Do you know how to assess inherent risk? Knowing when this risk is low is a key to efficient audits. In this article, I tell you how to assess inherent risk--and how lower risk assessments (potentially) decrease the amount of work you perform.
While audit standards don't require a separate assessment on inherent risk (IR) and control risk (CR), it's wise to do so. Why? So you know what drives the risk of material misstatement (RMM).
Many auditors assess control risk at high (after performing their risk assessment procedures). Why? So they don't have to test controls.
If control risk is high, then inherent risk is the only factor that can lower your risk of material misstatement. For example, a high control risk and a low inherent risk results in a moderate risk of material misstatement. Why is this important? Lower RMMs provide the basis for less substantive work.
The Audit Risk Model
Before we delve deeper into inherent risk assessment, let's do a quick review of the audit risk model. Auditing standards (AU-C 200.14) define audit risk as “The risk that the auditor expresses an inappropriate audit opinion when the financial statements are materially misstated. Audit risk is a function of the risks of material misstatement and detection risk.”
Audit risk is defined as follows:
Audit Risk = IR X CR X Detection Risk
Inherent risk and control risk live within the entity to be audited.
Detection risk lies with the auditor.
A material misstatement may develop within the company because the transaction is risky or complex. Then, controls may not be sufficient to detect and correct the misstatement.
If the auditor fails to detect the material misstatement, audit failure occurs. The auditor issues an unmodified opinion when a material misstatement is present.
If the RMM is high, more substantive work is needed. Why? To reduce detection risk.
But if the RMM is low to moderate, less substantive work is needed.
Inherent Risk Definition
What is inherent risk? The susceptibility of an assertion about a class of transaction, account balance, or disclosure to a misstatement that could be material, either individually or when aggregated with other misstatements, before consideration of any related controls.
The risk for cash is greater than that of a building. Cash is easily stolen. Buildings are not.
The risk of a hedge transaction is greater than that of a trade receivable. Hedges can be complicated to compute. Trade receivables are not.
Post-retirement liabilities are inherently risky. Why? It's a complex accounting area. The numbers usually come from an actuary. There are estimates in the form of assumptions.
Inherent Risk Factors
Consider factors such as the following in assessing risk:
Susceptibility to theft or fraudulent reporting
Complex accounting or calculations
Accounting personnel’s knowledge and experience
Need for judgment
Difficulty in creating disclosures
Size and volume of accounts balance or transactions
Susceptibility to obsolescence
Prior year period adjustments
Inherent risk is not an average of the above factors. Just one risk factor can make an account balance or transaction cycle or disclosure high risk.
Inherent Risk at Less Than High
When inherent risk is less than high, you can perform fewer or less rigorous substantive procedures.
An example of a low inherent risk is the existence assertion for payables. If experienced payables personnel accrue payables, then the existence assertion might be assessed at low. (The directional risk of payables is an understatement, not an overstatement.) The lower risk assessment for existence allows the auditor to perform little if any procedures in relation to this assertion.
Conversely, the completeness assertion for accounts payable is commonly a high inherent risk. Businesses can inflate their profits by accruing fewer payables. Fraudulent reporting of period-end payables is possible. Therefore, the risk of completeness for payables is often high. That's why auditors perform a search for unrecorded liabilities.
Base your risk assessment on factors such as those listed above. If inherent risk is legitimately low, then great. You can perform less substantive work. But if the assertion is high risk, then it should be assessed accordingly--even if that means more work. (The AICPA has included questions in peer review checklists regarding the basis for lower risk assessments. Their concern (I think) is that auditors might manipulate this risk in order to perform less work. I've heard no one from the AICPA say this. But I can see how they might be concerned about this possibility.)
So, what is the relationship between inherent risk and control risk?
Companies develop internal controls to manage areas that are inherently risky.
A business might create internal controls to lessen the risk that payables are understated. Examples of such controls include:
The CFO reviews the payables detail at period-end, inquiring about the completeness of the list
A payables supervisor reviews all invoices entered into the payables system
The payables supervisor inquires of all payables clerks about any unprocessed invoices at period-end
A budget to actual report is provided to department heads for review
Inherent risk exists independent of internal controls.
Control risk exists when the design or operation of a control does not remove the risk of misstatement.
