Category Archives for "Auditing"

Preliminary analytical procedures
Mar 11

Preliminary Analytical Procedures

By Charles Hall | Auditing

Preliminary analytical procedures are used to identify material misstatements in financial statements. In this article, I explain how to create planning analytics and how to use them to identify potential misstatements. I also provide documentation tips. 

Preliminary analytical procedures

Preliminary Analytical Procedures

The auditing standards provide four risk assessment procedures: 

  1. Inquiry
  2. Observation
  3. Inspection
  4. Analytical procedures

I previously provided you with information about the first three risk assessment procedures. Today, I provide you with the fourth, analytical procedures.

While analytical procedures should occur at the beginning and the end of an audit, this post focuses on preliminary analytical procedures (sometimes called a preliminary analytical review).

Below I provide the quickest and best way to develop audit planning analytics

What are Analytics?

If you're not an auditor, you may be wondering, "what are analytics?" Think of analytics as the use of numbers to determine reasonableness. For example, if a company's cash balance at December 31, 2020, was $100 million, is it reasonable for the account to be $5 million at December 31, 2021? Comparisons such as this one assist auditors in their search for errors and fraud.

Preliminary Analytical Procedures Overview

We'll cover the following:

  • The purpose of preliminary analytical procedures 
  • When to create planning analytics (at what stage of the audit)
  • Developing expectations 
  • The best types of planning analytics
  • How to document preliminary analytical procedures
  • Developing conclusions 
  • Linkage to the audit plan

(The following video comes from my Audit Risk Assessment Made Easy YouTube playlist. These videos correspond to my book of the same name. See it on Amazon.)

Purpose of Preliminary Analytical Procedures

Analytical procedures used in planning an audit should focus on identifying risks of material misstatement. Your goal as an auditor is to render an opinion regarding the fairness of the financial statements. So, like a good sleuth, you are surveying the accounting landscape to see if material misstatements exist.

A detective investigates a crime scene using various tools: fingerprints, forensic tests, interviews, timelines. Auditors have their own tools: inquiry, observation, inspection, analytical procedures. Sherlock Holmes looks for the culprit. The auditor (and I know this isn't as sexy) looks for material misstatements. 

The detective and the auditor are both looking for the same thing: evidence. And the deft use of tools can lead to success. A key instrument (procedure) available to auditors is preliminary analytical procedures.

When to Create Planning Analytics

Create your preliminary analytics after gaining an understanding of the entity. Why? Context determines reasonableness of numbers. And without context (your understanding of the entity), changes in numbers from one year to the next may not look like a red flag--though maybe they should.

Therefore, learn about the entity first. Are there competitive pressures?  What are the company's objectives? Are there cash flow issues? What is the normal profit margin percentage? Does the organization have debt? Context creates meaning.

Additionally, create your comparisons of numbers prior to creating your risk assessments. After all, the purpose of the analytical comparisons is to identify risk.

But before creating your planning analytics, you first need to know what to expect.

Developing Expectations 

Knowing what to expect provides a basis for understanding the changes in numbers from year to year. 

Expectations can include:

  • Increases in numbers
  • Decrease in numbers
  • Stable numbers (no significant change)

In other words, you can have reasons to believe payroll (for example) will increase or decrease. Or you might anticipate that salaries will remain similar to last year.

Examples of Expectations Not Met

Do you expect sales to decrease 5% based on decreases in the last two years? If yes, then an increase of 15% is a flashing light.

Or maybe you expect sales to remain about the same as last year? Then a 19% increase might be an indication of financial statement fraud.

But where does an auditor obtain expectations?

Sources of Expectations

Expectations of changes can come from (for example):

  • Past changes in numbers 
  • Discussions with management about current year operations
  • Reading the company minutes
  • Staffing reductions
  • Non-financial statistics (e.g., decrease the number of widgets sold)
  • A major construction project

While you'll seldom know about all potential changes (and that's not the goal), information--such as that above--will help you intuit whether change (or a lack of change) in an account balance is a risk indicator.

Now, let's discuss the best types of planning analytics. 

The Best Types of Planning Analytics

Auditing standards don't specify what types of planning analytics to use. But some, in my opinion, are better than others. Here's my suggested approach (for most engagements). 

Audit Planning Analytics

Comparative Numbers

First, create your planning analytics at the financial statement reporting level. Why? Well, that's what the financial statement reader sees. So, why not use this level (if you can)? (There is one exception in regard to revenues. See Analytics for Fraudulent Revenue Recognition below.)

The purpose of planning analytics is to ferret out unexpected change. Using more granular information (e.g., trial balance) muddies the water. Why? There's too much information. You might have three hundred accounts in the trial balance and only fifty at the financial statement level. Chasing down trial-balance-level changes can be a waste of time. At least, that's the way I look at it.

Comparative Ratios

Second, add any key industry ratios tracked by management and those charged with governance. Often, you include these numbers in your exit conference with the board (maybe in a slide presentation). If those ratios are important at the end of an audit, then they're probably important in the beginning.

