Bookkeeping, Preparations, Compilations, and Review Engagements: Questions and Answers

This Q&A covers common questions about bookkeeping and SSARS 21 engagements

Today, we’ll answer various questions regarding bookkeeping, preparations, compilations, and review engagement.

Bookkeeping, preparations, compilations

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Q: Should I issue management letters for preparation, compilation, or review engagements?

A: While not required, it is advisable to provide management letters when performing SSARS 21 services. Why? Two reasons: (1) It’s a way to add value to the engagement, and (2) it’s a way to protect yourself from potential litigation. Clients do–sometimes–sue CPAs in these so-called “lower risk” engagements. If we see control weaknesses (while performing a compilation for example), we should communicate those–even though standards don’t require it. Then, if theft occurs in that area and you are later sued regarding the fraud, you have a defense. If you don’t issue a management letter, at least send an email regarding the issues noted and retain a copy.

Q: Why obtain an engagement letter for nonattest services such as bookkeeping and tax (standards don’t require it)?

A: In all engagements, we want to state exactly what we are doing. Why? So, it is obvious what the client has hired us to do–and what they have not hired us to do. If a client says, “I told you to do my monthly bookkeeping and to file my property tax returns,” but you have no recollection of being asked to perform the latter, you need an engagement letter that specifies monthly bookkeeping (and nothing else).

Q: Should I say–in a bookkeeping engagement letter–the service is not designed to prevent fraud?

A: We should obtain a signed engagement letter for bookkeeping services, even though not required by standards. And yes, by all means, include a statement that the bookkeeping service is not designed to detect or prevent fraud.

Q: If I note fraud while performing a bookkeeping, preparation, compilation, or review engagement, should I report it to the appropriate levels of management?

A: Standards require this communication for review engagements. I would do likewise for the other services (though not required in SSARS 21).

Q: Am I required to be independent if I perform bookkeeping and preparation services?

A: No, since both are nonattest services.

Q: If I create financial statements as a byproduct of an 1120 tax return, am I subject to AR-C 70 Preparation of Financial Statements?

A: No, you are only subject to AR-C 70 if you are engaged to prepare financial statements.

Q: If I perform bookkeeping services in a cloud-based accounting package such as QuickBooks, am I subject to AR-C 70 (SSARS 21)?

A: It depends. Yes, if you are engaged to prepare financial statements. No, if you were not engaged to prepare financial statements. Who “pushes the button” to print the financial statements has no bearing on the applicability of AR-C 70.

Q: Am I required to have a signed engagement letter for all preparation, compilation and review engagements?

A: Yes.

Q: Can I act as a controller-for-hire and perform a compilation engagement?

A: Yes, but you need to state that you are not independent in the compilation report.

Q: Can I act as the controller-for-hire and perform a review engagement?

A: No. Independence is required for review engagements.

Q: If I prepare financial statements and perform a compilation, am I performing one service (as I did under SSARS 19) or are these considered two separate services?

A: They are two separate services. The preparation is a nonattest service, and the compilation is an attest engagement. Both can be specified in one engagement letter.

Bookkeeping or Preparation of Financial Statements: Being Clear About the Intended Service

When performing bookkeeping, communicate whether financial statements are a part of the engagement

Many accountants have asked, “When am I subject to SSARS 21?” This question often arises when a CPA provides bookkeeping services using a cloud-based accounting package such as Quickbooks. Bookkeeping or preparation of financial statements–which is it? Why the confusion? Well, once the bookkeeping is complete, the CPA or the client can print the financial statements–and we know that SSARS 21 is triggered when we are engaged to prepare financial statements.

Bookkeeping or Preparation of Financial Statements

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Bookkeeping or Preparation of Financial Statements

Suppose you enter the client’s monthly transactions in QuickBooks, and you reconcile the bank statements. Now you or the client can print the financial statements. Have you unintentionally wandered into a requirement to follow SSARS 21? Let me answer this question with another question.

Has your client engaged you to prepare financial statements? If yes, then SSARS 21 is in play. If not, then compliance is not required. The AICPA says, “the accountant has only been engaged to prepare financial statements when the client has ‘hired’ the accountant to do so.”