Audit Risk Assessment Book
My new book, Audit Risk Assessment Made Easy, is now available on Amazon. If you struggle with internal control walkthroughs, preliminary analytics, understanding the entity and its environment, risk assessment and linkage, then this book is for you. Click the book cover to see it now on Amazon.
This video provides an overview of the four opinions:
If there are no material misstatements, then you will issue an unmodified opinion. The unmodified opinion says the financial statements are presented fairly.
Example SAS 134 Unmodified Opinion
A sample unmodified audit opinion follows:
INDEPENDENT AUDITOR’S REPORT
We have audited the financial statements of [Entity Name], 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.
In our opinion, the accompanying financial statements present fairly, in all material respects, the financial position of [Entity Name] as of December 31, 2020 and 2019, 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 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 [Entity Name] 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 [Entity Name]’s ability to continue as a going concern for one year after the date that the financial statements are available to be issued.
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 there is a substantial likelihood that, individually or in the aggregate, they would influence the judgment made by a reasonable user based on the 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 [Entity Name]’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 [Entity Name]’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.
If material misstatements are present, then a modified audit opinion is necessary. Modifications can also occur when you are unable to obtain sufficient appropriate audit evidence; for instance, when a scope limitation is present.
AU-C 705 defines a modified opinion as a (1) qualified opinion, (2) an adverse opinion, or (3) a disclaimer of opinion.
Another key definition in AU-C 705 is that of pervasiveness. This term is used in the context of misstatements; so if a material misstatements are present, you’ll want to know if they are pervasive. Two factors–material misstatements and pervasiveness–affect the type of opinion to be issued. Additionally, the ability or inability to obtain sufficient appropriate audit evidence affects the type of opinion to be issued. A misstatement (or possible misstatement) is pervasive if:
It’s not confined to specific accounts or items of the financial statement, or
If confined, the amount represents a substantial portion of the financial statements, or
If in relation to disclosures, the information is fundamental to the users’ understanding of the financial statements
For example, if material misstatements are present for inventory, receivables, and debt, they are pervasive. Or if, in another example, inventory makes up 60% of total assets and a material misstatement is present in that area, then it’s pervasive. Lastly, if key disclosures are not appropriately communicated or if they are omitted, then that is pervasive.
Now, let’s look at the three modified opinions.
1. Qualified Opinion
Suppose your audit reveals inventories are materially misstated, the client does not record your proposed audit adjustment, and there are no other material misstatements. If this is your situation (a material misstatement exists that is not pervasive), then audit standards allow for the issuance of a qualified opinion.
Here is sample qualified opinion language (this is not the full opinion):
We have audited the financial statements of ABC Company, which comprise the balance sheets as of December 31, 20X1 and 20X0, 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 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 ABC Company as of December 31, 20X1 and 20X0, 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
The Company has property with impaired value. The impairment occurred in 20X9. Accounting principles generally accepted in the United States of America require that impaired assets be written down to their fair market value. The Company continues to reflect the property at cost. If the property was stated at fair value upon impairment, total assets and stockholder’s equity would have been reduced by $X,XXX,XXX as of December 31, 20X1 and 20X0, respectively.
2. Adverse Opinion
Now let’s suppose that you are auditing a consolidated entity, and your client is not willingto include a material subsidiary and which, if included, would have a pervasive impact on the statements.
Here is sample adverse opinion language (this is not the full opinion):
We have audited the consolidated financial statements of ABC Company and its subsidiaries, which comprise the consolidated balance sheet as of December 31, 20X1, and the related consolidated 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, because of the significance of the matter discussed in the Basis for Adverse Opinion section of our report, the accompanying consolidated financial statements do not present fairly the financial position of ABC Company and its subsidiaries as of December 31, 20X1, or the results of their operations or their 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 described in Note X, The Golfing Company has not consolidated the financial statements of its subsidiary Easy-Go Company that it acquired during 20X1. This investment is accounted for on a cost basis by The Golfing Company. Under accounting principles generally accepted in the United States of America, the subsidiary should have been consolidated. Had Easy-Go Company been consolidated, many elements in the accompanying consolidated financial statements would have been materially affected. The effects on the consolidated financial statements of the failure to consolidate have not been determined.
3. Disclaimer of Opinion
Finally, let’s suppose you are performing an audit in which insufficient audit information is provided with regard to receivables and inventories (both of which are material) and that the misstatements have a pervasive impact on the financial statements as a whole.
