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.

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

Picture from AdobeStock.com

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.