how to audit property
Mar 28

City Manager Pockets Cash from the Sale of Excess Property

By Charles Hall | Asset Misappropriation

The Theft

Is it possible to convert large pieces of excess property to cash–all without anyone knowing? Apparently yes.

Two men, Alfred Ketzler (the city manager) and Alfred Fabian, were found guilty of wire fraud and theft from the city of Tanana, Alaska.

Illegal sales of government property

Picture is courtesy of AdobeStock.com

Department of Justice Indictment Press Release

So what happened?

First, the Department of Justice stated “Ketzler would acquire surplus federal property that was stored at several different locations without notifying the mayor of Tanana or the city council for the city of Tanana of the federal excess and surplus property obtained on behalf of the city of Tanana.”

The Department of Justice went on to say “that Fabian, for his part, would transport federal excess and surplus property obtained on behalf of the city of Tanana to storage locations in and around Fairbanks, Alaska, including his own residence.”

Finally, the indictment stated that once the excess property was received, Ketzler would sell the equipment to individuals and businesses, telling them the property belonged to the City of Tanana. He asked that the checks be made out to him personally. The indictment continued by saying Ketzler would deposit the checks in his personal account and make payments to Fabian.

The indictment stated that the men received approximately $122,000 in illegal funds.

The property sold included:

  • Trucks
  • Fork Lifts
  • Bulldozers
  • Other industrial equipment

Department of Justice Sentencing Press Release

A June 2014 Department of Justice press release stated:

Anchorage, Alaska – U.S. Attorney Karen L. Loeffler announced today that two Fairbanks men were sentenced on Friday, June 6, 2014, in federal court in Fairbanks after being found guilty of wire fraud and theft from a local government receiving federal funds.

Alfred Richard Ketzler, Jr., also known as “Bear” Ketzler, 57, of Fairbanks, Alaska, was sentenced to 16 months in prison to be followed by two years of supervised release by Chief U.S. District Court Judge Ralph R. Beistline. Ketzler pled guilty in March 2014. Ketzler has already paid restitution to the City of Tanana in the amount of $116,500.

Alfred McQuestion Fabian, 62, of Fairbanks, Alaska, was sentenced to six months in prison to be followed by two years of supervised release by Chief U.S. District Court Judge Ralph R. Beistline. Fabian pled guilty in March 2014.

The Weakness

The city may have had appropriate inventory controls (the DOJ press releases did not say). Most noteworthy, this case appears to reflect a circumvention of controls. The city manager had the power and ability to consummate transactions that were (apparently) not recorded on the city’s records. The indictment states that Ketzler did not provide the city with appropriate notice of the receipt and sale of the excess property. Also the payments received were not recorded on the city’s books.

The Fix

Organizations should do all they can in the hiring process to bring people in that are honest. How? Background checks and the calling of references are critical.

It is imperative that all property be included in inventory—as soon as title transfers to the city. And, obviously, all payments should be made to the city (in this case) and not to individuals. A receipt should be issued to the payor that details the reason for the payment, the amount, and who made it.

audit and work paper mistakes
Mar 28

Forty Audit and Work Paper Mistakes

By Charles Hall | Auditing

Today, I offer you a list of forty audit and work paper mistakes.

audit and work paper mistakes

The list is based on my observations from over over thirty years of audit reviews (and not on any type of formal study).

You will, however, shake your head in agreement as you read these. I know you’ve seen them as well. The list is not comprehensive. So, you can add others in the comments section of this post.

Here’s the list.