Here is sample disclaimer of opinion language (this is not the full opinion):
Disclaimer of Opinion
We were engaged to audit the financial statements of ABC Company, which comprise the balance sheet as of December 31, 20X1, 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 opinionon the accompanying financial statements of ABC Company. Because of the significance of the matters 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 these financial statements.
Basis for Disclaimer of Opinion
The Company’s accounting system was hacked during the year by an unknown party, resulting in a series of changes in accounting entries. Additionally, the Company was unable to restore the accounting system. As a result of these matters, we were unable to determine the adjustments that were necessary to correct the balance sheet, statement of income, changes in stockholder’s equity, and cash flow statement as of and for the year ended December 31, 20X1.
Effective Date of SAS 134
The new SAS 134 opinions are required for periods ending on or after December 15, 2021.
Resolving Conflict with Clients
If, as described above, you have a client that is unwilling to post a material audit adjustment, consider creating a draft of the opinion and providing it to them. This is not a threat, just a way to clearly communicate the effect of not posting the adjustment.
Before doing anything, allow the client to fully explain their position. A modified opinion may not be necessary once you understand the facts. But if after the discussion, the you are still convinced there is a material misstatement, a modified opinion may be necessary.
In some cases, you may want to consider withdrawing from the engagement. Consult with your legal counsel before doing so.
Audit Opinion Research
Deciding on the opinion is often the most important decision you will make in an audit. So, do your research, and, if needed, consult with others to gain assurance about your decisions. AU-C 705: Modifications to the Opinion in the Independent Auditor’s Report provides several sample opinions; so refer to those as you create any modified opinions including qualified, adverse, or disclaimer. See AU-C 700: Forming an Opinion and Reporting on Financial Statements for information about unmodified opinions.
Peer reviewers are saying, “If it’s not documented, it’s not done.” Why? Because standards requiresufficient audit documentation in AU-C 230. And if it’s not documented, the peer reviewer can’t give credit. Work papers are your vehicle of communication.
But what does sufficient documentation mean? What should be in our work papers? How much is necessary? This article answers these questions.
Insufficient Audit Documentation
Insufficient audit documentation has been and continues to be a hot-button peer review issue. And it’s not going away.
But auditors ask, “What is sufficient documentation?” That’s the problem, isn’t it? The answer is not black and white. We know good documentation when we see it–and poor as well. It’s the middle that is fuzzy. Too often audit files are poor-to-midland. But why?
First, many times it boils down to profit. Auditors can make more money by doing less work. So, let’s go ahead and state the obvious: Quality documentation takes more time and may lessen profit. But what’s the other choice? Poor work.
Second, the auditor may not understand what the audit requirements are. So, in this case, it’s not motive (make more money), it’s a lack of understanding.
Thirdly, another contributing factor is that firms often bid for work–and low price usually carries the day. Then, when it’s time to do the work, there’s not enough budget (time)–and quality suffers. Corners are cut. Planning is disregarded. Confirmations, walkthroughs, fraud inquiries are omitted. And yes, it’s easier–at least in the short run.
But we all know that qualityis the foundation of every good CPA firm. And work papers tell the story–the real story–about a firm’s character. How would you rate your work paper quality? Is it excellent, average, poor? If you put your last audit file on a website and everyone could see it, would you be proud? Or does it need improvement?
Sufficient Audit Documentation According to AU-C 230
Let’s see what constitutes sufficient documentation.
AU-C 230Audit Documentation defines how auditors are to create audit evidence. It says that an experienced auditor with no connection to the audit should understand:
Nature, timing, and extent of procedures performed
Results and evidence obtained
Significant findings, issues, and professional judgments
While most auditors are familiar with this requirement, the difficulty lies in how to accomplish this. What does it look like? Here are some pointers for complying with AU-C 230.
Experienced Auditor’s Understanding
Here’s the key: When an experienced auditor reviews the documentation, does she understand the work?
Any good communicator makes it her job to speak or write in an understandable way. The communicator assumes responsibility for clear messages. In creating work papers, we are the communicators. The responsibility for transmitting messages lies with us (the auditors creating work papers).
A Fog in the Work Papers
So what creates fogginess in work papers? We forget we have an audience.Others will review the audit documentation to understand what was done. As we prepare work papers, we need to think about those who will see our work. All too often, the person creating a work paper understands what he is doing, but the reviewer doesn’t. Why? The message is not clear.
Just because I know why I am doing something does not mean that someone else will. So how can we create clarity?