Using QuickBooks to provide bookkeeping services does not–necessarily–mean you have been engaged to prepare financial statements. But how can you be clear? When in doubt spell it out–in an engagement letter. Use an engagement letter for all client services–even nonattest work such as bookkeeping. When you provide bookkeeping services, and the customer has not “hired” you to prepare financial statements, make it clear that you are not engaged to provide financial statements. The AICPA’s 2016/17 Audit Risk Alert–regarding Preparation services–advises that you might include this sentence when you are not engaged to prepare financial statements: This engagement does not contemplate us preparing financial statements.

More Information About Preparation Services

For more a fuller explanation regarding whether the use of QuickBooks triggers SSARS 21, click here.

For a deep dive into Preparation services, see my book on Amazon: Preparation of Financial Statements and Compilation Engagements.

SSARS 23: Parts are Effective Immediately

SSARS 23 affects compilation and review reports

SSARS 23, Omnibus Statement on Standards for Accounting and Review Services–2016, was issued in late October 2016, but parts of the standard are applicable immediately.

SSARS 23 Changes Effective Now

The two key changes effective immediately are:

  1. An update of compilation and review report language regarding supplementary information
  2. You must now report departures from the applicable financial reporting framework in the compilation report
SSARS 23

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1. Update of Compilation and Review Report Language for Supplementary Information

The compilation and review report language regarding supplementary information changed with the issuance of SSARS 23.

Compilation Report Supplementary Information Language

The compilation report language regarding supplementary language is as follows:

Compilation Report Language for Supplementary Information Subject to Compilation Procedures

The accompanying [identify the supplementary information] is presented for purposes of additional analysis and is not a required part of the basic financial statements. Such information is the responsibility of management. The supplementary information was subject to our compilation engagement. We have not audited or reviewed the supplementary information and do not express an opinion, a conclusion, nor provide any assurance on such information.

Compilation Report Language for Supplementary Information Not Subject to Compilation Procedures

The accompanying [identify the supplementary information] is presented for purposes of additional analysis and is not a required part of the basic financial statements. Such information is the responsibility of management. The supplementary information was not subject to our compilation engagement. We do not express an opinion, a conclusion, nor provide any assurance on such information.

Review Report Supplementary Information Language

The review report language regarding supplementary language is as follows:

Review Report Language for Supplementary Information Subject to Review Procedures

Other Matter

The accompanying [identify the supplementary information] is presented for purposes of additional analysis and is not a required part of the basic financial statements. Such information is the responsibility of management and was derived from, and relates directly to, the underlying accounting and other records used to prepare the financial statements. The supplementary information has been subjected to the review procedures applied in our review of the basic financial statements. We are not aware of any material modifications that should be made to the supplementary information. We have not audited the supplementary information and do not express an opinion on such information.

Review Report Language for Supplementary Information Not Subject to Review Procedures

Other Matter

The accompanying [identify the supplementary information] is presented for purposes of additional analysis and is not a required part of the basic financial statements. Such information is the responsibility of management. We have not audited or reviewed such information and we do not express an opinion, a conclusion, nor provide any assurance on it.

2. Disclose Departures in the Compilation Report

SSARS 21 allowed CPAs to report departures from the applicable financial reporting framework either in the notes or in the compilation report. SSARS 23 requires that such departures be reported “in a separate paragraph” in the compilation report. In other words, you can no longer just disclose the departure in the notes to the financial statements.

Impact on Peer Reviews

So, what happens if a firm fails to make the revisions to the supplementary information paragraphs as discussed in 1. above?

The February 2017 AICPA Reviewer Alert (the newsletter that peer reviewers receive) says the following:

If a firm failed to update the language in the additional paragraph for review and compilation reports, it would generally not result in a deficiency or significant deficiency. The changes made by SSARS No. 23 in relation to supplementary information are considered further clarifications to existing requirements. Therefore, the following guidance is applicable; PRP Section 6200 Appendix E Areas of Common Noncompliance With Applicable Professional Standards;

List of Matters and Findings That Generally Would Not Result in a Deficiency
Reports
• Omission of phrases or use of phrases not in conformity with the appropriate standards for the report issued

Failing to make the revisions will not result in a deficiency or a significant deficiency in a peer review.