  1. No preparer sign-off on a work paper
  2. No evidence of work paper reviews
  3. Placing documents in the file with no purpose (the work paper provides no evidential matter for the audit)
  4. Signing off on unperformed audit program steps
  5. No references to supporting documentation in the audit program
  6. Using canned audit programs that aren’t based on risk assessments for the particular entity
  7. Not documenting expectations for planning analytics
  8. Inadequate explanations for variances in planning analytics (“revenue went up because sales increased”)
  9. Planning analytics with obvious risk of material misstatement indicators, but no change in the audit plan to address the risk (sometimes referred to as linking)
  10. Not documenting who inquiries were made of
  11. Not documenting when inquiries were made
  12. Significant deficiencies or material weaknesses that are not communicated in written form
  13. Verbally communicating control deficiencies (those not significant deficiencies or material weaknesses) without documenting the conversation
  14. Performing needed substantive tests with no related audit program steps (i.e., the audit program was not amended to include the necessary procedures)
  15. Assessing control risk below high without testing controls
  16. Assessing the risk of material misstatement at low without a basis (reason) for doing so
  17. Documenting significant risks (e.g., allowance for uncollectible receivable estimates in healthcare entities) but no high inherent risks (when inherent risk are separately documented)
  18. Not documenting the predecessor auditor communication in a first-year engagement
  19. Not documenting the qualifications and objectivity of a specialist
  20. Not documenting all nonattest services provided
  21. Not documenting independence
  22. Not documenting the continuance decision before an audit is started
  23. Performing walkthroughs at the end of an engagement rather than the beginning
  24. Not performing walkthroughs or any other risk assessment procedures
  25. Not performing risk assessment procedures for all significant transaction areas (e.g., risk assessment procedures performed for billing and collections but not for payroll which was significant)
  26. Not retaining the support for opinion wording in the file (especially for modifications)
  27. Specific items tested are not identified (e.g., “tested 25 disbursements, comparing amounts in the check register to cleared checks” — we don’t know which particular payments were tested)
  28. Making general statements that can’t be re-performed based on the information provided (e.g., “inquired of three employees about potential fraud” — we don’t know who was interviewed or what was asked or their responses)
  29. Retrospective reviews of estimates are not performed (as a risk assessment procedure)
  30. Going concern indicators are present but no documentation regarding substantial doubt
  31. IT controls are not documented
  32. The representation letter is dated prior to final file reviews by the engagement partner or a quality control partner
  33. Consultations with external or internal experts are not documented
  34. No purpose or conclusion statement on key work papers
  35. Tickmarks are not defined (at all)
  36. Inadequately defining tickmarks (e.g., ## Tested) — we don’t know what was done
  37. No group audit documentation though a subsidiary is included in the consolidated financial statements
  38. No elements of unpredictability were performed
  39. Not inquiring of those charged with governance about fraud
  40. Not locking the file down after 60 days 

That’s my list. What would you add?

Mar 23

Five Dirty, No Good, Terrible, Audit Habits

By Charles Hall | Auditing

Today I describe five dirty, no good, terrible, audit habits. 

Certain peer review deficiencies continue to persist. Today I tell you about a few and how you can stop them.

Have you ever had a bad habit? You eat too much, don't exercise enough, put your make-up on while driving to work (one I've never had, thankfully), spend too much money. Yes, we've all had bad habits.

Auditors have them as well. Some problems seem to never die. The AICPA periodically provides a list of peer review deficiencies. Here are five and what you can do about them. 

Bad Habit 1 - Skipping Risk Assessment 

Do you have the habit of starting your audit by testing bank reconciliations or reconciling equity accounts to the general ledger? 

Solution - Start in the right place. At the beginning. And where is the beginning? First acceptance and continuance. Then risk assessment. Resolve to perform the following before doing any substantive work:

  1. Perform acceptance or continuance procedures
  2. Gain an understanding of the entity and its environment
  3. Perform walkthroughs 
  4. Review prior year estimates for potential bias
  5. Ask questions regarding fraud
  6. Create your planning analytics

Now, assess risk at the financial statement level and at the transaction level by assertion. Once risk assessment is complete, start your substantive work.

In a another bad habit, some auditors create their risk assessments but don't use them.

Bad Habit 2 - Performing But Not Using Risk Assessment

Don't allow another bad habit to persist: Performing risk assessment procedures and ignoring the results. In other words, using the same substantive procedures as last year, though new risks are present. 

Solution - Once a risk is identified, link a response to it. This can be done on your risk assessment summary form.

