Perspectives on the Public Company Accounting Oversight Board (PCAOB) 2004–2005

2014 ◽  
Vol 28 (4) ◽  
pp. 889-899 ◽  
Author(s):  
Andrew D. Bailey
Keyword(s):  
Financial Reporting ◽  
Professional Practice ◽  
Internal Control ◽  
Securities And Exchange Commission ◽  
Public Companies ◽  
Public Company ◽  
Audit Standard ◽  
Year 2000 ◽  
International Aspects ◽  
Audit Standards

SYNOPSIS This commentary reflects my experiences with the U.S. Securities and Exchange Commission (SEC) during the academic year 2000/2001 (Academic Fellow) and the two calendar years 2004–2005 (Deputy Chief Accountant [Professional Practice]). These comments reflect only my thoughts without citations in support of or contrary to those thoughts and resulting opinions. The topics covered in this commentary include: (1) early staff relations between the PCAOB and SEC in their respective roles of audit standard setter and oversight agency; (2) the PCAOB decision to act as the sole audit standard setter for registered public companies displacing the AICPA in this role; (3) the PCAOB's approach to “revising” the interim audit standards through Rule 3101, Certain Terms Used in Auditing and Related Professional Practice Standards; (4) Audit Standard 3 (AS3), Audit Documentation; and (5) Audit Standard 2 (AS2), An Audit of Internal Control over Financial Reporting Performed in Conjunction With an Audit of Financial Statements. I will also comment on several observations made by others concerning the competence of PCAOB staff and the PCAOB Board members to set audit standards and perform meaningful inspections. I conclude with a brief note on the international aspects of PCAOB actions during this period.

Repeat offenders: examining cases of multiple years of internal control weaknesses

2020 ◽  
Vol 35 (4) ◽  
pp. 499-520
Author(s):  
Kathleen Bakarich ◽  
Devon Baranek
Keyword(s):  
Financial Reporting ◽  
Internal Control ◽  
Securities And Exchange Commission ◽  
Repeat Offenders ◽  
Content Type ◽  
Public Company ◽  
Material Weaknesses ◽  
General Material ◽  
Current Sample ◽  
One Year

Purpose This study aims to identify characteristics of firms reporting multiple years of material weaknesses in internal control over financial reporting (MWICFR), labeled “Repeat Offenders”, and examine their characteristics and the types of material weaknesses they report using both broad and COSO-based classification schemes. The analysis compares these firms with firms reporting only one year of MWICFR and examines the differences between Repeat Offenders reporting consecutive and non-consecutive weaknesses. Design/methodology/approach Univariate and multivariate analyses were conducted on a sample of 1,793 firm-year observations, split into Repeat Offenders and non-Repeat Offenders, and collected from AuditAnalytics and Compustat from 2007 to 2015. Findings On average, 40% of adverse opinions in ICFR each year can be attributed to Repeat Offenders. Compared to one-time MWICFR firms, Repeat Offenders are significantly more likely to report general material weaknesses and, within the COSO framework, are significantly more likely to report issues with Segregation of Duties and Processes and Procedures. Repeat Offenders reporting consecutive years of MWICFR are significantly more likely to have general weaknesses than non-consecutive Repeat Offenders and are also significantly more likely to report issues with Segregation of Duties and Personnel. Research limitations/implications Prior studies have examined unremediated ICFR issues in the periods immediately following SOX implementation. This study extends this literature with a longer, more current sample period, focusing on both broad and COSO-specific control issues, as well as examining consecutive and non-consecutive MWICFR and firms with more than two years of MWICFR. Originality/value This study underpins recent Securities and Exchange Commission and Public Company Accounting Oversight Board concerns regarding pervasive ICFR issues. This study identifies some of the characteristics of firms associated with weaker ICFR and pinpoints more specific areas within internal controls that frequently lead to adverse opinions.

Koss Corporation Case: Trouble in Brew City

2011 ◽  
Vol 26 (3) ◽  
pp. 547-568 ◽  
Author(s):  
Brian Daugherty ◽  
Daniel G. Neely
Keyword(s):  
Financial Reporting ◽  
Internal Control ◽  
Real Life ◽  
Chief Executive ◽  
Securities And Exchange Commission ◽  
Financial Statement Fraud ◽  
President Obama ◽  
Public Companies ◽  
Chief Operating Officer ◽  
Sarbanes Oxley

ABSTRACT This instructional case provides auditing students an opportunity to examine an interesting real-life embezzlement and financial statement fraud occurring at a publicly traded company in the post-Sarbanes-Oxley (SOX) era. The case focuses on independent auditors' and senior management's reporting responsibilities related to internal control over financial reporting involving smaller public companies (nonaccelerated filers). While all public companies are subject to external auditor and management attestation on the effectiveness of internal control over financial reporting following SOX, the Securities and Exchange Commission (SEC) granted nonaccelerated filers numerous extensions for the effective date of required auditor attestation. In 2010, President Obama signed legislation to permanently exempt nonaccelerated filers from auditor attestation. The case also highlights inherent risk assessments by the independent auditor when one individual holds multiple C-level titles (Chief Executive Officer, Chief Financial Officer, Chief Operating Officer, etc.) within the organization concurrent with membership on the board of directors, and requires students to recommend internal control policies and procedures designed to prevent or detect the embezzlement.

