Category Archives for "Accounting and Auditing"

GASB 87 Lease Accounting
Jul 15

GASB 87 Lease Accounting

By Charles Hall | Accounting , Local Governments

Are you looking for GASB 87 lease accounting information? Are you a government that leases assets? Then you're in the right place. Below I provide information about lease terms, discount rates, accounting entries, and disclosure requirements.

GASB 87 Lease Accounting

Removal of Bright-Line Criteria

Historically governments have followed the guidance in FASB 13, Accounting for Leases. Lease classifications (i.e., operating or capital) were based on bright-line criteria such as whether the government leased an asset for more than 75% of its economic life. 

GASB 87, Leases, removes the bright-line criteria and calls for more judgment. (The words reasonably certain appears thirty-nine times in GASB 87.)

The new lease standard provides for various accounting alternatives. Let's see what they are.

Three Potential Accounting Alternatives

Regarding leases, there are now three accounting alternatives:

  1. Short-term leases
  2. Contracts that transfer ownership
  3. Contracts that do not transfer ownership

Before we dive deeper, here are three quick points about these alternatives:

First, know that short-term leases do not create a lease liability.

Second, understand that contracts that transfer ownership are a financed sale.

Third, know that contracts that do not transfer ownership create a lease liability. This third category is a catchall for arrangements that don't qualify for short-term lease treatment and don't transfer ownership.

Now, let's see how GASB defines a lease.

Definition of a Lease

GASB defines a lease this way:

A lease is defined as a contract that conveys control of the right to use another entity’s nonfinancial asset (the underlying asset) as specified in the contract for a period of time in an exchange or exchange-like transaction.

There are five points to this definition:

First, the lease must be a contract. 

Second, the contract must provide control of the right to use.

Third, this control is in relation to a nonfinancial asset.

Fourth, the control of the nonfinancial asset must be for a period of time.

And finally, the lease is an exchange or exchange-like transaction.

I think the terms contract, period of time, and exchange are easily understood. But the terms control and nonfinancial assets might cause some confusion. So let's clarify those.

Control

A government controls an asset if it has the right to the present service capacity and the right to determine the nature and manner of use of the asset.

In other words, the government must have the right to the benefits generated from the asset. A city can drive a leased police car. That is the benefit, the present service capacity.

Additionally, Nature and manner address whether the government controls the use of the asset. A city police officer can, for example, drive a leased police car at 3:00 a.m. And she can drive it as far as she likes. The police department determines the nature and manner of use.

Nonfinancial Asset

And what is a nonfinancial asset? It's generally anything that is not a financial asset (e.g., cash, receivable). Examples of nonfinancial assets include buildings, land, vehicles, and equipment. There are exceptions, however. 

GASB 87 Scope Exclusions

GASB 87 does not apply to:

  • Leases of intangible assets (e.g., rights to explore for oil and gas)
  • Leased biological assets (e.g., timber)
  • Inventory that is leased
  • Service concession arrangements
  • Leases in which the underlying asset is financed with outstanding conduit debt (unless the underlying asset and the conduit debt are reported by the lessor)
  • Supply contracts (e.g., power purchase agreements)

Now let's see how to determine the lease term.

Lease Term

Prior to GASB 87, the minimum lease payments determined the lease term. Not so any more. In some cases, GASB 87 provides for a more subjective determination of a lease's term, one based on what is reasonably certain.

Lease Options

Under GASB 87, lease terms are not just the noncancelable portion of the agreement. Governments add the following to the noncancelable period:

  • Periods covered by a lessee’s option to extend the lease if it is reasonably certain, based on all relevant factors, that the lessee will exercise that option 
  • Periods covered by a lessee’s option to terminate the lease if it is reasonably certain, based on all relevant factors, that the lessee will not exercise that option 
  • Periods covered by a lessor’s option to extend the lease if it is reasonably certain, based on all relevant factors, that the lessor will exercise that option  
  • Periods covered by a lessor’s option to terminate the lease if it is reasonably certain, based on all relevant factors, that the lessor will not exercise that option.
Reasonably Certain Factors

In determining what reasonably certain is, the government considers factors such as the economic impact of not exercising an option or how the government has acted in the past.

Once the lease term decision is made, document your basis for doing so. Why? So there is a record of the decision. (Your auditors may want to see this. Additionally, the record provides valuable information regarding future lease term decisions.)

Fiscal Funding Clauses Affect on Term

Additionally, you may be wondering if fiscal funding clauses affect leases. (Fiscal funding clauses allow a government to cancel a lease if the government does not appropriate funds for the payments.) If a government is reasonably expected to exercise such a provision, then this factor can impact the lease term. Personally, however, I've never seen a government terminate a lease through such a provision. Fiscal funding clauses will usually not affect lease terms.

So, should governments ever reassess the term period?

Reassessment of Term

Government will generally not reassess the lease term decision. 

Nevertheless, reassessment will occur in some cases. Consider this example. The government enters into a fifteen-year lease with a five-year lease extension. The government believes that it will not exercise the five-year extension. But then in year fifteen, it does so. Now the government binds itself for another five years. Therefore, the lease is extended. And the additional five years is added to the lease term. 

Now that you know about lease terms, you may be wondering about short-term leases. How does a government account for those?

Short-Term Leases

Treat leases with a maximum possible term of twelve months or less as short-term leases. And do not capitalize such leases. 

One word of caution: if there are renewal options, include those in making the short-term lease classification decision, regardless of probability. If, for example, the lease is for twelve months with an option to renew for another six months, then the lease is not short-term. Even if the government believes it will not exercise the option.

So, how do you record short-term lease payments? As expenses.