Examples of key industry ratios include:

  • Inventory turnover
  • Return on equity
  • Days cash on hand
  • Gross profit 
  • Debt/Equity 

Other Metrics

Other metrics such as earnings before interest, taxes, depreciation, and amortization (EBITDA) are consequential for some companies. If relevant, include those.

Hence, create planning analytics that align with the company’s focal points. And how do you know what those are? Read the company’s minutes before you create your preliminary analytics. Most of the time you’ll see the tracked numbers there. 

One last thought about analytical types. When relevant, use nonfinancial information, such as the number of products sold. If a company sells just three or four products and you have the sales statistics, why not compute the estimated revenue and compare it to the recorded revenue? It makes sense to do so. After all, the auditing standards say that preliminary analytics may include both financial and nonfinancial information. 

Okay, so we know what analytics to create, but how should we document them?

Analytics for Fraudulent Revenue Recognition

AU-C 240 says the auditor should include preliminary analytics relating to revenue accounts.

AU-C 240 suggests a more detailed form of analytics for revenues such as:

  • a comparison of sales volume with production capacity
  • a trend analysis of revenues by month and sales returns by month 
  • a trend analysis of sales by month compared with units shipped to customers

In light of these suggested procedures, it may be prudent to create revenue analytics at a more granular level than that shown in the financial statements.

How to Document Preliminary Planning Analytics

Here are my suggestions for documenting preliminary planning analytics.

  1. Document overall expectations.
  2. Include comparisons of prior-year/current-year numbers at the financial statement level. (You might also include multiple prior year comparisons if you have that information.)
  3. Document key industry ratio comparisons.
  4. Summarize your conclusions. Are there indicators of increased risks of material misstatement? Is yes, say so. If no, say so.

Once you create your conclusions, place any identified risks on your summary risk assessment work paper (where you assess risk at the transaction level--e.g., inventory).

Use Filtered Analytical Reports with Caution (if at all)

Some auditors use filtered trial balance reports for their analytics. For instance, all accounts with changes of greater than $30,000. There is a danger in using such thresholds. 

What if  you expect a change in sales of 20% (approximately $200,000) but your filters include:

  •  all accounts with changes greater than $50,000, and 
  • all accounts with changes of more than 15%

If sales remain constant, then this risk of material misstatement (you expected change of 20%, but it did not happen) fails to appear in the filtered report. The filters remove the sales account because the change was minimal. Now, the risk may go undetected.

Developing Conclusions

I am a believer in documenting conclusions on key work papers. So, how do I develop those conclusions? And what does a conclusion look like on a planning analytics work paper?

First, develop your conclusions. How? Scan the comparisons of prior year/current year numbers and ratios. We use our expectations to make judgments concerning the appropriateness of changes and of numbers that remain stable. Remember this is a judgment, so, there's no formula for this.

No Risk Identified

Now, you'll document your conclusions. But what if there are no unexpected changes? You expected the numbers to move in the manner they did. Then no identified risk is present. Your conclusion will read, (for example):

Conclusion: I reviewed the changes in the accounts and noted no unexpected changes. Based on the planning analytics, no risks of material misstatement were noted.

Risk Identified

Alternatively, you might see unexpected changes. You thought certain numbers would remain constant, but they moved significantly. Or you expected material changes to occur, but they did not. Again, document your conclusion. For example:

Conclusion: I expected payroll to remain constant since the company's workforce stayed at approximately 425 people. Payroll expenses increased, however, by 15% (almost $3.8 million). I am placing this risk of material misstatement on the summary risk assessment work paper at 0360 and will create audit steps to address the risk.

Now, it's time to place the identified risks (if there are any) on your summary risk assessment form.

Linkage to the Audit Plan

I summarize all risks of material misstatements on my summary risk assessment form. These risks might come from walkthroughs, planning analytics or other risk assessment procedures. Regardless, I want all of the identified risks--those discovered in the risk assessment process--in one place.

The final step in the audit risk assessment process is to link your identified risks to your audit program

Overview of Risk Assessment and Linkage

Now, I tailor my audit program to address the risks. Tailoring the audit program to respond to identified risks is known as linkage.

Audit standards call for the following risk assessment process:

  • Risk assessment procedures (e.g., planning analytics)
  • Identification of the risks of material misstatement
  • Creation of audit steps to respond to the identified risks (linkage)

Summary of Preliminary Analytical Procedure Considerations

So, now you know how to use planning analytics to search for risks of material misstatement--and how this powerful tool impacts your audit plan.

Let's summarize what we've covered:

  1. Planning analytics are created for the purpose of identifying risks of material misstatement
  2. Develop your expectations before creating your planning analytics (learn about the entity's operations and objectives; review past changes in numbers for context--assuming you've performed the audit in prior years)
  3. Create analytics at the financial statement level, if possible
  4. Use key industry ratios 
  5. Conclude about whether risks of material misstatement are present
  6. Link your identified risks of material misstatement to your audit program

So there you are. I hope you've found this article useful. For more information about risk assessment, check out my book Audit Risk Assessment Made Easy, available on Amazon. 

