2013 Peer Review Conference. Providence, RI. Committee Member Session: Topics and Questions for Discussion
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1 2013 Peer Review Conference Providence, RI Committee Member Session: Topics and Questions for Discussion 1
2 TABLE OF CONTENTS FOR COMMITTEE MEMBER SESSION TOPIC # TOPIC DESCRIPTION PAGE # 1 Clarified Auditing Standards 3 2 Reviewer Feedback and Other Communications 4 3 Problem Reviewers 6 4 Must Cover and Must Select Engagements 7 5 Tone at the Top 8 6 Aggregation of No Answers 9 7 Quality Control Document 10 8 Reviewer Independence 11 9 Partial and Scope Expansion Engagement Selections Access to Peer Review Workpapers Electronic Peer Review Documents Requirement to Review Publicly Available Information for A-133 and EBP Responding to Non-conforming Engagements Peer Reviewer Pool Dissolutions, Mergers and Acquisitions Develop a Peer Reviewer to Peer Reviewer Online Forum Future Topics 20 2
3 Topics and Questions for Discussion Topic # 1 Clarified Auditing Standards What challenges, if any, did your firm encounter when preparing for and implementing the clarified auditing standards? In your experience, what challenges, if any, are reviewed firms encountering with respect to the clarified auditing standards? What aspects of the clarified auditing standards, if any, did firms misapply or fail to apply? The document Summary of Differences Between Clarified SASs and Existing SASs, which is located on the AICPA website, provided a comprehensive analysis and discussion of the differences between the clarified auditing standards and the extant auditing standards, including substantive changes that were expected to result in adjustments to practice. Did you encounter other practice areas in which you made substantive changes to audit procedures that you performed? How often did you encounter situations in which the reviewed firm had early implemented all or some aspect of the clarified auditing standards? QUESTION 5 How often did you encounter situations in which the reviewed firm missed entirely implementing the clarified auditing standards? QUESTION 6 In cases in which the reviewed firm early implemented the clarified auditing standards, or some aspect of them, based on your professional judgment did you believe an MFC or FFC was justified? Why or why not? QUESTION 7 in this area? 3
4 Topic # 2 Reviewer Feedback and Other Communications For peer review documentation matters, should a reviewer feedback form be issued if the matter does not require a revision? For instance, the risk assessment does not address certain elements, but through other peer review documentation or follow up discussion it is clear that the issue was either not applicable or the reviewer properly considered it. Should a reviewer feedback form be issued if the reviewer continues to make the identical otherwise trivial errors (that individually would not rise to the level of feedback)? Does your administering entity have a method for keeping up with other communications to the reviewer in accordance with the peer review document retention period? Note that the retention period for other communications is 120 days after the completion of the peer review. When dealing with a reviewer unfamiliar to the administering entity (out of state reviewer) under what circumstances do you request feedback from other AEs? QUESTION 5 Do the technical reviewer and RAB apply a different evaluation and feedback criteria depending on the peer reviewer (new reviewer, out of state reviewer, high volume reviewer, current/former RAB member, etc.)? QUESTION 6 In what situations would you issue a reviewer monitoring letter? QUESTION 7 In what situations would you issue a reviewer deficiency letter? QUESTION 8 Are there any situations in which a reviewer deficiency letter should be issued without previously issuing a reviewer feedback form or a performance monitoring letter? 4
5 QUESTION 9 in this area? 5
6 Topic # 3 Problem Reviewers How do you define a problem reviewer? What is the impact of a problem reviewer on the report acceptance process? Has the revised guidance on Reviewer Performance (Chapter 8 of RAB HB) been beneficial? Can problem reviewers be remediated? What else can the AICPA do to remediate problem reviewers? 6
7 Topic # 4 Must Cover and Must Select Engagements Peer Review teams must include individuals with experiences that align with the firm s must cover and must select industries. If a firm has a concentration in a must cover or must select industry and the team captain does not have that experience, should the team captain qualify to be a team captain on the review? What if the firm performs multiple must cover and must select engagements but does not have a concentration in any particular industry? If the team captain does not have experience in any must cover or select area, should the team captain qualify to be a team captain on the review? If a team member is used to review a must cover or must select engagement, should the team member attend the exit conference if that engagement was included on an MFC, FFC or as a deficiency or significant deficiency in the report? Should a peer reviewer be required to have current experience (A level experience) in order to perform the review of a must-select engagement? QUESTION 5 in this area? 7
8 Topic # 5 Tone at the Top Have you ever seen a peer review report which included a deficiency resulting from the tone at the top at the reviewed firm? What challenges might a reviewer encounter when deciding whether to include a tone at the top deficiency in the peer review report? Do you believe tone at the top deficiencies are sometimes not reported and, if so, why? What would be an appropriate corrective action if a tone at the top deficiency was noted? QUESTION 5 in this area? 8
9 Topic # 6 Aggregation of No Answers Should all no answers be included on MFC forms unless they are clearly immaterial? What are the pros and cons of including all no answers on MFC forms? Do you think reviewers struggle with which items to include on MFC forms? Can no answers be disposed of and not included in MFC forms if they are isolated? Should a summary of no answers worksheet be added to the peer review working papers? If the worksheet is added, should it be included in the SRM for submission to the administering entity? Would a worksheet assist peer reviewers with aggregating no answers? 9
10 Topic # 7 Quality Control Document What would you expect a peer reviewer to do if they encountered one of the following situations? Firm s CPE is 100% self-study or virtually all tax Internal inspection is based on a dollar threshold or is performed by a lower level staff QCD states, The firm has chosen not to document the policies and procedures related to assignment of engagement teams due to the partner in charge s daily interaction in this process Small firm established EQCR criteria such that virtually no engagement would ever require an EQCR (for example, engagements with total assets equaling or exceeding $10 billion) QCD is dated after the peer review year Do you feel there should be a size of reviewed firm threshold above which it would be unreasonable for the reviewed firm to utilize PRP section 4400 in lieu of a formal QC document to document its system of quality control? If the answer is yes, what threshold, in terms of attest hours or attest engagements, or both, do you feel is reasonable? How would you expect a reviewer to treat a situation where one or more of a firm s six functional areas of quality control were not appropriately designed and complied with but the reviewer found no issues while reviewing the firm s engagements? in this area? 10