Work papers should include the following:
A purpose statement (what is the reason for the work paper?)
The source of the information (who provided it? where did they obtain it and how?)
An identification of who prepared and reviewed the work paper
The audit evidence (what was done)
A conclusion (does the audit evidence support the purpose of the work paper?)
When I make these suggestions, some auditors push back saying, “We’ve already documented some of this information in the audit program.” That may be true, but I am telling you–after reviewing thousands of audit files–the message (what is being done and why) can get lost in the audit program. The reviewer often has a difficult time tieing the work back to the audit program and understanding its purpose and whether the documentation provides sufficient audit evidence.
Remember, the work paper preparer is responsible for clear communication.
And here’s another thing to consider: You (the work paper preparer) might spend six hours on one document, so you are keenly aware of what you did. The reviewer, on the other hand, might spend five minutes–and she is trying (as quickly as she can) to understand your work.
Help Your Reviewers
To help your reviewers:
Tell them what you are doing (purpose statement)
Do it (document the test work)
Then, tell them how it went (the conclusion)
Now let’s move from proper to improper documentation.
Examples of Poor Work Paper Documentation
So, what does insufficient audit documentation look like? In other words, what are some of the signs that we are not complying with AU-C 230?
Here are examples of poor audit work paper documentation:
Signing off on audit steps with no supporting work papers (and no explanation on the audit program)
Placing a document in a file without explaining why (what is its purpose?)
Not signing off on audit steps
Failing to reference audit steps to supporting work papers
Listing a series of numbers on an Excel spreadsheet without explaining their source (where did they come from? who provided them?)
Not signing off on work papers as a preparer
Not signing off on work papers as the reviewer
Failing to place excerpts of key documents in the file (e.g., debt agreement)
Performing fraud inquiries but not documenting who was interviewed (their name) and when (the date)
Not documenting the selection of a sample (why and how and the sample size)
Failing to explain the basis for low inherent risk assessments
This list is not comprehensive, but it provides examples to consider. This list is based on my past experiences. Probably the worst offense (at least in my mind) is signing off on an audit program with no support.
Strangely, however, poor work papers are not the result of insufficient documentation, but too much documentation.
Too Much Audit Documentation
Many CPAs say to me, “I feel like I do too much,” meaning they believe they are auditing more than is necessary. To which I often respond, “I agree.”
Files received from clients that don’t support the audit opinion
Unnecessary work performed on extraneous documents
For whatever reason, clients usually provide more information than we request. And then–for some other reason–we retain those documents, even if not needed.
If auditors add purpose statements to each work paper, then they will discover that some work papers are unnecessary. In writing the purpose statement, we might realize it has none. Which is nice–now, we can eliminate it.
One healthy exercise is topretend we’ve never audited the company and that we have no prior year audit files. Then, with a blank page, we plan the audit. Once done, we compare the new plan to prior year files. If there’s any fat, start cutting.
The key to eliminating unnecessary work lies in performing the following steps (in the order presented):
Too often, we roll the prior year file forward and rock on. If the prior year file has extraneous audit procedures, we repeat them. This creates waste year after year after year.
Before I close this article, here is one good work paper suggestion from my friend Jim Bennett of Bennett & Associates: transaction area maps.
Transaction Area Maps
Include transaction area maps in your file. A summary creates organization and makes it easier to find your work papers. It also provides a birds-eye view of what you have done. Here’s an example:
ACCOUNTS RECEIVABLE WORKPAPER MAP
4-02 Audit Program
4-10 Risk Assessment Analyticals
ACCOUNTS RECEIVABLE AGING
4-20 Customer aging report
4-21 AR break-out of intercompany balances
4-23 AR aging tie in to TB
4-24 Review of AR aging
ACCOUNTS RECEIVABLE CONFIRMATIONS
4-50 Planning worksheet – substantive procedures
4-51 AR confirmation reconciliation
4-52 AR confirmation replies
4-60 Allowance for doubtful accounts
4-70 Intercompany balances and sales to significant customers
4-80 Sales analytics
4-90 Sales cut-off testing
4-95 Revenue recognition 606 support and disclosures
In summary, audit documentation continues to be a significant peer review problem. We can enhance the quality of our work papers by remembering we are not just auditing. We are communicating. It is our responsibility to provide a clear message. We need to do so to comply with AU-C 230, Audit Documentation.