Contract that Transfers Ownership

If an agreement transfers ownership of the asset to the lessee by the end of the contract, then the contract is a financed purchase. For the lessee, the government records the purchased asset (not an intangible) and the related debt (not a lease liability).

So, what about a lease agreement with a bargain purchase option? Should it be treated as financed purchase? The answer is no. The presence of a bargain purchase option in a lease contract is not the same as a provision that transfers ownership of the underlying asset.

Multiple Components of a Lease Contract

If an agreement has lease and non-lease components, split the transaction. 

A government might, for example, lease floors four and five of a ten-story building. In doing so, it is required to pay for common area maintenance. Split this transaction into a lease and a maintenance contract. Record the lease exclusive of the maintenance payments. If, however, it is not practicable to determine the separate price allocation, the government should account for the transaction as a single lease.

If a lease involves multiple underlying assets (say a police car and a water tank), the government should account for each as a separate lease component. 

Lessee Accounting

If the government is leasing an asset, then it will use the following guidance. (An exception exists if the lease is short-term as explained above.)

GASB 87 Lessee accounting

Initial Recognition

At commencement, the government recognizes an (1) intangible right-to-use asset and (2) a lease liability. 

So the government does not recognize the asset itself (e.g., tractor), but the right to use the asset. This is an intangible asset.

Now let's see how to compute the lease asset.

1. Lease Asset 

So. what goes in the lease asset calculation?

The government should include:

  • Initial lease liability (see below)
  • Payments made to lessor at or before commencement less any lease incentives received from the lessor at or before the commencement of the lease term
  • Initial direct costs that are ancillary charges necessary to place the lease asset into service

So what costs are not included in the intangible asset? Governments should exclude any debt issuance costs.

Notice that the lease asset can be greater than the lease liability. The lease asset starts with the lease liability and increases if, for example, the government makes a payment to the lessor prior to commencement of the lease term.

In governmental funds (e.g., general fund), the initial accounting entry is a debit to capital outlay and a credit to other financing sources. In full accrual funds (e.g., enterprise fund), the initial entry is a debit to the intangible lease asset and a credit to the lease liability.

So, how should the lease asset be amortized?

Lease Asset Amortization

Amortize the lease asset in a systematic and rational manner over the shorter of the lease term or the asset's useful life. Usually this will be straight-line amortization.

And what are the journal entries for recording the lease asset?

Lease Asset Accounting

The government records the lease asset and then amortizes it using an entry such as the following (for full-accrual funds; e.g., water and sewer fund):

Account
Amortization Expense
Accumulated Amortization - Right-of-Use Asset
Debit
XX


Credit


XX

GASB 87 says to report the amortization as an outflow of resources (e.g., amortization expense). The amortization expense can, for financial reporting purposes, be combined with the depreciation expense of other capital assets. 

Modified accrual funds (e.g., general fund) will not record an amortization entry. Why? The asset does not appear on the balance sheet.

2. Lease Liability 

How does a government compute the lease liability?

Simply put, the lease liability is the present value of everything you think you're going to pay. Prior to GASB 87, governments used the present value of minimum lease payments. Now governments include payments that are reasonably certain. (See information above regarding what is reasonably certain.)

The computation is made up of the present value of:

  • Fixed payments
  • Variable payments that depend on an index or a rate (e.g., consumer price index) measured using the index or rate as of the commencement of the lease
  • Variable payments that are fixed in substance
  • Amounts that are reasonably certain of being required to be paid by the lessee under residual value guarantees
  • The exercise price of a purchase option if it is reasonably certain that the lessee will exercise that option
  • Payments for penalties for terminating the lease
  • Any lease incentives receivable from the lessor
  • Any other payments that are reasonably certain of being required based on an assessment of all relevant factors
Variable Payments Based on Future Performance

Governments will not include payments based on future performance or usage in the lease liability. Expense such payments in the period incurred. 

For example, if a government leases a vehicle with a provision for 12,000 miles annually but the car is driven 15,000 miles, expense the payment for the additional mileage as incurred.

So, where does the discount rate come from?

Discount Rate

Use the rate charged by the lessor if specified in the agreement. If not specified, use the incremental borrowing rate for the government. This is the estimated rate the government would pay if, during the life of the lease, it borrowed the funds for those lease payments.

Lease Liability Accounting

Once the initial lease is recorded as a liability, the government will begin making periodic payments to the lessor. The effective interest rate method will be used. Record the payments as follows (for full-accrual funds; e.g., water and sewer fund):

Account
Lease liability
Interest Expense

Cash

Debit
XX

XX

Credit


XX

Post the payments to principal and interest expenditures in modified accrual accounting funds (e.g., general fund).

GASB 87 Disclosures

The following disclosures are required for lessees:

  • A general description of its leasing arrangements 
  • The total amount of lease assets, and the related accumulated amortization, disclosed separately from other capital assets
  • The amount of lease assets by major classes of underlying assets, disclosed separately from other capital assets
  • The amount of outflows of resources recognized in the reporting period for variable payments not previously included in the measurement of the lease liability
  • The amount of outflows of resources recognized in the reporting period for other payments (e.g., termination penalties) not previously included in the measurement of the lease liability
  • Principal and interest requirements to maturity, presented separately, for the lease liability for each of the five subsequent fiscal years and in five-year increments thereafter
  • Commitments under leases before the commencement of the lease term
  • The components of any loss associated with an impairment 

Transition

Apply GASB 87 retroactively, if practicable, for all periods presented. Use the facts and circumstances existing at the beginning of the implementation period to record the leases.

The notes to the financial statements should disclose the nature of the restatement and its effect. 

GASB 87 says that the provisions of this statement need not be applied to immaterial items.