Do Small Firms Benefit from Auditor Attestation of Internal Control Effectiveness?

2012 ◽  
Vol 31 (4) ◽  
pp. 115-137 ◽  
Author(s):  
Gopal V. Krishnan ◽  
Wei Yu
Keyword(s):  
Financial Reporting ◽  
Internal Control ◽  
Small Firms ◽  
Securities And Exchange Commission ◽  
Control Effectiveness

SUMMARY While auditor attestation of the effectiveness of internal control over financial reporting (ICFR) is required for firms with a public float of at least $75 million (accelerated filers), the Securities and Exchange Commission (SEC) has delayed auditor attestation for non-accelerated filers several times. The Dodd-Frank Act of 2010 exempts non-accelerated filers from auditor attestation. We examine the relation between auditor attestation and revenue quality for a sample of non-accelerated filers and small accelerated filers. We find that discretionary (abnormal) revenues, our proxy for revenue quality, are lower by about 1.5 percent of total assets for accelerated filers relative to non-accelerated filers. This finding holds even among firms whose management has certified their ICFR to be effective. Overall, the findings support the notion that auditor attestation of the effectiveness of ICFR benefits small accelerated filers via higher revenue quality. We believe our findings are timely and potentially informative to regulators, investors, and others.

Financial Reporting Fraud: Public and Private Companies

2016 ◽  
Vol 1 (1) ◽  
pp. A27-A41 ◽  
Author(s):  
A. Scott Fleming ◽  
Dana R. Hermanson ◽  
Mary-Jo Kranacher ◽  
Richard A. Riley
Keyword(s):  
Financial Reporting ◽  
Primary Objective ◽  
Private Company ◽  
Private Companies ◽  
Public And Private ◽  
Public Companies ◽  
Multivariate Tests ◽  
Public Company ◽  
Public Versus Private ◽  
Financial Reporting Fraud

ABSTRACT This study uses survey data gathered by the Association of Certified Fraud Examiners (ACFE) and provided to the Institute for Fraud Prevention (IFP) to examine differences in the profile of financial reporting fraud (FRF) between private companies and public companies. Although private companies represent a significant portion of the economy, largely due to lack of data on these companies, most research on FRF examines only public companies. The primary objective of this study is to determine how private company FRF is different from FRF in public companies. Our multivariate tests reveal that public companies have stronger anti-fraud environments, are more likely to have frauds that involve timing differences, tend to experience larger frauds, have frauds that involve a larger number of perpetrators, and are less likely to have frauds that are discovered by accident. Overall, it appears that the stronger anti-fraud environment in public companies leads public company FRF perpetrators to use less obvious fraud methods (i.e., timing differences) and to involve larger fraud teams to circumvent the controls. These public company frauds are larger than in private companies, and their larger size may make them more likely to be detected through formal means, rather than by accident. Based on the results, we encourage auditors and others to be particularly attuned to the unique risks of the public versus private setting.

scholarly journals Integration of Internal Control and Financial Statement Audits: Are Two Audits Better than One?

2018 ◽  
Vol 94 (2) ◽  
pp. 53-81 ◽  
Author(s):  
Lori Shefchik Bhaskar ◽  
Joseph H. Schroeder ◽  
Marcy L. Shepardson
Keyword(s):  
Financial Reporting ◽  
Internal Control ◽  
Audit Quality ◽  
Internal Controls ◽  
Data Availability ◽  
Financial Statement ◽  
Auditor Judgment ◽  
Public Company ◽  
Better Than

ABSTRACT The quality of financial statement (FS) audits integrated with audits of internal controls over financial reporting (ICFR) depends upon the quality of ICFR information used in, and its integration into, FS audits. Recent research and PCAOB inspections find auditors underreport existing ICFR weaknesses and perform insufficient testing to address identified risks, suggesting integrated audits—in which substantial ICFR testing is required—may result in lower FS audit quality than FS-only audits. We compare a 2007–2013 sample of small U.S. public company firm-years receiving integrated audits (accelerated filers) to firm-years receiving FS-only audits (non-accelerated filers) and find integrated audits are associated with higher likelihood of material misstatements and discretionary accruals, consistent with lower FS audit quality. We also find evidence of (1) auditor judgment-based integration issues, and (2) low-quality ICFR audits harming FS audit quality. Overall, results suggest an important potential consequence of integrated audits is lower FS audit quality. Data Availability: Data are publicly available from the sources identified in the text.