For example, the revenue recognition standard is effective for many of your December 31, 2019 clients. The standard represents change and can impact your risk of material misstatement for revenue. Change creates risk. And risk calls for a response. Link the risk (that revenue recognition and disclosures may be incorrect) to substantive procedures. Test the revenue recognition in light of Topic 606 and vet the disclosures with an updated disclosure checklist.

In another nasty habit, some auditors ignore controls.

Bad Habit 3 - Ignoring Controls

While a test of controls for effectiveness is not required, reviewing control design and implementation is. This is why we perform walkthroughs. But some auditors ignore or give little attention to this risk assessment procedure. Their attitude is "I already know what I'm going to do, so why waste time?" 

This attitude can be the result on believing a balance sheet audit approach is sufficient. This is the belief that auditing all significant balance sheet accounts is enough. But is it? Suppose the CFO steals $5 million dollars during the year, skimming cash from unbilled receipts. You can audit the year-end bank reconciliation. The bank account can reconcile to the general ledger. But the $5 million is still missing. 

Solution - Gain your understanding of controls early in the audit. Use walkthroughs to do so. 

The next bad habit is an extension of not gaining an understanding of controls.

Bad Habit 4 - Not Reviewing SOC Reports

Putting a service organization controls (SOC) report in the audit file is not enough. We must understand the service organization's controls.

Why? Because the service organization controls are a part of the company's controls. The company's accounting system includes outsourced components.

Your client, for example, may outsource its payroll to ADP. Does that mean the auditor doesn't need to understand ADP's processes and controls? No. Why? Because ADP is acting as an extension of the company's accounting system. The SOC report allows you to see if the payroll controls are designed appropriately and implemented. And this is what we desire whether the accounting is in-house or outsourced.

Solution - Read the SOC report and document your considerations. If control weaknesses are present, determine how those weaknesses impact your risk assessment. 

And what's the last bad habit? Drum roll. Auditors don't identify the significant risks.

Bad Habit 5 - Not Identifying Significant Risks

Every audit has at least one or two significant risks. Consider, for example. management override. Management can manipulate the books to satisfy their needs. 

So, what is a significant risk? Audit standards define it as "An identified and assessed risk of material misstatement that, in the auditor's professional judgment, requires special audit consideration." But what is "special audit consideration"? It's those high risk areas that deserve extra attention. They are the two or three areas (the number varies by audit) that deserve our greatest effort. Understand that not all high risk of material misstatements are significant risks. Significant risks are those areas of an even higher concern. Examples include:

  • Allowance for bad debt in a hospital
  • Management override
  • A fraud risk (because a known material theft exist)

By contrast, a high risk of material misstatement (RMM) for the completeness assertion in payables might not be a significant risk. The RMM might be high but, in this example, it's not a significant risk. 

Solution - Identify significant risks. Do so on your risk assessment summary form. Then link to a response in your audit program. And these responses should be beyond your normal basic procedures. Additionally, they must include a test of details.

AICPA Areas of Focus

Each year the AICPA creates areas of focus in its Enhancing Audit Quality (EAQ) work. You may want to put this in your tickler file. Why? So you'll know the hot-button peer review issues. That way you can build your audit processes in a proactive manner. 

Segregation of Duties
Mar 21

Segregation of Duties: How to Overcome

By Charles Hall | Auditing , Fraud

Segregation of duties is key to reducing fraud. But smaller entities may not be able to do so. Today, I tell you how overcome this problem, regardless of the entity’s size. 

Segregation of Duties

The Environment of Fraud

Darkness is the environment of wrongdoing.

Why?

No one will see us. Or so we think.

Fraud occurs in darkness.

In J.R.R. Tolkien’s Hobbit stories, Sméagol, a young man murders another to possess a golden ring, beautiful in appearance but destructive in nature. The possession of the ring and Sméagol’s hiding of self and his precious (the ring) transforms him into a hideous creature–Gollum. I know of no better or graphic portrayal of how that which is alluring in the beginning, is destructive in the end.

