At.3215 - Considering The Risk of Frauds Errors and NOCLAR
At.3215 - Considering The Risk of Frauds Errors and NOCLAR
At.3215 - Considering The Risk of Frauds Errors and NOCLAR
Since 1977
AT.3215
Considering the Risk of Frauds, Errors SOLIMAN/UY/RICAFRENTE
and Non-compliance with Laws and Regulations MAY 2022
References:
a. PSA 240 (Redrafted), The Auditor’s Responsibilities Relating to Fraud in an Audit of Financial Statements
b. PSA 250 (Redrafted), Considerations of Laws and Regulations in an Audit of Financial Statements
LECTURE NOTES
Auditor's Responsibility for Fraud and Error
The risk of the auditor not detecting management fraud is
Introduction greater than employee fraud, because management may
override otherwise effective internal controls.
The auditor is responsible for obtaining reasonable
assurance that the financial Statements taken as a whole Responsibility of Management and Those Charged
are free from material misstatement, whether caused with Governance (TCWG) vs. that of the Auditor
by fraud or error. Hence, the auditor’s responsibility for the
detection of fraud and error is essentially the same. The primary responsibility for the prevention and detection
of fraud rests with both TCWG of the entity and
Fraud refers to an intentional act by one or more individuals management. Management shall establish a control
among management, those charged with governance environment and implement internal control policies and
(TCWG), employees, or third parties, involving the use of procedures to prevent and detect fraud. On the other hand,
deception to obtain an unjust or illegal advantage. While, TCWG, through its oversight function, shall ensure the
error pertains to unintentional misstatements or omissions integrity of accounting and financial reporting systems and
in financial statements, including the omission of an amount that appropriate controls are in place.
or disclosure. Differentiating fraud from error requires
professional judgment. The risk of not detecting fraud is On the other hand, the auditor’s responsibility is to obtain
higher than that of error because fraud may be concealed, reasonable assurance about whether the financial
especially if through collusion. statements taken as a whole are free from material
misstatement, whether caused by fraud or error. The
Although fraud is a broad legal concept, the auditor is auditor is not responsible for discovering fraud, and is not
concerned with fraud that causes a material misstatement and cannot be held responsible for the prevention of
in the financial statements. In addition, the auditor does fraud. Unless the auditor has reason to believe the
not make legal determinations of whether fraud has actually contrary, the auditor may accept records and documents as
occurred. genuine. An audit rarely involves the authentication of
documents.
Types of Fraud
Summary of Auditor’s Consideration of Fraud
In relation to audit of financial statements:
Step Approach
• fraudulent financial reporting – involves intentional • Discussion among the
misstatements, including omissions of amounts or Staff discussion engagement team
disclosures in financial statements, to deceive financial Step of the risk of (Brainstorming)
statements users, normally involves management. 1. material • Consider fraud triangle
examples are the following: misstatement • Exercise professional
§ manipulation or falsification of financial records skepticism
§ misrepresentation or intentional omission of Obtain • Make inquiries of
information in the financial statements information management and others
§ intentional misapplication of accounting policies Step
needed to • Consider results of
identify risks of analytical procedures
2.
• misappropriation of assets (theft) - involves the theft of material • Consider fraud risk factors
an entity’s assets and is often perpetrated by employees misstatement • Consider other
in relatively small and immaterial amounts. however, it due to fraud information
can also involve management and TCWG. examples of For risks identified, consider
this type of fraud are the following: Identify risks • Type of risk that may
§ embezzling receipts that may result exist
§ lapping of accounts receivable Step
3.
in a material • Significance of risk
§ entity funds sent to a personal bank account misstatement (magnitude)
§ inventory items sold personally by entity employees due to fraud • Likelihood of risk
§ goods or services paid for by the entity but not • Pervasiveness of risk
received
• Consider understanding of
§ use of entity assets for personal use Assess the internal control
identified risks • Evaluate whether internal
As to perpetrator: Step
after controls address the
4.
considering identified risks
1. Management fraud – refers to fraud involving one or
internal controls • Assess risks taking into
more members of management or TCWG.
account this evaluation
2. Employee fraud – refers to fraud involving only
employees of the entity.
The important concepts of the above steps further discussed • Other Information
below.
The auditor shall consider whether other information
Auditor’s Consideration of Fraud obtained by the auditor indicates risk of material
misstatement (ROMM) due to fraud.
Discussion Among the Engagement Team
• Evaluation of Fraud Risk Factors
This discussion shall place particular emphasis on how and
where the entity’s financial statements may be susceptible Fraud risks factors refer to events or conditions that
to material misstatement due to fraud, including how fraud indicate an incentive or pressure to commit fraud or
might occur. The team shall set aside beliefs that provide an opportunity to commit fraud.
management and TCWG are honest and have integrity.