GASB 87 Effective Date

The effective date of GASB 87 is for reporting periods beginning after December 15, 2019. On May 8, 2020, the Governmental Accounting Standards Board (GASB) issued Statement No. 95Postponement of the Effective Dates of Certain Authoritative Guidance. This standard postponed GASB 87 by eighteen months.

So GASB 87 is effective for fiscal year-ends of June 30, 2022 (years starting after June 15, 2021) and calendar year-ends of December 31, 2022 (again, years starting after June 15, 2021). 

test of controls
May 29

Test of Controls: When to Perform and How

By Charles Hall | Auditing

Most auditors don’t perform a test of controls? But should they? Below I explain when such a test is required. I also explain why some auditors choose to use this test even when not required. 

test of controls

Once risk assessment is complete, auditors have three further audit procedures they can use to respond to identified risks:

  1. Test of details 
  2. Substantive analytics
  3. Test of controls

This article focuses on the third option.

Below you will see:

  • The Right Response
  • Not Testing Controls (including video about the same)
  • The Decision Regarding Testing 
  • How to Test Controls
  • Required Tests
  • Which Controls to Test
  • Three-year Rotation of Testing
  • Interim or Period-End Testing

The Right Response 

Which responses to risks of material misstatement are best? That depends on what you discover in risk assessment.

If, for example, your client consistently fails to record payables, then assess control risk for completeness at high and perform a search for unrecorded liabilities (a substantive procedure).

By contrast, if the internal controls for receivables are strong, then assess control risk for the existence assertion at less than high, and test controls for effectiveness. (You do, however, have the option to perform substantive tests rather than test controls, even when controls are appropriate. More about this in a moment.)

Not Testing Controls

Many auditors assess control risk at high (after risk assessment is complete) and use a fully substantive approach. That is fine, especially in audits of smaller entities. Why? Because smaller entities tend to have weaker controls. As a result, controls may not be effective. Therefore, you may not be able to assess control risk at less than high. 

Control risk assessments of less than high must be supported with a test of controls to prove their effectiveness. But if controls are not effective, you must assess control risk at high. This is one reason why you might bypass testing controls: you know, either from prior experience or from current-year walkthroughs, that controls are not effective. If your test reveals ineffectiveness, you are back to square one: a control risk assessment of high. Then substantive procedures are your only option. In such a situation, the initial test was a waste of time. 

The Decision Regarding Testing 

But if controls are effective, why not test them? Doing so allows you to reduce your substantive procedures. There is one reason, however, why you might not test controls even though they appear appropriate: substantive tests may take less time.

Once risk assessment is complete, your responses—the further audit procedures—are based on efficiency and effectiveness. If control testing takes less time, then use this option. If substantive procedures takes less time, then perform a test of details or use substantive analytics. But, regardless of efficiency considerations, address all risks with appropriate responses.

How to Test Controls 

Suppose you’ve decided to test controls for effectiveness. But how? Let’s look at an example starting with risk assessment.

control test

Risk Assessment

Your approach to testing controls depends on risk. 

For example, suppose your billing and collections walkthrough reveals appropriate segregation of duties. You see that authorized personnel issue receipts for each payment received. Additionally, you determine that total daily cash inflows are reconciled by the collections supervisor to the online bank statement, and she signs off on a reconciliation sheet as evidence of this procedure. Lastly, you note that a person not involved in cash collections reconciles the monthly bank statement. In other words, controls are properly designed and in use. 

Furthermore, you believe completeness is a relevant assertion. Why? Theft of incoming cash is a concern since the business handles a high volume of customer checks. If checks are stolen, cash collections would not be complete. Consequently, the inherent risk for completeness is high. The fraud risk is a significant risk which requires a test of details in addition to the test of controls.

Test Supports Effectiveness

Now it’s time to test for effectiveness. 

Test the receipt controls on a sample basis. But before doing so, document the controls you desire to test and the sample size determinations. (See AICPA’s Audit Sampling standard, AU-C 530.)

The first control you are testing is the issuance of receipts by an authorized person and your sample size might be sixty. 

The second control you are testing is the daily reconciliation of cash to the bank statement. For example, you could agree total daily receipts to the bank statement for twenty-five days. As you do so, you review the daily sign-offs on the reconciliation sheets. Why? The collection supervisor’s sign-off is the evidence that the control was performed. 

The third control you are reviewing is the reconciliation of the bank account by a person not involved in the receipting process. So, you review the year-end bank reconciliation and confirm that the person that reconciled the bank statement was not involved in cash collections. 

Once the tests are performed, determine whether the controls are effective. If they are, assess control risk for the completeness assertion at less than high. Now you have support for that lower assessment. 

And what about substantive tests?

You need to perform a test of details since a significant risk (the fraud risk) is present. You might, for example, reconcile the daily total receipts to the general ledger for a month.

Test Doesn’t Support Effectiveness

If your tests do not support effectiveness, expand your sample size and examine additional receipts. Or skip the tests (if you believe the controls are not effective) and move to a fully substantive approach. Regardless, if controls are not effective, consider the need to communicate the control deficiency to management and those charged with governance. 

So, when should you test controls? First let’s look at required tests and then optional ones. 

Required Audit Tests of Controls

Here are two situations where you must test controls:

  • When there is a significant risk and you are placing reliance on controls related to that risk
  • When substantive procedures don’t properly address a risk of material misstatement

Let me explain.

Auditing standards allow a three-year rotation for control testing, as long as the area tested is not a significant risk. But if the auditor plans to rely on a test of controls related to a significant risk, operating effectiveness must be tested annually. 

