AI 20: Other Information in Documents Containing Audited Financial Statements: Auditing Interpretations of AS 2710

View AS 2710, Other Information in Documents Containing Audited Financial Statements   

[1.] Reports by Management on Internal Accounting Control

[.01-.06]        [Paragraphs deleted.]

2. Reports by Management on Internal Control Over Financial Reporting

.07        Question—Communications to various parties specified in paragraph .02 of AS 2710, Other Information in Documents Containing Audited Financial Statements, may include a separate report by management containing an assertion about the effectiveness of the entity's internal control over financial reporting. What is the auditor's responsibility concerning such report?

.08        Interpretation—If the auditor has been engaged to perform an audit of management's assessment of the effectiveness of internal control over financial reporting, the auditor should follow the requirement of AS 2201, An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements.

.09        If the auditor has not been engaged to perform an audit of management's assessment of the effectiveness of internal control over financial reporting, the auditor should follow the requirements in AS 3105.59–60. 

[.10]        [Paragraph deleted.]

.11        Because an auditor is required to consider internal control in an audit of the financial statements, he or she would often be familiar with matters covered in a management report on internal control over financial reporting. As a result, the auditor may become aware of information that causes him or her to believe that management's assertion on the effectiveness of internal control over financial reporting contains a material misstatement of fact as described in AS 2710.⁶ If the auditor becomes aware of information in the report by management that conflicts with his or her knowledge or understanding of such matters, he or she should discuss the information with the client. If, after discussions with the client, the auditor concludes that a material misstatement of fact exists, the auditor should follow the guidance in AS 2710.06.

3. Other References by Management to Internal Control Over Financial Reporting, Including References to the Independent Auditor

.12        Question—Communications to various parties specified in AS 2710.02 may include a statement by management about the entity's internal control over financial reporting. Such documents may also refer to the independent auditor in circumstances other than when the auditor has been engaged to examine and report on management's assertion about the effectiveness of internal control over financial reporting. What is the auditor's responsibility in such circumstances?

.13        Interpretation—The auditor should follow the guidance in AS 2710, which states that "the auditor has no obligation to perform any procedures to corroborate other information contained in [such] a document." Under AS 2710, the auditor is required to read other information in documents containing audited financial statements and consider whether it is materially inconsistent with information appearing in the financial statements and, as a result, he or she may become aware of a material misstatement of fact. If the auditor becomes aware of information in the report by management that conflicts with his or her knowledge or understanding of such matters, he or she should discuss the information with the client. If, after discussions with the client, the auditor concludes that a material misstatement of fact exists, the auditor should follow the guidance in AS 2710.06.

.14        Generally, management may discuss its responsibility for internal control over financial reporting and report on its effectiveness. In reading such information, the auditor should evaluate specific references by management that deal with the auditor's consideration of internal control in planning and performing the audit of the financial statements, particularly if such reference would lead the reader to assume the auditor had performed more work than required under PCAOB auditing standards or would lead the reader to believe that the auditor was giving assurances on internal control. The auditor should also consider whether management's comment or statement uses the auditor's name in such a way as to indicate or imply that the auditor's involvement is greater than is supported by the facts.⁷ If management misstates the auditor's responsibility for consideration of internal control over financial reporting, the auditor should discuss the matter with the client and consider whether any further action is needed in accordance with AS 2710.06.

.15        AI 12, Communications About Control Deficiencies in an Audit of Financial Statements: Auditing Interpretations of AS 1305, titled "Reporting on the Existence of Material Weaknesses" (AI 12.01-.07), permits an auditor to report to management that he or she has not become aware of any material weaknesses⁸ during his or her audit of the financial statements, but requires such reports to be solely for the information and use of the entity's audit committee, management and others within the organization. If, however, management decides to include or refer to this communication in a general use document, the auditor should communicate to management the restrictions on use of the communication and the potential for such a statement to be misunderstood. For example, the fact that an audit has not disclosed any material weaknesses does not necessarily mean none exist since an audit of the financial statements does not constitute an examination of a management assertion about the effectiveness of internal control over financial reporting. If management refuses to make appropriate changes to the report, the auditor should advise management that he or she has not consented to the use of his or her name and should consider what other actions might be appropriate. In considering what actions, if any, may be appropriate in the circumstances, the auditor may wish to consult legal counsel.

4. Other Information in Electronic Sites Containing Audited Financial Statements

.16        Question—An entity may make information available in public computer networks, such as the World Wide Web area of the Internet, an electronic bulletin board, the Securities and Exchange Commission's EDGAR system, or similar electronic venues (hereinafter, "electronic sites"). Information in electronic sites may include annual reports to shareholders, financial statements and other financial information, as well as press releases, product information and promotional material. When audited financial statements and the independent auditor's report thereon are included in an electronic site, what is the auditor's responsibility with respect to other information included in the electronic site?

.17        Interpretation—Electronic sites are a means of distributing information and are not "documents," as that term is used in AS 2710. Thus, auditors are not required by AS 2710 to read information contained in electronic sites, or to consider the consistency of other information (as that term is used in AS 2710) in electronic sites with the original documents.

.18        Auditors may be asked by their clients to render professional services with respect to information in electronic sites. Such services, which might take different forms, are not contemplated by AS 2710. Other auditing or attestation standards may apply, for example, agreed-upon procedures pursuant to AT section 201, Agreed-Upon Procedures Engagements, depending on the nature of the service requested.