First-Year Businesses and Planning Analytics

You may be wondering, "but what if I my client is new?" New entities don't have prior numbers. So, how can you create planning analytics? 

First Option

One option is to compute expected numbers using non-financial information. Then compare the calculated numbers to the general ledger to search for unexpected variances.

Second Option

A second option is to calculate ratios common to the entity’s industry and compare the results to industry benchmarks.

While industry analytics can be computed, I’m not sure how useful they are for a new company. An infant company often does not generate numbers comparable to more mature entities. But we’ll keep this choice in our quiver--just in case.

Third Option

A more useful option is the third: comparing intraperiod numbers. 

Discuss the expected monthly or quarterly revenue trends with the client before you examine the accounting records. The warehouse foreman might say, “We shipped almost nothing the first six months. Then things caught fire. My head was spinning the last half of the year.” Does the general ledger reflect this story? Did revenues and costs of goods sold significantly increase in the latter half of the year?

Fourth Option

The last option we’ve listed is a review of the budgetary comparisons. Some entities, such as governments, lend themselves to this alternative. Others, not so–those that don’t adopt budgets.

Summary

So, yes, it is possible to create useful risk assessment analytics–even for a first-year company.

SSAE 19
Feb 26

SSAE 19: Agreed-Upon Procedures Engagements

By Charles Hall | Auditing

On December 19, 2019, the AICPA released SSAE 19, Agreed-Upon Procedures Engagements. AUPs provide you with the ability to provide assurance in a targeted manner (e.g.,  just for inventory). Though you’ve been able to perform AUPs for many years, the new guidance in SSAE 19 provides you with greater flexibility. See how below. 

Greater AUP Flexibility

CPAs will find the new agreed-upon procedures (AUP) standard (SSAE 19) more flexible that the preceding guidance (SSAE 18 AT-C section 215).

How is it more flexible?

  • You no longer request an assertion from the responsible party
  • You can issue general-use reports 
  • Intended users are not required to take responsibility for the sufficiency of the procedures
  • You can develop or assist in developing the procedures over the course of the engagement

And which of these do I like the best? No requirement for assertions.

Additionally, I like the option to develop AUP procedures as the engagement progresses. In the past, the client might review the draft AUP report (at the end of the engagement) and realize it doesn't meet their needs. Sometimes it's better for practitioners to develop procedures as they perform the AUP. SSAE 19 allows you to do just that.

So, if you develop new procedures, what must you do? Prior to issuance of the AUP report, obtain the engaging party's agreement regarding the procedures. Moreover, obtain their acknowledgement that the procedures are appropriate and that they satisfy the intended purpose of the engagement. In effect, the client reviews the procedures, agrees with them, and expresses satisfaction.

Definition of an Agreed-Upon Procedures Engagement

SSAE 19 defines an agreed-upon procedures engagement as "an attestation engagement in which a practitioner performs specific procedures on subject matter and reports the findings without providing an opinion or conclusion. The subject matter may be financial or nonfinancial information." The standard goes on to say "Because the needs of engaging party may vary widely, the nature, timing, and extend of the procedures may vary, as well."

SSAE 19

Now, let's see what the AUP objectives are.

SSAE 19 Objectives

The objectives of an SSAE 19 engagement include:

  • Applying specific procedures to subject matter
  • Issuing a written practitioner's report that describes the procedures applied and the findings

Next, let's look at the structure of an AUP report.

AUP Report Structure

The structure of the AUP report should be as follows:

  • Procedures
  • Findings

So, the CPA should state what was done and then provide the findings (results). The procedures and findings are placed in the body of the AUP report. 

The description of the procedures should be simple and clear.

Good AUP Procedure and Finding

Here's an example of a good AUP procedure and finding:

Procedure - We obtained the January 2022 check register and the January operating bank account statement. We compared check numbers 2850, 2892, 2933, 2935, 2972 to cleared checks agreeing the payee and the amount. 

Findings - No exceptions were noted.

Now, let's look at a poor example:

Poor AUP Procedure and Finding

Procedure - We scanned the company's 2022 bank statements and talked with the CFO. The books seemed to be in order with the exception of July errors.

Finding - Overall, the check disbursements appear to be okay after our general review.

In this poor example, we see general words or statements. What does the word scanned mean? How about seemed to be in order ? Additionally, the finding is vague: okay after our general review.

SSAE 19 provides examples of acceptable and unacceptable wording.

Acceptable and Unacceptable AUP Wording

SSAE 19 calls the practitioner to clearly define procedures. Moreover, the standard states that practitioners should not perform procedures that are open to varying interpretations or that are vague. 

Unacceptable Terms

.A27 of the standard even provides examples of unacceptable AUP terms such as:

  • General review
  • Evaluate
  • Examine

Acceptable Terms

.A27 also provides examples of acceptable AUP terms such as:

  • Inspect
  • Compare
  • Agree
  • Recalculate

In addition to proper wording, document your engagement in accordance with SSAE 19.