Also a test of controls is necessary if substantive procedures don’t properly address a risk of material misstatement. For example, consider the controls related to reallocation of investments in a 401(k). The participant goes online and moves funds from one account to another. Other than the participant, there are no humans involved in the process. When processes are fully automated, substantive procedures may not provide sufficient audit evidence. If that is your situation, you must test of controls. Thankfully, a type 2 service organization control report is usually available in audits of 401(k)s. Such a report provides evidence that controls have already been tested by the service organization’s auditor. And you can place reliance upon those tests. In most cases, substantive procedures can properly address risks of material misstatement. So this test requirement is usually not relevant. 

Optional Audit Test of Controls

We just covered the two situations when testing is required. All other control testing is optional.

internal controls

Prior to making the decision about testing, consider the following:

  • Do you anticipate effectiveness? There’s no need to test an ineffective control. 
  • Does the control relate to an assertion for which you desire a lower control risk? 
  • Will it take less time to test the control than to perform a substantive procedure? Sometimes you may not know the answer to this question until you perform the test of controls. If the initial test does not prove effectiveness, then you have to expand your sample or just punt—in other words, use a fully substantive approach. 
  • Will you use the control testing in conjunction with a test of details or substantive analytics? How would effective controls reduce these substantive tests? In other words, how much substantive testing time would you save if the control is effective?
  • Is the control evidence physical or electronic? For example, are the entity’s receipts in a physical receipt book or in a computer? It’s usually easier to test electronic evidence.
  • How large will your sample size be? Some controls occur once a month. Others, thousands of times in the period. The larger the population, the larger the sample. And, of course, the larger the sample size, the more time it will take to perform the test. 
  • Can you test the population as a whole without sampling? Data analytics software—in some instances—can be used to test the entire population. For example, if a purchase order is required for all payments above $5,000, it might be easy to compare all payments above the threshold to purchase orders, assuming the purchase orders are electronic. 

Three-Year Rotation of Testing

As I said earlier, audit standards allow a three-year rotation for testing. For example, if you test accounts payable controls in 2020, then you can wait until 2023 to test them again. In 2021 and 2022, you need to ensure that these controls have not changed. You also want to determine that those controls have continuing relevance in the current audit. How? See if the controls continue to address a risk of material misstatement. And as you perform your annual walkthroughs, inquire about changes, observe the controls, and inspect documents. Why? You want to know that everything is working as it was in 2020, when the initial test was performed. And, yes, you do need to perform those walkthroughs annually, if that is how you corroborate your understanding of controls.

In short, testing for effectiveness can, in most cases, occur every three years. But walkthroughs are necessary each year. If you tested sixty transactions for an appropriate purchase order in 2020, then you can wait until 2023 to do so again. But review of the purchase order process each year in your annual walkthroughs. 

So should you test controls at interim or after year-end?

Interim or Period-End Testing

Some auditors test controls after the period-end (after year-end in most cases). Others at interim. Which is best?

It depends.

interim audit test

Perform interim tests if this fits better in your work schedule. Here’s an example: You perform an interim test on November 1, 2021. Later, say in February 2022, consider whether controls have changed during the last two months of the year. See if the same people are performing those controls. And consider performing additional tests for the November 1 to December 31 period. Once done, determine if the controls are effective. 

Testing on an interim date is not always the answer. For example, if management is inclined to manipulate earnings near year-end, then interim tests may not be appropriate

If you choose to test after period-end, then do so for the full period being audited. Your sample should be representative of that timeframe.

So should you ever test controls at a point in time and not over a period of time? Yes, sometimes. For example, test inventory count controls at year-end only. Why? Well those controls are only relevant to the year-end count, a point in time. Most controls, however, are in use throughout the period you are auditing. Therefore, you need to test those controls over that period of time (e.g., year).

Conclusion

As I said above, many auditors tend to rely fully on substantive responses to the risks of material misstatement. But, in some cases, that may not be the best or wisest approach. If controls are designed well and functioning, why not test them? Especially if it takes less time than substantive procedures.

Finally, take a look at my two related articles regarding responses to the risk of material misstatement: (1) Test of Details: Substantive Procedures and (2) Substantive Analytical Procedures: Power Up.

Substantive Analytical Procedures
May 06

Substantive Analytical Procedures: Power Up

By Charles Hall | Auditing

Are you using substantive analytical procedures in your audits? Many auditors rely solely on tests of details when a better option is available. Substantive analytics, in some cases, provide better evidential matter. And they are often more efficient than tests of details.

In this article, I provide:

  • Substantive Analytics – A Video Overview
  • Analytics in Three Stages
  • Substantive Analytics
  • Responses to Risk of Material Misstatement
  • Substantive Analytical Assurance Level
  • Examples of Substantive Analytics
  • Documenting Substantive Analytical Procedures
  • Other Substantive Analytical Considerations

Professional standards define analytical procedures as evaluations of financial and non-financial data with plausible relationships. An example of such a relationship is salaries may be expected to be a certain percent of total expenses. In other words, numbers behave in particular ways. Because they do, we can use these relationships as evidential matter for our audit opinions.

Substantive Analytics – A Video Overview

This video provides an overview of substantive analytical procedures. 

Before we look at what substantive analytics are and how we use them, let’s see how analytical procedures are used in audits.

Analytics in Three Stages

Auditors use analytics in three stages:

  1. Preliminary (risk assessment)
  2. Final (wrap up)
  3. Substantive (response to risk of misstatement)

Preliminary analytics are performed as a risk assessment procedure. We use them to locate potential material misstatements. And if we identify unexpected activity, we plan a response. For example, if we expect payroll to go up 5% but it goes down 8%, then we plan further audit procedures to see why: these can include tests of details, substantive analytics, and test of controls. 

