Tag: auditor independence

What did I say?

~ C.O.R.E. Beliefs by John ~ Leave a comment

I guess I stepped in it today.

On my other blog for CORE, I wrote today about independence, you know that little section of rules which constrain the CPA from essentially reporting on their own work.

  • Yes, I know that it is done;
  • Yes, I know it is done all the time;
  • Yes, it is a literal interpretation;
  • No, I don’t think you should try and paper it over.

Two reports require the CPA to be independent of the client and management: Audit and Review.  No one is forcing the CPA firm to perform an audit or a review.  If you want to be part of management, I say GO FOR IT!  Help management get their act together.  Help them adjust their books and, more importantly, know when they need to debit this and credit that.  Help them, but don’t come back and then claim your independence isn’t impaired.

Impairment of independence isn’t just a factual matter.  Yes, you can create lots of paper which says that Ms. Whatshername, the a/p clerk, understands what you are doing on her behalf and she is ok with you making that journal entry for her.  But when you are brought in to re-enter the entire accounts payable because Ms. Whatshername didn’t enter anything and the controller was fired so there is no one to check your work… don’t push your luck.

The appearance of impairment is even more important for those reviews and audits.  You are dealing with the integrity of the profession when you ignore what some other person might think about your independence, or lack of it.  If it looks to an innocent person that you are doing the work of management, well, guess what?  You are.

To paraphrase a letter which went from an association to the owners of a condominium:

  • Management way back when got it wrong
  • New management starting in 20XX got it even more wrong
  • New management denied their work was wrong consistently from then until now
  • New management denied it was wrong even after being beat over the head with it
  • Board hired independent CPA to redo management’s work
  • Independent CPA recalculated the numbers, resulting in a major change
  • The CPA says their work is correct
  • And, you can rely upon the CPA for this because they are trustworthy

Sorry, but that wonderful letter praising the CPA now means the CPA probably is no longer independent as to the financial statement audit.

Their work was awesome.  Totally correct.  Nailed it to within $0.02 for every owner.  Told the attorney and the board they were right and said so in a letter to the owners.  they were worth every dime they were paid to fix the mess.

But their independence is now impaired.  There is no one, not management, not the board, definitely not the attorney, who is going to take responsibility for the CPA’s work.  The CPA owns it.  They said so.  Under the rules, both of the AICPA and common sense, they are no longer independent of the client.

No independence no audit.

I get it, it is my interpretation.  Well… Not really.  It is 20 odd years of practicing in this area and reading hundreds of ethics interpretations.  It is having to struggle with deciding when we cross a line and are no longer looked at by Tommy Banker or Amanda Bonding Agent as separate from management.  When the question is, “Are you getting paid to help management or to report on them?”; it does become a little more clear.

Attest firms MUST err on the side of caution.  The big 4 don’t, the next 8 don’t.  Their failures don’t give the rest of us license to slide down that wonderful chute into impairment hell.  Take the road less traveled but best for your client.  Have integrity to admit your lack of independence when it exists.

Make the right call.  Help management or report on them.  If you can’t tell the difference, well, you probably shouldn’t be playing this game.

 

What to Look for in an Auditor

~ C.O.R.E. Beliefs by John ~ Leave a comment

“Why should we engage C.O.R.E.?”, asked the condominium board president.  It is an interesting question which deserves an entertaining answer.  And, even though Kubae says I should never do it, I always answer that question with another question.

“What do you hope to get from your audit?”

If you are looking for an independent CPA firm who believes that it is important to hold management accountable, then you should engage C.O.R.E.  If you want to feel good that the financial information you are using for decision-making is accurate, you should engage C.O.R.E.  If you want to understand how to better protect your neighbor’s hard earned money, then you should engage C.O.R.E.

If you are interviewing audit firms for your association, you may want to think about asking the following questions of the prospective firms:

  • Have you ever had a disagreement with management?  If so, explain the disagreement and how it was handled
  • Who do you believe is responsible for the preparation of the financial statement?
  • What steps do you take to ensure that client money isn’t misappropriated by management?
  • How do you handle GAAP departures when management doesn’t record a transaction correctly?
  • What are the three biggest weaknesses you see in association accounting overall?
  • Who do you believe is your client?
  • Have you ever caught management doing something which showed a significant weakness in the internal control structure?
    • What did you say about it?
    • Did you help management resolve it?
    • Did you help the board understand the weakness and how to address it in the future?

Each of these questions will give you insight into how the auditor might respond to your particular needs when it comes to auditing your association’s financial statements.  It is important to remember that your role, as directors, is oversight, not operations.  You are there to make sure that the management team you hired is presenting accurate information that you can use in making decisions about your association.

You want to make sure your auditor takes their role as independent, objective auditors seriously.  They do not need to go out of their way to find fault with management, but the reality is, they have almost total control over how your money is being spent.  You should want your auditor to focus on their spending of your money to ensure it is done to support your association.

As a director, you want to feel confident that the financial information that management presents is accurate and follows some standard.  How your auditor handles a GAAP departure could be important as the more management does things “their own way” the harder it is for you and your neighbors to follow it.  Make sure your auditor challenges management’s accounting treatment so you get the best information possible.

You want to feel confident that your auditor is looking for risk of material errors.  Your auditor should have a strong idea of what could go wrong and plan the audit for those key risk areas.  Thinks like spending money over the approved budget; paying themselves above their contract without the board reviewing the additional charges; hiring businesses where there is a conflict of interest.  The auditor should be on the look-out for those activities.

Keep in mind that the auditor works for the board.  This means you will want to interview the auditor and approve the audit engagement letter.  The audit is focused on management’s work so you never want to allow management to select the auditor.  Keeping these questions and approach in mind will help you get the maximum value from your audit and auditing professional.

