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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

83. Identifying Controls to Test. The auditor should obtain evidence about the
effectiveness of controls (either by performing tests of controls himself or herself, or by
using the work of others) (14)  for all relevant assertions related to all significant accounts
and disclosures in the financial statements. After identifying significant accounts,
relevant assertions, and significant processes, the auditor should evaluate the following
to identify the controls to be tested:
 
• Points at which errors or fraud could occur;
 
• The nature of the controls implemented by management;
 
• The significance of each control in achieving the objectives of the control
criteria and whether more than one control achieves a particular objective
or whether more than one control is necessary to achieve a particular
objective; and
 
• The risk that the controls might not be operating effectively. Factors that
affect whether the control might not be operating effectively include the
following:
 
– Whether there have been changes in the volume or nature of
transactions that might adversely affect control design or operating
effectiveness;
 
– Whether there have been changes in the design of controls;
 
– The degree to which the control relies on the effectiveness of other
controls (for example, the control environment or information
technology general controls);
 
– Whether there have been changes in key personnel who perform
the control or monitor its performance;
 
– Whether the control relies on performance by an individual or is
automated; and
 
– The complexity of the control.
 
(14) See paragraphs 108 through 126 for additional direction on using the work
of others.
 
84. The auditor should clearly link individual controls with the significant accounts
and assertions to which they relate.
 
85. The auditor should evaluate whether to test preventive controls, detective
controls, or a combination of both for individual relevant assertions related to individual
significant accounts. For instance, when performing tests of preventive and detective
controls, the auditor might conclude that a deficient preventive control could be
compensated for by an effective detective control and, therefore, not result in a
significant deficiency or material weakness.
 
For example, a monthly reconciliation control procedure, which is a detective control,
might detect an out-of-balance situation resulting from an unauthorized transaction
being initiated due to an ineffective authorization procedure, which is a preventive control.
 
When determining whether the detective control is effective, the auditor should evaluate
whether the detective control is sufficient to achieve the control objective to which the preventive control relates.
 
Note: Because effective internal control over financial reporting often includes a
combination of preventive and detective controls, the auditor ordinarily will test a
combination of both.
 
86. The auditor should apply tests of controls to those controls that are important to
achieving each control objective. It is neither necessary to test all controls nor is it
necessary to test redundant controls (that is, controls that duplicate other controls that
achieve the same objective and already have been tested), unless redundancy is itself a
control objective, as in the case of certain computer controls.
 
87. Appendix B, paragraphs B1 through B17, provide additional direction to the
auditor in determining which controls to test when a company has multiple locations or
business units. In these circumstances, the auditor should determine significant
accounts and their relevant assertions, significant processes, and major classes of
transactions based on those that are relevant and significant to the consolidated
financial statements. Having made those determinations in relation to the consolidated
financial statements, the auditor should then apply the directions in Appendix B.
Testing and Evaluating Design Effectiveness
 
88. Internal control over financial reporting is effectively designed when the controls
complied with would be expected to prevent or detect errors or fraud that could result in
material misstatements in the financial statements. The auditor should determine
whether the company has controls to meet the objectives of the control criteria by:
• Identifying the company's control objectives in each area;
 
• Identifying the controls that satisfy each objective; and
 
• Determining whether the controls, if operating properly, can effectively
prevent or detect errors or fraud that could result in material
misstatements in the financial statements.
 
89. Procedures the auditor performs to test and evaluate design effectiveness
include inquiry, observation, walkthroughs, inspection of relevant documentation, and a
specific evaluation of whether the controls are likely to prevent or detect errors or fraud
that could result in misstatements if they are operated as prescribed by appropriately
qualified persons.
 
90. The procedures that the auditor performs in evaluating management's
assessment process and obtaining an understanding of internal control over financial
reporting also provide the auditor with evidence about the design effectiveness of
internal control over financial reporting.
 
91. The procedures the auditor performs to test and evaluate design effectiveness
also might provide evidence about operating effectiveness.
 
Testing and Evaluating Operating Effectiveness
 
92. An auditor should evaluate the operating effectiveness of a control by
determining whether the control is operating as designed and whether the person
performing the control possesses the necessary authority and qualifications to perform
the control effectively.
 
93. Nature of Tests of Controls. Tests of controls over operating effectiveness
should include a mix of inquiries of appropriate personnel, inspection of relevant
documentation, observation of the company's operations, and reperformance of the
application of the control. For example, the auditor might observe the procedures for
opening the mail and processing cash receipts to test the operating effectiveness of
controls over cash receipts. Because an observation is pertinent only at the point in
time at which it is made, the auditor should supplement the observation with inquiries of
company personnel and inspection of documentation about the operation of such
controls at other times. These inquiries might be made concurrently with performing
walkthroughs.
 
94. Inquiry is a procedure that consists of seeking information, both financial and
nonfinancial, of knowledgeable persons throughout the company. Inquiry is used
extensively throughout the audit and often is complementary to performing other
procedures. Inquiries may range from formal written inquiries to informal oral inquiries.
 
95. Evaluating responses to inquiries is an integral part of the inquiry procedure.
Examples of information that inquiries might provide include the skill and competency of
those performing the control, the relative sensitivity of the control to prevent or detect
errors or fraud, and the frequency with which the control operates to prevent or detect
errors or fraud. Responses to inquiries might provide the auditor with information not
previously possessed or with corroborative evidence. Alternatively, responses might
provide information that differs significantly from other information the auditor obtains
(for example, information regarding the possibility of management override of controls).
 
In some cases, responses to inquiries provide a basis for the auditor to modify or
perform additional procedures.
 
96. Because inquiry alone does not provide sufficient evidence to support the
operating effectiveness of a control, the auditor should perform additional tests of
controls. For example, if the company implements a control activity whereby its sales
manager reviews and investigates a report of invoices with unusually high or low gross
margins, inquiry of the sales manager as to whether he or she investigates
discrepancies would be inadequate. To obtain sufficient evidence about the operating
effectiveness of the control, the auditor should corroborate the sales manager's
responses by performing other procedures, such as inspecting reports or other
documentation used in or generated by the performance of the control, and evaluate
whether appropriate actions were taken regarding discrepancies.
 
97. The nature of the control also influences the nature of the tests of controls the
auditor can perform. For example, the auditor might examine documents regarding
controls for which documentary evidence exists. However, documentary evidence
regarding some aspects of the control environment, such as management's philosophy
and operating style, might not exist.
 
In circumstances in which documentary evidence of controls or the performance of controls
does not exist and is not expected to exist, the auditor's tests of controls would consist of
inquiries of appropriate personnel and observation of company activities.
 
As another example, a signature on a voucher package to indicate that the signer approved
it does not necessarily mean that the person carefully reviewed the package before signing.
 
The package may have been signed based on only a cursory review (or without any review).
As a result, the quality of the evidence regarding the effective operation of the control might
not be sufficiently persuasive. If that is the case, the auditor should reperform the control
(for example, checking prices, extensions, and additions) as part of the test of the control.
 
In addition, the auditor might inquire of the person responsible for approving voucher packages
what he or she looks for when approving packages and how many errors have been
found within voucher packages. The auditor also might inquire of supervisors whether
they have any knowledge of errors that the person responsible for approving the
voucher packages failed to detect.

 

 

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