At the completion of the audit, we use final analytics to determine if we have addressed all risks of material misstatement. Here we compare our numbers and ask, “Have we dealt with all risks of material misstatement?” If yes, fine. If not, then we may need to perform additional further audit procedures. 

Less precision is necessary for preliminary and final analytics as compared to substantive analytics. Preliminary analytics locate misstatements and final analytics confirm the results of the audit. But substantive analytics are used to prove material misstatements are not present. 

Substantive Analytics

Substantive analytical procedures can, in certain cases, be more effective and efficient than a test of details. 

For example, if the ratio of salaries to total expenses has been in the 46% to 48% range for the last few years, then you can use this ratio as a substantive analytic to prove the payroll occurrence assertion. If your expectation is that payroll would be in this range and your computation yields 48%, then your substantive analytic provides evidence that salaries occurred. And this is much easier than a test of details such as a test of forty payroll transactions (where you might agree hours paid to time records and payroll rates to authorized amounts). 

Disaggregation of Data

For a small entity with six employees, one payroll substantive analytic might be sufficient, but you may need to disaggregate the payroll information for a larger company with six hundred people. For instance, you might divide departmental salaries by total salaries and compare those ratios to the prior year. Disaggregation adds more precision to the analytic, resulting in better evidential matter. 

Another example of disaggregation is in relation to revenues. If the company has four major sources of revenue, disaggregate the substantive analytical revenue sources. You might use a trend analysis by revenue source for the last three years. Or you might recompute an estimate of one or more revenue sources based of units sold or property rented. 

The type of substantive analytic is dependent on the nature of the transaction or account balance. If a company rents fifty apartments at the same monthly rate, computing an estimate of revenue is easy. But if a company sells fifty different products at different prices, you may need to disaggregate the substantive analytical data. 

Additionally, consider disaggregating substantive analytics by region if the company has different geographic locations. 

Not for Significant Risk Areas (at least not alone)

Are there audit areas where substantive analytical procedures should not be used alone? Yes. When responding to a significant risk. A test of details must be used when a significant risk is present. For example, a bank’s allowance for loan losses. This allowance is a highly complex estimate; therefore, a test of details is required. You could not solely compare the allowance to prior years,  for example, though such a comparison could complement a test of details. In other words, you could perform a test of details and use a substantive analytic. But a substantive analytic alone would not do. 

Now let’s consider how auditors use substantive analytics to respond to the risk of material misstatement.

Responses to Risks of Material Misstatement

Once you identify a risk of material misstatement, you plan further audit procedures including (1) test of details, (2) substantive analytical procedures, and (3) test of controls. Many auditors use a test of details without performing substantive analytics. Why? For many, it’s habit. We’ve always tested bank reconciliations, for example, so we continue to do so. But maybe we’ve never used substantive analytics to prove revenues or expenses. 

A test of details is often used in relation to balance sheet accounts such as cash, receivables, and debt. 

Substantive Analytical Procedures as a Response

Substantive analytics, on the other hand, are sometimes more fitting for income statement accounts such as revenue or expenses. Why? Because income statement accounts tend to be more consistent from year to year. Here are some examples:

  • Depreciation expense
  • Payroll expense
  • Lease revenue
  • Property tax revenue (in a government)

So consider using substantive analytics when the volume of transactions is high and the account balance is predictable over time. Additionally, use substantive analytics in lower risk areas, including some balance sheet accounts such as: 

  • Plant, property, and equipment (if no significant additions or retirements)
  • Debt (if no new debt or early payoffs)
  • Prepaid assets (e.g., prepaid insurance)

Audit standards tell us that substantive analytics are more appropriate when the risk of misstatement is lower. The higher the risk of misstatement, the more you should use a test of details. For instance, it’s better to use tests of details for significant receivable accounts. But substantive analytics may work well for prepaid insurance. 

Additionally, substantive analytics can be combined with a test of details or a test of controls. If, for example, you’re planning a risk response for accounts payable and expenses, you might use a combined approach: a test of details for accounts payable (e.g., search for unrecorded liabilities) and substantive analytics for expense (e.g., departmental expenses divided by total expenses compared to the prior year).

Another common combined approach is a test of details sample along with substantive analytics. If the substantive analytics are effective, you can reduce the sample size, making the overall approach more efficient. 

Substantive Analytical Assurance Level

Certain substantive analytics provide higher levels of assurance. For example, computing expected rental income provides high assurrance. If your client rents fifty identical apartments at $2,000 a month, the computation is easy and the assurance is high. 

How to Increase Assurance When Using Substantive Analytics

Other types of analytics provide lower assurance: topside ratios or period-to-period comparisons at the financial statement level, as examples. You can, however, increase the substantive analytical assurance level by taking actions such as:

  • Using more comparative periods (e.g., years or months)
  • Comparing ratios to independently published industry statistics 
  • Disaggregating the data (e.g., revenues by product line and units sold)
  • Documenting expectations prior to creating the analytics (to remove bias)
  • Documenting client responses regarding differences along with the follow up procedures and results

Comparing balances with a prior period and providing no explanations is not sufficient as a substantive analytic. Also, if the activity is unexpected, solely documenting client responses to questions is not sufficient. For example, these client answers will not do:

  • Client expected revenues to go up
  • Numbers declined because sales activity went down
  • Client said it’s reasonable

Vague responses are not evidential matter and can result in audit failure, or—worse yet—litigation against your firm. 

