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Sarbanes Oxley Act - Auditing Standards

Public Company Accounting Oversight Board

Bylaws and Rules – Standards – AS3

June 9, 2004
AUDITING AND RELATED PROFESSIONAL PRACTICE STANDARDS
Auditing Standard No. 3 – Audit Documentation
 
Documentation of Specific Matters
 
10. Documentation of auditing procedures that involve the inspection of documents
or confirmation, including tests of details, tests of operating effectiveness of controls,
and walkthroughs, should include identification of the items inspected. Documentation
of auditing procedures related to the inspection of significant contracts or agreements
should include abstracts or copies of the documents.
 
Note: The identification of the items inspected may be satisfied by indicating the
source from which the items were selected and the specific selection criteria, for
example:
 
• If an audit sample is selected from a population of documents, the
documentation should include identifying characteristics (for example, the
specific check numbers of the items included in the sample).
 
• If all items over a specific dollar amount are selected from a population of
documents, the documentation need describe only the scope and the
identification of the population (for example, all checks over $10,000 from
the October disbursements journal).
 
• If a systematic sample is selected from a population of documents, the
documentation need only provide an identification of the source of the
documents and an indication of the starting point and the sampling interval
(for example, a systematic sample of sales invoices was selected from the
sales journal for the period from October 1 to December 31, starting with
invoice number 452 and selecting every 40th invoice).
 
11. Certain matters, such as auditor independence, staff training and proficiency and
client acceptance and retention, may be documented in a central repository for the
public accounting firm ("firm") or in the particular office participating in the engagement.
If such matters are documented in a central repository, the audit documentation of the
engagement should include a reference to the central repository. Documentation of
matters specific to a particular engagement should be included in the audit
documentation of the pertinent engagement.
 
12. The auditor must document significant findings or issues, actions taken to
address them (including additional evidence obtained), and the basis for the
conclusions reached in connection with each engagement. Significant findings or
issues are substantive matters that are important to the procedures performed,
evidence obtained, or conclusions reached, and include, but are not limited to, the
following:
 
a. Significant matters involving the selection, application, and consistency of
accounting principles, including related disclosures. Significant matters
include, but are not limited to, accounting for complex or unusual
transactions, accounting estimates, and uncertainties as well as related
management assumptions.
 
b. Results of auditing procedures that indicate a need for significant
modification of planned auditing procedures, the existence of material
misstatements, omissions in the financial statements, the existence of
significant deficiencies, or material weaknesses in internal control over
financial reporting.
 
c. Audit adjustments. For purposes of this standard, an audit adjustment is a
correction of a misstatement of the financial statements that was or should
have been proposed by the auditor, whether or not recorded by
management, that could, either individually or when aggregated with other
misstatements, have a material effect on the company's financial
statements.
 
d. Disagreements among members of the engagement team or with others
consulted on the engagement about final conclusions reached on
significant accounting or auditing matters.
 
e. Circumstances that cause significant difficulty in applying auditing
procedures.
 
f. Significant changes in the assessed level of audit risk for particular audit
areas and the auditor's response to those changes.
 
g. Any matters that could result in modification of the auditor's report.
 
13. The auditor must identify all significant findings or issues in an engagement
completion document. This document may include either all information necessary to
understand the significant findings, issues or cross-references, as appropriate, to other
available supporting audit documentation. This document, along with any documents
cross-referenced, should collectively be as specific as necessary in the circumstances
for a reviewer to gain a thorough understanding of the significant findings or issues.
Note: The engagement completion document prepared in connection with the
annual audit should include documentation of significant findings or issues
identified during the review of interim financial information.
 
Retention of and Subsequent Changes to Audit Documentation
 
14. The auditor must retain audit documentation for seven years from the date the
auditor grants permission to use the auditor's report in connection with the issuance of
the company's financial statements (report release date), unless a longer period of time
is required by law. If a report is not issued in connection with an engagement, then the
audit documentation must be retained for seven years from the date that fieldwork was
substantially completed. If the auditor was unable to complete the engagement, then
the audit documentation must be retained for seven years from the date the
engagement ceased.
 
15. Prior to the report release date, the auditor must have completed all necessary
auditing procedures and obtained sufficient evidence to support the representations in
the auditor's report. A complete and final set of audit documentation should be
assembled for retention as of a date not more than 45 days after the report release date
(documentation completion date). If a report is not issued in connection with an
engagement, then the documentation completion date should not be more than 45 days
from the date that fieldwork was substantially completed. If the auditor was unable to
complete the engagement, then the documentation completion date should not be more
than 45 days from the date the engagement ceased.
 
16. Circumstances may require additions to audit documentation after the report
release date. Audit documentation must not be deleted or discarded after the
documentation completion date, however, information may be added. Any
documentation added must indicate the date the information was added, the name of
the person who prepared the additional documentation, and the reason for adding it.
 
17. Other standards require the auditor to perform procedures subsequent to the
report release date in certain circumstances. For example, in accordance with AU sec.
711, Filings Under Federal Securities Statutes, auditors are required to perform certain
procedures up to the effective date of a registration statement.3/ The auditor must
identify and document any additions to audit documentation as a result of these
procedures consistent with the previous paragraph.
 
3/ Section 11 of the Securities Act of 1933 makes specific mention of the
auditor's responsibility as an expert when the auditor's report is included in a registration
statement under the 1933 Act.
 
18. The office of the firm issuing the auditor's report is responsible for ensuring that
all audit documentation sufficient to meet the requirements of paragraphs 4-13 of this
standard is prepared and retained. Audit documentation supporting the work performed
by other auditors (including auditors associated with other offices of the firm, affiliated
firms, or non-affiliated firms), must be retained by or be accessible to the office issuing
the auditor's report.4/
 
4/ Section 106(b) of the Sarbanes-Oxley Act of 2002 imposes certain
requirements concerning production of the work papers of a foreign public accounting
firm on whose opinion or services the auditor relies. Compliance with this standard
does not substitute for compliance with Section 106(b) or any other applicable law.

 

 

 

 

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