Category Archives for "Accounting and Auditing"

First Year Audit
Mar 02

First Year Audit Considerations

By Charles Hall | Auditing

Congratulations! You've won a new audit client. Now, let's consider the first year audit considerations.

In this post, I explain why it's necessary to obtain supporting information for opening balances and how contacting the predecessor auditor is to your advantage.

First Year Audit Considerations

First Year Audit Considerations

Here are three key first year audit considerations:

  1. Obtaining information about opening balances 
  2. Reviewing the predecessor auditor's workpapers
  3. Complying with your firm's quality control standards 

Let's take a look at each of these.

1. Obtaining Information about Opening Balances

AU-C 510.08 states "The auditor should obtain sufficient appropriate audit evidence about whether the opening balances contain misstatements that materially affect the current period's financial statements." If you are unable to obtain such information, then you will need to qualify or disclaim your opinion. So, it's important to get comfortable with these balances.

Some auditors think, "Well, I'll just review the prior year audit report." That's a good start, but not good enough.

Why can't we just review the prior audit report? If the prior audit covered the period ending December 31, 2018, it does not cover the January 1, 2019 balances. If your audit is for the year ended December 31, 2019, then reviewing the audited financial statements for the year ending December 31, 2018 helps but it does not ensure the legitimacy of the January 1, 2019 opening balances. The audit standards state that the auditor has to determine whether the prior period closing balances were correctly brought forward to the new period. Additionally, we need to consider how the predecessor's audit work affects our current year risk assessment (more in a moment).

Also, determine that the opening balances are in compliance with appropriate accounting policies. If the prior year financial statements were created using the modified cash basis of accounting but GAAP financials are required in the current year, then bringing forward prior year balances won't do. GAAP is full accrual; the modified cash is not.

Additionally, the audit standards state that the successor auditor should perform "specific audit procedures to obtain evidence regarding opening balances" (per AU-C 510.08). You might, for example, examine the depreciation schedule for the prior year and compare it to the opening balances. For debt or investments, you could confirm the opening balances (I'm not saying this is required, just an option). For some (less significant balances) you might examine investment statements or loan amortizations and agree those to the opening balances. The opening balances for current assets or liabilities might be proven by activity early in the current year: Were prior year receivables collected? Were prior year payables paid?

What we can't do, however, is nothing. The General Audit Engagement Checklist (PRP Section 20,400) asks the peer reviewer the following:

Did the successor auditor obtain sufficient appropriate audit evidence regarding opening balances about whether opening balances contain misstatements that materially affect the current period's financial statements and appropriate accounting policies reflected in the opening balances have been consistently applied?

The peer reviewer will look for documentation as it relates to opening balances. If not present, then there is a problem. At a minimum, write a memo stating how you got comfortable with all significant opening balances. And create an audit program related to opening balances.

2. Reviewing the Predecessor Auditor's Workpapers

Reviewing the predecessor auditor's workpapers is one of the more unpleasant duties of an auditor. I did so recently. The predecessor auditor is a friend of mine. As I visited him, I was uncomfortable. He was cordial, respectful, and nice. Some predecessor auditors don't exactly roll out the red carpet for you (and I get that). I try to remember the importance of professional courtesy when I lose a job (though it stings my pride).

Reviewing the Predecessor Auditor's Workpapers

In any event, the successor auditor is required to initiate communications with the predecessor auditor prior to accepting the engagement (see AU-C 210.11-12). The peer review checklist asks:

If the auditor succeeded another auditor, did the successor auditor initiate communications with the predecessor auditor to ascertain whether there were matters that might assist the auditor in determining whether to accept the engagement?

Why call the predecessor auditor? To see if there were disagreements between the auditor and the company. To see if there were ethical issues.

Additionally, you need to request permission to review their prior year workpapers. AU-C 510.A 7 says, "The extent, if any to which a predecessor auditor permits access to the audit documentation...is a matter of the predecessor auditor's professional judgment." Translation: They don't have to permit access, but they (generally) should. If the predecessor allows access to their workpapers, you can use that information in planning your current year audit. 