Have a great Monday.

 

Take one for the team?

~ C.O.R.E. Beliefs by John ~ Leave a comment

As a follow up to my post the other day I wanted to add a few things which I have pondered since I wrote.

One of the main reasons we are not “part of the team” is that we understand that “team” is typically a one way street.  It is an effort on behalf of a certain party to gain our cooperation in not holding them accountable.  Our independence is seen as a problem and the easiest way to overcome it is to hoist the flag of our mutual interest so that we feel uncomfortable addressing our “team mates” weaknesses.  After all, team mates cover for each other, one person’s strength is used to offset another’s weakness, right?

We learned this lesson long ago in auditor school.  Also known as the University of Adversity.  “The Team”, in these instances, only exists to protect one party.  How can I say this?

Is it really a team effort when someone in management knows a fact and fails to bring it to our attention?  When management hides facts from the auditor in the hopes we won’t find out?  “We are a team but I am under no obligation to give you what you need to do your job.”  This isn’t what team mates do.

Is it really a team effort when you say, “I know I have an obligation to take a step but frankly it isn’t important and you can just trust me.”  Team mates hold each other accountable.  I will trust you when you show you can be trusted, why should it be an obligation of “Team work”?  You create a one way street of loyalty wherein you expect me to help you be successful but you have no obligation to help me.  Hardly team spirit.

Is it a duty of a team member to turn a blind eye to sloth and laziness?  Can you imagine a ball club saying, “Yeah, that Brady.  Never shows up to practice, can’t block worth a damn but meh, he is part of the team so I guess it is ok that he is starting Tackle.”  You believe you can forgo your “A” game and it is everyone else’s responsibility to pick up the slack?

Ignore for the moment an auditor’s ethical responsibility.  Let’s say that we could be part of the team.  Don’t you think, team mate of ours, that part of your belonging to the “TEAM” demands that you give your best to the shared result?  That if our part is to help you fix your errors, your part is to identify them?  That when you know a material fact, you should tell us so we can be successful?

But that isn’t the sort of team you want.  You want the team that feels obligated to commit extra to cover for your inadequacies.  You are the lunch buddy who orders the filet mignon while everyone else orders a salad and then says that the team should split the bill evenly.  No one deserves to be part of THAT team.

So no, auditors are not part of the team.  We are not here to be popular and we are not here to sweep poor behavior under the rug.  We took our “oath of office” to protect owners from management.  We actually kinda like the job, even if it upsets certain people.

If you want me to be part of the team, pay my consulting rates.  I will walk away from auditing on behalf of your owners.  I will help you fix your obvious deficiencies in ethics and business practice.  I will even endeavor to fix those that are not so obvious.  Trust me, “team mate”, you won’t like accountability this way either, but you can at least say we are on the same “Team.”

 

Auditor Relationship

~ C.O.R.E. Beliefs by John ~ 1 Comment

I have written about this before but it is probably worth repeating.

In a meeting today we were told “management’s expectation”… that we are part of the team.  Somewhere there is a misunderstanding as we are not part of any team.

To be clear:

Auditors are engaged by the board of directors to independently audit management on behalf of the owners or others who contractually require an independent check on the financial reports being issued..

The key term there is independently.  To be effective, auditors must be independent of management.  So, how can an auditor remain independent while also being part of “the team?”  We really can’t and we definitely shouldn’t.

Part of the confusion is no doubt that some auditor’s have billed this as a team effort to provide information to the owners.  I have seen proposals by firms which essentially tout this approach; but it is not quite accurate to say this.  I would argue it is against auditing standards to say that you, as an independent auditor, are going to help management through their tough spots.  The independent auditor is not the clean-up position.  We are not fixers.  Finding the error, correcting the error and then expecting the entity to pay for it, when they have already paid management (and the accounting department) to get it wrong defeats the purpose of auditing the books.

Remember: Boards set policy.  Management implements policy.  Auditor’s verify that the implementation was correct.  If it isn’t, well, that is a problem.  It will obviously need to be cleaned up.  The problem is that when the auditor cleans it up, they are actually stepping into management’s role.  Acting as management impairs independence.  There are numerous ethics rulings on this matter.   The auditor is only as good as their independence by the way.  So why would we do it?

By the way, management has access to lots of consultants and CPA’s who could help them get the information right to begin with.  It isn’t like no one would help them.  But when it is done wrong and you expect the auditor to fix it, you are waiting far too long.  Months, possibly even longer than a year has gone by with the incorrect information being reported over and over.  Every report was inaccurate and somehow my pointing it out during the audit means I am not a team player?  Where is management’s responsibility in this?

Management could even have requested the board to make the auditor available to explain the expectations.  We love to talk (most of us anyway) and help you make sure it is right.  Believe it or not, we often sit around and dream about how awesome it would be to have the perfect audit – where everything balanced, management adjusted for all the issues before we brought it up, every receivable was collected and nothing ever happened after the balance sheet date.  We would be happy with just 10% of that truth be told.

Truthfully, we can’t be on your team.  We might like you, hell, you could be the greatest thing since sliced bread and we are going to be envious of your stock options and bonuses; but we can’t support you.  Our job, remember, is to make sure your stock option and bonus isn’t clouding your judgement when you decided to record a transaction.  Our responsibility is to ensure that you didn’t record only one part of the transaction to ensure you hit your target to keep your cushy job.  It isn’t that we don’t trust you but… oh who am I kidding, it is precisely that we don’t trust you.  You are management after all.

So, record the transactions.  Document compliance with policy.  Keep your financial statements in accordance with GAAP.  Or don’t.  But don’t blame the auditor when we find the work lacking.  We are doing our job of keeping “the team” honest and we make no apologies for it.