Peer Reviews: Avoiding Independence Problems

Peer reviewers are finding plenty of issues regarding independence (and documentation)

Peer reviewers continue to hammer independence and related documentation. So it is vitally important that we not only be independent but that we also properly document its presence. My prior independence post pointed out that peer review checklists require reviewers to examine your independence documentation. This short video provides tips regarding independence and staying out of the dog house.

SSARS 23 Changes Preparation and Compilation Standards

SSARS 23 amends SSARS 21 to encompass prospective information

The Accounting and Review Services Committee (ARSC) issued SSARS 23 in October 2016. Parts of the standard (e.g., that applying to supplementary information language in compilation and review reports) were effective immediately, while other parts (mainly regarding preparation and compilation of prospective information) are required as of May 1, 2017. This post tells you how SSARS 23 affects Preparation (AR-C 70) and Compilation (AR-C 80) engagements.

SSARS 23 changes preparation and compilation standards

You’ll recall that ARSC issued SSARS 21 back in October 2014. It was effective for years ending December 31, 2015. A clarified version of the compilation and review standards is included in SSARS 21. SSARS 21 also provides new guidance for the preparation of financial statements. The Standard did not address prospective financial statements. Why? The AICPA was working on clarifying the Attestation Standards (SSAE 18), the place where compiled prospective financial statement guidance was (previously) housed. With the issuance of SSARS 23, the AICPA moved this guidance from the Attestation Standards to SSARS.

The primary impact of SSARS 23 is to provide standards for the preparation and compilation of prospective financial information.

How Preparation of Financial Statements (AR-C 70) Changed

The Preparation Standard (AR-C 70) now includes guidance regarding prospective financial information. Since significant assumptions are essential to understanding prospective information, SSARS 23 requires their inclusion. The accountant should not prepare prospective financial information without including the disclosure of the summary of significant assumptions. Also, a financial projection should not be created unless it includes:

  • an identification of the hypothetical assumptions, or 
  • a description of the limitations on the usefulness of the presentation

SSARS 23 deletes the word “accordingly” from the AR-C 70 disclaimer; the change is shown below:

How Compilation Engagements (AR-C 80) Changed

AR-C 80, Compilation Engagements, now applies to compilations of prospective financial information (new with SSARS 23), pro forma financial information (see SSARS 22), and other historical information (as provided for in SSARS 21). 

SSARS 23 also clarifies that accountants must disclose known departures from the applicable financial reporting framework in the accountant’s compilation report. Prior to SSARS 23, accountants could disclose such departures in the notes without doing so in the compilation report.

Prospective Financial Information Guidance

Both AR-C 70 and AR-C 80 were amended to clarify that the AICPA Guide Prospective Financial Information provides comprehensive guidance regarding prospective financial information, including suitable criteria for the preparation and presentation of such information.

Clarification Projects Complete

The AICPA has clarified the audit standards (AU-C), the attestation standards (AT-C), and the SSARS (AR-C).

Short SSARS 23 Video

If you desire additional information about SSARS 23, check out my video:

SSARS 21 Book

If you need SSARS 21 guidance, see my book on Amazon.

Compilations: Lacking Independence in the Current or Prior Period

CPAs must disclose independence impairments in compilation reports

Do you lack independence in a compilation engagement? If yes, then here’s how to disclose the impairment in the compilation report.

An accountant can issue a compilation report even though independence is lacking. When independence is impaired, SSARS 21 requires that the CPA modify the compilation report. The cause of the impairment (e.g., you own a portion of the business) can be disclosed in the compilation report but is not required. You can–if you prefer–simply say you are not independent; this is what most CPAs do.

Lacking Independence

Lacking Independence in Current Year

The accountant’s compilation report can disclose a lack of independence as follows:

We are not independent with respect to ABC Company.

Just add this sentence separately at the bottom of the compilation report.

Lacking Independence in the Prior Year

If you were not independent in 2016 but you are independent in 2017 (and comparative statements are presented), the accountant’s report can read:

As of and for the year ended December 31, 2016, we were not independent with respect to ABC Company.

Alternatively, the report can read:

As of and for the year ended December 31, 2016, we were not independent with respect to ABC Company. We are currently independent with respect to ABC Company.