3. Complying with Your Firm's Quality Control Standards

See what your firm's quality control document says about initial audits. Many firms require an engagement quality control review (an EQCR) for first-year engagements. (If yours does not, consider adding it to your QC document.) Why? New audits take a great deal of time. Because they do, it's tempting to cut corners. An EQCR lessens the temptation. The engagement partner knows the engagement will be reviewed by another firm member (often, another partner). 

How the Predecessor Auditor's Work Helps You

Contacting the predecessor auditor may be the best thing you can do prior to accepting an audit. They might tell you, for example, that the potential client is unethical or that they are slow to pay their audit fees. Because you desire a healthy book of business, this step may save you plenty of headaches. As I've said before client acceptance is the important audit step.

If you accept the engagement, consider how the predecessor's responses and workpapers affect your risk assessment. Were there several material audit adjustments in the prior year? Did the predecessor auditor issue a material weakness letter? Then such considerations should be included in your current year risk assessment.

The predecessor auditor's work can also help you get comfortable with opening balances. 

Yellow Book Independence
Feb 02

Threats to Yellow Book Independence

By Charles Hall | Auditing , Local Governments

Yellow Book independence is a big deal. And if you prepare financial statements in a Yellow Book audit, you need to be aware of the independence rules. Below I tell you how to maintain your independence—and stay out of hot water,

Yellow Book Independence

Yellow Book Independence Impairment in Peer Review

Suppose that--during your peer review--it is determined your firm lacks independence in regard to a Yellow Book engagement.

What could happen? Well, I can't say for sure, but I think it would be nasty. At a minimum, you would probably receive a finding for further consideration. The engagement is definitely nonconforming (not conforming to professional standards).

Then, you'd need to provide a response--explaining what you intend to do about the lack of independence. And this could get very interesting. Not where you want to be.

Preparation of Financial Statements is a Significant Threat

If you prepare financial statements (a nonattest service) for your audit client, you have a significant threat. Why? You are auditing something (the financial statements) that you created. There is a self-review threat. 

When there is a significant threat, you must use a safeguard (to lessen the threat). Such as? A second partner review. So, for example, you might have a second audit partner (someone not involved in the audit) review the financial statements. Since the second partner did not create the financial statement, the self-review threat is mitigated.

Notice the safeguard (the second partner review) is something the audit firm does--and not an action of the audit client. Therefore, it qualifies as a safeguard.

2018 Yellow Book

The 2018 Yellow Book states the following in paragraph 3.88:

Auditors should conclude that preparing financial statements in their entirety from a client-provided trial balance or underlying accounting records creates significant threats to auditors' independence, and should document the threats and safeguards applied to eliminate and reduce threats to an acceptable level...or decline to provide the services. 

But My Client has Sufficient SKE

You've heard your audit client must have sufficient skill, knowledge and experience (SKE) and that they must oversee and assume responsibility for nonattest services. This is true and is always required when nonattest services are provided to an audit client. 

Even so, the client's SKE does not address the self-review threat. 

Think of the SKE issue as a minimum requirement. Do not pass "go" if the client does not assign someone (with SKE) to oversee the nonattest service. You are not independent. End of discussion. (If the client does not have sufficient SKE, see section below titled Inadequate Skill, Knowledge, and Experience.)

SKE is not a safeguard

The January AICPA Reviewer Alert distinguishes the SKE requirement from safeguards saying, "Client SKE should not be viewed as a safeguard, but rather a mandatory condition before performing any nonaudit services."

Once the client SKE issue is dealt with, consider if auditor safeguards are necessary. Why? A self-review threat may be present. 

The AICPA (in its AICPA Yellow Book Practice aid) provides examples of safeguards (again, these are actions of the audit firm) including:

  • Obtaining secondary reviews of the nonaudit services by professional personnel who were not involved in planning or supervising the audit engagement.
  • Obtaining secondary reviews of the nonaudit services by professional personnel who were not members of the audit engagement team.

See Appendix E of the AICPA Yellow Book Practice Aid for additional examples of safeguards and how to apply them.

Independence Documentation is Required

The Yellow Book requires that your independence be documented. If it is not, a violation of professional standards exists. 

So, document the SKE of the client and the safeguards used to address significant threats. Also, document which nonattest services are signficiant threats. Peer reviewers focus on Independence documentation.

