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© Copyright FocusROI Inc. 2012 www.focusroi.com
A Guide to the QAM update #4
Stuart Hartley FCA
© Copyright FocusROI Inc. 2012 www.focusroi.com
Agenda An overview of QAM #4
New features in the manual and sample policy manuals.
A comparison between new sample policies and previous ones.
Guidance on QC requirements for:
Firm monitoring,
Ongoing compliance documentation, and
Engagement quality control reviews.
Common QC system deficiencies.
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QC Stakeholders
AuditCommittees
ExternalAuditors
Management
Regulators
Users
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The Perceived Conflict
Slide M1- 5
The auditor is hired and fired by management not investors!!!
Man
agem
ent
Users
Ban
kers, Investo
rs &
Public
The Auditor
Dem
and
for Ser
vice
Dem
and for Protection
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Recent Criticisms of Auditors
PCAOB in USA (2008 banking crisis)
FRC in UK (2008 banking crisis)
European Commission (2008 banking crisis)
Lack of
Professional Skepticism being used by partners and staff
Whatever the client says must be right!!!
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An essential ATTITUDE to enhance ability to:
Identify/respond to conditions that indicate possible misstatement.
Critically assess
audit evidence.
Remain
for:alert Contradictory
audit evidence or evidence that
questions reliability ofinformation from
management/TCWG
Draw appropriate conclusions.
Professional Skepticism
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Canadian
QC Standards Quality control
for other engagements Engagement
level Policies& Procedure
The Firms Quality Control System(CSQC 1)
Firm level policies &Procedures
Quality control foran audit of financial statements
(CAS 220)
Quality control fora review engagement
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Objective of CSQC 1
11. The objective of the firm is to:
establish and maintain a system of
quality control to provide it with
reasonable assurance that:
1. The firm and its personnel comply with
professional standards and regulatory and
legal requirements; and
2. Reports issued by the firm or engagement
partners are appropriate in the
circumstances.
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CSQC1 has 47 “SHALLS”
CANADIAN STANDARD ON QUALITY CONTROL CSQC1
Subject matter "Shalls"
Applying, and Complying with, Relevant Requirements 3
Elements of a System of Quality Control 2
Leadership Responsibilities for Quality within the Firm 2
Relevant Ethical Requirements 6
Acceptance/ Continuance of Client Relationships 3
Human Resources 3
Engagement Performance 16
Monitoring 9
Documentation of the System of Quality Control 3
Totals 47
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Engagement Level Objectives - CAS 220
Implement QC procedures at the engagement
level to provide reasonable assurance that:
(a) The audit complies with professional standards
and applicable legal and regulatory
requirements; and
(b) The auditor's report issued is appropriate in
the circumstances.
Mirrors firm level objectives
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CAS 220 has 18 “SHALLS”
Quality Control for an Audit of Financial Statements CAS 220
Subject matter "Shalls"
Leadership Responsibilities for Quality within the Firm 1
Relevant Ethical Requirements 3
Acceptance/ Continuance of Client Relationships 2
Assignment of Engagement Teams 1
Engagement Performance 8
Monitoring 1
Documentation 2
Totals 18
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Elements of a QC system
Firm level QC (CSQC1)
1. Leadership
2. Ethics
3. Acceptance /continuance
4. Human resource management
5. Engagement performance
6. Monitoring
7. Documentation (QAM)
Engagement level QC (CAS 220)
1. Leadership
2. Ethics
3. Acceptance/continuance
4. Engagement team
5. Engagement performance
6. Monitoring
QAM = Quality Assurance Manual
.16 The firm shall establish and maintain a system of quality control
that includes policies and procedures that address each of the
following elements:
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Overview of
Substantially rewritten and expanded for changes
in clarified CSQC 1 & CAS 220
Key features:
Four updated sample Quality Assurance Manuals
Closely follow the QC standards
More guidance for firms to customize sample manuals
Optional best practice text shaded in sample policies
Chapters provide commentary on each sample policy
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Structure of
Part Description
A Requirements and Responsive Solutions
B Sample Quality Control Manuals and Appendices
C Practice Aids
D Other Reference Materials
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Guide to designing/implementing Firm QAM
AdditionalGuidance on
Tracking updates
Documenting compliance
Listed entities
Monitoring
Focus onFirm
LeadershipOrg charts
Job descriptionsreporting
Closely Follows
Clarified
Standards
Updated
Practical AidsReview checklistsReport formats
Risk assessmentsLetters
QAM update 4
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Part A
Standards CSQC 1 Chapter QAM
Objectives 11 1 A system of Quality Control
Applying, and Complying with,
Relevant Requirements
13-15 2 Commitment to Quality Work
Elements of a System of Quality
Control 16-17 2 A system of Quality Control
Leadership Responsibilities for
Quality within the Firm 18-19 3 Leadership
Relevant ethical requirements 20-25 4 Relevant Ethical Requirements
Acceptance and Continuance of
Client Relationships and Specific
Engagements
26-28 5 Client Acceptance/Continuance
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Standards CSQC 1 Chapter QAM
Human resources 29-31 6 Human Resources
Engagement performance
Consultation
Engagement Quality Control
Reviews
Differences Of Opinion
Engagement Documentation
