in the software); tell the payroll clerk that this procedure will occur with some frequency and will happen without notice
  • For hourly employees, have someone (other than the payroll clerk) pull the reported hours for two departments and review for appropriateness; inquire of the department head regarding any higher-than-normal hours
  • Examine the W-2s of the payroll personnel
  • Print a budget to actual salary report or a current year/prior year comparison of wages; provide the same to the governing body
  • Report findings from these procedures to the governing body; do this at least once per year (regularity makes the payroll personnel think twice about theft)

Take Away

By the way, the payroll clerk was the only person with access to the payroll master file. This is not necessarily a bad thing. You want to limit the number of persons with access to payroll master file, but a second person should monitor the payroll clerk’s inputs into the payroll software.

So how can you prevent payroll fraud? Think about your own payroll system. Are there any potential threats to your payroll system? Also, be aware of ghost employees.

If you’ve seen payroll fraud, please share a comment about how it happened.

If you are interested in more information about white-collar crime, check out my other fraud prevention articles.

make your CPE incredibly useful
May 26

Make CPE Useful: Seven Suggestions

By Charles Hall | Accounting and Auditing

In a thirty-five year career as a CPA, you will spend well over 1,400 hours taking CPE classes. Are you using this time wisely? Today I share how you can make your CPE useful.

It’s 3:32 p.m. on a Friday and you are thinking, “When will this CPE class ever end?” Your golf swing, a late tax return, your daughter’s college tuition cost–each float through your mind. Your thoughts continue, “So much to do, and I sit here wasting another day. Why can’t this be more interesting?” Tired. Bored. Numb. You want to be anywhere but where you are. You feel trapped. 

make your CPE useful

Why does this happen? Many CPAs mistakenly believe this pain is a requirement of the profession. They seem resigned to death-by-CPE, as though there is no other choice.

But then you’ve been in classes where you’re laughing, learning, and even wanting more. The day ends quickly, and you walk away satisfied.

Wouldn’t you love to increase the quality of your training and your engagement with what you are learning? Here are seven suggestions to make your CPE useful.

1. Create Three-Year CPE Learning Goals: Tie Training to Vision

Create a three-year rolling CPE plan. While you may not be able to plan each individual class, you can still sketch out your desired objectives and learning path.

Fifteen years ago, I decided to become a Certified Fraud Examiner. I thought, “Why not use my CPE hours to move me in that direction?” Over the next year, I purchased the training material from the Association of Certified Fraud Examiners and trained. In September 2004, I reached that goal. Without the goal, the idea would still be just that–an idea. 

What training goal can you set that will make your dream a reality? What vision do you have for your future?

In your career, you will spend hundreds of hours in training. Why not use those precious hours to get you to your desired destination? Continuous learning about new things is no longer an option.

2. Plan Your CPE Classes Annually: Avoid Cramming in December

Planning your CPE calendar will allow you to spread out the learning load (I do not recommend taking 40 hours of CPE the last week of December). The human mind is not designed to absorb large quantities of complex information in a short period. Space out your classes. The separation will allow your mind to digest and retain what you learn. 

3. Seek Out the Best CPE Trainers: They Will Elevate Your Game

Will excellent trainers cost more money? Sometimes yes, but what’s the alternative? Cheap teachers that bore you to death. Signing up for any old class for convenience’s sake or because it’s cheap is a terrible idea.

Great trainers make for excellent learning experiences. Seek them out. Pay the extra money, if need be. This will make your CPE more useful.

4. Revisit CPE Information: Move Learning to Long-Term Memory

For each one-day class, write a one-page summary. Do this the day after you attend the course. (Once you create the one-page outline, archive it in Evernote for future reference.) Merely writing the summary will drive the learning deeper into your mind. 

make your CPE useful

Then revisit the summary using the following intervals:

  • One week later – review for 20 minutes
  • Two weeks later – review for 10 minutes
  • Three weeks later – review for 5 minutes

There’s nothing sacred about the intervals. The method is what is essential.

Additionally, try to recall the information before reviewing the notes. Doing so facilitates retention according to the book Make It Stick. Revisiting the information and trying to recall it will move your knowledge from short-term to long-term memory–where you need it!

Another suggestion to help you remember the information is that you teach it to your firm members. You can’t explain something you don’t understand. Teaching forces you to learn.

5. Use Livescribe Pen to Take Notes: Record the Audio 

For about $180, you can own the Livescribe pen. No, it will not allow you to remember everything you hear. However, it will record the full audio as you write. Then, later, you can touch a particular word in your notes with the tip of the pen and “voilà,” you hear–from the pen–what was said at that moment. You can upload the written notes and audio to your computer. Don’t ask me how it does this, but it works. Amazing! Now you can have a full recording of your training with shortcuts (notes) to find the audio you want to hear. The pen holds up to 200 hours of audio. 

In terms of learning, writing your notes is more effective than typing (and I might add, less distracting to those around you). Science has proven that writing has a more significant effect on learning and retention than typing.