Document Significant Threats

The January 2019 Reviewer Alert (an AICPA newsletter provided to peer reviewers) provides a scenario where an audit firm performs a Yellow Book audit and prepares financial statements. Then the firm has an engagement quality control review (EQCR) performed, but it does not identify the preparation of financial statements as a significant threat. The newsletter states "the engagement would ordinarily be deemed nonconforming for failure to document identification of a significant threat." So, even if a safeguard (e.g., a second partner review) is in use, the lack of documentation makes the engagement nonconforming.

Judging Client's SKE

Here are examples of client personnel that might be available to oversee the financial statements preparation service:
  1. A 15 year mayor who is a businessman, no accounting education, no formal training in reading governmental financial statements. He understands the fund level statements but can't grasp the reconciliation between the government-wide financial statements and the fund level financial statements.
  2. Second year finance director with no prior accounting experience, graduated from a two year college with a degree in general business.
  3. Finance director with 25 years experience and is a CPA and a member of GFOA. She trains others in governmental accounting.
  4. Finance director with a high school education but has extensive governmental accounting training from the Carl Vinson Institute. He has the ability to create the financial statements from scratch.

As you can see, the Yellow Book independence assessment will sometimes be black and white, but other times, not so. Regardless, the audit client has to have someone with sufficient skill, knowledge and experience to oversee the financial statements preparation. Why? The auditor can't assume responsibility for the statements. This is a management responsibility.

Management Responsibilities

The 2018 Yellow Book (paragraph 3.75) says the following about management responsibilities:

In cases where the audited entity is unable or unwilling to assume these responsibilities (for example, the audited entity does not have an individual with suitable skill, knowledge, or experience to oversee the nonaudit services provided, or is unwilling to perform such functions because of lack of time or desire), auditors should concluded that the provisions of these services is an impairment to independence.

Additionally, paragraph 3.73 of the Yellow Book states:

Auditors should determine that the audited entity has designated an individual who possesses suitable skill, knowledge, or experience and that the individual understands the services to be provided sufficiently to oversee them.

If the government has no one with sufficient SKE, then the external auditor is not independent and can't perform the audit.

So, is there another option when the client does not have sufficient SKE?

Inadequate Skill, Knowledge, and Experience

If the auditor can't get comfortable with the client's SKE (e.g., the client's ability to review the financial statements and assume responsibility), what can be done? The audited entity can hire someone with sufficient SKE. For example, the entity could contract with a CPA not affiliated with the external audit firm to review the financial statements on their behalf.

Many smaller governments need to contract with an outside person in order to have sufficient SKE. The problem, however, is they may not have the funds to do so. If you as the auditor make this suggestion, be prepared for this question: "Isn't this why I hired you?" Regardless, the client has to have sufficient SKE before the auditor can issue an opinion. 

In Summary

Here's the lowdown to protect your firm:

  1. Document the nonattest services you are to perform
  2. Document the client person that will oversee and assume responsibility for the nonattest service
  3. Document the SKE of the designated person
  4. Consider whether any nonattest services are significant threats 
  5. Document which, if any, nonattest services are significant threats
  6. Use (and document) a safeguard to address each significant threat (examples of safeguards include an EQCR or a second-partner review)

Looking for a tool to document Yellow Book independence? Consider the AICPA's practice aid. Here is the free PDF version. You can also purchase the fillable version here. (Cost is $39 for AICPA members.) This is the 2011 Yellow Book aid. I am thinking the AICPA will create a 2018 Yellow Book version as well. 

nonprofit accounting
Jan 01

Understanding the New Nonprofit Accounting Standard

By Charles Hall | Accounting

Are you ready to implement FASB’s new nonprofit accounting standard? Back in August 2016, FASB issued ASU 2016-14, Presentation of Financial Statements of Not-for-Profit Entities. In this article, I provide an overview of the standard and implementation tips.

Nonprofit accounting

New Nonprofit Accounting – Some Key Impacts

What are a few key impacts of the new standard?