AUP Documentation

SSAE 19 calls for the following documentation:

  • Written agreement with the engaging party regarding the appropriateness of the procedures performed for the intended purpose of the engagement
  • The nature, timing, and extent or procedures performed
  • The results of the procedures

You'll also need a written engagement letter (see paragraph .15 of SSAE 19 for an example) and a representation letter (see paragraph .27 of SSAE 19 for an example).

So what about dating the representation letter? The representation letter date should be the date of the AUP report. Additionally, the representation letter should address the subject matter and periods covered by the practitioner's findings.

By now you may be thinking, "Where can I find AUP report examples?"

SSAE 19 Illustrative AUP Report

SSAE 19 provides four illustrative AUP reports in its exhibit (see .A78). 

The four example AUP reports relate to:

  1. Statement of investment performance statistics
  2. Cash and accounts receivable
  3. Claims of creditors
  4. Procedures specified in regulation

If you're looking for a template to follow, see example 2. Why? The cash and accounts receivable procedures and findings are excellent. Build procedures and findings like these and you'll be in good shape.

I suggest you download SSAE 19 and keep these reports handy.

So, what about independence? Is that required?

Attestation Independence

The practitioner has to be independent in order to perform an AUP.  

One exception exists when the practitioner "is required by law or regulation to accept an agreed-upon procedures engagement and report on the procedures performed and findings obtained."

SSAE 19 Effective Date

The effective date of SSAE 19 is for AUP reports dated on or after July 15, 2021.

Early implementation is permitted.

If third party assurance is not needed, consider issuing a consulting report in lieu of an AUP report. See my article: AICPA Consulting Standards - The Swiss Army Knife.

significant risk
Feb 08

Significant Risks in Audits of Financial Statements

By Charles Hall | Auditing

Peer reviews find that many CPA firms don't identify significant risks in audits, and that's a problem. Why? Because they are the seedbed of many material misstatements. And when material misstatements are not identified, audit failure often occurs.

Below, I will tell you how to identify, assess, and respond to significant risks.

I also explain the new requirement to communicate significant risks to those charged with governance.  

significant risk

Defining Significant Risk

The Auditing Standards Board previously defined significant risks as those deserving special audit consideration. They've amended this definition in SAS 145 to focus on the inherent risk characteristics rather than the response

For example, a highly complex receivable allowance is inherently risky because it's subjective and complicated. Yes, we will give it special audit consideration. But it's a significant risk because of its nature (subjective and complex), not because of our response (re-computing the estimate and comparing it with prior periods, for example). 

How Many Significant Risks?

At least one significant risk exists in most audits, and frequently there are more. The number depends on the entity, its environment, the types of services it provides or goods it sells, the complexity of its accounts, the subjectivity of determining balances, the susceptibility of accounts to bias or fraud, and the level of change.

Defined in SAS 145

SAS 145, Understanding the Entity and Its Environment and Assessing the Risk of Material Misstatement, defines significant risk in terms of likelihood and magnitude. The threat must be likely, and the result must be material. (See my SAS 145 article.)

The audit standard defines the risk as one close to the upper end of the spectrum of inherent risk without regard for controls. In other words, we consider the inherent risk factors, and we disregard internal controls as we identify these risks.

Align Inherent Risk with Significant Risk

Notice that significant risks are based solely upon inherent risk. So don’t make the mistake of identifying such a risk and then assessing inherent risk below high. After all, the definition says close to the upper end of the spectrum of inherent risk.

Suppose, for example, you identify a significant risk for the allowance for uncollectible receivables, an estimate, due the concerns about the valuation assertion (because it's complex and subjective; see inherent risk factors below). Then the inherent risk for the valuation assertion must be high (or max). 

It's useful to think of inherent risk on a scale of 1 to 10, with 10 being high risk. If you believe the inherent risk is a 9 or a 10 (close to the upper end of the spectrum of inherent risk), then a significant risk is present. Though auditors commonly use low, moderate, high to measure inherent risk, the audit standards don't specify how this is to be done. I'm not saying don't use low, moderate, high, only that thinking of inherent risks on scale of 1 to 10 helps me evaluate risk and to determine whether a significant risk is present.

Inherent Risk Factors

And what are the inherent risk factors? 

  • Complexity
  • Subjectivity
  • Change
  • Uncertainty
  • Susceptibility to misstatement due to management bias or other fraud risk factors (in terms of how they affect inherent risk)

Two Questions to Consider

So the auditor reviews an assertion and asks, "In light of these risk factors, what is the probability of misstatement without regard for controls?" The auditor also asks, "Would a material misstatement occur?" So we consider two things:

  • Is it highly likely that a misstatement will occur for the assertion (without regard for controls)?
  • Will the misstatement be material?

If both answers are yes, it's a significant risk.

Responses to Significant Risks

Peer reviews find that auditors sometimes identify these risks but plan inadequate responses. If the risk is significant, then a strong response is necessary. 

For example, if inventory obsolescence is an issue, the auditor should plan procedures to identify the impaired items and test for appropriate valuation. You may need a specialist in such a situation. So, what would be an inadequate response?  Performing basic inventory procedures. Additional procedures, sometimes referred to as extended steps, are necessary to address the inventory valuation assertion.