Another learning tip to make your CPE useful: Read the table of contents before the class starts.

6. Read the Table of Contents: Prepare Your Mind 

The human mind likes to anticipate, to know what’s coming. If you can access your CPE material before the class, I encourage you to scan the table of contents and highlight the areas you are most interested in. Highlighting the table of contents will prepare you for what’s coming.

7. Sit Up Front: You’ll Learn More

Finally, sit up front. The farther back you sit, the more distractions you will see (like the guy reading the latest ESPN headlines or the couple talking all day).

Take Action Now: Plan Time to Consider Your Goals

I challenge you to take action now! Go ahead. Specify a time on your calendar to think about your goals and the CPE classes that will get you there. Become an expert in cybersecurity, fraud prevention, litigation support, data mining, artificial intelligence. Pick an area and move toward your goal. 

clear financial statement disclosures
Apr 27

How to Write Clear Financial Statement Disclosures

By Charles Hall | Accounting and Auditing

Creating clear financial statement disclosures is not always easy. Creating (unintentional) confusion? Well, that’s another matter.

clear financial statement disclosures

Clear Financial Statement Disclosures

Let’s pretend that Olympic judges rate your most recent disclosures, flashing scores to a worldwide audience. What do you see? Tens everywhere—or something else?

Balance sheets tend to be clear. Why? The accounting equation. Assets always equal liabilities plus equity. But there is no disclosure equation (darn it), and without such, we flounder in our communication. 

CPAs tend to be linear thinkers. We enjoy Pascal more than Hemingway, numbers more than words, debits and credits more than paragraphs. Our brains are wired that way.

But accounting is more than just numbers. It is the communication of financial statements and disclosures. In the name of clear disclosures, I offer these suggestions.

Consider Your Readers

Who will read the financial statements? Owners, lenders, and possibly vendors. Owners—especially those of smaller businesses—may need simpler language. Some CPAs write notes as if CPAs (alone) will read them. While accounting is technical, we need—as much as possible—to simplify.  

Use Short Paragraphs

Lengthy paragraphs choke the reader. Breaking long paragraphs into shorter ones makes the print accessible. 

Less is more in many instances. When we try to say too much, we sometimes say…too much. Additionally, short sentences are helpful.   

Use Short Sentences

CPAs may have invented the run-on sentence. As I read one of those beauties, I feel as though I can’t breathe. And by the end, I’m gasping. Breaking long sentences into shorter ones makes the reader more comfortable. And she will thank you. 

Use Shorter Words

CPAs don’t receive merit badges for long, complicated words. Our goal is to communicate, not to impress. For example, split is better than bifurcate.  

Attorneys are not our model. I sometimes see notes that are regurgitations of legal agreements, copied word for word—and you can feel the stiltedness. Do your reader a favor and translate the legalese into digestible—and might I say more enjoyable—language. 

Use Tables

Long sentences with several numbers can be confusing. Tables are easier to understand.

Write Your Own Note

Too many CPAs copy disclosures from the Internet without understanding the language. Make sure the language is appropriate for your company.

Put Disclosures in the Right Buckets 

Think of each disclosure header as a bucket. For example, if the notes include a related party note, then that’s where the related party information goes. If the debt note includes a related party disclosure (and this may be necessary), place a reference in the related party note to the debt disclosure. You don’t want your reader to think all of the related party disclosures are in one place (the related party note) when they are not. The same issue arises with subsequent event notes.

Have a Second Person Review the Notes

When writing, we sometimes think we are clear when we are not. Have a second person review the note for proper punctuation, spelling, structure, and clarity. If you don’t have a second person available, perform a cold review the next day—you will almost always see necessary revisions. I find that reading out loud helps me to assess clarity.

I also use Grammarly to edit documents. The software provides grammar feedback as you write. If you don’t have a second person to review your financials, I recommend it.

Use a Current Disclosure Checklist

Vetting your notes with a disclosure checklist may be the most tedious and necessary step. FASB and GASB continue to issue new statements at a rapid rate, so using a checklist is necessary to ensure completeness.   

Winning Gold

I hope these suggestions help you win gold–10s everywhere. I think I hear the national anthem.

going concern
Mar 27

Going Concern in Compilation and Review Engagements

By Charles Hall | Preparation, Compilation & Review

Do you need to concern yourself with going concern in compilation and review engagements? Yes, if the financial statements are prepared in accordance with the FASB Codification. But is going concern relevant to special purpose frameworks such as the cash basis or tax basis financial statements. Yes, going concern is in play even with special purpose frameworks. This post provides an overview of what you need to know about going concern as it relates to compilation and review engagements.

going concern in compilation and review engagements

A while back I wrote a post about ASU 2014-15, Disclosure of Uncertainties about an Entity’s Ability to Continue as a Going Concern, which was effective for years ending after December 15, 2016. This standard requires companies to include certain disclosures when substantial doubt is present. So, we know that financial statements prepared in accordance with GAAP must include these disclosures. Otherwise, there is a GAAP departure. And in an audit, we modify our opinion when there is a departure.

