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Sarbanes Oxley Act - Auditing Standards

Public Company Accounting Oversight Board

Bylaws and Rules – Standards – AS2

Auditing Standard No. 2: An Audit of Internal Control Over Financial Reporting Performed in Conjunction With an Audit of Financial Statements

Materiality Considerations in an Audit of Internal Control Over Financial Reporting
 
22. The auditor should apply the concept of materiality in an audit of internal control
over financial reporting at both the financial-statement level and at the individual
account-balance level. The auditor uses materiality at the financial-statement level in
evaluating whether a deficiency, or combination of deficiencies, in controls is a
significant deficiency or a material weakness.
 
Materiality at both the financial-statement level and the individual account-balance level
is relevant to planning the audit and designing procedures.
 
Materiality at the account-balance level is necessarily lower than materiality at the
financial-statement level.
 
23. The same conceptual definition of materiality that applies to financial reporting
applies to information on internal control over financial reporting, including the relevance
of both quantitative and qualitative considerations. (6)
 
• The quantitative considerations are essentially the same as in an audit of
financial statements and relate to whether misstatements that would not
be prevented or detected by internal control over financial reporting,
individually or collectively, have a quantitatively material effect on the
financial statements.
 
• The qualitative considerations apply to evaluating materiality with respect
to the financial statements and to additional factors that relate to the
perceived needs of reasonable persons who will rely on the information.
Paragraph 6 describes some qualitative considerations.
 
(6)  AU sec. 312, Audit Risk and Materiality in Conducting an Audit, provides
additional explanation of materiality.
 
Fraud Considerations in an Audit of Internal Control Over Financial Reporting
 
24. The auditor should evaluate all controls specifically intended to address the risks
of fraud that have at least a reasonably possible likelihood of having a material effect on
the company's financial statements. These controls may be a part of any of the five
components of internal control over financial reporting, as discussed in paragraph 49.
Controls related to the prevention and detection of fraud often have a pervasive effect
on the risk of fraud. Such controls include, but are not limited to, the:
 
• Controls restraining misappropriation of company assets that could result
in a material misstatement of the financial statements;
 
• Company's risk assessment processes;
 
• Code of ethics/conduct provisions, especially those related to conflicts of
interest, related party transactions, illegal acts, and the monitoring of the
code by management and the audit committee or board;
 
• Adequacy of the internal audit activity and whether the internal audit
function reports directly to the audit committee, as well as the extent of the
audit committee's involvement and interaction with internal audit; and
 
• Adequacy of the company's procedures for handling complaints and for
accepting confidential submissions of concerns about questionable
accounting or auditing matters.
 
25. Part of management's responsibility when designing a company's internal control
over financial reporting is to design and implement programs and controls to prevent,
deter, and detect fraud. Management, along with those who have responsibility for
oversight of the financial reporting process (such as the audit committee), should set the
proper tone; create and maintain a culture of honesty and high ethical standards; and
establish appropriate controls to prevent, deter, and detect fraud. When management
and those responsible for the oversight of the financial reporting process fulfill those
responsibilities, the opportunities to commit fraud can be reduced significantly.
 
26. In an audit of internal control over financial reporting, the auditor's evaluation of
controls is interrelated with the auditor's evaluation of controls in a financial statement
audit, as required by AU sec. 316, Consideration of Fraud in a Financial Statement
Audit. Often, controls identified and evaluated by the auditor during the audit of internal
control over financial reporting also address or mitigate fraud risks, which the auditor is
required to consider in a financial statement audit.
 
If the auditor identifies deficiencies in controls designed to prevent and detect fraud during
the audit of internal control over financial reporting, the auditor should alter the nature, timing, or extent of procedures to be performed during the financial statement audit to be responsive to such deficiencies, as provided in paragraphs .44 and .45 of AU sec. 316.

 

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