11 Topic # 8 Reviewer Independence Reviewer A performs the review of Firm B. Reviewer A was not independent with respect to Firm B because he performed pre-issuance reviews for them in the peer review year. If Reviewer A's lack of independence isn't discovered until RAB presentation, what should the RAB do? What if Reviewer A had performed pre-issuance reviews in the prior year but not the review year? Should the firm be required to engage a new reviewer or could comprehensive oversight be performed? in this area? 11
12 Topic # 9 Partial and Scope Expansion Engagement Selections Have you seen reviewers perform partial reviews of engagements so that they can gain coverage over specific significant audit areas without having to review the entire engagement? How have you seen this approach documented in the peer review working papers? Should the selection of the engagements be included in the review s engagement statistics? If yes, should the statistics include the full engagement s hours, or just an estimate of time the firm spent on the significant audit area? Should engagements selected to expand scope be included in the engagement s engagement statistics, and if yes, how could that be done? QUESTION 5 in this area? 12
13 Topic # 10 Access to Peer Review Workpapers Should technical reviewers at each AE have access to full peer review workpapers? What level of obligation for their review is appropriate? In what situations would it be appropriate to review a full set of workpapers? In what situations would it be inappropriate to review a full set of workpapers? How would consistency in this review be obtained? What procedures should be performed? QUESTION 5 Approximately how much time do you think the above procedures would require? 13
14 Topic # 11 Electronic Peer Review Documents What has your experience been with the electronic MFC forms so far? What kind of feedback have you heard from reviewers and firms? What kind of obstacles have you had to overcome and what kind of efficiencies have you identified? or training in this area? QUESTION 5 Do you have any suggestions for a seamless transition to electronic FFC forms? 14
15 Topic # 12 Requirement to Review Publicly Available Information for A-133 and EBP Engagements If a firm does not indicate on their background scheduling form that they perform A-133 or employee benefit plan audits, do you think peer reviewers should be required to check publicly available information online? Do you think the administering entity should perform this online review? Have you ever researched publicly available information to see if a firm practiced in either of these areas? Have you ever been notified or discovered the firm performed an A-133 or EBP engagement after the firm s peer review report has been accepted and one of these types of engagements was not reviewed? QUESTION 5 in this area? 15
16 Topic # 13 Responding to Non-conforming Engagements When a non-conforming engagement is found during the peer review, do you believe that firms generally respond appropriately and in accordance with the standards governing these situations? In your experience, have firms provided any legitimate reasons for not notifying the client when an engagement is deemed non-conforming during the peer review? What if it is a material reporting error instead of a procedural/documentation matter that makes the engagement nonconforming? Do you think that non-conforming engagements for which the firm indicates it will make corrections should be followed up on by the peer review program to ensure correction to the engagement (along with the firm s system of quality control, if applicable)? If so, are there any particular thresholds that should be used when determining whether and which type of engagements should be followed up on by the peer review program through either a corrective action or implementation plan? in this area? 16
17 Topic # 14 Peer Reviewer Pool What challenges are reviewers in your state experiencing in acquiring new peer review clients? What challenges are reviewers in your state experiencing in identifying a successor or buyer for their practice? What role could administering entities play in helping reviewers to either expand or wind down their practice? What role could the AICPA play in helping reviewers to either expand or wind down their practice? 17
18 Topic # 15 Dissolutions, Mergers and Acquisitions Note: When there is a dissolution, merger, or acquisition, a successor firm is the firm that retains the peer review history and is permitted to continue using a firm s peer review report (e.g. in conjunction with proposals). When firms dissolve, should all former partners of the firm be permitted to use the peer review report until they are able to obtain a new peer review report? What are the risks associated with allowing the non-successor firm partners to use the report? If all former partners are permitted to use the peer review report when firms dissolve, should the partners of the non-successor firm be required to provide a cover letter with the report explaining the changes in the firm structure or the changes to the system of quality control? When firms dissolve, should there be an outright prohibition of using the peer review report by the firm who is not the successor firm? Should the partners in the non-successor firm be limited to use the report for proposals for governmental audits, as long as they provide a cover letter explaining that they are the non-successor firm? When firms dissolve, are there any specific situations where the non-successor firm should be allowed to use the report? Such as, the partner in charge of the quality control system is not part of the successor firm. If non-successor firms are given the ability to use the report, should there be a minimum threshold for using the report? What if one of the partners retained less than 20% of the A&A hours from the original firm? 18
19 Topic # 16 Develop a Peer Reviewer-to-Peer Reviewer Online Forum Should peer review have an online forum where peer reviewers can network, exchange information, share best practices and discuss issues with other peer reviewers similar to the GAQC and EBPAQC member-to-member forums? Should the forum be moderated and every question answered? Do you think this would help in locating team members to cover specific industries? Have you ever used an online forum for guidance related to a peer review? QUESTION 5 Do you think this would help promote consistency across the various administering entities? QUESTION 6 in this area? 19
20 Topic # 17 Future Topics What topics would you like to discuss at next year s conference? 20
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