Going Concern in Compilation Engagements

But what about financial statements subject to a compilation engagement, especially when substantially all disclosures are omitted? Is it permissible for the CPA to ignore the going concern standard since it just requires disclosures? Yes, but be careful. Ask yourself whether the financial statements would be misleading (without the going concern disclosure). If they are misleading, then include a selected disclosure regarding going concern. Also, consider adding an emphasis-of-matter paragraph (regarding going concern) to your compilation report.

Consider the following scenario. Your client (who has significant going concern issues) takes your compilation report (which has no emphasis of a matter paragraph) and their financial statements (that has no disclosures) to a local bank. It’s obvious that the company is not doing well. But the bank makes a large loan anyway, and later, the company defaults on the loan. Then the bank files suit against you (the CPA) asserting that you issued the compilation report without the emphasis-of-matter paragraph and that you knew the financial statements had no going concern disclosure. The bank says the financial statements were misleading.

While the emphasis-of-matter paragraph is not required, consider adding one anyway.

Going Concern in Review Engagements

Since review engagements require full disclosure, going concern disclosures are not optional when substantial doubt exists in GAAP financial statements. They must be provided. If they are not, a GAAP departure exists.

So what going concern procedures should you perform in a review engagement?

In regard to going concern when the financial reporting framework includes going concern requirements (e.g. GAAP), AR-C 90.65 states:

If the applicable financial reporting framework includes requirements for management to evaluate the entity’s ability to continue as a going concern for a reasonable period of time in preparing financial statements, the accountant should perform review procedures related to the following: 

    1. Whether the going concern basis of accounting is appropriate
    2. Management’s evaluation of whether there are conditions or events that raised substantial doubt about the entity’s ability to continue as a going concern
    3. If there are conditions or events that raised substantial doubt about the entity’s ability to continue as a going concern, management’s plans to mitigate those matters
    4. The adequacy of the related disclosures in the financial statements

In regard to going concern when the applicable financial reporting framework does not address going concern (e.g., tax basis), AR-C 90.66 states:

If the applicable financial reporting framework does not include a requirement for management to evaluate the entity’s ability to continue as a going concern for a reasonable period of time in preparing financial statements and conditions or events that raise substantial doubt about an entity’s ability to continue as a going concern for a reasonable period of time existed at the date of the prior period financial statements (regardless of whether the substantial doubt was alleviated by the accountant’s consideration of management’s plans) or, in the course of performing review procedures on the current period financial statements, the accountant becomes aware of conditions or events that raise substantial doubt about the entity’s ability to continue as a going concern, the accountant should do the following: 

    1. Inquire of management whether the going concern basis of accounting is appropriate.
    2. Inquire of management about its plans for dealing with the adverse effects of the conditions and events. 
    3. Consider the adequacy of the disclosure about such matters in the financial statements. 

SSARS 24 does say that the nature and extent of procedures performed regarding going concern are a matter of professional judgment. If the audited entity has a history of profitable operations and access to financing, inquiry alone might be sufficient in a review engagement.

Going Concern Paragraph in a Review Report

If the accountant concludes that substantial doubt will remain for a reasonable period of time, an emphasis-of-matter paragraph is required in the review report. (Some reporting frameworks specify a “reasonable period of time.” For GAAP, it is one year from the date the financial statements are issued or are available to be issued.)

AR-C 90.A123 provides the following example of a going concern paragraph in a review engagement when (1) substantial doubt exists for a reasonable period of time, (2) management’s plans don’t alleviate the substantial doubt, and (3) the reporting framework requires a note disclosure.

Emphasis of Matter

The accompanying financial statements have been prepared assuming that the Company will continue as a going concern. As discussed in Note X 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 X. The financial statements do not include any adjustments that might result from the outcome of this uncertainty. Our conclusion is not modified with respect to this matter. 
 
Representation Letter in Review Engagements
 
Be sure to update your representation letter when performing review engagements. SSARS 24 tweaked some language in the letter and added additional wording such as the following:
 
  • Management has disclosed to the accountant all information relevant to use of the going concern assumption in the financial statements.

Special Purpose Frameworks and Going Concern

While the cash, modified cash, or tax bases of accounting do not address going concern, accountants still need to consider the effects of negative financial conditions and trends. Why? When using a special purpose framework (like the tax basis), the accountant should follow the guidance in GAAP. No, that doesn’t mean your disclosures are just like GAAP, but it does mean they are similar to GAAP.

Since GAAP tells the financial statement preparer to consider whether substantial doubt exists, then persons creating cash basis, modified cash basis or tax basis financial statements should do the same. If substantial doubt is present, going concern disclosures are necessary. 

So, what is substantial doubt? The FASB Codification defines it this way:

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.

If substantial doubt is present and going concern disclosures are not included in full disclosure compilations or reviews, then modify your accountant’s report (for the departure). 

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