Independence in Review Engagements and Audits

CPAs must be independent to perform review engagements or audits. There are no exceptions. See the AICPA Code of Professional Conduct for guidance on independence issues. Independence rules are found in section 1.200.

Independence in Preparation of Financial Statement Engagements

CPAs can perform a Preparation of Financial Statement engagement without being independent. No independence disclosure is required since this service is a nonattest engagement. 

My SSARS 21 Book

If you are looking for SSARS 21 guidance regarding Preparation of Financial Statements and Compilation Engagements, check out my book on Amazon.

Have you ever desired to become a fraud prevention champion? In this half-day course, we will peer into real-life governmental fraud cases and see how they occurred. You will leave the class with practical fraud prevention steps for any national, state or local government. The course location is the Capital Hilton Hotel in Washington DC.

Date:August 9, 2017
Time:8:00-11:35 a.m.
Event:Charles Hall Speaking at AICPA Governmental Accounting and Auditing Update Conference
Topic:How to Become a Super Fraud-Prevention Champion
Sponsor: AICPA
Public:Public
Registration:Click here to register.

CPA Scribo Facebook Group: Join Now

If you are interested in some dialog about accounting and auditing issues, I invite you to join my new Facebook group: CPA Scribo.

Why the group? I believe this will give you a community where you can engage with other CPAs and accountants on a one-on-one basis. The communication will be more free-flowing than my blog.

So join and share a thought, a pain, a victory, a challenge, a question. I look forward to getting to know you better.

It’s a closed group, so you will need to ask to join.

The link to join is: https://www.facebook.com/groups/1260820653952216/?ref=bookmarks

How to Create New Accounting Products and Services

Here are steps to ensure the success of your new projects

This is a guest post by Harry Hall, the Project Risk Coach. Harry is a speaker, teacher, and blogger who helps leaders and project managers get results. Harry has managed projects–mainly for insurance companies–for more than 17 years. He also teaches project management courses to CPA firms. Harry lives in Macon, Georgia with his wife Sherri. He can be found on LinkedIn.

Are you wondering how to create new accounting products and services? In this post, I’ll explain how.

how to create new accounting products and services

Imagine an accounting firm (we’ll call it Premier CPAs) that has struggled in recent years. Revenue is down, and the firm has lost several top clients. To make matters worse, the firm recently received a fail report in its peer review.

The partners recently met and were brutally honest with one another. Something has to change.

Premier CPAs has a great team of auditors. However, they are failing to understand their client’s needs, and they are not changing their business model accordingly. Over time, competing CPA firms have created superior products and services.

The partners selected a team to go offsite and develop a strategic plan. The group was challenged to perform an assessment of where the firm is and where it needs to go.

The top strategies identified were to:

  • Implement a more modern auditing software solution
  • Map and re-engineer Premier CPAs’ audit processes
  • Implement a small customer service center

How to Make Your Dreams Come True

Great ideas, but how do we make them a reality? It’s easy to talk about things, but it’s another matter to plan and execute new ideas.

Well, you could do this like many lack-luster firms. Just do the projects willy-nilly. Do it as you have time. Find a few warm bodies who are not busy to do the work. Maybe assign the activities to the IT guy.

Will you get there? Maybe, but how long will it take? How much further will you fall behind your competition?

Take a different approach. Focus on your goals and strategies. Be intentional.

How to Create New Accounting Products and Services

The following steps can put you on a fast track to greater success:

  1. Define your projects. In the initiation of your projects, define them with project charters. Spell out the problems you are attacking, your goals, what you will deliver, the assumptions of the project, the constraints of the project, key stakeholders, top risks, and who will serve on the project team.
  2. Assign project sponsors. Select partners and senior management who will define and cast the vision for the projects. These leaders should have the authority to provide resources and money to complete the projects. While the project team does most of the work, the sponsors are ultimately responsible for ensuring success (and should be held accountable).
  3. Create project teams. One of the most important things you can do for your projects is to staff the teams. Carefully select individuals who have the knowledge and skills to deliver the project in a timely manner. There will likely be some opportunity cost in this equation. You may have to assign some audit personnel to perform the project work.
  4. Kick off projects. Get your project team and key stakeholders together for the project kick-off. The sponsors should share their vision for the project. The individual leading the project (i.e., project manager) should review the project charter, ensuring that everyone understands the project and their roles.
  5. Monitor progress. The project managers should periodically meet with their team members to check the status of the project and to plan their next steps. The project managers report to the sponsors, and in some firms, the sponsors report to senior management and partners. Doing so provides transparency throughout the firm’s leadership.
  6. Celebrate success. Create a robust project culture by celebrating when teams hit milestones or complete projects on time and under budget. Thank your teams.
  7. Perform benefits realization. How do we ensure that the projects produce the desired results? Measure your results at designated times (e.g., six months and twelve months after the completion of each project).

Parting Words…This Is NOT Easy

These steps may require a significant transformation in the firm’s culture. Changing what people believe, their attitudes, and their behavior is the toughest part of creating a productive project culture.

First, leadership is required, not optional. Without a firm hand, people will fall back into old bad habits. The senior leadership team of the firm must consistently communicate their expectations and lead by example. Make sure there is a high level of accountability with appropriate rewards and recognition for high performing teams.

Second, train your teams in project management. At a minimum, identify and train individuals who will serve as project managers. You may want to get a project coach to work with your firm. Many progressive firms require their project managers to get project management certifications.

Lastly, all of these actions must be performed with an eye on your firm’s strategic goals and objectives. Make sure the changes align and support your vision, mission, and goals.

Your best days are ahead!

Financial Statement References (at the Bottom of the Page)

What financial statement page references are required?

What wording is required at the bottom of financial statement pages? Is there a difference in the references in audited statements and those in compilations or reviews? What wording should be placed at the bottom of supplementary pages? Below I’ll answer these questions.

financial statement references

Picture is courtesy of Dollarphotoclub.com

Audited Financial Statements and Supplementary Information

First, let’s look at financial statement references in audit reports.

While generally accepted accounting principles do not require financial page references to the notes, it is a common practice to do so. Here are examples:

  • See notes to the financial statements.
  • The accompanying notes are an integral part of these financial statements.
  • See accompanying notes.

Accountants can also–though not required–reference specific disclosures on a financial statement page. For example, See Note 6 (next to the Inventory line on a balance sheet). It is my preference to use general references such as See accompanying notes.

Audit standards do not require financial statement page references to the audit opinion.

Supplementary pages attached to audited financial statements should not include a reference to the notes or the opinion.

Preparation, Compilation, and Review Engagements

Now, let’s discuss references in preparation, compilation, and review engagements. 

Compilation and Review Engagements

SSARS 21 does not require a reference (on financial statement pages) to the compilation or review report; however, it is permissible to do so. What do I do? I do not refer to the accountant’s report. I just put See accompanying notes at the bottom of each financial statement page.

You are not required to include a reference to the accountant’s report on the supplementary information pages. SSARS 21 does suggest that such references be included in case the financial statements or supplementary information are separated from the compilation or review report. Examples include:

  • See Accountant’s Compilation Report.
  • See Independent Accountant’s Review Report.

What do I do? I include a reference to the accountant’s report on each supplementary page.

Preparation of Financial Statement Engagements

SSARS 21 provides an option (to compilations) called the preparation of financial statements (AR-C 70), a nonattest service. AR-C 70 requires that the accountant either state on each page that “no assurance is provided” or provide a disclaimer which precedes the financial statements. AR-C 70 does not require that the financial statement pages refer to the disclaimer (if provided), but it is permissible to do so. Such a reference can read See Accountant’s Disclaimer.

If your AR-C 70 work product has supplementary information, consider including this same reference (See Accountant’s Disclaimer) on the supplementary pages.

Selected Disclosures in Preparation and Compilation Engagements

You can include one or two notes rather than all

Do you ever want to include just one disclosure in your financial statements without providing all the notes? Selected disclosures can be included in certain situations.

Do professional standards allow this? Yes. But only if you use AR-C 70 (the preparation guidance) or AR-C 80 (the compilation guidance).

selected disclosures

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Selected Disclosures in Compilations

As you probably already know, a CPA can issue compiled financial statements without disclosures as long as the compilation report discloses the omission. An example follows.