Today we look at one of most misunderstood parts of auditing: audit risk assessment.
Are auditors leaving money on the table by avoiding risk assessment? Can inadequate risk assessment lead to peer review findings? This article shows you how to make more money and create higher quality audit documentation. Below you’ll see how to use risk assessment procedures to identify risks of material misstatement. You’ll also learn about the risk of material misstatement formula and how you can use it to plan your engagements.
Audit Risk Assessment as a Friend
Audit risk assessment canbe our best friend, particularly if we desire efficiency, effectiveness, and profit—and who doesn’t?
This step, when properly performed, tells us what to do—and what can be omitted. In other words, risk assessment creates efficiency.
So, why do some auditors (intentionally) avoid audit risk assessment? Here are two reasons:
We don’t understand it
We're creatures of habit
Too often auditors continue doing the same as last year (commonly referred to as SALY)--no matter what. It’s more comfortable than using risk assessment.
But what if SALY is faulty or inefficient?
Maybe it’s better to assess risk annually and to plan our work accordingly (based on current conditions).
Are We Working Backwards?
The old maxim “Plan your work, work your plan” is true in audits. Audits—according to standards—should flow as follows:
Determine the risks of material misstatements (plan our work)
While we may not complete these steps in this order, we do need to perform our risk assessment first (1.-4.) and then assess risk.
Okay, so what procedures should we use?
Audit Risk Assessment Procedures
AU-C 315.06 states:
The risk assessment procedures should include the following:
Inquiries of management, appropriate individuals within the internal audit function (if such function exists), others within the entity who, in the auditor's professional judgment, may have information that is likely to assist in identifying risks of material misstatement due to fraud or error
Observation and inspection
I like to think of risk assessment procedures as detective tools used to sift through information and identify risk.
Just as a good detective uses fingerprints, lab results, and photographs to paint a picture, we are doing the same.
First, we need to understand the entity and its environment.
Understand the Entity and Its Environment
The audit standards require that we understand the entity and its environment.
I like to start by asking management this question: "If you had a magic wand that you could wave over the business and fix one problem, what would it be?"
The answer tells me a great deal about the entity's risk.
I want to know what the owners and management think and feel. Every business leader worries about something. And understanding fear illuminates risk.
Think of risks as threats to objectives. Your client's fears tell you what the objectives are--and the threats.
To understand the entity and its related threats, ask questions such as:
How is the industry faring?
Are there any new competitive pressures or opportunities?
Have key vendor relationships changed?
Can the company obtain necessary knowledge or products?
Are there pricing pressures?
How strong is the company’s cash flow?
Has the company met its debt obligations?
Is the company increasing in market share?
Who are your key personnel and why are they important?
What is the company’s strategy?
Does the company have any related party transactions?
As with all risks, we respond based on severity. The higher the risk, the greater the response.
Audit standards require that we respond to risks at these levels:
Financial statement level
Responses to risk at the financial statement level are general, such as appointing more experienced staff for complex engagements.
Responses to risk at the transaction level are more specific such as a search for unrecorded liabilities.
But before we determine responses, we must first understand the entity's controls.
Understand Transaction Level Controls
We must do more than just understand transaction flows (e.g., receipts are deposited in a particular bank account). We need to understand the related controls (e.g., Who enters the receipt in the general ledger? Who reviews receipting activity?).
So, as we perform walkthroughs or other risk assessment procedures, we gain an understanding of the transaction cycle, but—more importantly—we gain an understanding of controls. Without appropriate controls, the risk of material misstatement increases.
AU-C 315.14 requires that auditors evaluate the design of their client's controls and to determine whether they have been implemented. However, AICPA Peer Review Program statistics indicate that many auditors do not meet this requirement. In fact, noncompliance in this area is nearly twice as high as any other requirement of AU-C 315 - Understanding the Entity and Its Environment and Assessing the Risk of Material Misstatement.
Some auditors excuse themselves from this audit requirement saying, "the entity has no controls."
All entities have some level of controls. For example, signatures on checks are restricted to certain person. Additionally, someone usually reviews the financial statements. And we could go on.
The AICPA has developed a practice aid that you'll find handy in identifying internal controls in small entities.
The use of walkthroughs is probably the best way to understand internal controls.
Sample Walkthrough Questions
As you perform your walkthroughs, ask questions such as:
Who signs checks?
Who has access to checks (or electronic payment ability)?