Substantive analytics can be used in a wide variety of ways. 

substantive analytical procedures

Examples of Substantive Analytics

Here are examples of substantive analytics:

  • Comparison of monthly sales for the current year with that of the preceding year (to test occurrence)
  • Comparison of profit margins for the last few months of the audit period with those subsequent to period-end (to test cutoff)
  • Percent of expenses to sales compared with the prior year (to test occurrence)
  • Current ratio compared to prior year (to test for solvency and going concern)
  • Comparing current year profit margins with prior periods (to test accuracy and occurrence)
  • For pension or postemployment benefit plans: actuarial value of plan assets divided by actuarial accrued liability compared to prior year (to test completeness and accuracy)
  • For debt: total debt divided by total assets compared to prior year (to test the financial strength of the entity and going concern)
  • For inventory: cost of goods sold divided by average inventory compared to prior year (to test existence and occurrence)

Now let’s see how to document your substantive analytics.

Documenting Substantive Analytical Procedures

In performing substantive analytical procedures, document the following:

1. The reliability of the data 

Document why you believe the data is trustworthy. Reasons could include your prior experience with the client’s accounting system and internal controls related to the information you are using. Though a walkthrough sheds light on those controls, a test of controls for effectiveness provides even greater support for the reliability of the data. Testing controls is optional, however. 

2. Assessed risk of material misstatement by assertion 

Document the assertions being addressed and the related risks of material misstatement. 

3. Expectation 

Document a sufficiently precise expected result of the computation or comparison. You can use a range. Document the expectation prior to examining the recorded numbers. Why? To reduce bias. If the current year expectation is different from the prior year, explain why. For example, if payroll has been stable over the last three years but is expected to increase eight percent in the current year, document why. A less precise expectation may be acceptable if a test of details is performed along with the substantive analytic. 

4. Approach 

Document if the substantive analytic is to be used alone or in conjunction with a test of details. 

5. Acceptable difference 

The acceptable difference is the amount that requires no further investigation. So, for example, if the analytic is $30,000 different from the recorded amount and the acceptable difference is $50,000, you are done. No additional work is necessary. Unacceptable differences require further investigation such as inquiries of management and other audit procedures. Consider the performance materiality for the transaction or account balance as you develop the acceptable difference amount. Also, consider the assessed risk of material misstatement. Higher risk requires a lower acceptable difference. 

6. Conclusion 

Document whether the computation or comparison falls within your expectation. Perform and document other procedures performed if the result is not within your acceptable difference. Your conclusion should include a statement regarding whether you believe the account or transaction balance is materially correct. After all, that’s the purpose of the substantive analytic. 

Here are some concluding thoughts about substantive analytics. 

Other Substantive Analytical Considerations

Substantive analytics are not required. So, think of them as an efficient alternative to test of details.

If the company has weak internal controls or a history of significant misstatements, rely more on tests of details. Substantive analytics work better in stable environments. Additionally, if you, as the auditor, expect to make several material audit adjustments, record those prior to creating substantive analytics. This will help reduce the distortion from those misstatements. 

Testing of controls for effectiveness lends strength to substantive analytics. If the controls are effective, you’ll have more confidence in the substantive analytics. For example, if you test the disbursement approval controls and find them to be effective, the expense analytics will be more trustworthy. If you are testing controls for effectiveness, you may want to do so before creating any related substantive analytics. 

You may also want to see AU-C 520, Analytical Procedures in the audit standards. 

emphasis of matter
Apr 25

Emphasis of Matter & Other Matter Paragraphs: SAS 134

By Charles Hall | Accounting and Auditing

Do you know what you need to know about emphasis of matter and other matter paragraphs? Sometimes auditors elect to or are required to add an extra paragraph. You need to know why and when and how. This article provides information about emphasis of matter (EOM) paragraphs and other matter (OM) paragraphs. (This article is based on AU-C 706, Emphasis-of-Matter Paragraphs and Other-Matter Paragraphs in the Independent Auditor’s Report. See my prior EOM and OM article if you have not adopted SAS 134, 137, 140 and 141.)

emphasis of matter

Definitions

First, let’s first define the two terms.

AU-C 706.07 provides the following definitions:

Emphasis-of-matter paragraph. A paragraph included in the auditor’s report that is required by GAAS, or is included at the auditor's discretion, and that refers to a matter appropriately presented or disclosed in the financial statements that, in the auditor's professional judgment, is of such importance that it is fundamental to users’ understanding of the financial statements.
Other-matter paragraph. A paragraph included in the auditor’s report that is required by GAAS, or is included at the auditor's discretion, and that refers to a matter other than those presented or disclosed in the financial statements that, in the auditor's professional judgment, is relevant to users’ understanding of the audit, the auditor’s responsibilities, or the auditor’s report.

Notice that an EOM refers to “a matter appropriately presented or disclosed in the financial statements,” while an OM refers to “a matter other than those presented or disclosed in the financial statements.” So, EOMs are used in relation to information included in the financial statements, and OMs are used in reference to information outside the financial statements.

Now, let us take a look at sample EOM and OM paragraphs.

Sample Emphasis of Matter Paragraph

Here’s a sample EOM paragraph:

Emphasis of Matter

As discussed in Note X to the financial statements, subsequent to the date of the financial statements, there was flood damage to the Company’s inventory facilities. Our opinion is not modified with respect to that matter.

Sample Other Matter Paragraph

Here is a sample OM paragraph:

Other Matter

In our report dated April 18, 20X5, we expressed a qualified opinion since the Company’s main office had a material unrecognized impairment loss. As disclosed in Note 12, the Company has now recognized the impairment in conformity with accounting principles generally accepted in the United States of America. Accordingly, our present opinion on the restated 20X4 financial statements, as presented herein, is different from that expressed in our previous report.

You also need to know the presentation requirements for EOM and OM paragraphs.

Presentation Requirements for an Emphasis of Matter

The purpose of the EOM is to draw attention to information contained in the financial statements.