  • Classes of net assets
  • Net assets released from “with donor restrictions”
  • Presentation of expenses
  • Intermediate measure of operations
  • Liquidity and availability of resources
  • Cash flow statement presentation

Classes of Net Assets

Presently nonprofits use three net asset classifications:

  1. Unrestricted
  2. Temporarily restricted
  3. Permanently restricted

The new standard replaces the three classes with two:

  1. Net assets with donor restrictions
  2. Net assets without donor restrictions

Terms Defined

These terms are defined as follows:

Net assets with donor restrictions – The part of net assets of a not-for-profit entity that is subject to donor-imposed restrictions (donors include other types of contributors, including makers of certain grants).

Net assets without donor restrictions – The part of net assets of a not-for-profit entity that is not subject to donor-imposed restrictions (donors include other types of contributors, including makers of certain grants).

Presentation and Disclosure

The totals of the two net asset classifications must be presented in the statement of financial position, and the amount of the change in the two classes must be displayed in the statement of activities (along with the change in total net assets). Nonprofits will continue to provide information about the nature and amounts of donor restrictions.

Additionally, the two net asset classes can be further disaggregated. For example, donor-restricted net assets can be broken down into (1) the amount maintained in perpetuity and (2) the amount expected to be spent over time or for a particular purpose.

Net assets without donor restrictions that are designated by the board for a specific use should be disclosed either on the face of the financial statements or in a footnote disclosure.

Sample Presentation of Net Assets

Here’s a sample presentation:

Net Assets
Without donor restrictions
  Undesignated  $XX
  Designated by Board for endowment      XX
     XX
With donor restrictions
  Perpetual in nature      XX
  Purchase of equipment XX
  Time-restricted XX
XX
Total Net Assets $XX

Net Assets Released from “With Donor Restrictions”

The nonprofit should disaggregate the net assets released from restrictions:

  • program restrictions satisfaction
  • time restrictions satisfaction
  • satisfaction of equipment acquisition restrictions
  • appropriation of donor endowment and subsequent satisfaction of any related donor restrictions
  • satisfaction of board-imposed restriction to fund pension liability

Here’s an example from ASU 2016-14:

nonprofit statement of activities

Presentation of Expenses

Presently, nonprofits must present expenses by function. So, nonprofits must present the following (either on the face of the statements or in the notes):

  • Program expenses
  • Supporting expenses

The new standard requires the presentation of expenses by function and nature (for all nonprofits). Nonprofits must also provide the analysis of these expenses in one location. Potential locations include:

  • Face of the statement of activities
  • A separate statement (preceding the notes; not as a supplementary schedule)
  • Notes to the financial statements

I plan to add a separate statement (like the format below) titled Statement of Functional Expenses. (Nonprofits should consider whether their accounting system can generate expenses by function and by nature. Making this determination now could save you plenty of headaches at the end of the year.)

External and direct internal investment expenses are netted with investment income and should not be included in the expense analysis. Disclosure of the netted expenses is no longer required.

Example of Expense Analysis

Here’s an example of the analysis, reflecting each natural expense classification as a separate row and each functional expense classification as a separate column.

expenses by function and nature

The nonprofit should also disclose how costs are allocated to the functions. For example:

Certain expenses are attributable to more than one program or supporting function. Depreciation is allocated based on a square-footage basis. Salaries, benefits, professional services, office expenses, information technology and insurance, are allocated based on estimates of time and effort.

Intermediate Measure of Operations

If the nonprofit provides a measure of operations on the face of the financial statements and the use of the term “operations” is not apparent, disclose the nature of the reported measure of operations or the items excluded from operations. For example:

Measure of Operations

Learning Disability’s operating revenue in excess of operating expenses includes all operating revenues and expenses that are an integral part of its programs and supporting activities and the assets released from donor restrictions to support operating expenditures. The measure of operations excludes net investment return in excess of amounts made available for operations.

Alternatively, provide the measure of operations on the face of the financial statements by including lines such as operating revenues and operating expenses in the statement of activities. Then the excess of revenues over expenses could be presented as the measure of operations.

Liquidity and Availability of Resources

FASB is shining the light on the nonprofit’s liquidity. Does the nonprofit have sufficient cash to meet its upcoming responsibilities?