Identifying and Assessing the ROMM Due to Fraud
Fraud Triangle
The auditor shall identify and assess the ROMM due to fraud
The three conditions (the fraud triangle or characteristics) at the financial statements level, and at the assertion level
generally present when fraud occurs are: for classes of transactions, account balances and
disclosures.
1. Attitudes or rationalizations – Those involved in the
fraud are able to rationalize committing a fraudulent
act. This relates to either a person committing the
fraud, or to the entity’s control environment.
Responding to Assessed ROMM Due to Fraud • If material or unable to evaluate whether material or
immaterial:
• Overall Responses
§ Consider implications for audit, e.g., reliability of
The auditor shall determine overall responses to management representations
address the assessed risk of material misstatement due § Investigate further, i.e., discuss with appropriate
to fraud at the financial statements level. level of management (one level above the person
involved)
• Audit Procedures Responsive to Assessed Risks of § Obtain evidence of fraud and its effects
Material Misstatement Due to Fraud at the Assertion § Suggest client consult legal counsel
Level
Communication of Misstatements due to Fraud
The auditor shall design and perform further audit
procedures whose nature, timing and extent are In the exceptional circumstances where the auditor has
responsive to the assessed risk of material doubts about the integrity or honesty of management or
misstatement due to fraud at the assertion level. TCWG, the auditor may consider it appropriate to obtain
legal advice to assist in determining the appropriate course
• Audit Procedures Responsive to Risks Related to of action.
Management Override of Controls
• Communication To Management
Management is in a unique position to perpetrate fraud
because of management’s ability to manipulate accounting The communication enables management to act on a
records and prepare fraudulent financial statements by timely basis. The communication is made even if the
overriding controls that otherwise appears to be operating matter might be considered inconsequential (for
effectively. Due to the unpredictable way in which such example, a minor defalcation by an employee at a low
override could occur, it is a risk of material misstatement level in the entity’s organization). The determination
due to fraud and thus a significant risk. whom to communicate is a matter of professional
judgment which normally is at least one level above the
Irrespective of the auditor’s assessment of the risks of person involved.
management override of controls, the auditor shall design
and perform audit procedures to: • Communication With Those Charged With Governance
1. Test the journal entries and other adjustments made in The auditor’s communication with TCWG may be made
the preparation of the financial statements. orally or in writing. Due to the nature and sensitivity of
2. Review accounting estimates for biases. fraud involving senior management, or fraud that
3. For significant transactions that are outside the normal results in a material misstatement in the financial
course of business for the entity, or appear to be statements, the auditor reports such matters on a
unusual, the auditor shall evaluate business rationale timely basis and may consider it necessary to also
(or the lack thereof) of the transactions. report such matters in writing.
Evaluating Audit Evidence and Results of Audit In some cases, the auditor may consider it appropriate
to communicate with TCWG when the auditor becomes
Based on the audit procedures performed and the audit aware of fraud involving employees other than
evidence obtained, to evaluate whether the assessments of management that does not result in a material
the risk of material misstatement at the assertion level misstatement. Similarly, TCWG may wish to be
remain appropriate. This evaluation is primarily a informed of such circumstances.
qualitative matter based on the auditor’s judgment.
• Communications to Regulatory and Enforcement
• Analytical Procedures Performed in the Overall Review Authorities
of the Financial Statements
The auditor’s professional duty to maintain the
The auditor shall evaluate whether analytical confidentiality of client information may preclude
procedures that are performed when forming an overall reporting fraud to a party outside the client entity.
conclusion as to whether the financial statements as a However, the regulatory requirements, statute, the law
or courts of law overrides this duty. For example, under 5. Communications about fraud made to management,
a BSP requirement, the auditor of a financial institution TCWG, regulators and others; and
has a statutory duty to report the occurrence of fraud 6. Reasons for that conclusion risk of material
to the BSP. Also, under an SEC requirement, the auditor misstatement due to fraud related to revenue
has a duty to report material audit findings, such as recognition is not applicable.
those involving fraud or error.
Auditor’s Responsibility to Consider Laws and
Management Written Representations Regulations
• The entity does not take the appropriate action In relation to financial statements, there are two types:
regarding fraud that the auditor considers necessary,
even when the fraud is not material to the financial 1. Direct effect–Amounts and disclosures, as a result of
statements; compliance, are reported on the financial statements
such as tax and pension laws and regulations
• The auditor’s consideration of the risk of material
misstatement due to fraud and the results of audit tests
2. Indirect effect–Relates primarily to operations of the
indicate a significant risk of material and pervasive
entity but does not have a direct effect on an entity’s
fraud; or
financial statements. However non-compliance may
• The auditor has significant concern about the
result in fines, litigation or other consequences for the
competence or integrity of management or TCWG.
entity that may have a material effect on the financial
statements. Examples may include compliance with the
If, as a result of circumstances, the auditor shall:
terms of an operating license, regulatory solvency
requirements, or environmental regulations.