Management has elected to omit substantially all of the disclosures required by accounting principles generally accepted in the United States of America. If the omitted disclosures were included in the financial statements, they might influence the user’s conclusions about the Company’s financial position, results of operations and cash flows. Accordingly, the financial statements are not designed for those who are not informed about such matters.

If the financial statements include one or two notes, then the financial statements still omit substantially all of the disclosures, so the accountant (still) uses the wording in the preceding paragraph.

Sample Selected Disclosure

An example of a selected disclosure follows:

ABC Company

Selected Information –

Substantially All Disclosures Required by Accounting Principles

Generally Accepted in the United States of America are Not Included

December 31, 2017

Note 1. Long-Term Debt.

ABC Company borrowed $450,000 on July 15, 2017, from XYZ Bank. The rate of interest is 5%, and the loan is collateralized by equipment of the Company. Payments are $10,000 per month plus interest for two years with a balloon payment for the balance of the amount owed.

Preparation Engagements

AR-C 70 says:

The accountant may prepare financial statements that include disclosures about only a few matters in the notes to the financial statements. Such disclosures may be labeled “Selected Information—Substantially All Disclosures Required by [the applicable financial reporting framework] Are Not Included.”

So, the selected-disclosure option is available in a Preparation of Financial Statements engagement. Include the required disclaimer at the bottom of the page such as “No assurance is provided on these financial statements.” 

Other Considerations

The accountant should consider whether management’s election to include only selected disclosures causes the financial statements to be misleading (for example, by omitting the disclosures that contain negative information). If so, the accountant should request that the financial statements be revised to include the omitted disclosures.

The selected-disclosure option is not available for financial statements subject to a review engagement. Such financial statements must be full disclosure.

What About You?

Do you ever use this selected-disclosure option? Any reservations about doing so?

SSAE 18: The Clarified Attestation Standards

Effective May 1, 2017

SSAE 18 is effective on May 1, 2017, and changes the Attestation Standards.

Do you issue any attestation reports such as agreed upon procedures? If yes, then be aware of the recent changes from the Auditing Standards Board (ASB). The ASB has clarified the Attestation Standards. The ASB did the same with the audit standards a few years ago; that change resulted in the AU-C (clarity) designations for audit standards.

SSAE 18

Picture from AdobeStock.com

The re-write of the Attestation Standards culminated in the April 2016 issuance of SSAE 18.

SSAE 18 supersedes all Attestation Standards other than:

  • AT section 701, Management’s Discussion and Analysis (MD&A). AT section 701 will not be clarified because practitioners rarely perform attestation engagements to report on MD&A; it will be retained in the attestation standards in its current form. AT section 701 has been renumbered as AT-C section 395.

Also be aware that AT section 501 An Examination of an Entity’s Internal Control Over Financial Reporting That is Integrated With An Audit of Financial Statements was moved to the auditing standards as Statement on Auditing Standards (SAS) No. 130, as An Audit of Internal Control Over Financial Reporting That is Integrated With An Audit of Financial Statements.

Just as the ASB did with the audit clarity standards, a “-C” is added to the clarified Attestation Standards. So the clarified attestation standards are identified as AT-C. The clarified standards are written using ASB’s clarity conventions, including:

  • Objectives for each chapter
  • Definitions in each chapter
  • Separating requirements from application and explanatory material
  • Using various formatting techniques such as bulleted lists to enhance readability
  • When applicable, including additional considerations for governmental entities or smaller less complex entities

Attestation Levels of Service

The clarified standards provide for the following types of attestation services:

ServiceAT-C SectionReport Type
Examination205Opinion
Review210Conclusion
Agreed Upon Procedures215Findings

Sample report excerpts follow:

Examination Report on Subject Matter; Unmodified Opinion

In our opinion, the schedule of investment returns of ABC Company for the year ended December 31, 2020, is presented in accordance with the ABC criteria set forth in Note 1 in all material respects.

Review Report on Subject Matter; Unmodified Conclusion

Based on our review, we are not aware of any material modifications that should be made to the accompanying schedule of investment returns of ABC Company for the year ended December 31, 2020, in order for it to be in accordance with XYZ criteria set forth in Note 1.

