PCAOB Issues Alert No. 11 on Internal Control Audit Deficiencies

By Jason Bramwell
 
A staff audit practice alert issued by the Public Company Accounting Oversight Board (PCAOB) on October 24 let auditors know about a large number of audit deficiencies the PCAOB has seen in the last three years related to audits of internal control over financial reporting.
 
The PCAOB said it publishes staff audit practice alerts to highlight new, emerging, or otherwise noteworthy circumstances that may affect how auditors conduct audits under the existing requirements of board standards and relevant laws.
 
"Auditors should take note of the matters discussed in this alert in planning and performing their audits, given the importance of the controls companies use to produce their financial statements," PCAOB Chairman James Doty said in a written statement.
 
Effective internal control over financial reporting helps assure that companies produce reliable published financial statements that investors can use in making investment decisions, according to the PCAOB.
 
 
The alert specifically discusses the following topics:
  • Auditors' risk assessment and the audit of internal control.
  • Selecting controls to test.
  • Testing management review controls.
  • IT considerations, including system-generated data and reports.
  • Roll forward of control testing performed at an interim date.
  • Using the work of others.
  • Evaluating identified control deficiencies.
Auditing Standard No. 5 establishes requirements for performing and reporting on audits of internal control. The standard is designed to focus auditors on the most important matters in the audit of internal control and avoid procedures that are unnecessary to an effective audit. 
 
The PCAOB issued a report in December 2012 on observations from 2010 inspections of audits of internal control over financial reporting performed by domestic annually inspected firms. The report found that in 15 percent of the 309 integrated audit engagements inspected, firms failed to obtain sufficient audit evidence to support their opinions on the effectiveness of internal control due to one or more deficiencies.
 
Inspections in subsequent years have identified similarly high levels of deficiencies in audits of internal control at other registered firms, according to the PCAOB.
 
"It is particularly important for the engagement partner and senior engagement team members to focus on these areas and for engagement quality reviewers to keep these matters in mind when performing their engagement quality reviews," Martin Baumann, PCAOB chief auditor and director of professional standards, said in a written statement. "Auditing firms also should consider whether additional training of their auditing personnel is needed. Appropriate application of the top-down, risk-based approach pursuant to PCAOB standards can result in an effective audit of internal control while avoiding unnecessary work."
 
The PCAOB noted that audit committees of public companies for which audits of internal control are conducted may want to take note of the alert the board issued on October 24. The PCAOB recommended that audit committees and auditors discuss the level of auditing deficiencies in this area identified in their auditor's internal inspections and PCAOB inspections, request information from their auditor about potential root causes, and inquire how their auditor is responding to these matters.
 
The PCAOB also emphasized that auditors should determine whether and how to respond to these circumstances based on the specific facts presented. The statements contained in the practice alerts do not establish rules of the PCAOB and do not reflect any board determination or judgment about the conduct of any particular firm, auditor, or any other person.
 

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