As you plan the additional audit procedures, link them from the identified risk (usually on your summary risk assessment form) to your responses (usually on your audit program). In the inventory example, you would link the risk for the valuation assertion to the inventory audit steps (the extended steps to identify and value the impaired items).


You must also communicate these risks to those charged with governance. 

Communicating Significant Risks

Communicate the significant risks to those charged with governance as you implement SAS 134, Auditor Reporting and Amendments, Including Amendments Addressing Disclosures in the Audit of Financial Statements (required for December 31, 2021 year-end engagements and after).

(See my SAS 134 article to understand the types of audit opinions.)  

Present guidance states that significant risks are those that deserve special audit consideration, so you'll use that definition until SAS 145 is implemented. (Even so SAS 145 will help you understand these risks now.)

significant risk

How to Communicate 

You can communicate significant risks in one of three ways:

  1. Engagement letter
  2. Planning letter to those charged with governance
  3. Verbally to the board with documentation of that communication in the audit file--this could be a separate Word document that says who you talked with, when, and the significant risk areas communicated. 

The Communication Change

SAS 134 amended AU-C 260.11 (AU-C 260 The Auditor's Communication with Those Charged with Governance) as follows (amended language is underlined):

The auditor should communicate with those charged with governance an overview of the planned scope and timing of the audit, which includes communicating about the significant risks identified by the auditor.

Sample Significant Risk Language 

Here's an example of the language to be used in any of the three options above:

The anticipated significant risk areas in the audit are:

  1. receivables/revenues,
  2. the allowance for uncollectibles 
  3. the pension liability and disclosure. 

Aligning the Communication with Workpapers

The significant risk areas communicated to the board during planning should align with those identified in your workpapers. You could, however, not know all of the risk areas when you create your initial communication. It's even possible you might not identify a these risks until you are well into the engagement. So the initial significant risk communication and the identified risks in the audit file could be different. You can communicate any additional risks in your final communication to those charged with governance. 

Why are we making this communication the board? Well the board governs the entity, so they need to be aware of areas with a higher risk of potential misstatements. 

Optional Communication 

The explanatory information that accompanies AU-C 260 (specifically .A21) states you may include in the governance communication how you (as the auditor) are going to address the significant risks, but this is optional.  

Audit Risk Assessment Book on Amazon

See my book on Amazon: Audit Risk Assessment Made Easy, Seeing What Others Miss.

 

Auditing accounts payable
Feb 02

Auditing Accounts Payable and Expenses

By Charles Hall | Auditing

Accounts payable is usually one of the more important audit areas. Why? Risk. First, it’s easy to increase net income by not recording period-end payables. Second, many forms of theft occur in the accounts payable area.

Auditing accounts payable

In this post, I’ll answer questions such as, “how should we test accounts payable?” And “should I perform fraud-related expense procedures?” We’ll also take a look at common payables-related risks and how to respond to them. In short, you will learn what you need to know about auditing accounts payable.

Auditing Accounts Payable and Expenses — An Overview

What is a payable? It’s the amount a company owes for services rendered or goods received. Suppose the company you are auditing receives $2,000 in legal services in the last week of December 2019, but the law firm sends the related invoice in January 2020. The company owes $2,000 as of December 31, 2019. The services were provided, but the payment was not made until after the year-end. Consequently, the company should accrue (record) the $2,000 as payable at year-end.

In determining whether payables exist, I like to ask, “if the company closed down at midnight on the last day of the year, would it have a legal obligation to pay for a service or good?” If the answer is yes, then record the payable even if the invoice is received after the year-end. Was a service provided or have goods been received by year-end? If yes (and the amount has not already been paid), accrue a payable.

In this chapter, we will cover the following things an accounts payable auditor need to consider:

  • Primary accounts payable and expense assertions
  • Accounts payable and expense walkthroughs
  • Directional risk for accounts payable and expenses
  • Primary risks for accounts payable and expenses
  • Common accounts payable and expense control deficiencies
  • Risks of material misstatement for accounts payable and expenses
  • Search for unrecorded liabilities
  • Auditing for accounts payable and expense fraud
  • Substantive procedures for accounts payable and expenses
  • Typical accounts payable and expense work papers

So, let’s begin our journey of auditing accounts payable and expenses.

Primary Accounts Payable and Expense Assertions

The primary relevant accounts payable and expense assertions are:

  • Existence
  • Completeness
  • Cutoff
  • Occurrence

Of these assertions, I believe completeness and cutoff (for payables) and occurrence (for expenses) are usually most important. When a company records its payables and expenses by period-end, it is asserting that they are complete and that they are accounted for in the right period. Additionally, the company is implying that amounts paid are legitimate.

Accounts Payable and Expense Walkthroughs

As we perform walkthroughs of accounts payable and expenses, we are looking for understatements (though they can also be overstated as well). We are asking, “what can go wrong?” whether intentionally or by mistake.

