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Internal Control Deficiencies: Assessment and Reporting Under SAS 112

Author/Moderator: Bharat (Bert) Merchant, MBA, CPA, Attorney with Dennis L. Parish, CPA, Contributing Editor
Publisher: AICPA
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Description

Ideal for self-study or on-site training!

SAS 112 places significant responsibilities on the auditors of non-public companies to communicate internal control deficiencies identified in an audit. SAS 112, combined with the requirements in the recently effective risk assessment standards, will likely increase the quantity and variety of control deficiencies required to be communicated to management and those charged with governance – not just in the initial year of discovery, but in each subsequent year until the deficiency is remediated.

This course focuses on compliance with the standard’s requirement by examining each stage of the decision making framework using numerous illustrations and practice exercises. The course also applies to managers of non-public companies to enable them to decide whether a control deficiency exists and how to correct it.

Objectives: 
  • Evaluate the severity of control deficiencies identified in an audit and communicate them to management and those charged with governance in accordance with SAS 112

Prerequisite:Basic understanding of accounting and auditing principles

View the video clip

In this video, Brahat (Bert) Merchant, MBA, CPA, Attorney, a New Jersey-based consultant and AICPA 2006 Outstanding Discussion Leader, discusses SAS No. 112 with William I. Eskin, CPA, President at WIE, Inc. in Baltimore, Maryland and AICPA 2005 Outstanding Discussion Leader, and Elizabeth S. Gantnier, CPA, Director of Quality Control at Stegman & Company in Baltimore, Maryland and AICPA 2006 Outstanding Discussion Leader.

*(149-min. video) The DVD disk contains the video presentation and a viewable copy of the Manual.
**The Additional Manual is for group study training only. Unlike other formats, it has no exam answer sheet and cannot be used to earn self-study credit.

