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Sarbanes Oxley Act - Auditing Standards

Public Company Accounting Oversight Board

Bylaws and Rules – Standards – AS3

June 9, 2004
AUDITING AND RELATED PROFESSIONAL PRACTICE STANDARDS
Auditing Standard No. 3 – Audit Documentation
 
Introduction
 
1. This standard establishes general requirements for documentation the auditor
should prepare and retain in connection with engagements conducted pursuant to the
standards of the Public Company Accounting Oversight Board ("PCAOB"). Such
engagements include an audit of financial statements, an audit of internal control over
financial reporting, and a review of interim financial information. This standard does not
replace specific documentation requirements of other standards of the PCAOB.
Objectives of Audit Documentation
 
2. Audit documentation is the written record of the basis for the auditor's
conclusions that provides the support for the auditor's representations, whether those
representations are contained in the auditor's report or otherwise. Audit documentation
also facilitates the planning, performance, and supervision of the engagement, and is
the basis for the review of the quality of the work because it provides the reviewer with
written documentation of the evidence supporting the auditor's significant conclusions.
Among other things, audit documentation includes records of the planning and
performance of the work, the procedures performed, evidence obtained, and
conclusions reached by the auditor. Audit documentation also may be referred to as
work papers or working papers.
 
Note: An auditor's representations to a company's board of directors or audit
committee, stockholders, investors, or other interested parties are usually
included in the auditor's report accompanying the financial statements of the
company.
 
The auditor also might make oral representations to the company or
others, either on a voluntary basis or if necessary to comply with professional
standards, including in connection with an engagement for which an auditor's
report is not issued. For example, although an auditor might not issue a report in
connection with an engagement to review interim financial information, he or she
ordinarily would make oral representations about the results of the review.
 
3. Audit documentation is reviewed by members of the engagement team
performing the work and might be reviewed by others. Reviewers might include, for
example:
 
a. Auditors who are new to an engagement and review the prior year's
documentation to understand the work performed as an aid in planning
and performing the current engagement.
 
b. Supervisory personnel who review documentation prepared by assistants
on the engagement.
 
c. Engagement supervisors and engagement quality reviewers who review
documentation to understand how the engagement team reached
significant conclusions and whether there is adequate evidential support
for those conclusions.
 
d. A successor auditor who reviews a predecessor auditor's audit
documentation.
 
e. Internal and external inspection teams that review documentation to
assess audit quality and compliance with auditing and related professional
practice standards; applicable laws, rules, and regulations; and the
auditor's own quality control policies.
 
f. Others, including advisors engaged by the audit committee or
representatives of a party to an acquisition.
 
Audit Documentation Requirement
 
4. The auditor must prepare audit documentation in connection with each
engagement conducted pursuant to the standards of the PCAOB. Audit documentation
should be prepared in sufficient detail to provide a clear understanding of its purpose,
source, and the conclusions reached. Also, the documentation should be appropriately
organized to provide a clear link to the significant findings or issues.1/ Examples of audit
documentation include memoranda, confirmations, correspondence, schedules, audit
programs, and letters of representation. Audit documentation may be in the form of
paper, electronic files, or other media.
 
1/ See paragraph 12 of this standard for a description of significant findings
or issues.
 
5. Because audit documentation is the written record that provides the support for
the representations in the auditor's report, it should:
 
a. Demonstrate that the engagement complied with the standards of the
PCAOB,
 
b. Support the basis for the auditor's conclusions concerning every relevant
financial statement assertion, and
 
c. Demonstrate that the underlying accounting records agreed or reconciled
with the financial statements.
 
6. The auditor must document the procedures performed, evidence obtained, and
conclusions reached with respect to relevant financial statement assertions.2/ Audit
documentation must clearly demonstrate that the work was in fact performed. This
documentation requirement applies to the work of all those who participate in the
engagement as well as to the work of specialists the auditor uses as evidential matter in
evaluating relevant financial statement assertions. Audit documentation must contain
sufficient information to enable an experienced auditor, having no previous connection
with the engagement:
 
a. To understand the nature, timing, extent, and results of the procedures
performed, evidence obtained, and conclusions reached, and
 
b. To determine who performed the work and the date such work was
completed as well as the person who reviewed the work and the date of
such review.
 
Note: An experienced auditor has a reasonable understanding of audit activities
and has studied the company's industry as well as the accounting and auditing
issues relevant to the industry.
 
2/ Relevant financial statement assertions are described in paragraphs 68-70
of PCAOB Auditing Standard No. 2, An Audit of Internal Control Over Financial
Reporting Performed in Conjunction with An Audit of Financial Statements.
 
7. In determining the nature and extent of the documentation for a financial
statement assertion, the auditor should consider the following factors:
 
• Nature of the auditing procedure;
 
• Risk of material misstatement associated with the assertion;
 
• Extent of judgment required in performing the work and evaluating the
results, for example, accounting estimates require greater judgment and
commensurately more extensive documentation;
 
• Significance of the evidence obtained to the assertion being tested; and
 
• Responsibility to document a conclusion not readily determinable from the
documentation of the procedures performed or evidence obtained.
 
Application of these factors determines whether the nature and extent of audit
documentation is adequate.
 
8. In addition to the documentation necessary to support the auditor's final
conclusions, audit documentation must include information the auditor has identified
relating to significant findings or issues that is inconsistent with or contradicts the
auditor's final conclusions. The relevant records to be retained include, but are not
limited to, procedures performed in response to the information, and records
documenting consultations on, or resolutions of, differences in professional judgment
among members of the engagement team or between the engagement team and others
consulted.
 
9. If, after the documentation completion date (defined in paragraph 15), the auditor
becomes aware, as a result of a lack of documentation or otherwise, that audit
procedures may not have been performed, evidence may not have been obtained, or
appropriate conclusions may not have been reached, the auditor must determine, and if
so demonstrate, that sufficient procedures were performed, sufficient evidence was
obtained, and appropriate conclusions were reached with respect to the relevant
financial statement assertions. To accomplish this, the auditor must have persuasive
other evidence. Oral explanation alone does not constitute persuasive other evidence,
but it may be used to clarify other written evidence.
 
• If the auditor determines and demonstrates that sufficient procedures were
performed, sufficient evidence was obtained, and appropriate conclusions
were reached, but that documentation thereof is not adequate, then the
auditor should consider what additional documentation is needed. In
preparing additional documentation, the auditor should refer to paragraph
16.
 
• If the auditor cannot determine or demonstrate that sufficient procedures
were performed, sufficient evidence was obtained, or appropriate
conclusions were reached, the auditor should comply with the provisions
of AU sec. 390, Consideration of Omitted Procedures After the Report
Date.

 

 

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