CPA Hall Talk

Mar 10

Text, Email, or Call: Which is Best?

A CPA called me today and left a message with a question. My first thought was to call him. I knew if I phoned, one of the following would happen:

No answer and we’d play phone tag.
He’d answer, and we would talk about other things.
He’d answer, and I would respond to his question.

The first two possibilities are not good (if you are busy like I am–and I know you are).

My next thought: I will text him. I did, and it took about 30 seconds.

With the options to text, email, or call, which is best? Let’s see.

I like to think of the choices as a sprint, a run, or a walk.

Text – A Sprint

If a client or firm member text me, I will text back–as long as:

The response is short and
The answer does not contain sensitive information

Why not just email or call?

In the middle of busy season, I’m looking for every moment I can save. Many times a text answers the question–and I can do so promptly (this is better than not responding at all because I’m too busy).

Email – A Run

When is an email the better option?

Mainly when you need to send attachments. Emails take longer than texts but seem to work better–at least for me–when more than one or two short answers are necessary.

If you are emailing sensitive information, consider using a secure method such as ShareFile. ShareFile offers an Outlook add-in that makes the transfer seamless.

Call – A Walk

I call when the message is essential or lengthy.

We lose something in electronic communications. Our tone of voice and inflections say a great deal. Phone calls usually take longer than a text or an email, but could be warranted if the issue is important.

If my communication is lengthy (say more than three points), I usually opt for a phone call. If you are providing accounting, tax, or auditing advice, consider whether you need to document the phone conversation in a memo. I sometimes use a form (that I keep in Evernote) for this purpose. What does it address? The discussion, the referenced professional standards, the advice given, who I talked with, and the date.

Summary

Sprint, run or walk. Each has advantages and disadvantages. Regardless of your choice, it’s all about communicating clearly and timely.

Check out my post An Auditor’s Cell Phone.

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

Here are three key first year audit considerations:

Obtaining information about opening balances
Reviewing the predecessor auditor's workpapers
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).

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.

Feb 06

Fraud Prevention for Small Governments

By Charles Hall | Fraud , Local Governments

Many small governments suffer losses from theft since they lack a sufficient number of employees to segregate accounting duties. There are, however, steps you can take to protect your resources. In this post, I provide ideas for fraud prevention in small governments.

Most government officials don’t realize that external audits are not designed to detect immaterial fraud (immaterial can be tens of thousands of dollars – sometimes even more). Such officials incorrectly believe that a clean opinion means no fraud is occurring in their locale – this is a mistake. External financial statement opinion audits are not designed to look for fraud at immaterial levels. Even if your government has an external audit, consider implementing fraud prevention procedures.

In a typical small government accounting setting, the city of In Between (as in between two stop lights) (population 1,202) has a mayor and three council members. The city has one bookkeeper (we’ll call him Dale) who orders and receives all purchased items; he writes all checks, reconciles bank statements, and keys all transactions into the accounting system. Dale also receipts all collections and makes all deposits. Mayor Chester signs all checks (vendor and payroll). (In a long-standing tradition, the mayor also graces the city Christmas parade float as Santa Claus.) With so little segregation of duties, what can be done?

The smaller the government, the greater the need for fraud prevention – even if Santa Claus in involved. And yet, these are the governments that most often don’t have the resources–whether the money to pay for outside assistance or employees to segregate duties–to prevent fraud. Here are few ideas for even the smallest of governments.

Low-Cost Fraud Prevention

First, let’s look at low-cost fraud prevention options:

Have all bank statements mailed directly to Mayor Chester who will open and inspect the bank statement activity before providing the bank statements to Dale; alternatively, provide online access to Mayor Chester who reviews bank statement activity and signs a monthly memo documenting his review
Once or twice a year, have council members pick two months at random (e.g., May and September) and review key bank statement activity (e.g., the operating and payroll accounts)
Once or twice a year, have council members randomly select checks (e.g., ten vendor checks and ten payroll checks) and review supporting documentation (e.g., invoices and time sheets)
Once or twice a year, have the mayor and council review receipt collections and related documentation (e.g., for two days deposits); agree receipts to bank deposits and to the general ledger
Provide monthly budget to actual reports to mayor and council
Provide monthly overtime summaries to mayor and council
Do not allow Dale to sign checks
Require two signatures on checks above a certain level (e.g., $5,000); have two of the council members (in addition to the mayor) on the bank signature cards; supporting documentation (e.g., invoice) should be provided to check signers for review
Require Mayor Chester and Dale to authorize any wire transfers
Have Dale provide the mayor with monthly bank reconciliations; the mayor should document (e.g., initial the reconciliation) his review
Don’t provide Dale with a credit card
If Dale is provided a credit card, provide him with one card; use a low maximum credit limit (e.g., $1,000); Dale’s credit card statements should be provided to the mayor when he signs the related check for payment
Use a centralized receipting location (if possible); receipts should always be written upon collection of a payment