Nonprofits should include disclosures regarding the liquidity and availability of resources. The purpose of the disclosures is to communicate whether the organization’s liquid available resources are sufficient to meet the cash needs for general expenditures for one year beyond the balance sheet date. The disclosure should be qualitative (providing information about how the nonprofit manages its liquid resources) and quantitative (communicating the availability of resources to meet the cash needs).

Sample Liquidity and Availability Disclosure

The FASB Codification provides the following example disclosure in 958-210-55-7:

NFP A has $395,000 of financial assets available within 1 year of the balance sheet date to meet cash needs for general expenditure consisting of cash of $75,000, contributions receivable of $20,000, and short-term investments of $300,000. None of the financial assets are subject to donor or other contractual restrictions that make them unavailable for general expenditure within one year of the balance sheet date. The contributions receivable are subject to implied time restrictions but are expected to be collected within one year.

NFP A has a goal to maintain financial assets, which consist of cash and short-term investments, on hand to meet 60 days of normal operating expenses, which are, on average, approximately $275,000. NFP A has a policy to structure its financial assets to be available as its general expenditures, liabilities, and other obligations come due. In addition, as part of its liquidity management, NFP A invests cash in excess of daily requirements in various short-term investments, including certificate of deposits and short-term treasury instruments. As more fully described in Note XX, NFP A also has committed lines of credit in the amount of $20,000, which it could draw upon in the event of an unanticipated liquidity need.

Alternatively, the nonprofit could present tables (see 958-210-55-8) to communicate the resources available to meet cash needs for general expenditures within one year of the balance sheet date.

Cash Flow Statement Presentation

A nonprofit can use the direct or indirect method to present its cash flow information. The reconciliation of changes in net assets to cash provided by (used in) operating activities is not required if the direct method is used.

Consider whether you want to incorporate additional changes that will be required by ASU 2016-18, Statement of Cash Flows–Restricted Cash. If your nonprofit has no restricted cash, then this standard is not applicable.

You can early implement ASU 2016-18. (The effective date is for fiscal years beginning after December 15, 2018.) Once this standard is effective, you’ll include restricted cash in your definition of cash. The last line of the cash flow statement might read as follows: Cash, Cash Equivalents, and Restricted Cash.

Effective Date of ASU 2016-14

The effective date for 2016-14, Not-for-Profit Entities, is for fiscal periods beginning after December 15, 2017 (2018 calendar year-ends and 2019 fiscal year-ends). The standard can be early adopted.

For comparative statements, apply the standard retrospectively. 

If presenting comparative financial statements, the standard does allow the nonprofit to omit the following information for any periods presented before the period of adoption:

  • Analysis of expenses by both natural classification and functional classification (the separate presentation of expenses by functional classification and expenses by natural classification is still required). Nonprofits that previously were required to present a statement of functional expenses do not have the option to omit this analysis; however, they may present the comparative period information in any of the formats permitted in ASU 2014-16, consistent with the presentation in the period of adoption.
  • Disclosures related to liquidity and availability of resources.
restricted cash
Dec 05

Restricted Cash: The Skinny on ASU 2016-18

By Charles Hall | Auditing

FASB issued ASU 2016-18, Statement of Cash Flows, in November 2016. This standard changes the way restricted cash is shown in cash flow statements.

The standard is effective in 2019 for calendar year-end private companies. Early adoption is permitted

Here’s the skinny on the new standard. (To download the slidedeck, click here. The video below was created before I changed the name of my blog from CPA Scribo to CPA Hall Talk, but the information is current.)

 

changes in VIE accounting
Nov 30

ASU 2018-17: A VIEry Good Gift from FASB

By Charles Hall | Accounting

It's time for another change to VIE accounting! 

The variable interest entity (VIE) considerations just got much easier. FASB is—with ASU 2018-17—providing another get-out-of-jail-free card to private companies.

VIE accounting

When FASB originally issued its VIE accounting guidance many years ago, it created a thorny issue for private companies—one almost incomprehensible to anyone but a seasoned CPA. FASB required companies to consider whether entities under common control should be consolidated, even if the reporting entity did not own a majority of the voting stock. While FASB’s intent was noble (it was addressing issues that arose from Enron’s use of special purpose entities), it created one of the most difficult accounting standards ever. In the ensuing years, private companies begged for relief. The first leg of that relief came with the issuance of ASU 2014-07 (more in a moment); the second leg of that relief comes now with ASU 2018-17. 