Who approves payments?
Who initiates purchases?
Who can open and close bank accounts?
Who posts payments?
What software is used? Does it provide an adequate audit trail? Is the data protected? Are passwords used?
Who receives and opens bank statements? Does anyone have online access? Are cleared checks reviewed for appropriateness?
Who reconciles the bank statement? How quickly? Does a second person review the bank reconciliation?
Who creates expense reports and who reviews them?
Who bills clients? In what form (paper or electronic)?
Who opens the mail?
Who receipts monies?
Are there electronic payments?
Who receives cash onsite and where?
Who has credit cards? What are the spending limits?
Who makes deposits (and how)?
Who keys the receipts into the software?
What revenue reports are created and reviewed? Who reviews them?
Who creates the monthly financial statements? Who receives them?
Are there any outside parties that receive financial statements? Who are they?
Understanding the company’s controls illuminates risk. The company’s goal is to create financial statements without material misstatement. And a lack of controls threatens this objective.
So, as we perform walkthroughs, we ask the payables clerk (for example) certain questions. And—as we do—we are also making observations about the segregation of duties. Also, we are inspecting certain documents such as purchase orders.
This combination of inquiries, observations, and inspections allows us to understand where the risk of material misstatement is highest.
In a AICPA study regarding risk assessment deficiencies, 40% of the identified violations related to a failure to gain an understanding of internal controls.
failure to gain understanding of internal controls
Another significant risk identification tool is the use of planning analytics.
Preliminary Analytical Procedures
Use planning analytics to shine the light on risks. How? I like to use:
Multiple-year comparisons of key numbers (at least three years, if possible)
In creating preliminary analytics, use management’s metrics. If certain numbers are important to the company, they should be to us (the auditors) as well—there’s a reason the board or the owners are reviewing particular numbers so closely. (When you read the minutes, ask for a sample monthly financial report; then you’ll know what is most important to management and those charged with governance.)
You may wonder if you can create planning analytics for first-year businesses. Yes, you can. Compare monthly or quarterly numbers. Or you might compute and compare ratios (e.g., gross profit margin) with industry benchmarks. (For more information about, see my preliminary analytics post.)
Sometimes, unexplained variations in the numbers are fraud signals.
Identify Fraud Risks
In every audit, inquire about the existence of theft. In performing walkthroughs, look for control weaknesses that might allow fraud to occur. Ask if any theft has occurred. If yes, how?
Also, we should plan procedures related to:
Management override of controls, and
The intentional overstatement of revenues
My next post—in The Why and How of Auditing series—addresses fraud, so this is all I will say about theft, for now. Sometimes the greater risk is not fraud but errors.
Same Old Errors
Have you ever noticed that some clients make the same mistakes—every year? (Johnny--the controller--has worked there for the last twenty years, and he makes the same mistakes every year. Sound familiar?) In the risk assessment process, we are looking for the risk of material misstatement whether by intention (fraud) or by error (accident).
One way to identify potential misstatements due to error is to maintain a summary of the larger audit entries you’ve made over the last three years. If your client tends to make the same mistakes, you’ll know where to look.
Now it’s time to pull the above together.
Creating the Risk Picture
Once all of the risk assessment procedures are completed, we synthesize the disparate pieces of information into a composite image.
What are we bringing together? Here are examples:
Unexpected variances in significant numbers
Entity risk characteristics (e.g., level of competition)
Large related-party transactions
Occurrences of theft
Armed with this risk picture, we can now create our audit strategy and audit plan (also called an audit program). Focus these plans on the higher risk areas.
How can we determine where risk is highest? Use the risk of material misstatement (RMM) formula.
Assess the Risk of Material Misstatement
Understanding the risk of material misstatement formula is key to identifying high-risk areas.
What is the risk of material misstatement formula?
Using the RMM formula, we are assessing risk at the assertion level. While audit standards don’t require a separate assessment of inherent risk and control risk, consider doing so anyway. I think it provides a better representation of your risk of material misstatement.
Here's a short video about assessing inherent risk.
And another video regarding control risk assessment.
My new book titled Audit Risk Assessment Made Easy is now available on Amazon. I’ve been working on this for over a year and a half. I think you’ll find it to be a valuable resource in understanding, documenting, planning, and performing risk assessment procedures.