Table of Contents

  • Overview
    • Course Objectives
    • Background of SAS 112
      • Purpose
      • Exposure Draft
      • Relation to AS No. 2
    • Summary of SAS 112
      • Key Requirements
      • Effective Date
      • Application
      • Effects on Audits
    • Comparison of SAS 112 and SAS 60
      • Points of Comparison
    • About This Course
      • Contents
      • Conventions
  • Chapter 1: The Context for SAS 112
    • Learning Objectivess
    • Introduction
    • Changes in Definition of Internal Control over Financial Reporting
      • Evolution of the Internal Control Definition
      • SAS 109 Changes
      • SAS 55 Definition of Internal Control
      • SAS 109 Definition of Internal Control
    • Consideration of Internal Control in Financial Statement Audits
      • Overview
      • Audit Consideration of IC under SAS 55
      • Audit Consideration of IC under SAS 109 and SAS 110
    • Interaction of Effective Dates
      • Risk Assessment SASs
      • SAS 112
      • Interaction
    • Summary
  • Chapter 2: SAS 112: Concepts and Definitions
    • Learning Objectives
    • Introduction
    • What Are Control Deficiencies?
      • Purpose
      • Definition
      • Does Not Allow
      • Management or Employees
      • Normal Course of Performing Assigned Functions
      • Timely Basis
    • What Are the Types of Control Deficiencies?
      • Purpose
      • Deficiency in Design
      • Importance of Recognizing Deficiencies in Design
      • Deficiency in Operation
      • Importance of Recognizing Deficiencies in Operation
      • Examples
      • Practice
      • Suggested Solutions
    • How to Identify Control Deficiencies
      • Relation to the Audit
      • Audit Activities Likely to Identify Control Deficiencies
      • Where in the Accounting System Control Deficiencies May be Identified
      • The Five Interrelated Components of Internal Control
      • Financial Statement Level
      • Examples
    • What are Relevant Assertions?
      • Relevant Assertions
      • Examples
      • Types of Assertions
      • Identifying Relevant Assertions
    • What are Significant Risks?
      • Significant Risks
      • Example
      • Identification
      • Potential Significant Risks from Nonroutine Transactions
      • Potential Significant Risks from Judgmental Matters
      • Internal Controls for Significant Risks
      • Example
    • What Are Risks for Which Substantive Procedures Alone Do Not Provide Sufficient Appropriate Audit
      Evidence?
      • Purpose
      • Examples
      • Identification
    • Practice: Identifying Control Deficiencies
      • Suggested Solutions
    • Summary
  • Chapter 3: Evaluating Deficiencies
    • Learning Objectives
    • A Framework for Complying with SAS 112
      • Other Resources
    • What Is the Likelihood of a Potential Misstatement?
      • Purpose
      • Definition
      • SAS 112’s Two Ranges of Likelihood
      • The Threshold between Remote and More than Remote
      • Illustration
    • How to Assess the Likelihood of a Potential Misstatement
      • Factors to Consider
      • “Potential” Over What Time Period?
    • Practice: Assessing Likelihood of Deficiency
      • Suggested Solutions
    • What Is the Magnitude of a Potential Misstatement?
      • Purpose
      • Definition
      • Three Ranges of Magnitude
      • Illustration
      • Components
    • What is Materiality?
      • Definition
      • Observation
    • What Is the Magnitude of “Material” Potential Misstatements at the Financial Statement Level?
      • Quantitative Factors
      • Qualitative Factors to Consider
      • Illustration
    • What Is the Magnitude of “Material” Misstatements for Particular Items?
      • Definition
      • Considerations in Determining Materiality for Particular Items
      • Examples
    • What Is the Magnitude of “Inconsequential” Misstatements?
      • Definition
      • The Range of “Inconsequential,” Before Qualitative Factors
      • Qualitative Factors to Consider
      • Illustration
    • What Is the Magnitude of “More Than Inconsequential”?
      • More than Inconsequential
      • The Range of “More than Inconsequential,” Before Qualitative Factors
      • Illustration
      • Qualitative Factors to Consider
    • What Are the Qualitative Factors to Consider?
      • Purpose
      • List of Factors
    • How to Assess the Magnitude of a Potential Misstatement
      • Basic Approach
      • Other Considerations
    • Practice: Assessing Likelihood and Magnitude of Potential Misstatements
      • Situation
      • Questions
      • Suggested Solution
    • What Are Revisions to the Magnitude of “Material”?
      • Purpose
      • The Problem
      • The Solution
    • Practice: Revising the Materiality Threshold
      • Suggested Solution
    • What Is the Severity of a Deficiency?
      • Purpose
      • Definitions
      • Three Categories
      • Illustration
      • Relations between a Deficiency of Control’s Severity, Likelihood, and Magnitude
    • How to Categorize Deficiencies by Severity
      • Criteria for Material Weakness
      • Criteria for Significant Deficiency
      • Example
    • Practice: Categorizing Deficiencies by Severity
      • Suggested Solution
    • What Deficiencies Are Presumed to be Significant?
      • Purpose
    • Presumed Significant Deficiencies in Specified Areas
      • Description
    • What Deficiencies Are Strong Indicators of Material Weakness?
      • List
    • What Are Compensating Controls?
      • Purpose
      • Definition
      • Criteria for Consideration of the Compensating Control
      • Example
    • What Is the Prudent Official Test?
      • Description
      • Officials
      • The Wall Street Journal Test
    • What Are Combined Deficiencies?
      • Purpose
      • Definition
    • Practice: Combination of Several Deficiencies
      • Situation
      • Suggested Solution
    • FAQ: Does Assessing the Control Risk as High Trigger a Deficiency to Communicate?
      • Background
      • SAS 112 Requirements
    • Framework Stages Requiring a High Degree of Judgment
    • Practice: Assessing Control Deficiencies
      • Lack of Segregation of Duties
      • Lack of Client Expertise in Financial Accounting and Reporting
      • Inventory-Related Control Deficiencies
      • Failure to Review Modifications of Standard Sales Contracts to Evaluate Their Effect on the Timing
        and Amount of Revenue Recognition
      • Frauds Involving Cash
      • Control Testing Exceptions
      • Lack of a Formal Process for Changes in Application Controls
    • Summary
  • Chapter 4: Communicating Deficiencies
    • Learning Objectives
    • Introduction
    • Who Is the Required Addressee of a SAS 112 Communication?
      • Importance
      • Definitions
    • How to Identify the Addressee in Governance
      • Importance
      • Selecting the Appropriate Person among Those Charged with Governance
      • Communication with a Governance Subgroup
    • How to Communicate with Management
      • Communication with Management
      • When All of Those Charged with Governance Are in Management
    • What Should Be the Date of the Communication?
      • Standard
      • Report Release Date
      • Interim Communications
      • Practical Matters
    • What Are the Contents of the SAS 112 Communication?
      • Requirements
      • Prior Year Matters Not Communicated in Writing
      • Prior Year matters Not Remedied Due to Cost Benefit Decisions
      • Illustrative Communication Containing a Significant Deficiency or Material Weakness
      • Need for Planning
      • Option to Include Additional Language in the Communication
      • Language Describing Inherent Limitations of Controls
      • Language Explaining Management Override of Controls
      • Language Describing Auditor’s Consideration of Internal Control
      • Determining Whether Additional Language Should Be Used
    • Communication for Submission to Governmental Authorities
      • Applicability
      • Requisite Conditions
      • Practice Note
      • Illustrative Communication for Submission to Governmental Authorities
    • Prohibition against Issuing a “No Significant Deficiency” Communication
    • Management’s Written Response to Auditor’s SAS 112 Communication
      • Requirement
      • Desirability of the Management’s Written Communication
      • Practice Note
      • Need for Planning
    • What Other Communications Regarding Internal Control Matters Are Available?
    • Summary
  • Chapter 5: Practice Issues
    • Learning Objectives
    • Accounting Services and Deficiencies in Controls over Financial Reporting
      • Overview
      • Practice Exercise
      • Suggested Solution
      • Analysis
      • Responses to Consider
    • The Need for Planning and Communication with the Client
    • SAS 112’s Effect on the Audit
      • The Challenge
      • Areas Demanding a High Degree of Judgment
      • Other Challenges
      • Challenges and Opportunities for Practitioners
      • Changing the Client’s Perception
      • Changing Your Own Perception
      • Opportunities and Cautions
    • Summary
  • Chapter 6: Ethics Focus: Accounting and Auditing
    • Ethics Overview
    • Recent Developments
    • Spotlight on Independence
    • Key Ethical Dilemmas
    • Addressing Ethical Dilemmas
    • Available Resources
  • Chapter 7: Latest Developments
  • Appendix A - SAS 112
  • Appendix B - Commentary on Lists of Strong Indicators and Presumed Deficiencies
    • Deficiencies in Specified Areas that are Presumed to Ordinarily be at Least Significant Deficiencies
      • Controls over Selection and Application of Accounting Principles
      • Antifraud Programs and Controls
      • Controls over Non-Routine and Nonsystematic Transactions
      • Controls over the Period-End Financial Reporting Process
    • Indicators of Deficiencies that Should Be Regarded at Least as Significant Deficiencies
      • Ineffective Oversight of the Entity's Financial Reporting and Internal Control by Those Charged With
        Governance
      • Restatement of Previously Issued Financial Statements to Reflect the Correction of a Material
        Misstatement
      • Auditor Finds a Material Misstatement
      • Ineffective Internal Audit or Risk Assessment Functions
      • Ineffective Regulatory Compliance Function
      • Fraud by Senior Management
      • Failure of Management to Assess and/or Remediate Known Significant Deficiencies
      • An Ineffective Control Environment