How Effective are Organizations' Internal Controls? Insights into Specific Internal Control Elements

2012 ◽  
Vol 6 (1) ◽  
pp. A31-A50 ◽  
Author(s):  
Dana R. Hermanson ◽  
Jason L. Smith ◽  
Nathaniel M. Stephens
Keyword(s):  
Financial Reporting ◽  
Internal Control ◽  
Financial Services ◽  
Audit Committee ◽  
Internal Audit ◽  
Internal Controls ◽  
Component Level ◽  
Public Companies ◽  
Tone At The Top ◽  
Survey Responses

SUMMARY Based on survey responses from approximately 500 Chief Audit Executives (CAEs) and other internal auditors, this article provides an insider's view of the perceived strength of organizations' internal controls (i.e., internal control over financial reporting) in the Control Environment, Risk Assessment, and Monitoring components of the Committee of Sponsoring Organizations' (COSO 1992a) Internal Control—Integrated Framework. Although the respondents largely rate control strength as relatively high, we identify several areas for potential improvement of internal controls, especially related to assessing the “tone at the top,” as well as following up on deviations from policy and management override of controls. In analyzing individual control elements, we find that public companies' controls are consistently rated as more effective than those of other organizations. We also find a number of interesting differences across key industries, especially in the Monitoring component, where banks and other financial services firms appear to have more robust Monitoring controls than do healthcare and other services firms. The component-level analysis reveals that internal control component strength is positively related to the CAE reporting primarily to the audit committee, public company status, and the average tenure of the internal audit function staff, among other findings. Based on the survey findings, we describe key implications relevant to internal and external auditors, accounting researchers and educators, and management.

COSO 2013: Aligning Internal Controls and Principles

2016 ◽  
Vol 32 (3) ◽  
pp. 117-127 ◽  
Author(s):  
Denise Dickins ◽  
Rebecca G. Fay
Keyword(s):  
Critical Thinking ◽  
Financial Reporting ◽  
Internal Control ◽  
Financial Statements ◽  
Thinking Skills ◽  
Securities And Exchange Commission ◽  
Internal Controls ◽  
Critical Thinking Skills ◽  
Reading Assignment

ABSTRACT Strong systems of internal control over financial reporting (ICFR) are critical to the production of reliable financial statements. Securities and Exchange Commission (SEC) regulations require that companies design, maintain, and regularly evaluate their systems of ICFR, and Auditing Standard No. 5 requires that auditors evaluate companies' systems of ICFR. Therefore, it is necessary for accountants to be able to (1) describe and classify internal controls and (2) determine deficiencies in internal control. Recent reports suggest that accountants may lack sufficient training and guidance in these respects (e.g., Rapoport 2012). This activity provides an opportunity for students to practice these skills while learning more about the Committee of Sponsoring Organizations of the Treadway Commission's (COSO) 2013 Framework. Provided are a summary discussion of ICFR and the COSO 2013 Framework, an outside-of-class reading assignment, and an activity that requires students (independently or in groups, either in or outside of class) to employ critical-thinking skills to: (1) classify (i.e., map) a listing of controls as being aligned with one (or more) of the COSO 2013 Framework's five components and 17 principles that comprise a well-designed system of internal control, and (2) identify any deficiencies (gaps) in design due to missing or inadequate internal controls.

scholarly journals From Phishing To Advanced Persistent Threats: The Application Of Cybercrime Risk To The Enterprise Risk Management Model

2010 ◽  
Vol 14 (4) ◽  
Author(s):  
John W. Moore
Keyword(s):  
Risk Management ◽  
Financial Reporting ◽  
Internal Control ◽  
Enterprise Risk Management ◽  
Management Model ◽  
Material Weakness ◽  
Public Companies ◽  
Advanced Persistent Threats ◽  
Sarbanes Oxley ◽  
Enterprise Risk

This paper examines the issues of cybercrime in the context of risk to organizations.  In particular, it considers the control frameworks most commonly used by U.S. public companies to benchmark their internal controls over financial reporting.  It discusses the market for stolen identities, looking at the sources from which many of those identities are stolen.  It reviews the available internal control frameworks and explains how a firm’s risk of cybercrime might be classified as a material weakness under Sarbanes-Oxley Section 404.  It models how the use of COSO’s Enterprise Risk Management model could improve an organization’s chances of avoiding a serious incident.

Of Hurricanes and Harness Racing: The Accounting Fraud at DHB Industries, Inc.

2012 ◽  
Vol 28 (1) ◽  
pp. 131-152
Author(s):  
Michael C. Knapp ◽  
Carol A. Knapp
Keyword(s):  
Financial Reporting ◽  
Internal Control ◽  
Large Scale ◽  
Audit Quality ◽  
Securities And Exchange Commission ◽  
Accounting Fraud ◽  
Accounting Firms ◽  
Fraud Risk ◽  
Wide Range ◽  
The Impact

ABSTRACT: This instructional case focuses on an accounting and financial reporting fraud involving DHB Industries, Inc., the nation's largest manufacturer of bullet-resistant vests. Three executives of this Securities and Exchange Commission (SEC) registrant, including its founder and CEO, masterminded a large-scale fraud that grossly misrepresented DHB's financial statements. The three executives colluded to conceal their misdeeds from the four accounting firms that served as the company's independent auditors over the course of the fraud. In late 2010, a federal jury convicted DHB's former CEO and COO of multiple counts of fraud and related charges. This case addresses a wide range of auditing issues raised by the DHB fraud, including the identification of fraud risk factors, auditing of related-party transactions, the impact of frequent auditor changes on audit quality, and the internal control reporting responsibilities of auditors.

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