Brainstorming and planning your response to fraud risk
Auditor’s Responsibility for Detecting Fraud – AU-C 240
I still hear auditors say, “We are not responsible for detecting fraud.” But are we not? The detection of material misstatements whether caused by error or fraud is the heart and soul of an audit. So writing off our responsibility for fraud is not an option. We must plan to look for material fraud.
Audits will not, however, detect every material misstatement—even if the audit is properly planned and conducted. Audits are designed to provide reasonable assurance, not perfect assurance. Some material frauds will not be detected. Why? First, an auditor’s time is limited. He can’t audit forever. Second, complex systems make it extremely difficult to discover fraud. Third, the number of potential fraud schemes (there are thousands) makes it challenging to consider all possibilities. And, finally, some frauds are so well hidden that auditors won’t detect them.
Even so, auditors should not turn a blind eye to fraud.
Turning a Blind Eye to Fraud
Why do auditors not detect fraud?
We don’t look for fraud because we don’t understand it
Think of these reasons as an attitude—a poor one—regarding fraud. This disposition manifests itself in the audit file with signs of disregard for fraud.
Signs of Auditor Disregard for Fraud
A disregard for fraud appears in the following ways:
Asking just one or two questions about fraud
Limiting our inquiries to as few people as possible (maybe even just one)
Discounting the potential effects of fraud (after known theft occurs)
Not performing walkthroughs
We don’t conduct brainstorming sessions and window-dress related documentation
Our files reflect no responses to brainstorming and risk assessment procedures
Our files contain vague responses to the brainstorming and risk assessment (e.g., “no means for fraud to occur; see standard audit program” or “company employees are ethical; extended procedures are not needed”)
The audit program doesn’t change though control weaknesses are noted
In effect, auditors—at least some—dismiss the possibility of fraud, relying on a balance sheet approach.
So how can we understand fraud risks and respond to them? First, let’s look at fraud incentives.
Incentives for Fraud
The reasons for theft vary by each organization, depending on the dynamics of the business and people who work there. Fraudsters can enrich themselves indirectly (by cooking the books) or directly (by stealing).
Fraud comes in two flavors:
Cooking the books (intentionally altering numbers)
Cooking the Books
Start your fraud risk assessment process by asking, “Are there any incentives to manipulate the financial statement numbers.” For example, does the company provide bonuses or promote employees based on profit or other metrics? If yes, an employee can indirectly steal by playing with the numbers. Think about it. The chief financial officer can inflate profits with just one journal entry—not hard to do. While false financial statements is a threat, the more common fraud is theft.
If employees don’t receive compensation for reaching specific financial targets, they may enrich themselves directly through theft. But employees can only steal if the opportunity is present. And where does opportunity come from? Weak internal controls. So, it’s imperative that auditors understand the accounting system and—more importantly—related controls.
Discovering Fraud Opportunities
My go-to procedure in gaining an understanding of the accounting system and controls is walkthroughs. Since accounting systems are varied, and there are no “forms” (practice aids) that capture all processes, walkthroughs can be challenging. So, we may have to “roll up our sleeves,” and “get in the trenches.”
For most small businesses, performing a walkthrough is not that hard. Pick a transaction cycle; start at the beginning and follow the transaction to the end. Ask questions and note who does what. Inspect the related documents. As you do, ask yourself two questions:
What can go wrong?
Will existing control weakness allow material misstatements?
In more complex companies, break the transaction cycle into pieces. You know the old question, “How do you eat an elephant?” And the answer, “One bite at a time.” So, the process for understanding a smaller company works for a larger one. You just break it down and allow more time.
Discovering fraud opportunities requires the use of risk assessment procedures such as observations of controls, inspections of documents and inquiries. Of the three, the more commonly used is inquiries.
Inquiries Required by Audit Standards
Audit Standards (AU-C 240) state that we should inquire of management regarding:
Management’s assessment of the risk that the financial statements may be materially misstated due to fraud, including the nature, extent, and frequency of such assessments
Management’s process for identifying, responding to, and monitoring the risks of fraud in the entity, including any specific risks of fraud that management has identified or that have been brought to its attention, or classes of transactions, account balances, or disclosures for which a risk of fraud is likely to exist
Management’s communication, if any, to those charged with governance regarding its processes for identifying and responding to the risks of fraud in the entity
Management’s communication, if any, to employees regarding its views on business practices and ethical behavior
The auditor should make inquiries of management, and others within the entity as appropriate, to determine whether they know of any actual, suspected, or alleged fraud affecting the entity
For those entities that have an internal audit function, the auditor should make inquiries of appropriate individuals within the internal audit function to obtain their views about the risks of fraud; determine whether they have knowledge of any actual, suspected, or alleged fraud affecting the entity; whether they have performed any procedures to identify or detect fraud during the year; and whether management has satisfactorily responded to any findings resulting from these procedures
Notice that AU-C 240 requires the auditor to ask management about its procedures for identifying and responding to the risk of fraud. If management has no method of detecting fraud, might this be an indicator of a control weakness? Yes. What are the roles of management and outside auditors regarding fraud?