SSARS 21 Book

To see my SSARS 21 book on Amazon, click here.

 

Are You Up to Speed on the New Pro Forma Information Standard?

Providing "What if?" information to clients can be helpful

The Accounting and Review Services Committee (ARSC) issued SSARS 22 Compilation of Pro Forma Financial Information. You may remember that ARSC did not address pro forma information in SSARS 21. SSARS 22 clarifies AR 120 Compilation of Pro Forma Information and codifies it as AR-C 120.

Pro Forma Information

So what is pro forma information? It is a presentation that shows what the significant effects on historical financial information might have been had a consummated or proposed transaction (or event) occurred at an earlier date.

Pro Forma Information

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To understand SSARS 22, let’s answer a few questions.

Examples of Pro Forma Information

Examples of pro forma information include presenting financial statements for the following:

  • Business combinations
  • The selling of a significant part of a business
  • A change in the capitalization of an entity

Again we are providing financial information as though the transaction or event has–already–occurred.

Required Disclosures

In pro forma financial information, what should be disclosed?

  • A description of the transaction (or event) that is reflected in the presentation
  • The date on which the transaction (or event) is assumed to occur
  • The financial reporting framework
  • The source of the financial information
  • The significant assumptions used
  • Any significant uncertainties about those assumptions
  • A statement that the pro forma information should be read in conjunction with the related historical information and that the pro forma information is not necessarily indicative of the results that would have been attained had the transaction (or event) actually taken place

Independence

Must the accountant consider his or her independence? Yes, since this is a compilation engagement. (Note: The preparation of the pro forma information is considered a nonattest service.)

Acceptance and Continuance

Should the accountant perform acceptance and continuance procedures? Yes.

Engagement Letter

Is an engagement letter required? Yes, and it must be signed by the accountant’s firm and management or those charged with governance.

Compilation Procedures

What compilation procedures should be performed?

  • Read the pro forma financial information to determine if it is appropriate in form and free from obvious material misstatement
  • Obtain an understanding of the underlying transaction or event (that the pro forma information is based upon)
  • Determine that management includes:
    • Complete financial statements for the most recent year (or from the preceding year if financial statements for the most recent year are not yet available) or make such financial statements readily available (e.g., post on a public website)
    • If pro forma financial information is presented for an interim period, either historical interim financial information for that period (which may be in condensed form) or make such interim information readily available
    • For business combinations, the relevant financial information for the significant parts of the combined entity
  • Determine that the information in the preceding bullet has been subjected to a compilation, review or an audit
  • Determine that the compilation, review or audit report on the historical information is included in any document containing the  pro forma financial information (or made readily available such as on a public website)
  • Determine whether the significant assumptions and uncertainties are disclosed
  • Determine whether the source of the historical financial information on which the pro forma information is based is appropriately identified

Pro Forma in Conjunction with Other Services

Can the pro forma engagement be performed in conjunction with a compilation, review or an audit? Yes. Alternatively, the pro forma engagement can be performed separately.

Required Documentation

What documentation is to be retained in the file?

  • Engagement letter
  • The results of procedures performed
  • Copy of the pro forma financial information
  • Copy of the accountant’s compilation report

Compilation Report Required

Is a compilation report to be issued? Yes. (See sample report below.)

Is the accountant offering any assurance regarding the pro forma information? No.

Can the pro forma compilation report be added to the accountant’s report on historical financial statements? Yes. Alternatively, the pro forma compilation report can be presented separately.

Effective Date of SSARS 22

What’s the effective date of SSARS 22? The standard is effective for compilation reports on pro forma financial information dated on or after May 1, 2017.

Potential New Service for Your Clients

If you are not already providing pro forma information to clients, consider suggesting this service when appropriate. Clients may find pro forma information helpful in evaluating the potential sale of stock, the borrowing of funds for a project, or the sale of a part of the business.