Higher Cost Fraud Fraud Prevention

Now let’s examine some higher cost options (that are probably more effective):

Have an outside CPA or Certified Fraud Examiner (CFE) perform the receipting and payment tests listed above
Have an outside CPA or CFE map your internal control system and make system-design recommendations
Have an outside CPA or CFE make surprise unannounced visits (e.g., two per year) to examine the receipting system, payroll, and the payment system; at the beginning of the year, tell Dale that the surprise visits will occur (details of what will be tested should not be communicated to Dale)
Install a security camera to record all of Dale’s collection and receipting activity
Purchase fidelity bond to cover elected officials and Dale

Keep in mind that you can limit the cost of the outside CPA. The contract might read Surprise audit of vendor payments with cost limited to $1,500. Try to contract with a CPA or CFE with governmental experience. The surprise audits and the fidelity bond recommendations are, in my opinion, the most critical steps.

Some states like New York audit local governments for fraud; consequently, if your local government is frequently audited by a state agency, there may be less of a need to hire an outside CPA or CFE to perform fraud prevention procedures.

Additional Fraud Prevention Resources

Click here for a list of local government controls to consider.

For additional insights into preventing fraud in your government, get The Little Book of Local Government Fraud Prevention on Amazon.

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 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:

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.
Second year finance director with no prior accounting experience, graduated from a two year college with a degree in general business.
Finance director with 25 years experience and is a CPA and a member of GFOA. She trains others in governmental accounting.
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:

Document the nonattest services you are to perform
Document the client person that will oversee and assume responsibility for the nonattest service
Document the SKE of the designated person
Consider whether any nonattest services are significant threats
Document which, if any, nonattest services are significant threats
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.

Jan 14

Statement on Standards for Forensic Services

By Charles Hall | Fraud

The AICPA has issued an exposure draft titled Statement of Standards for Forensic Services No. 1 (SSFS 1), Forensic Services: Definitions and Standards. If approved, the standard will be effective for new engagements accepted on or after May 1, 2019.

Who Created SSFS 1?

SSFS 1 was created by the AICPA’s Forensic and Valuation Services Executive Committee.

Why SSFS 1?

The purpose of the standard is to improve the consistency and quality of forensic services provided by CPAs.

It appears the AICPA is being responsive to a growing demand for forensic services. A report created by IBISWorld (a market research firm) showed that employment in forensic accounting grew at an annualized rate of 18% from 2012 to 2017.

Services Covered by SSFS 1

SSFS 1 covers the following types of forensic services (per paragraph .01 of the proposed standard):

Litigation – an actual or potential legal or regulatory proceeding before a trier of fact or a regulatory body as an expert, consultant, neutral, mediator or arbitrator in connection with the resolution of disputes between parties. Litigation used herein is not limited to formal litigation, but is inclusive of other alternative dispute resolution forums;

Investigation – a matter that is not a litigation but which may involve using the same skills and the services are performed in response to specific concern(s) of wrong doing in which the member is engaged to perform procedures to collect, analyze, evaluate or interpret certain evidential matter to assist the stakeholder (e.g. client, board of directors, independent auditor or regulator) in reaching a conclusion on the merits of the concern(s).

Prohibitions

SSFS 1 includes two prohibitions:

A legal opinion can not be provided regarding the occurrence of fraud, and
Forensic services can’t be provided on a contingent fee basis

Why can’t a member provide a legal opinion regarding fraud? The final determination of whether fraud exists is determined by the “trier-of-fact,” according to paragraph .08 of the standard.

Applicability

The standard would apply to all AICPA members, AICPA members firms, and employees of AICPA member firms.

Paragraph .03 of the standard states “the key consideration of this Statement’s applicability is the purpose (e.g., Litigation or Investigation) for which the member was engaged.” The applicability is not based on a particular service provided such as data analysis. But if data analysis, for example, is performed in relation to litigation or investigative services, then the statement would apply.

Understanding with Client

The understanding with the client regarding the nature, scope, and limitations of the services can be written or oral.

« Previous 1 … 25 26 27 28 29 … 41 Next »