1. Consider whether it is appropriate to withdraw from the
engagement; and
Responsibility for Compliance with Laws and
2. If the auditor withdraws:
Regulations
• Discuss with the appropriate level of management Responsibility of Management for Compliance with Laws and
and TCWG, including the reasons thereof; and Regulations
• Determine whether there is a professional or legal
requirement to report to the person or persons or, Management, with the oversight of TCWG, is responsible for
in some cases, to regulatory authorities. ensuring that the entity’s operations are conducted in
accordance with laws and regulations.
Documentation
Responsibility of the Auditor
The auditor’s documentation shall include the:
The auditor is responsible for obtaining reasonable
1. Significant decisions reached during ‘brainstorming’ assurance that the financial statements, taken as a whole,
regarding the susceptibility of the entity’s financial are free from material misstatement, whether caused by
statements to material misstatement due to fraud; fraud or error.
2. Identified and assessed risk of material misstatement
due to fraud at the financial statements level and at the The auditor shall identify ROMM of the financial statements
assertion level. due to non-compliance with laws and regulations. However,
3. Responses to the assessed risk of material the auditor is not responsible for preventing non-compliance
misstatements: the overall responses and the nature, and cannot be expected to detect non-compliance with all
timing and extent of further audit procedures; laws and regulations. In the absence of evidence to the
4. Results of the audit procedures; contrary, the auditor is entitled to assume the entity is in
compliance with applicable laws and regulations affecting performing substantive tests of details of classes of
the client transactions, account balances or disclosures.
In the context of laws and regulations, the potential effects Written Representations
of inherent limitations on the auditor’s ability to detect
material misstatements are greater because: The auditor shall request management and, where
appropriate, TCWG to provide written representations that
• Many laws and regulations, relating principally to the all known instances of non-compliance or suspected non-
operating aspects of an entity, do not affect the financial compliance with laws and regulations whose effects should
statements. be considered when preparing financial statements have
• Non-compliance may be concealed, management been disclosed.
override of controls or intentional misrepresentations to
the auditor. No Identified or Suspected Non-compliance
• Whether an act constitutes non-compliance is ultimately
determined by a court of law. In the absence of identified or suspected non-compliance,
the auditor is not required to perform audit procedures
Ordinarily, the further removed non-compliance is from the regarding the entity’s compliance with laws and regulations,
events and transactions reflected in the financial other than those set out above.
statements, the less likely the auditor is to become aware
of it or to recognize the non-compliance. Audit Procedures When Non-Compliance Is Identified
or Suspected
The Auditor’s Consideration of Compliance with Laws
and Regulations The auditor shall obtain:
Obtaining an Understanding of the Legal and Regulatory 1. An understanding of the nature of the act and the
Framework circumstances in which it has occurred; and
2. Further information to evaluate the possible effect on
As part of obtaining an understanding of the entity and its the financial statements
environment, the auditor shall obtain a general
understanding of:
Summary of Auditor’s Responsibility for Fraud, Error and Non-compliance with Laws and Regulations
Non-compliance with laws & regulations
Errors Fraud Direct effect Indirect effect
Relate primarily to entity’s
operations but does not
Amounts and
have a direct effect on an
disclosures, as a
entity’s financial
Unintentional Intentional result of
statements. Non-
Definition misstatements or misstatements or compliance, are
compliance may result in
omissions omissions reported on the
fines, litigation or other
financial
consequences that may
statements
have a material effect on
the financial statements.
Two types—fraudulent
Mistake in processing financial reporting
accounting data, incorrect (falsification of Terms of an operating
Tax and pension
accounting estimates due accounting records) license, regulatory
Examples laws and
to oversight, mistakes in and misappropriation solvency requirements, or
regulations
application of accounting of assets environmental regulations.
principles (embezzlement or
theft)
1. Be aware of possibility
that they may have
occurred.
1. Assessment of ROMM.
2. Inquire of
2. Based on assessment,
management and
design audit to
TCWG regarding
provide reasonable
compliance.
assurance of detection
3. Inspect
of material
correspondence with
misstatements.
Detection regulatory authorities
3. Exercise due care in (Same as for
responsi- (Same as for errors) 4. 4. If specific
planning, performing, errors)
bility information comes to
and evaluating results
attention on an illegal
of audit procedures,
act with a possible
and proper degree of
material indirect
professional
financial statement
skepticism to achieve
effect, apply audit
reasonable assurance
procedures necessary
of detection.
to determine whether
illegal act has
occurred.