Accounts payable walkthrough

In performing accounts payable and expense walkthroughs, ask questions such as:

  • Who reconciles the accounts payable summary to the general ledger?
  • Does the company use an annual expense budget?
  • Are budget/expense reports provided to management or others? Who receives these reports?
  • What controls ensure the recording of payables in the appropriate period?
  • Who authorizes purchase orders? Are any purchases authorized by means other than a purchase order? If yes, how?
  • Are purchase orders electronic or physical?
  • Are purchase orders numbered?
  • How does the company vet new vendors?
  • Who codes invoices (specifies the expense account) and how?
  • Are three-way matches performed (comparison of purchase order with the receiving document and the invoice)?
  • Are paid invoices marked “paid”?
  • Does the company have a purchasing policy?
  • Can credit cards be used to bypass standard purchasing procedures? Who has credit cards and what are the limits? Who reviews credit card activity?
  • Are bids required for certain types of purchases or dollar amounts? Who administers the bidding process and how?
  • Do larger payments require multiple approvals?
  • Which employees key invoices into the accounts payable module?
  • Who signs checks or makes electronic payments?
  • Who is on the bank signature card?
  • Are signature stamps used? If yes, who has control of the signature stamps and whose signature is affixed?
  • How are electronic payments made (e.g., ACH)?
  • Is there adequate segregation of duties for persons:
    • Approving purchases,
    • Paying payables,
    • Recording payables, and
    • Reconciling the related bank statements
  • Which persons have access to check stock and where is the check stock stored?
  • Who can add vendors to the payables system?
  • What are the entity’s procedures for payments of travel and entertainment expenses?
  • Who reconciles the bank statements and how often?

As we ask these questions, we inspect documents (e.g., payables ledger) and make observations (e.g., who signs checks or makes electronic payments?). So, we are inquiring, inspecting, and observing.

If controls weaknesses exist, we create audit procedures to respond to them. For example, if–during the walkthrough–we see that one person prints and signs checks, records payments, and reconciles the bank statement, then we will perform fraud-related substantive procedures (more about this in a moment).

Here’s a short video about risk assessment for accounts payable auditors.

Directional Risk for Accounts Payable and Expenses

The directional risk for accounts payable and expenses is an understatement. So, perform procedures to ensure that invoices are properly included. For example, perform a search for unrecorded liabilities (see below).

Primary Risks for Accounts Payable and Expenses

The primary risks for accounts payable and expenses are:

  1. Accounts payable and expenses are intentionally understated
  2. Payments are made to inappropriate vendors
  3. Duplicate payments are made to vendors

Keep these in mind as you audit accounts payable.

Common Payable and Expense Control Deficiencies

payables control deficiencies

In smaller entities, it is common to have the following control deficiencies:

  • One person performs two or more of the following:
    • Approves purchases,
    • Enters invoices in the accounts payable system,
    • Issues checks or makes electronic payments,
    • Reconciles the accounts payable bank account,
    • Adds new vendors to the accounts payable system
  • A second person does not review payments before issuance
  • No one performs surprise audits of accounts payable and expenses
  • Bidding procedures are weak or absent
  • No one reconciles the accounts payable detail to the general ledger
  • New vendors are not vetted for appropriateness
  • The company does not create a budget
  • No one compares expenses to the budget
  • Electronic payments can be made by one person (with no second-person approval or involvement)
  • The bank account is not reconciled on a timely basis
  • When bank accounts are reconciled, no one examines the canceled checks for appropriate payees (the dollar amount on the bank statement is agreed to the general ledger but no one compares the payee name on the cleared check to the vendor name in the general ledger)

When segregation of duties is lacking, consider whether someone can use the expense cycle to steal funds. How? By making payments to fictitious vendors, for example. Or intentionally paying a vendor twice–and then stealing the second check. (See the section titled Auditing for Fraud below.)

Risks of Material Misstatement for Payables and Expenses

In smaller engagements, I usually assess control risk at high for each assertion. When I assess control risk at less than high, I have to test controls to support the lower risk assessment. Therefore, assessing risks at high is usually more efficient (than testing controls).

When control risk is assessed at high, inherent risk becomes the driver of the risk of material misstatement (control risk X inherent risk = risk of material misstatement). The assertions that concern me the most are completeness, occurrence, and cutoff. So my RMM for these assertions is usually moderate to high.

My response to higher risk assessments is to perform certain substantive procedures: namely, a search for unrecorded liabilities and detailed expense analyses. The particular expense accounts that I examine are often the result of my preliminary planning analytics.

Search for Unrecorded Liabilities

How does one perform a search for unrecorded liabilities? Use these steps:

  1. Obtain a complete check register for the period subsequent to your audit period
  2. Pick a dollar threshold ($10,000) for the examination of subsequent payments
  3. Examine the subsequent payments (above the threshold) and related invoices to determine if the payables are suitably included or excluded from the period-end accounts payable detail
  4. Inquire about any unrecorded invoices

As the RMM for completeness increases, vouch payments at a lower dollar threshold.

How should you perform a detailed analysis of expense accounts? First, compare your expenses to budget—if the entity has one—or to prior year balances. If you note any significant variances (that can’t be explained), then obtain a detail of those particular expense accounts and investigate the cause.