AU-C 706.08 and 706.09 provides EOM guidance. These paragraphs tell you how and when to provide an EOM paragraph.

How to Present an Emphasis of Matter

The auditor should:

  • Refer only to information presented or disclosed in the financial statements
  • Include the paragraph in a separate part of the auditor’s report with a heading (such as Emphasis of Matter)
  • Include in the heading Emphasis of Matter when key audit matters are communicated in the report
  • Include a clear reference to the matter being emphasized and the location of relevant disclosures
  • State that the auditor’s opinion is not modified with respect to the matter emphasized

The EOM can be located just after the Basis for Opinion paragraph unless there is a key audit matters section. If there is a key audit matter section, the EOM can be placed after the Basis for Opinion paragraph or after the Key Audit Matters section. (AU-C 706.A14 does not specify placement of the EOM or OM. It says placement depends on the auditor’s judgment about the significance of the information compared to other elements of the report.)

So, when should an EOM be provided?

When to Present an Emphasis of Matter Paragraph

The auditor presents an EOM when he or she believes the information is fundamental to a user’s understanding of the financial statements. But the auditor can only provide an EOM when (1) the auditor is not qualifying the opinion because of the matter, and (2) when the matter is not a key audit matter. EOMs are sometimes required by audit standards.

Exhibit B of AU-C 706, “List of AU-C Sections Containing Requirements for Emphasis-of-Matter Paragraphs” provides information about audit standards requiring an EOM. Those include:

  • AU-C 560.16c, Subsequent Events and Subsequently Discovered Facts
  • AU-C 708.08-.09 and 708.11-.13, Consistency of Financial Statements

See Exhibit B of AU-C 706 for the full list.

Now let us look at other matter paragraph requirements.

Presentation Requirements for an Other Matter

An OM is used to highlight information external to the financial statements, usually regarding the auditor’s actions, responsibilities, or report. In other words, an OM addresses information not included in the financial statements or notes.

AU-C 706.10 provides OM guidance.

The auditor should:

  • Include the paragraph within a separate part of the auditor’s report with the heading Other Matter or other appropriate wording
  • Not include an OM for an issue that is a key audit matter (such information is reported in the key audit matter section)

How to Present an Other Matter

AU-C 706.A14 does not specify where the OM is to be placed in the auditor’s report, saying the placement “depends on the nature of the information” and “the auditors judgement.” Nevertheless, see AU-C 706.A14 for guidance, especially if there are key audit matters, or legal or regulatory requirements. AU-C 706.A17 shows the OM paragraph following Key Audit Matters paragraph in Illustration 2. (The order in this illustration is Basis of Opinion, Emphasis of Matter, Key Audit Matters, and Other Matter. So, if there are no Emphasis of Matter or Key Audit Matter paragraphs, the OM could—based on this illustration—follow the Basis of Opinion paragraph.)

When to Present an Other Matter Paragraph

Auditors can elect to provide an OM paragraph to provide information about the audit, including the auditor’s responsibilities and report. However, there are instances where such a paragraph is required. Exhibit C of AU-C 706, “List of AU-C Sections Containing Requirements for Other-Matter Paragraphs” provides information about auditing standards that require an OM. Those include:

  • AU-C 700.55-.56 and .58-59, Forming an Opinion and Reporting on Financial Statements
  • AU-C 800.20, Special Considerations—Audits of Financial Statements Prepared in Accordance with Special Purpose Frameworks

See exhibit C of AU-C 706 for the full list.

Simple Summary

Use EOMs and OMs to highlight important matters

SAS 134 amends the EOM and OM requirements

EOMs refer to matters presented or disclosed in the financial statements

OMs refer to a matter other than those presented or disclosed in the financial statements

EOMs and OMs are—in certain situations—required by audit standards

An EOM should refer to the note that describes the issue; include the heading “Emphasis of a Matter” or other appropriate heading

An OM should include the heading “Other Matter” or other appropriate heading

SOC Report
Apr 24

When are SOC Reports Needed by an External Auditor?

By Charles Hall | Auditing

Service organization control (SOC) reports are often necessary to understand outsourced accounting services. So, what are SOC reports and when are they needed?

SOC Report

What are SOC Reports?

When an entity provides services to other entities (e.g., ADP payroll services), the service organization desires to provide comfort to their clients. Why? Well the service organization wants to provide assurance regarding the safety and effectiveness of its services. Trust is foundational to the business relationship. Therefore, the service organization provides comfort to clients by hiring an outside independent auditor to review its accounting system. The result of that review is a service organization control report. 

So if ADP desires to give comfort to its clients regarding the design and operation of its accounting system, it will hire an outside audit firm to review and render an opinion on its internal controls. While SOC reports provide comfort the service organization’s clients, they are also used in another manner. 

Suppose ADP provides payroll services to Jet Sports, Inc. The auditors of Jet Sports will review ADP’s SOC report to see if their accounting system is appropriately designed and operating. After all, ADP, in this example, is an extension of Jet Sports, Inc.’s accounting system. Jet’s auditors view ADP’s services as a part of Jet’s accounting system: Jet has simply outsourced their payroll services to ADP. That’s why ADP’s SOC report is relevant to Jet Sports, Inc.’s audit. 

When are SOC Reports Needed?

SOC reports are needed when:

  • The user entity’s complementary controls are not sufficient to lessen the possibility of material misstatements
  • The SOC report provides information concerning a significant transactions cycle

Many organizations outsource portions of their accounting to service organizations, such as ADP’s payroll services. External auditors need to understand a service organization’s system and related controls–particularly if that work could allow material misstatements in the user’s financial statements. This understanding is provided in SOC reports.