Excerpts

Overview

Course Objectives

During the course, you will

  • Familiarize yourself with the provisions of Statement on Auditing Standards (SAS) 112, Communicating Internal Control Related Matters Identified in an Audit.
  • Identify primary changes from the previous auditing standard SAS 60.
  • Learn to apply the concepts in SAS 112 through numerous illustrations and exercises.
  • Be exposed to practical problems and potential solutions.

Background of SAS 112

Purpose

As to the purpose of issuing a new standard to replace SAS 60, the May 2005, exposure draft of SAS 112 indicates:

"This exposure draft is being issued to enhance the auditor's ability to identify and communicate to management and those charged with governance significant deficiencies and material weaknesses in internal control identified in a financial statement audit. The ASB believes that the proposed guidance will strengthen the quality of auditor communications concerning internal control matters noted in a financial statement audit."

Exposure Draft

In March 2003, the Auditing Standards Board (ASB) issued an exposure draft on the subject matter. After reviewing the comments, the ASB decided in September 2003 that additional changes to the exposure draft were needed. Some of the changes needed were to conform certain definitions and guidance with those in PCAOB AS No. 2, An Audit of Internal Control over Financial Reporting Performed in Conjunction with an Audit of Financial Statements. As a result, in December 2004, the ASB decided to re-expose the draft with some changes. The revised exposure draft was issued in September 2005. SAS 112 was unanimously adopted by all 19 members of the ASB and was issued in May 2006. It is effective for audits of financial statements for periods ending on or after December 15, 2006.

Relation to AS No. 2

The importance of these events lies in the fact that the issuance of SAS 112 is not a "knee jerk" reaction to the issuance of PCAOB AS NO. 2, as the first exposure draft was issued before the PCAOB AS No. 2 was issued.

