Tuesday, May 29, 2007

SEC-PCAOB Reform of Internal Control Reporting Has Many Elements

The SEC’s management guidance, rules, and the PCAOB’s new audit standard No. 5, have reformed the internal control reporting system by:
  • Focusing the audit on the matters most important to internal control by directing the auditor to test the most important controls
  • Adopting a flexible principles-based system reliant on professional judgment
  • Eliminating the requirement that the auditor evaluate management’s process
  • Scaling the audit for smaller companies
  • Aligning SEC regulations with the PCAOB standard
  • Eliminating the principal evidence provision to allow more reliance on the work of others
  • Redefining material weakness upward
  • Requiring audit committee pre-approval of non-audit internal control services
  • Placing the main testing focus on entity or company level controls
  • Requiring auditors to assess the risk of fraud when planning the audit
  • Reducing the number of walkthroughs while preserving quality
  • Integrating internal control and financial statement audits
  • Requiring risk assessment at each of the decision points in a top-down approach
  • Testing controls important to assessing the risk of financial statement misstatement
  • Allowing a risk-based approach for auditing multiple corporate locations
  • Allowing auditors to use knowledge obtained during past audits
  • Refocusing internal controls to prevent material misstatements in financial statements