All financial statement audits focus upon whether material misstatements are occurring. Moreover, the auditor’s opinion is supported by audit evidence proving the financial statements are fairly stated. But does (some of this) audit evidence come from SOC reports? Sometimes, yes.

A financial statement auditor is concerned with material misstatements, regardless of how or where they occur, and regardless of who allows the misstatement. Therefore, auditors look for internal controls weaknesses in both the entity being audited and service organizations.

As we will see, the external auditor may not need all SOC reports. On the other hand, some SOC reports may be needed but don’t exist.

Definitions Related to Service Organizations

Before delving into the details of service organization controls, let’s define a few key words

Complementary user entity controls. These are the controls performed by users of a service organization’s services. These entity controls complement the service organization’s controls: both are necessary to ensure the process is safe and effective. For example, your client might perform the complementary control of reviewing payroll hours reported before providing those to an outside payroll service organization. 

Service auditor. The auditor that reports on controls at a service organization.

Service organization. An organization that provides services to user entities that impact the user entity’s financial reporting.

User auditor. The auditor that audits the financial statements of a user entity.

User entity. An entity that uses a service organization and its related SOC report. 

Audit Standard for Service Organizations

AU-C 402, Audit Considerations Relating to an Entity Using a Service Organization, states the following:

Services provided by a service organization are relevant to the audit of a user entity’s financial statements when those services and the controls over them affect the user entity’s information system, including related business processes, relevant to financial reporting.

So if a service organization’s activities affect an entity’s information system, business processes, or financial reporting, then that activity is relevant. 

When is a SOC report not needed?

When does the external auditor not need SOC reports or other information related to a service organization? Paragraph .05 of AU-C 402 answers that question as follows:
 
This section does not apply to services that are limited to processing an entity’s transactions that are specifically authorized by the entity, such as the processing of checking account transactions by a bank or the processing of securities transactions by a broker (that is, when the user entity retains responsibility for authorizing the transactions and maintaining the related accountability).
 
Additionally, complementary user entity controls may be strong enough to eliminate the need for information about the service organization’s controls.

Complementary User Entity Controls

The user entity–an entity that uses a service organization and whose financial statements are being audited–may have controls sufficient to eliminate the need for SOC reports or other information from the service organization. Sometimes the user entity has controls that mitigate the risk of material misstatements caused by service organization deficiencies. Such controls are referred to as complementary user entity controlsIf the complementary controls operate effectively, the user auditor–the auditor who audits and reports on the financial statements of a user entity–may not need SOC reports or other service organization information.

Alternatively, if the service organization initiates, executes, and does the processing and recording of the user entity’s transactions and the complementary controls would not detect material misstatements, then the user auditor may need SOC reports or other service organization information.

When complementary controls are present, they should be reviewed in the walkthrough of controls by the user auditor. For example, if your client reviews payroll time recorded prior to submission to an outside payroll service provider, then determine if this control is designed appropriately and implemented (as you do for all key controls). SOC reports usually provide a list of complementary controls, so look there for potential client controls. Then see if they are in use. 

Is the Placement of a SOC Report in the Audit File Sufficient?

Placing a SOC report in an audit file without reading and understanding it provides little-to-no audit evidence.

A SOC report provides information about how the service organization’s controls lessen the possibility of material misstatement. So, the user auditor needs to read and document how the service organization’s controls lessen the risk of material misstatement. This understanding of controls is necessary if the service organization’s work affects a significant transaction cycle such as payroll.

Think of SOC reports in this manner: Pretend there is no service organization and the company being audited performs the same processes and controls. If the audited entity performs these controls–and no service organization exists–the auditor gains an understanding of the controls using risk assessment procedures such as inquiry, observations, and inspections of documents. Potential control weaknesses are exposed by the risk assessment process. Thereafter, the identified risks are used to develop the audit program and substantive procedures. The same audit process is true when there is a service organization. But when a service organization is used, the user auditor is using the SOC report to gain the understanding of the service organization’s part of the entity’s accounting system.

If controls weaknesses are noted in the SOC report, the user auditor may–as a response–perform substantive procedures. By doing so the auditor lowers the overall audit risk (which is the risk that the auditor will issue an unmodified opinion when one is not merited).

Type 1 or Type 2 SOC Reports?

Service organization auditors can issue type 1 or type 2 reports.

A type 1 SOC report provides a description of a service organization’s system and the suitability of the design of controls.

A type 2 SOC report includes a service organization auditor’s opinion on the fairness of the presentation of management’s description of the service organization’s system and the suitability of the design and operating effectiveness of the controls.

The type 1 report provides information about the service organization’s system and related controls. The type 2 report provides an opinion on the system description and the design and effectiveness of the controls. A type 1 or a type 2 report can be used to gain an understanding of the controls.

You may see, in some of these SOC reports, carve-outs. 

Carve-Outs

Many SOC reports carve out services that are provided to the service organization by another service provider (a service provider to a service provider, if you will). In such a situation, consider whether you need to review the sub-service provider’s SOC report. (Sub-service providers are named in the SOC report along with what they do.)

So, should you (the user auditor) ever visit a service organization’s office?

Should the Auditor Visit the Service Organization?

Usually, the user auditor does not need to visit the service organization, but sometimes it is necessary to do so. If the service organization provides no SOC report and the complementary user controls are not sufficient, then the auditor may have no choice but to review the service organization’s system and controls. Only do so if the service organization handles significant parts of the accounting system.

SOC Reports Summary

In summary, if you audit an entity that uses a service organization, consider whether you need a SOC report. If the service organization provides services that impact a significant transaction cycle or account balance, then you probably need to review the related SOC report. Why? To see if there are any service organization internal control weaknesses that impact your client’s audit. 

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