Theft can occur in numerous ways—such as fictitious vendors or duplicate payments. If control weaknesses are present, consider performing fraud-related procedures. When fraud-related control weaknesses exist, assess the RMM for the occurrence assertion at high. Why? There is a risk that the expense (the occurrence) is fraudulent.

So, how should you respond to such risks?

Auditing for Fraud

An example of a fraud-related test is one for duplicate payments. How?

  • Obtain a check register in Excel
  • Sort by the vendor
  • Scan the check register for payments made to the same vendor for the same amount
  • Inquire about payments made to the same vendor for the same amount

In a duplicate payment fraud, the thief intentionally pays an invoice twice. He steals the second check and converts it to cash.

This is just one example of expense fraud. There are dozens of such schemes.

Substantive Procedures for Accounts Payable and Expenses

My customary audit tests are as follows:

  1. Vouch subsequent payments to invoices using the steps listed above (in Search for Unrecorded Liabilities)
  2. Compare expenses to budget and examine any unexplained variances
  3. When control weaknesses are present, design and perform fraud detection procedures

If there are going concern issues, you may need to examine the aged payables listing. Why? Management can fraudulently shorten invoice due dates. Doing so makes the company appear more current. For example, suppose the business has three unpaid invoices totaling $1.3 million that were due over ninety days ago. The company changes the due dates in the accounts payable system, causing the invoices to appear as though they were due just thirty days ago. Now the aged payables listing looks better than it would have.

Accounts payable work papers

Typical Payable and Expense Work Papers

My accounts payable and expense work papers usually include the following:

  • An understanding of internal controls as they relate to accounts payable and expenses
  • Risk assessment of accounts payable and expenses at the assertion level
  • Documentation of any accounts payable and expense control deficiencies
  • Accounts payable and expense audit program
  • An aged accounts payable detail at period-end
  • A search for unrecorded liabilities work paper
  • Budget to actual expense reports and, if unexpected variances are noted, a detailed analysis of those accounts
  • Fraud-related expense work papers (if significant control weaknesses are present)

So, now you learned about auditing accounts payable. My next post addresses auditing payroll.

In some entities such as governments, payroll makes up over 50% of total expenses. Consequently, knowing how to audit payroll expenses is of great importance. My next post is titled The Why and How of Auditing Payroll. So, stay tuned.

See my prior posts in The Why and How of Auditing.

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control risk
Jan 14

Control Risk: Financial Statement Audits

By Charles Hall | Auditing , Risk Assessment

Control risk continues to create confusion in audits. Some auditors assess control risk at less than high when they shouldn’t. Others assess control risk at high when it would be better if they did not. The misunderstandings about this risk can result in faulty audits and problems in peer review. In this article, I explain what control risk is and how you can best leverage it to perform quality audits in less time.

control risk

Control Risk Defined

What is control risk? It’s the chance that an entity’s internal controls will not prevent or detect material misstatements in a timely manner. 

Companies develop internal controls to manage inherent risk. The greater the inherent risk, the greater the need for controls.

Audit Risk Model

As we begin this article, think about control risk in the context of the audit risk model:

Audit risk = Inherent risk X Control risk X Detection risk

Recall the client’s risk is made up of inherent risk and control risk. And the remainder, detection risk, is what the auditor controls. Auditors gain an understanding of inherent risk and control risk. Why? To develop their audit plan and lower their detection risk (the risk that the audit will not detect material misstatements). Put more simply, the auditor understands the client’s risk in order to lower her own.

Further Audit Procedures

And how does the auditor reduce detection risk? With further audit procedures. Those include test of controls and substantive procedures (test of details or substantive analytics). 

After the auditor gains an understanding of the entity and its environment, including internal controls, control risk is often assessed at high. Why? Two reasons: one has to do with efficiency and the other with weak internal controls.

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Assessing Control Risk at High

Consider the first reason for high control risk assessments: efficiency

Control risk can be assessed at high, even if—during your walkthroughs— you see that controls are properly designed and in use. But why would you assess this risk at high when controls are okay? 

Let me answer that question with a billing and collection example. 

Risk At High: Efficiency Decision

You can test billing and collection internal controls for effectiveness (assuming your walkthrough reveals appropriate controls). But if this test takes eight hours and a substantive approach takes five hours, which is more efficient? Obviously, the substantive approach. And if you use a fully substantive approach, you must assess control risk at high for all relevant assertions. 

At this point, you may still be thinking, But, Charles, if controls are appropriately designed and implemented, why is control risk high? Because a test of controls is required for control risk assessments below high: the auditor needs a basis (evidence) for the lower assessment. And a walkthrough is not (in most cases) considered a test of controls for effectiveness: it does not provide a sufficient basis for the lower risk assessment. A walkthrough provides an initial impression about controls, but that impression can be wrong. That’s why a test of controls is necessary when control risk is below high, to prove the effectiveness of the control.

In our example above, a substantive approach is more efficient than testing controls. So we plan a substantive approach and assess control risk at high for all relevant assertions. 

