The Auditor and the Books - Part 2

Maintaining Accounting Records and Financial Statement Preparation
The Companies Act in Section 90 only prohibits the engagement partner from the maintenance of any of the company's financial records. There is no specific provision that the engagement partner may not prepare the financial statements. However as Regulation 25 of the Companies Regulations state that accounting records includes any document that would facilitate the preparation of financial statements it can be concluded that by maintaining the accounting records to a degree that would require no more (or every few) adjustments to comply financial reporting standards the financial statements would be considered to be included in the definition of accounting records. An auditor cannot create records or systems and then audit them with independence. Providing an audit client with accounting and bookkeeping services, such as preparing accounting records or financial statements, creates a self-review threat when the firm subsequently audits the financial statements. The audit process, however, necessitates dialogue between the firm and management of the audit client, which may involve: the application of accounting standards or policies and financial statement disclosure requirements, the appropriateness of financial and accounting control and the methods used in determining the stated amounts of assets and liabilities, or proposing adjusting journal entries. These activities are considered to be a normal part of the audit process and do not, generally, create threats to independence.
An underlying principle is that maintenance of the records is a management function for which management must be responsible, even though a client may ask the auditor for assistance. As a practical matter, this principle can limit the extent to which an auditor can provide bookkeeping services without applying appropriate safeguards. This principle that should be applied are: An auditor should not:
  • Prepares or change a journal entry, determine or change an account code or a classification for a transaction or prepare or change another accounting record without obtaining the approval of management of the entity and
  • Prepares a source document or originating data, or makes a change to such a document or data.

The degree of self-review threat arising from the preparation of, or changes to, journal entries is also influenced by the complexity of the entries. If the entries are complex, in addition to obtaining the approval of management, it may be necessary for the auditor to consult with another professional accountant for a second opinion. As noted, auditors cannot prepare, or make changes to, source documents or originating data. There is nothing in the independence rules to prevent an auditor from providing typing services, such as, for example, typing cheques for signature by the client. The distinction is that it is the client's signature on the cheque and not its initial preparation that makes the cheque an official document.
A similar analysis can be applied to the question of the auditor providing bookkeeping services. If an auditor takes source documents that originate from other sources independent of the auditor, such as suppliers, customers or the client itself, and simply records those documents in the books, this does not pose an independence problem. Therefore, an auditor can provide basic bookkeeping services as long as management takes full responsibility for the accounting records being audited and, if any threats to independence do arise, they are reduced to an acceptable level.
How can this position be reconciled with the rule that an auditor who prepares adjusting journal entries must have the client approve the entries as an indication of management's taking responsibility for them? The difference is that, in the case of the journal entries, the auditor often derives or calculates the content of the entry rather than simply recording the entry in the accounting records. For example, the auditor might prepare an entry for amortization and actually calculate the amount. In this case, it is important to make sure the client agrees with, and takes responsibility for, the entry by, for example, the auditor obtaining the client's signature to denote approval.
In summary, audit firms must exercise judgment in assessing their independence when offering services involving bookkeeping and preparation of journal entries. Such services can create a self-review threat that requires adequate safeguards for protecting independence. Where a self-review threat is considered serious, the auditor and or the client should consider hiring a contract bookkeeper or establishing a clear separation between the audit personnel and bookkeeping personnel.
The new independence rules do not prohibit providing advice on accounting policies and issues, the treatment of particular financial statement items or the wording of notes to the financial statements. The auditors of entities that are not reporting issuers may also prepare the financial statements and draft notes to the financial statements. The basic principle remains, however, that an entity's management must make the decisions.
Because financial statements are the representations of management, and management has to accept responsibility for them, an auditor must be satisfied that small entity management has sufficient understanding of the financial statements and underlying entries to be able to accept this responsibility. This can be accomplished by reviewing the financial statements with management and discussing the management representation letter with them. The engagement letter also can be a useful vehicle for reminding small entity management of their responsibility for the financial statements.

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