Sample SSARS 22 Compilation Report

Exhibit B of SSARS 22 provides the following sample compilation report on pro forma financial information:

Management is responsible for the accompanying pro forma condensed balance sheet of XYZ Company as of December 31, 20X1, and the related pro forma condensed statement of income for the year then ended (pro forma financial information), based on the criteria in Note 1. The historical condensed financial statements are derived from the financial statements of XYZ Company, on which I (we) performed a compilation engagement, and of ABC Company, on which other accountants performed a compilation engagement. The pro forma adjustments are based on management’s assumptions described in Note 1. (We) have performed a compilation engagement in accordance with Statements on Standards for Accounting and Review Services promulgated by the Accounting and Review Services Committee of the AICPA. I (we) did not examine or review the pro forma financial information nor was (were) I (we) required to perform any procedures to verify the accuracy or completeness of the information provided by management. Accordingly, I (we) do not express an opinion, a conclusion, nor provide any form of assurance on the pro forma financial information.

The objective of this pro forma financial information is to show what the significant effects on the historical financial information might have been had the underlying transaction (or event) occurred at an earlier date. However, the pro forma condensed financial statements are not necessarily indicative of the results of operations or related effects on financial position that would have been attained had the above mentioned transaction (or event) actually occurred at such earlier date.

[Additional paragraph(s) may be added to emphasize certain matters relating to the compilation engagement or the subject matter.]

[Signature of accounting firm or accountant, as appropriate] [Accountant’s city and state]
[Date of the accountant’s report]

Which Special Purpose Reporting Framework Should I Use?

Choosing between cash, modified cash, and tax basis accounting

You’ve been contacted by your client to prepare their financial statements and issue a compilation report. At first, you think, “I’ll create the financials in accordance with GAAP,” but then you remember there are special purpose reporting framework options. Maybe the cash basis or tax basis is better for your client.

Special Purpose Reporting Frameworks

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Special Purpose Reporting Frameworks

What is a special purpose reporting framework?  It is a reporting framework other than generally accepted accounting principles (GAAP) that is one of the following:

  • Cash basis
  • Tax basis
  • Regulatory basis
  • Contractual basis
  • Other basis (as long as the basis uses reasonable, logical criteria that are applied to all material items)

Let’s begin our exploration of special purpose reporting frameworks by examining the simplest basis: the cash basis.

Cash Basis

While a pure cash basis financial statement is the easiest to create, it may be too simple. After all, you only create one financial statement. For example:

ABC Company

Statement of Cash Receipts and Disbursements

For the Year Ended December 31, 2016

Receipts

Rent                                                                                                                      $XX

Sales                                                                                                                        XX

Other                                                                                                                       XX

Total Receipts                                                                                                       XX

Disbursements

Supplies                                                                                                                  XX

Wages                                                                                                                      XX

Utilities                                                                                                                   XX

Total Disbursements                                                                                            XX

Increase in Cash                                                                                           XX

Beginning Cash                                                                                                 XX

Ending Cash                                                                                                     $XX

Notice there are no accruals and no balance sheet. When the company spends and receives cash, the transaction is recorded; otherwise, there is no entry. So who might benefit from the pure cash basis? The cash basis might be useful for a small nonprofit, a trust, or a student activity fund.

If the cash basis is not an appropriate solution, then consider another special purpose reporting framework: the modified cash basis.

Modified Cash Basis

Using the modified cash basis, you can present a balance sheet, an income statement, and a cash flow statement. It is, however, permissible to create just one statement–such as the income statement–and issue a compilation report. If you present a balance sheet and an income statement, the cash flow statement is optional.

What Modifications to Cash are Permissible?

SSARS 21 defines cash basis as a basis of accounting that the entity uses to record cash receipts and disbursements and modifications of the cash basis having substantial support (for example, recording depreciation on fixed assets). So we see that modifications to the cash basis are permissible under SSARS 21.

A modification to the cash basis is considered to have substantial support if it is equivalent to GAAP and is not illogical. What is an example of an illogical modification? The balance sheet includes accrued receivables but no payables are recorded. If such a presentation were allowed, the company’s financial health would appear stronger than it is.