The original VIE accounting guidance issued in the early 2000s required reporting entities to consolidate related companies if certain conditions were met. For example, if a reporting entity rented real estate from a commonly owned company, then consolidation might be required. This original guidance applied to both public and private companies. Public companies tend to have the muscle and knowledge to make these complicated evaluations. Not so for private companies. That’s why private companies asked for relief. 

First, FASB had issued ASU 2014-07, Consolidation (Topic 810): Applying Variable Interest Entities Guidance to Common Control Leasing Arrangements. That standard allowed reporting entities, when specified conditions were met, to not consolidate lessee companies. A private company could elect to not apply variable interest entity guidance to a lessor entity if those specified conditions were met. 

Then, on October 31, 2018, FASB issued Accounting Standards Update (ASU) 2018-17, Consolidation (Topic 810): Targeted Improvements to Related Party Guidance for Variable Interest Entities. ASU 2018-17 expands the provisions in ASU 2014-07, permitting the accounting alternative to include all private company common control arrangements (see criteria below). 

VIE Accounting Alternative

Using 2018-17, a legal entity need not be evaluated by a private company (reporting entity) under the VIE accounting model if all of the following are true: 

  1. The reporting entity and the legal entity are under common control. 
  1. The reporting entity and the legal entity are not under common control of a public business entity. 
  1. The legal entity under common control is not a public business entity. 
  1. The reporting entity does not directly or indirectly have a controlling financial interest in the legal entity when considering the voting interest model (see ASC 810-10-05; under the voting interest model, the usual condition for a controlling financial interest is ownership by one reporting entity, directly or indirectly, of more than 50 percent of the outstanding voting shares of another entity). 

The Alternative is an Election

Applying this accounting alternative is an accounting policy election. If the election is made, then the private company must apply the criteria above to all legal entities. If, for example, a reporting entity has consolidated companies A and B due to VIE considerations, the election must be applied to both entities. 

Combined Financial Statements (Still an Option)

If a private company reporting entity makes the alternative election, it can still create combined financial statements for entities under common control. For example, if a reporting entity consolidates companies A and B under the prior VIE guidance, it might no longer do so after the election. Nevertheless, the reporting entity could issue combined financial statements. The reporting entity might, for example, issue combined financial statements for the reporting entity and company B (and exclude company A). See ASC 810-10-55-1B. 

Entities that Can’t Use the Alternative

The entities that can’t use the VIE alternative (under ASU 2018-17) include: 

  1. Public business entities 
  2. Not-for-profit entities 
  3. Employee benefit plans (within the scope of ASC 960, 962, and 965) 

Required Disclosures

A private company that makes the election to use the alternative is required to include information about the relationship of the entities. Those disclosures include (see 810-10-50-2AG, 810-10-50-2AH and 810-10-50-2AI for complete list of disclosures): 

  1. The nature and risks as a result of the reporting entity’s involvement with the legal entity under common control 
  2. How a reporting entity’s involvement with the legal entity under common control affects: 
    • Financial position 
    • Financial performance 
    • Cash flows 
  3. The carrying amounts and classification of the assets and liabilities in the reporting entity’s statement of financial position as a result of its involvement with the legal entity under common control 
  4. The reporting entity’s maximum exposure to loss based on its relationship with the legal entity under common control (if not quantifiable, then that fact should be disclosed) 
  5. If the maximum exposure to loss exceeds the carrying amount of the assets and liabilities, that information is to be disclosed (including the terms of the arrangements) 

Effective Dates 

For entities other than private companies, the amendments in ASU 2018-17 are effective for fiscal years beginning after December 15, 2019, and interim periods within those fiscal years. The amendments in this Update are effective for a private company for fiscal years beginning after December 15, 2020, and interim periods within fiscal years beginning after December 15, 2021. All entities are required to apply the amendments in this Update retrospectively with a cumulative-effect adjustment to retained earnings at the beginning of the earliest period presented.  

Early adoption is permitted. 

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