In this article I explain how you can use unpredictable audit procedures.
The audit standards require elements of unpredictability. Why? So clients can’t guess what the auditor is going to do. Clients naturally observe and learn what auditors normally do. The client’s knowledge of what is audited (and what is not) makes it easier to steal. The client takes from unaudited areas. This knowledge also enables the company to manipulate numbers. The client alters unaudited balances.
The purpose of the unpredictable element is to create uncertainty–in the client’s mind–regarding audit procedures. We do so by using unpredictable audit procedures.
AU-C 240.29 states the following:
In determining overall responses to address the assessed risks of material misstatement due to fraud at the financial statement level, the auditor should…incorporate an element of unpredictability in the selection of the nature, timing, and extent of audit procedures.
AU-C 240.A42 states:
Incorporating an element of unpredictability in the selection of the nature, timing, and extent of audit procedures to be performed is important because individuals within the entity who are familiar with the audit procedures normally performed on engagements may be better able to conceal fraudulent financial reporting. This can be achieved by, for example,
To introduce elements of unpredictability, perform procedures such as these:
Since unpredictable tests are required in every audit, document where you performed this procedure. Reference your audit program step for unpredictable tests to the work performed. Title your work paper, “Unpredictable Test,” and then add a purpose statement such as, “Purpose: To confirm the immaterial bank account with ABC Bank as an unpredictable test.” Doing so will eliminate the potential for a peer reviewer to say, “that’s a normal procedure.” You are overtly stating the purpose of the test is to satisfy the unpredictable test requirement.
Change your unpredictable tests annually. Otherwise, they will–over time–become predictable.
Charles Hall is a practicing CPA and Certified Fraud Examiner. For the last thirty years, he has primarily audited governments, nonprofits, and small businesses. He is the author of The Little Book of Local Government Fraud Prevention and Preparation of Financial Statements & Compilation Engagements. He frequently speaks at continuing education events. Charles is the quality control partner for McNair, McLemore, Middlebrooks & Co. where he provides daily audit and accounting assistance to over 65 CPAs. In addition, he consults with other CPA firms, assisting them with auditing and accounting issues.
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