Difference in Cash Basis and Modified Cash Basis

So how does the modified cash basis differ from the cash basis? Using the modified cash basis, you can record an item on a balance sheet when the transaction involves cash. So if a company loans cash to an outside party, a loan receivable could be recorded on the balance sheet. (If the cash basis is used, the loan is reflected as a disbursement.) The accounting entry for the loan is as follows:

                                                  Dr.      Cr.

Loans Receivable                  XX

Cash                                                    XX

Since cash is a part of the entry, it is okay to record the loan on the balance sheet using the modified cash basis.

But if a company sells inventory on credit it would not record the transaction–no cash is involved in the transaction. The same is true of payables–they are not booked since cash is not a part of the entry. To accrue a payable (amount owed to vendors), the entry is as follows:

                                                 Dr.     Cr.

Supplies Expense                 XX

Accounts Payable                          XX

We do not record the payables on the balance sheet. Why? Because cash is not a part of the entry.

So when a company pays cash for inventory or plant, property, and equipment, then those assets can be reflected on the balance sheet. (Also, plant, property, and equipment can be depreciated.) The same is true when the company obtains a loan–cash is received, so the debt can be recorded on the balance sheet.

Transactions that Should Not be Recorded

What are some examples of transactions that should not be recorded using the modified cash basis? Here are a few:

  • Purchase of assets with a capital lease
  • The receipt of donated equipment
  • The receipt of donated investments
  • Receivables when cash is not loaned (e.g. accounts receivable)
  • Payables when cash is not received (e.g., accounts payable)
  • Accrued interest

Ill-Defined Recognition Criteria

The modifications of the cash basis are not defined in auditing or SSARS guidance. In other words, there is judgment in selecting the modifications. Does this make you uneasy? Is the modified cash basis too ill-defined for you? If yes, you may find the tax basis of accounting a better option.

Tax Basis

In using the tax-basis, the transaction recognition criteria is simpler than that of the modified cash basis of accounting. Just ask, “Is this transaction recognized on the tax return?”

What financial statements can be presented using the tax basis? You can present just one financial statement (e.g., balance sheet), or you can present the balance sheet (referred to as the statement of assets, liabilities, and equity-tax basis) and the income statement–with or without the cash flow statement.

What entities can use the tax basis of accounting? Any entity that files a return with the IRS–either an income tax return or an information return. So a nonprofit that pays no taxes can use the tax basis, but a government that files no return could not. Those entities that can use the income tax basis include:

  • C corporation
  • S corporation
  • LLC
  • Partnerships
  • Nonprofit corporations
  • Sole proprietors

As we have seen in an earlier post, if you prepare a tax return for a client, then tax basis is the most efficient way to deliver financials.

Advantages of Special Purpose Frameworks

Special purpose reporting frameworks provide certain advantages including:

  • If the tax basis is used and you prepare the tax return, there is no conversion to GAAP
  • No cash flow statement is required
  • Special purpose frameworks are often easier to prepare (e.g., no accruals for the cash basis)

Reference Books

Are there reference guides for special purpose reporting frameworks? Yes. The two I use are:

Cash, Tax and Other Bases of Accounting — Thomson Reuters

Accounting and Financial Reporting Guidelines for Cash- and Tax-Basis Financial Statements–AICPA

While both publications provide sample financial statements, the Thomson Reuters guide has several sample statements and checklists.

I am looking forward to the 2016 NAAATS Conference. Hope to see you in Salt Lake.

Date:July 21, 2016—July 22, 2016
Event:AICPA NAAATS Conference
Public:Public

Is a Continuance Decision Necessary for Attest Engagements?

Why continuance decisions matter

Most accounting firms do a fine job of thinking about and documenting the initial client acceptance. But after the first year, the continuance decision and related documentation are sometimes forgotten or ignored. Why?

Continuance decision

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Continuance Decision

The CPA may think the continuance decision is one those “management by exception” things–only to be thought about when apparent issues arise.