32-33
34
35-42
43-44
45-47
7
8
9
10
11
Engagement performance
Consultation
Engagement Quality Control
Reviews
Differences Of Opinion
Engagement Documentation
Monitoring
Monitoring the Firm's Quality
Control Policies and Procedures
Evaluating, Communicating and
Remedying Identified
Deficiencies
Complaints and Allegations
48
49-54
55-56
12
13
Monitoring The Firm’s System
Of Quality Control
Complaints and Allegations
Documentation of the System of
Quality Control 57-59 2-13 Suggested documentation
provided throughout manual
Part A
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Part B: Sample Manuals
1. Sole Practitioner with No Staff
2. Sole Practitioner with Staff
3. Small or Medium-Sized Partnership
4. Partnerships including Audits of
Listed Entities/Reporting Issuers
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Implementing QC in your firm Activity Purpose Documentation
Read “engagement level” QC
standards (i.e., CAS 220)
QAM, CSQC 1 and
Design an appropriate system of quality control for firm
Implement the system of quality
control within firm
Assign firm leaders (internal and external)
with operational responsibilities for QC
A set of P&P (firm’s own QAM) that complies with CSQC 1
Build a culture of quality within the Firm
of CSQC 1 are consistently achieved
Ensure the objectives
Gett
ing S
tart
ed
Evidence of understandingby those responsible forQC in firm
A manual (QAM) for firm Evidence of QAM approval
(by partners)
Evidence of:- regular communication with firm personnel.- staff training provided- ongoing compliance
A current list of firm leadersSpecific job descriptionsEvidence of actions takenby the leaders
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Monitoring QC
Ensure system is operating effectively and deficiencies are corrected on a timely basis
Annually monitor compliance
with firms QAM
Annually assess need for
changes in firm’s QAM
Annual confirmation (by all personnel)
of compliance with firm’s QAM
Annually communicate results of QC monitoring
to firm personnel
Ensure firm’s QAM is relevant and up to date
Ensure personnel understand and comply with firm’s QAM
Correct deficiencies and e
nsure continual improvement in quality of work performed
M a i n
t a i n
i n g t
h e
S y s t
e m
Reports from firm leaders Reports from firm monitors Action plans to address weaknesses
Details of the QAM review and the changes (if any) made as a result
Signed confirmations by all partners and staff Details on how any issues arising were resolved
Annual communication to personnel with action plans for remediation and improvement
Activity Purpose Documentation
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Monitoring Question Response
Who? Persons with sufficient and appropriate
experience, technical ability and authority.
What is scope of
Ongoing Policy
Monitoring (annual)?
Evaluation of the firm's system of quality control. Firms can self monitor.
What is scope of
Completed File
Monitoring?
Inspection of at least one completed engagement file for each engagement partner every three years. Inspector has to be Independent. No involvement in performing the engagement or the EQCR.
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The EQCR
Question Response
What is the role? An objective evaluation of
judgments and conclusions.
Extent of
involvement?
• Attend planning meeting as observer
• Review/comment on planning decisions
• Provide consultation as needed
• Perform review of completed file
When? Audits of ALL listed entities.
When firm criteria for EQCR is met.
Who? Partner equivalent.
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EQCR vs. Completed File Monitoring
EQCR Completed File Monitoring
TASK Agree that audit report can be dated and release d
R eport on file deficiencies to MP
WHO Qualified Partner (or equivalent) not involved in engagement
Qualified person not involved in engagement or the E Q C R
PURPOSE Objective evaluation of significant judgments and conclusions reached
E valuation of the firm's QC system
SCOPE Specific Engagement file S a mple files selected
TIMING BEFORE audit report dated AFTER report issued
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Appendices to Sample Manuals
A. ANNUAL CONFIRMATION OF COMPLIANCE
B. SUGGESTED RESPONSIBILITIES FOR THE FIRM’S LEADERS
C. CONFIDENTIALITY AGREEMENT
D. ENGAGEMENT RISK ASSESSMENT - WORKSHEET
E. HIRING AN EXTERNAL CONSULTANT
F. WHEN TO CONSULT - WORKSHEET
G. USE OF CONSULTANTS - WORKSHEET
H. CRITERIA FOR WHEN AN EQCR IS REQUIRED
I. HIRING AN EXTERNAL PERSON TO PERFORM AN EQCR
J. EQCR WORKSHEET
K. HIRING AN EXTERNAL MONITOR
L. ONGOING POLICY MONITOR’S REPORT
M. COMPLETED FILE MONITOR’S WORKSHEET – AUDIT FILE
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Comparison between Old and
New Sample Manuals – App A
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Common QC Deficiencies
Ongoing (annual) monitoring reports not being prepared
Evaluation of whether EQCR is required on entities
other than listed
Auditor’s report not in compliance with CAS 700
Communications with those charged with governance
Determining whether design of internal controls effective
Assessment of RMM at the F/S and assertion levels
Documentation deficiencies:
Discussions with management and TCWG.
Substantive audit procedures.
Results of monitoring procedures performed and action plans.
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Summary of Benefits - QAM Update #4
Apply/comply with CSQC 1 and CAS 220
Develop/update your firm’s customized QA Manual
Assign leadership roles and document work performed
Practical Guidance
Continually improve your firm’s system of quality control
Staff appraisals
Annual confirmations, etc.
Sample engagement letters for external monitors
Organize, perform and prepare monitors’ reports for:
Ongoing policy monitoring (OPM)
Completed file monitoring (CFM)