Management develops control systems to lessen the risk of fraud.
Auditors review the accounting system to see if fraud-prevention procedures are designed and operating appropriately.
So, the company creates the accounting system, and the auditor gains an understanding of the same. As auditors gain an understanding of the accounting system and controls, we put together the pieces of a story.
The Accounting Story and Big Bad Wolves
Think of the accounting system as a story. Our job is to understand the narrative of that story. As we describe the accounting system in our work papers, we may find missing pieces. Controls may be inadequate. When they are, we ask more questions to make the story complete.
The purpose of writing the storyline is to identify any “big, bad wolves.”
The threats in our childhood stories were easy to recognize. The wolves were hard to miss. Not so in walkthroughs. It is only in connecting the dots—the workflow and controls—that the wolves materialize.
So, how long should the story be? That depends on the size of the organization. Scale your documentation. If the transaction cycle is simple, the documentation should be simple. If the cycle is complex, provide more details. By focusing on control weaknesses that allow material misstatements, you’ll avoid distracting details.
I summarize the internal control strengths and weaknesses within the description of the system and controls and highlight the wording “Control weakness.” For example:
Control weakness: The accounts payable clerk (Judy Jones) can add new vendors and can print checks with digital signatures. In effect, she can create a new vendor and have a check sent to that provider without anyone else’s involvement.
Highlighting weaknesses makes them more prominent. Then I can use the identified fraud opportunities to brainstorm about how theft might occur and to develop my responses to the threats.
Brainstorming and Planning Your Responses
Now, you are ready to brainstorm about how fraud might occur and to plan your audit responses.
Armed with knowledge about the company, the industry, fraud incentives, and the control weaknesses, we are ready to be creative.
In what way are we to be creative? Think like a thief. By thinking like a fraudster, we unearth theft schemes. Why? So we can audit those possibilities. This is the reason for risk assessment procedures in the first place.
What we discover in risk assessment informs the audit plan. Now we are ready to perform our fraud risk assessment. With the information gained in from the risk assessment procedures, we know where the risks are. If, for example, there is a risk that fictitious vendors are present, we might assess the risk of material misstatement at high for the expense occurrence assertion. (Our risks of material misstatement should be assessed at the assertion level.) Then we plan our response which might be testing new vendors added to determine if they are legitimate. So the fraud risk assessment occurs after we perform our risk assessment procedures. This tells us where the risks of material misstatement are.
The Auditor’s Responsibility for Detecting Fraud – AU-C 240
In conclusion, I started this post saying I’d answer the question, “What is an auditor’s responsibility for detecting fraud?”
Hopefully, you now better understand fraud procedures. But to understand the purpose of them, look at a standard audit opinion:
The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the consolidated financial statements, whether due to fraud or error. In making those risk assessments,the auditor considers internal control relevant to the entity’s preparation and fair presentation of the consolidated 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 entity’s internal control. Accordingly, we express no such opinion.
The purpose of fraud risk assessmentsis not to opine on internal control systems or to discover every fraud. It is to assist the auditor in determining where material misstatements—due to fraud—might occur.
Additionally, even well-performed audits will not detect all material fraud. As we saw above, some frauds are extremely difficult to detect. Audits are designed to provide reasonable assurance, not perfect assurance. The standard audit opinion states:
Our responsibility is to express an opinion on these financial statements based on our audits. We conducted our audits 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.
In summary, the auditor should conduct the audit in a manner to detect material fraud. But it is possible that some material frauds will be missed, even when we perform the audit correctly.
The Why and How of Auditing: A Blog Series About Audit Basics
You’ll see how to audit cash, receivables/revenues, payables/expenses, investments, and other transaction cycles. You’ll also see how to perform risk assessment procedures before you plan your further audit procedures.