However, independence threats sometimes arise subtly. For example, what if a partners’ spouse invests in an audit client? Or maybe a staff member becomes a board member of a nonprofit audit client and he doesn’t tell anyone.

Also, problems can also arise on the client-side. Have they paid last year’s audit fees? Has the client engaged in any unethical activities? Some actions may cause you to question their integrity.

The time to discover changing engagement dynamics is before the engagement letter is signed. We certainly don’t want to near the end of an audit and realize we are not independent.

Need another reason to document the continuance decision? Think about peer review.

Peer Review

AICPA peer review checklists focus on independence documentation–whether an acceptance or continuance decision is made. So, if for no other reason, we need to consider and document the continuance decision to be safe in peer review.

Nonattest Services

While you are documenting continuance, summarize the nonattest services being performed and the client personnel that will oversee and assume responsibility for those services. Potential independence issues can arise from changes in client personnel. If a key accounting person leaves the employ of your attest client, is there a replacement with sufficient skill, knowledge, and experience to assume responsibility for the financial statements (if you create them)?

Check Your Files

Now would be a good time to sample a few of your files to see if they contain requisite acceptance or continuance documentation. Such documentation is necessary for the following types of engagements:

  • Audits
  • Reviews
  • Compilations (when the report is not disclosing a lack of independence)
  • Attestation engagements including agreed-upon-procedures

Looking for Answers to Independence Questions?

If you are looking for answers to independence questions, check out the AICPA’s Plain English Guide to Independence. Click here. This is a great resource.

Is Membership in the Center for Plain English Accounting Worth the Money?

The AICPA's CPEA provides technical support to CPAs

One of my readers asked me to write a review concerning my firm’s membership in The Center for Plain English Accounting (CPEA). So here it is. (These are my thoughts and not necessarily those of my firm.)

membership in the Center for Plain English Accounting

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Why My Firm Joined the CPEA

My firm joined the CPEA about six months ago. What led to that decision? We used the AICPA hotline for several years, and the experience was positive. But as you may (or may not know), the AICPA hotline does not offer written responses. I would send the hotline an email with a technical inquiry, and the AICPA would call me–usually within 24 hours–with an answer. I would document that discussion in my engagement file. But, in the back of my mind, I always longed for a written response. Why? These were usually thorny, high-risk problems.

The CPEA provides written responses to inquiries.

What Does the CPEA Do?

Here’s an excerpt from their website:

The Center for Plain English Accounting is the AICPA’s National A&A resource center, available exclusively to members of the Private Companies Practice Section. The CPEA’s team of experts assists member firms in understanding and implementing accounting, auditing, review, compilation, and quality control standards by sharing technical advice and guidance in a straight-forward manner. CPEA professional staff provide A&A support by describing “how to do” what you “need to do” in implementing the authoritative literature.

In short, the CPEA provides information about evolving technical issues and answers to specific questions.

Cost for CPEA Membership

What’s the cost of joining the CPEA? For our firm, it is $1,495. So this is not a cheap decision. But I felt like my company received its money’s worth in the first month. We have posed several questions since joining, and we have received timely written responses — every time. For firms that don’t have a national office (and most of us don’t), this is an excellent solution.

For more information about joining the CPEA, click here.

How to Submit Questions

How do you submit your questions to the CPEA? With an online form such as the following:

image

Are there other benefits?

I often hear CPAs lament about keeping up with new standards, and I feel their pain. So how can we do so?

The CPEA provides information in the following ways:

  • Webcasts
  • Emails with summaries of new information
  • Website

Here’s a screenshot showing recent reports and alerts that the CPEA has provided:

image

Worth the Money?

For me, the cost of membership has been worth the money. If your firm desires to keep up with evolving standards, the CPEA is an excellent choice. (I have received no compensation for this recommendation.)

Episode 7 – A Comparison of Preparation and Compilation Engagements under SSARS 21

You’ve been wondering how the Preparation of Financial Statements option in SSARS 21 compares with the Compilation Engagement option in the same standard. Maybe you’ve also been wondering, “Which is the best to use?” Here’s a brief summary of how the two standards compare as well as information about how to choose between the two.