Agreed-Upon Procedures Report

We obtained the accounts receivable subsidiary ledger as of June 30, 2017, from Topaz, Inc. We compared all customer account balances in the aged trial balance (exhibit B) as of June 30, 2017, to the balances shown in the accounts receivable subsidiary ledger.

We found no exceptions as a result of the procedure.

New SSAE 18 Requirements

In addition to clarifying (restructuring) the attestation standards, SSAE 18 also:

  • Separates the review engagement procedures and reporting requirements from those of examination engagements (and highlights the similarities of reviews performed under the SSAEs and those performed under Statements on Standards for Accounting and Review Services [SSARS])
  • Requires the practitioner to request a written representation letter in all attestation engagements (the pre-clarity standards only required representation letters for certain engagements)
  • Changes the existing requirements related to scope limitations, indicating that based on the practitioner’s assessment of the effect of the scope limitation, the practitioner should express a qualified opinion, disclaim an opinion, or withdraw from the engagement
  • Eliminated compilations of prospective financial information from the attestation standards (the Accounting and Review Services Committee issued SSARS 23 to cover this service)

Effective Date

The guidance in SSAE No. 18 is effective for practitioners’ reports dated on or after May 1, 2017.

For a full copy of SSAE No. 18, click here.

How to Review Financial Statements on Computer Screens

Here are suggestions to help you review financial statements

Today I give you seven steps to review financial statements on computer screens.

I recently provided you with a post titled How to Review Financial Statements Efficiently and Effectively. That article provides information about creating and reviewing financial statements, but it does not provide information about doing so on a computer screen. Many accountants prefer to review physical copies of financial statements. Others prefer to do so on their computer screens. This article is for the latter group.

reviewing financial statements

How to Review Financial Statements on Computer Screens

  1. First, open and visually scan the entire financial statement (spend two to three seconds per page) just to get a feel for the whole product. How do the parts fit together? Are the financial statements subject to the Yellow Book? Do they contain supplementary information? Are the statements comparative?
  2. Second, use a large computer screen (22 inches or more) to compare your financial statement pages. Reduce the financial statement page size by holding the control key down and scrolling back with your mouse. As you do so, you will see multiple statements on the screen, for instance: balance sheet, income statement and cash flow statement.  Now that you can see multiple statements, you can tick and tie your numbers. I use step 2. to compare the financial statement numbers. For example, I compare the net income number on the income statement to the same number on the cash flow statement. Then I use step 3. to compare the financial statements to the notes and the supplementary information.
  3. Next, use two to three computer screens to compare your financial statements with the notes and supplementary information. Open the financial statement on each screen–for instance, the balance sheet on screen 1, the notes on screen 2, and the supplementary information on screen 3. In Word, click View, New Window and another instance of the document will open. Then you can move the new instance to a second screen. Alternatively, you can use the side-by-side feature in Word to place two open documents on one screen. (To see my physical office setup, click here.)
  4. After completing your review of the notes, return to and take a second look at the balance sheet to see if the disclosures are complete. (Since you just reviewed the notes, it’s easier to compare them to the balance sheet. If, for example, you look at the balance sheet and see inventory but no disclosure for the same, you’ll more easily see the error.)
  5. Use the find feature (in Word, click the Home tab, click Find, then key in the number–or word–you are looking for) to locate words or numbers. If you want to compare the long-term debt number on the balance sheet to the notes and to supplemental information, type that number into your search dialog box and you’re immediately taken to the same number in the notes. Click next, and you will see the next instance (in the supplementary information). You can do the same with words. (Note-If you embed Excel tables in the Word document, the find feature will not locate numbers in the embedded tables.)
  6. When needed, take breaks. Never spend more than 1.5 hours reviewing statements without taking a short break. You get more done by relaxing periodically.
  7. Finally, if you are reviewing financial statements in Word, consider turning on Track Changes and key in suggested revisions. Word reflects your modifications in a distinct color–that way, others can see your suggested changes. They can also see who made the suggested corrections. Thereafter, they can accept or reject the proposed changes.

Your Suggestions

Those are my ideas. What are yours?