Risk at High: Weak Controls

Now, let’s look at the second reason for high control risk assessments: weak internal controls. Here again, allow me to explain by way of example. 

If the billing and collection cycle walkthrough reveals weak internal controls, then control risk is high. Why? Because the controls are not designed appropriately or they are not in use. In other words, they would not prevent or detect a material misstatement. You could test those controls for effectiveness. But why would you? They are ineffective. Consequently, risk has to be high. Why? Again, because there is no basis for the lower risk assessment. (Even if you tested controls, the result would not support a lower risk assessment: the controls are not working.)

If, on the other hand, controls are appropriate, then you might test them (though you are not required to). 

Assessing Control Risk at Less than High

What if, based on your walkthrough, controls are okay. And you believe the test of controls will take four hours while a substantive approach will take eight hours? Then you can test controls for effectiveness. And if the controls are effective, you can assess the risk at less than high. Now you have support for the lower risk assessment. 

But what if you test controls for effectiveness and the controls are not working? Then a substantive approach is your only choice. 

Many auditors don’t test controls for this reason: they are afraid the test of controls will prove the controls are ineffective. For example, if you test sixty transactions for the issuance of a purchase order, and seven transactions are without purchase orders, the sample does not support effectiveness. The result: the test of controls is a waste of time. 

Some auditors mistakenly believe they don’t need an understanding of controls because they plan to use a fully substantive audit approach. But is this true?

Fully Substantive Audit Approach

Weak internal controls can result in more substantive procedures, even if you normally use a substantive approach

Suppose you assess control risk at high for all billing and collection cycle assertions and plan to use a fully substantive approach. Now, consider two scenarios, one where the entity has weak controls, and another where controls are strong.

Billing and Collection Cycle – Weak Controls

Think about a business that has a cash receipt process with few internal controls. Suppose the following is true:

  • Two employees receipt cash  
  • They both work from one cash drawer 
  • The two employees provide receipts to customers, but only if requested
  • They apply the payments to the customer’s accounts, but they also have the ability to adjust (reduce or write off) customer balances 
  • At the end of the day, one of the two employees creates a deposit slip and deposits the money at a local bank (though this is not always done in a timely manner)
  • These same employees also create and send bills to customers 
  • Additionally, they reconcile the related bank account 

Obviously, a segregation of duties problem exists and theft could occur. For example, the clerks could steal money and write off the related receivables. Child’s play. 

Billing and Collection Cycle – Strong Controls

But suppose the owner detects theft and fires the two employees. He does background checks on the replacements. Now the following is true:

  • A separate cash drawer is assigned to each clerk
  • The controller is required to review customer account adjustments on a daily basis (the controller can’t adjust receivable accounts)
  • The cash receipt clerks reconcile their daily activity to a customer receipts report, and the money along with the report is provided to the controller 
  • The controller counts the daily funds received and reconciles the money to the cash receipts report
  • Then the controller creates a deposit slip and provides the funds and deposit slip to a courier
  • Once the deposit is made, the courier gives the bank deposit receipt to the controller
  • A fourth person (that does not handle cash) reconciles the bank statement in a timely manner
  • The monthly customer bills are created and mailed by someone not involved in the receipting process
  • Moreover, the owner reviews a monthly cash receipts report 

Now, let me ask you: would you use the same substantive audit procedures for each of the above scenarios? Hopefully not. The first situation begs for a fraud test. For example, we might test the adjustments to receivables on a sample basis. Why? To ensure the clerks are not writing off customer balances and stealing cash. 

Audit Procedures: Basic and Extended

Basic audit procedures for the billing and collection cycle might include:

  • Test the period-end bank reconciliation
  • Create substantive analytics for receivable balances and revenues
  • Confirm receivable accounts and examine subsequent receipts

We perform these basic procedures whether controls are good or weak. But we would add—when controls are weak and might allow theft—extended substantive procedures such as testing accounts receivable adjustments. 

Do you see how the understanding of controls impacts planning (even when control risk is assessed at high)? If we were unaware of the control weaknesses, we would not plan the needed fraud detection procedures. 

In summary, we need to understand controls even if we plan to use a fully substantive approach, and even if risks are assessed at high for all assertions. More risk means more audit work. 

A Simple Summary

  • Control risk is the probability that an entity’s internal controls will not prevent or detect material misstatements in a timely manner
  • Internal control weaknesses may require a control risk assessment of high
  • Control risk can only be assessed below high when a test of control proves the control to be effective (the test of control provides the basis for the lower risk assessment)
  • If walkthroughs show controls to be appropriately designed and implemented, the auditor can (1) assess control risk at high and use a fully substantive approach, or (2) assess control risk below high and test controls for effectiveness, whichever is most efficient
  • Even if an auditor intends to use a fully substantive approach, walkthroughs are necessary to determine if additional substantive tests are needed; additional substantive procedures may be necessary when material fraud is possible due to internal control weaknesses

See my inherent risk article here

For additional information about risk assessment, see the AICPA’s SAS 145, Understanding the Entity and Its Environment and Assessing the Risk of Material Misstatement The guidance was issued in October 2021. 

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