Fraud opportunities have those same properties: they are alluring and harmful. And, yes, darkness is the environment where fraud happens.

What’s the solution? Transparency. It protects businesses, governments, and nonprofits.

But while we desire open and understandable processes, our businesses often have just a few employees that perform the accounting duties. And, many times, no one else understands how the system works.

It is desirable to divide accounting duties among various employees, so no one person controls the whole process. This division of responsibility creates transparency. How? By providing multiple eyes to see what’s going on.

But this segregation of duties is not always possible.

Lacking Segregation of Duties

Many small organizations lack appropriate segregation of duties and believe that solutions do not exist or that they are too costly. But is this true? I don’t think so.

Here’s two easy steps to create greater transparency and safety.

1. Bank Account Transparency

First, consider this simple control: Provide all bank statements to someone other than the bookkeeper. Allow this second person to receive the bank statements before the bookkeeper. While no silver bullet, it has power.

Persons who might receive the bank statements first (before the bookkeeper) include the following:

  • A nonprofit board member
  • The mayor of a small city
  • The owner of a small business
  • The library director
  • A church leader

What is the receiver of the bank statements to do? Merely open the bank statements and review the contents for appropriateness (mainly cleared checks).

In many small entities, accounting processes are a mystery to board members or owners. Why? Only one person (the bookkeeper) understands the disbursement process, the recording of journal entries, billing and collections, and payroll.

Relying on a trusted bookkeeper is not a good thing. So how can you shine the light?

Fraud Prevention

Picture courtesy of DollarPhoto.com

Allow a second person to see the bank statements.

Fraud decreases when the bookkeeper knows someone is watching. Suppose the bookkeeper desires to write a check to himself but realizes that a board member will see the cleared check. Is this a deterrent? You bet.

Don’t want to send the bank statements to a second person? Request that the bank provide read-only online access to the second person. And let the bookkeeper know.

Even the appearance of transparency creates (at least some) safety. Suppose the second person reviewer opens the bank statements (before providing them to the bookkeeper) and does nothing else. The perception of a review enhances safety. I am not recommending that the review not be performed. But if the bookkeeper even thinks someone is watching, fraud will lessen.

When you audit cash, see if these types of controls are in place.

Now, let’s look at the second step to overcome a lack of segregation of duties. Surprise audits.

2. Surprise Audits

Another way to create small-entity transparency is to perform surprise audits. These reviews are not opinion audits (such as those issued by CPAs). They involve random inspections of various areas such as viewing all checks clearing the May bank statement. Such a review can be contracted out to a CPA. Or they can be performed by someone in the company. For example, a board member.

Segregation of Duties

Picture courtesy of DollarPhoto.com

Additionally, adopt a written policy stating that the surprise inspections will occur once or twice a year.

The policy could be as simple as:

Twice a year a board member (or designee other than the bookkeeper) will inspect the accounting system and related documents. The scope and details of the inspection will be at the judgment of the board member (or designee). An inspection report will be provided to the board.

Why word the policy this way? You want to make the system general enough that the bookkeeper has no idea what will be examined but distinct enough that a regular review occurs. 

Surprise Audit Ideas

Here are some surprise audit ideas:

  • Inspect all cleared checks that clear a particular month for appropriate payees and signatures and endorsements
  • Agree all receipts to the deposit slip for three different time periods
  • Review all journal entries made in a two week period and request an explanation for each
  • Inspect two bank reconciliations for appropriateness
  • Review one monthly budget to actual report (look for unusual variances)
  • Request a report of all new vendors added in the last six months and review for appropriateness

The reviewer may not perform all of the procedures and can perform just one. What is done is not as important as the fact that something is done. In other words, the primary purpose of the surprise audit is to make the bookkeeper think twice about whether he or she can steal and not get caught.

I will say it again. Having multiple people involved reduces the threat of fraud.

Segregation of Duties Summary

In summary, the beauty of these two procedures (bank account transparency and surprise audits) is they are straightforward and cheap to implement. Even so, they are powerful. So shine the light.

What other procedures do you recommend?

