Finally, the US audit committees will be getting the full picture of the financial statements from the auditors. The Public Company Accounting Oversight Board (“PCAOB” or the “Board”) of US is adopting Auditing Standard No. 16 – Communications with Audit Committees. It is aimed at improving dialogue between auditors and audit committees to enable better oversight and financial reporting.
The scope of communications has increased from the previous practice of discussing – accounting policies, procedures and estimates, quality of financial reporting, unusual transactions and significant auditing and accounting matters. It covers a more matters that will increase clarity.
Previously the status of communication was aptly described by George Bernard Shaw’s quote – “The single biggest problem in communication is the illusion that it has taken place.” Audit committees in my view lacked critical information . Secondly, as there is a shortage of financial experts (just one is mandatory) they were in no position to analyse the details of the financial statements. It was easy to hide artistic accounting from them. This standard will reduce communication gap between the auditors and audit committee.
In India, though the roles and responsibilities of the auditor and audit committee are defined in the Listing Agreement of SEBI and New Companies Bill, the nature, content and quality of communication is not specified. It mandates audit committee should meet at least four times a year, however doesn’t shed light on the quality of discussion to take place. The audit committees in India, are required to look into loan transactions, related party transactions and a couple of other things. These requirements are not mentioned in the list below.
In brief, as per Auditing Standard No. 16 the auditor would be required to communicate the following to the audit committee:
a. The terms of appointment and engagement, objective of the audit, and responsibilities of management and auditor.
b. An overview of the overall audit strategy, including timing of the audit, significant risks the auditor identified including risk assessment procedures, and significant changes to the planned audit strategy or identified risks;
c. Information about the nature and extent of specialized skill or knowledge needed in the audit, the extent of the planned use of internal auditors, company personnel or other third parties, and other independent public accounting firms, or other persons not employed by the auditor that are involved in the audit;
d. The basis for the auditor’s determination that he or she can serve as principal auditor, if significant parts of the audit will be performed by other auditors;
e. Significant accounting policies and practices including changes. Reasons certain policies and procedures were considered critical and the effect on them in respect to current and future events. Effect of policies and disclosures in controversial area and where there is lack of authoritative guidance.
f. Situations in which the auditor identified a concern regarding management’s anticipated application of accounting pronouncements that have been issued but are not yet effective and might have a significant effect on future financial reporting;
g. Description of process for developing critical accounting estimates including the significant assumptions. If any significant changes are made in the process or estimates.
h. Significant unusual transactions with policy and procedures used by management for accounting unusual transaction;
i. Quality of financial reporting including whether auditor identified bias in management’s judgement about the amounts and disclosures in financial statements. Assessment and conclusion of critical accounting policies. Auditor’s understanding of the business rationale for significant unusual transactions.
j. The results of auditor’s evaluation about financial statement presentation. Whether the reporting including form, content and arrangement are in conformity to standards.
k. Difficult or contentious matters for which auditors consulted external consultants
l. Auditor is aware management consulted external sources, the auditors should also give their opinion;
m. The auditor’s evaluation of going concern;
n. Uncorrected and corrected mis-statements including those discussed with management;
o. Material written communication with management
p. Disagreements with the management
q. Departure from the auditor’s standard report;
r. Difficulties encountered in performing the audit, and
s. Other matters arising from the audit that are significant to the oversight of the company¡¦s financial reporting process, including complaints or concerns regarding accounting or auditing matters.
The various auditing and accounting standards in India cover most of the points mentioned above. The auditor is required to ensure conformity to the standards and comment on the same if there are variances. However, there is no specific guideline for communication between auditor and audit committee. As the US standard just defines minimum communication requirements it would be beneficial to formulate and adopt a similar one in India and other countries. It will ensure a specific level of interaction with auditor and audit committee is maintained and the audit committee makes informed decisions.
What do you say? Should there be a global standard for communication with audit committees? What other steps can be taken to reduce barriers to communication between the auditor and audit committees?