Summary of SAS 112

Key Requirements

SAS 112, Communicating Internal Control Related Matters Identified in an Audit, supercedes SAS No. 60 and requires that whenever an audit opinion is issued or disclaimed, within sixty days of the audit report release date, written auditor communication be given to management and those charged with governance describing significant deficiencies and material weaknesses in internal control over financial reporting that were identified in course of the current audit (as well as those communicated in prior audits and still not remediated) and evaluated using the guidance and definitions in SAS 112 (which contains certain guidance and definitions found in PCAOB Auditing Standard 2).

Effective Date

SAS 112 is effective for the audit of financial statements for periods ending on or after December 15, 2006.

Application

SAS 112 applies to the audit of all non-issuers companies. Such companies range in size and complexity from small owner-operated entities to large multi-national entities. They also range from profit-motivated entities to not-for-profit entities. The divergence in entities poses a challenge to an auditor in applying SAS 112 because these entities vary as to the effectiveness and sophistication of their internal controls.

Effects on Audits

SAS 112 provides definitions of the kinds of control deficiencies that must be communicated, optional items that may be communicated, and illustrative communications. However, an auditor will need to understand the entity and its environment, analyze the facts and circumstances surrounding the control deficiency, and apply sound judgment in determining the items that must be communicated.

The SAS 112 requirement that the communication relating to internal control deficiencies be in writing may pose particular problems in audits of smaller entities. Since such entities may not have as elaborate internal control features as some larger companies do, the auditors of smaller entities are likely to identify and communicate significant deficiencies and material weaknesses. This may create unnecessary conflict between the auditor and the client. The prevention or resolution of such conflict will require better communication between the auditor and the client. This course includes tips and hints to that end.

Because SAS 112 may have a significant impact on auditors of smaller entities, many of the illustrations and exercises in this course are written as applicable to be smaller entities, including owner-operated entities.

Auditors of small entities should recognize that SAS 112 together with the requirements of the risk assessment standards (SAS 104-111) to have a significant impact on their work.1 These requirements are likely to cause an auditor to focus closely on more internal control, which may reveal control deficiencies that require communication under SAS 112.

Comparison of SAS 112 and SAS 60

Points of Comparison

Exhibit 0-1 shows the main points of comparison between SAS 112 and SAS 60.

Exhibit 0-1
A Comparison of Major SAS 112 Provisions with SAS 60

Point of Comparison SAS 112 SAS 60
What must be reported "Significant deficiencies" and "material weaknesses" "Reportable Conditions," matters coming to the auditor's attention that, in his or her judgment, should be communicated to the audit committee because they represent significant deficiencies in the design or operation of internal control.
Guidance for determining what is to be reported More detailed guidance in the Statement and examples in the Appendix as to what must be and may be reported The guidance is less detailed and is in an Appendix.
Addressee Management and "those charged with governance" Management, audit committee, or others within the organization.
How to communicate Must be in writing Verbally or in writing
When to communicate Within 60 days of "report release date" (see SAS 103) No comparable requirement
Reporting format Elaborate reporting that requires explanations of a "significant deficiency" and "material weakness". Also requires a disclaimer of opinion on internal controls No comparable requirements

 

About This Course

Contents

The material is divided in five chapters

  1. The Context for SAS 112: The Risk Assessment Standards
  2. SAS 112's Key Concepts and Definitions
  3. Evaluating Control Deficiencies under SAS 112
  4. SAS 112 Communication
  5. Practice Issues

The course Appendices includes SAS 112, background explanations of major control deficiencies, and cases illustrating the evaluation of deficiencies.

Illustrations and exercises are also included to reinforce or test the participant's understanding of this material.

Conventions

All quotations from authoritative sources are inset.

The following acronyms are used throughout the manual. They are presented below for convenient reference although they are also explained each time they are first used in the chapter.

  • AICPA - American Institute of Certified Public Accountants
  • AS - Auditing Standard issued by the PCAOB
  • ASB - Auditing Standards Board
  • FASB - Financial Accounting Standards Board
  • FDICIA - Federal Deposit Insurance Corporation Improvement Act
  • PCAOB - Public Company Accounting Oversight Board
  • SAS - Statement on Auditing Standards
  • SOX - Sarbanes-Oxley Act
  • SSAE - Statement on Standards for Attestation Engagements

 

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