For more information about preventing fraud, check out my book: The Little Book of Local Government Fraud Prevention.

Auditing Receivables and Revenues
Mar 20

Auditing Receivables and Revenues: The Why and How Guide

By Charles Hall | Auditing

Today we take a look at auditing receivables and revenues.

Revenues are the lifeblood of any organization. Without cash inflows, the entity may cease to exist. So, it’s important that each business generate sales or some type of revenue. For you, the auditor, it’s important to verify the revenue.  

Along with revenues, auditors need to prove receivables. Why? Some companies manipulate their earnings by inflating their period-end receivables.  When trade receivables increase, revenues increase. So, a company can increase its net income by recording nonexistent receivables.

In this post, we’ll answer questions such as, “should I confirm receivables or examine subsequent receipts?” and “why should I assume that revenues are overstated?"

Auditing Receivables and Revenues

Auditing Receivable and Revenues — An Overview

In this post, we will cover the following:

  1. Primary accounts receivable and revenue assertions
  2. Accounts receivable and revenue walkthrough
  3. Directional risk for accounts receivable and revenues
  4. Primary risks for accounts receivable and revenues
  5. Common accounts receivable and revenue control deficiencies
  6. Risk of material misstatement for accounts receivable and revenues
  7. Substantive procedures for accounts receivable and revenues
  8. Common accounts receivable and revenue work papers

Primary Accounts Receivable and Revenue Assertions

First, let’s look at assertions. The primary relevant accounts receivable and revenue assertions are:

  • Existence and occurrence
  • Completeness
  • Accuracy
  • Valuation
  • Cutoff

Of these assertions, I believe—in general—existence (of receivables), occurrence (of revenues) and valuation (of receivables) are most important. So, clients assert that:

  • Receivables exist 
  • Receivables are properly valued, and 
  • Revenues occurred

Accuracy comes into play if the customer has complex receivable transactions. Additionally, the cutoff assertion is often relevant, especially if the client has incentives to inflate the receivables balance (e.g., bonuses triggered at certain income levels).

Accounts Receivable and Revenue Walkthrough

Second, think about performing your risk assessment work in light of the relevant assertions.

As we perform walkthroughs of accounts receivable and revenue, we are looking for ways they are overstated (though they can also be understated as well). We are asking, “What can go wrong, whether intentionally or by mistake?”

In performing accounts receivable and revenue walkthroughs, ask questions such as:

  • Are receivables subsidiary ledgers reconciled to the general ledger?
  • Is a consistent allowance methodology used?
  • What method is used to compute the allowance and is it reasonable?
  • Who records and approves the allowance?
  • Who reviews aged receivables?
  • What controls ensure that revenues are recorded in the right period?
  • Is there adequate segregation of duties between persons recording, billing, and collecting payments? Who reconciles the related records?
  • What software is used to track billings and collections?
  • Are there any decentralized collection locations?
  • When are revenues recognized and is the recognition in accordance with the reporting framework?
  • What receivables and revenue reports are provided to the owners or the governing body?

As we ask questions, we also inspect documents (e.g., aged receivable reports) and make observations (e.g., who collects the payments?).

If controls weaknesses exist, we create audit procedures to respond to them. For example, if—during the walkthrough—we see inconsistent allowance methods, we will perform more substantive work to prove the allowance balances.

Directional Risk for Accounts Receivable and Revenues

Third, consider the directional risk of accounts receivable and revenues.

Auditing receivables and revenues

The directional risk for accounts receivable and revenue is an overstatement. So, in performing your audit procedures, perform procedures to ensure that accounts receivables and revenues are not overstated. For example, review the cutoff procedures at period-end. Be sure that no subsequent period revenues are recorded in the current fiscal year. 

Audit standards require that auditors review estimates for management bias. So, consider the current year allowance and bad debt write-offs in light of the prior year allowance. This retrospective review allows the auditor to see if the current estimate is fair. The threat is that management might reduce allowances to inflate earnings.

Moreover, the audit standards state there is a presumption (unless rebutted) that revenues are overstated. Therefore, we are to assume revenues are overstated, unless we can explain why they are not.

Primary Risks for Accounts Receivable and Revenues

Fourth, think about the risks related to receivables and revenues.

The main risks are:

  1. The company intentionally overstates accounts receivable and revenue 
  2. Company employees steal collections 
  3. Without proper cutoff, an overstatement of accounts receivables and revenue occurs 
  4. Allowances are understated
  5. Revenue recognition

Risks related to revenue also vary from company to company. For example, one telecommunications company might sell bundled services while another may not. Revenue recognition is more complex (risky) for the company selling bundled services.

Also, revenue risks vary from industry to industry. For example, the allowance for uncollectible is normally a high risk area for healthcare entities, but may not be so for other industries.

Common Accounts Receivable and Revenue Control Deficiencies

Fifth, think about the control deficiencies noted during your walkthroughs and other risk assessment work.

In smaller entities, the following control deficiencies are common:

  • One person performs one or more of the following: 
    • bills customers
    • receipts monies
    • makes deposits 
    • records those payments in the general ledger
    • reconciles the related bank account
  • The person computing allowances doesn’t possess sufficient knowledge to do so correctly
  • No surprise audits of receivables and revenues 
  • Multiple people work from one cash drawer
  • Receipts are not appropriately issued
  • Receipts are not reconciled to daily collections
  • Daily receipts are not reviewed by a second person
  • No one reconciles subsidiary receivable ledgers to the general ledger
  • Individuals with the ability to adjust customer receivable accounts (with no second-person approval or review) also collect cash 
  • Inconsistent bad debt recognition with no second-person review process
  • The revenue recognition policy may not be clear and may not be in accordance with the reporting framework

Risk of Material Misstatement for Accounts Receivable and Revenues

Sixth, now it’s time to assess your risks.

In smaller engagements, I usually assess control risk at high for each assertion. Controls must be tested to support any lower control risk assessments. Assessing risks at high is often more efficient than testing controls.

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

My response to higher risk assessments is to perform certain substantive procedures: namely, receivable confirmations and tests of subsequent collections. As RMM increases, I send more confirmations and examine more subsequent collections.

Additionally, I thoroughly test management’s allowance computation. I pay particular attention to uncollected amounts beyond 90 days. Uncollected amounts beyond 90 days should usually be heavily reserved. And amounts beyond 120 days should—generally—be fully reserved.  

Substantive Procedures for Accounts Receivable and Revenues

And finally, it’s time to determine your substantive procedures in light of your identified risks.

auditing receivables and revenues

My customary audit procedures are as follows:

  1. Confirm accounts receivable balances (especially larger amounts)
  2. Vouch subsequent period collections, making sure the subsequent collections relate to the period-end balances (sampling can be used)
  3. Thoroughly review allowance computations to see if they are consistent with prior years; compare allowance percentages to industry averages; agree to supporting documentation (e.g., histories of uncollectible amounts); recompute the related numbers
  4. Create comparative summaries of all significant revenue accounts, comparing the current year amounts with historical data (three or more years if possible)
  5. Create summaries of average per customer income and compare with prior years (you may want to do this by specific revenue categories)
  6. Compute average profit margins by sales categories and compare with previous years

Common Accounts Receivable and Revenue Work Papers

My accounts receivable and revenue work papers frequently include the following:

  • An understanding of accounts receivable and revenue-related internal controls
  • Risk assessment of accounts receivable and revenue at the assertion level
  • Documentation of any control deficiencies
  • Accounts receivable and revenue audit program
  • A detail of receivables comprising amounts on the general ledger
  • Copies of confirmations sent
  • A summary of confirmations received
  • Subsequent collections work papers
  • Allowance work paper
  • Revenue comparison work papers

In Summary

In this chapter, we’ve looked at the following for receivables and revenues:

  • How to perform risk assessment procedures, 
  • Relevant assertions, 
  • Risk assessments (as a result of the risk assessment procedures), and
  • Substantive procedures

Next, we’ll see how to audit investments.

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