Reporting Modify auditor’s reports
(Same as for
responsi- for material misstatement (Same as for errors) (Same as for errors)
errors)
bility or inability to obtain SAAE
- done -
DISCUSSION QUESTIONS
Fraud and Error d. Misrepresentation in the financial statements of
events, transaction or other significant information.
Fraud vs. Error
3. The risk of not detecting a material misstatement
1. What differentiates fraud from an error? resulting from fraud is higher than the risk of not
a. Materiality. detecting a material misstatement resulting from error
b. Effect on misstatements. because
c. Intent. a. The effect of fraudulent act is likely omitted in the
d. Frequency of occurrence . accounting records.
b. Fraud is ordinarily accompanied by acts specifically
2. The following are examples of error, except designed to conceal its existence, and auditors do
a. A mistake in gathering or processing data from not make legal determinations of whether fraud has
which financial statements are prepared. actually occurred.
b. An incorrect accounting estimate arising from c. Fraud is always a result of connivance between or
oversight or misinterpretation of facts. among employees.
c. A mistake in the application of accounting principles d. The auditor is responsible to detect errors but not
relating to measurement, recognition, classification, fraud.
presentation, or disclosure.
14. Which of the following issues is normally part of the a. Capitalization of repairs and maintenance into the
“brainstorming” session required by PSAs? property, plant, and equipment asset account.
a. b. c. d. b. Improper revenue recognition.
How assets could be c. Improper interest expense accrual.
misappropriated Yes Yes Yes No d. Introduction of significant new products.
How and where the entity’s
financial statements are Responding to Assessed ROMM due to fraud
susceptible to material
misstatements due to Yes Yes Yes Yes 20. Statement 1: Auditors are required to perform
fraud extended audit procedures to detect material errors and
The need for professional irregularities if previously performed examinations
skepticism Yes No No Yes indicate that they may exist.
The audit team’s response to
potential fraud risks Yes Yes No No Statement 2: Audit procedures that are effective for
detecting an unintentional misstatement may be
Identifying and Assessing the ROMM due to Fraud ineffective for an intentional misstatement that is
concealed through collusion.
15. The fraud triangle consists of three components a. True, true c. False, true
(incentive or pressure, opportunity, and attitude or b. True, false d. False, false
rationalization). Which of the three components are
present in most every fraud? 21. Which of the following is most likely to be an overall
a. All three factors are usually present when fraud response to fraud risks identified in an audit?
occurs. a. Supervise members of the audit team less closely
b. Pressure and opportunity and rely more upon judgment.
c. Opportunity and rationalization b. Only use certified public accountants on the
d. Rationalization and pressure engagement.
c. Place increased emphasis on the audit of objective
16. Categories of fraud risk factors (whose presence often transactions rather than subjective transactions.
has been observed in circumstances where frauds have d. Use less predictable audit procedures.
occurred) in relation to misstatements arising from
misappropriation of assets and fraudulent financial 22. Which of the following is most likely to be a response to
reporting are opportunities, attitudes or the auditor's assessment that the risk of material
rationalizations, and pressures or incentives. Which of misstatement due to fraud for the existence of inventory
the following creates an opportunity for fraud to be is high?
committed in an organization? a. Observe test counts of inventory at certain locations
a. Management demands financial success or is on an unannounced basis.
aggressive in its application of accounting rules. b. Perform analytical procedures rather than taking
b. Poor internal control. test counts.
c. Commitments tied to debt covenants. c. Request that inventories be counted prior to year-
d. Finding loopholes in the accounting rules to achieve end.
earnings targets. d. Request that inventory counts at the various
locations be counted on different dates so as to
17. The following are examples of circumstances that may allow the same auditor to be present at every count.
indicate the possibility that the financial statements
may contain a material misstatement resulting from 23. As part of designing and performing procedures to
fraud, except address management override of controls, auditors
a. Transactions that are recorded in a complete or must perform which of the following procedures?
timely manner or are properly recorded as to a. b. c. d.
amount, accounting period, classification, or entity Review accounting estimates
policy. for biases Yes Yes Yes No
b. Unsupported or unauthorized balances or Examine all journal entries
transactions. above materiality Yes No Yes Yes
c. Last-minute adjustments that significantly affect Examine adjusting entries Yes Yes No Yes
financial results or unusual journal entries. Review unusual transactions Yes Yes No No
d. Tips or complaints to the auditor about alleged
fraud. Conclusion and Reporting
18. The following are examples of circumstances that may 24. Communication of a misstatement resulting from fraud,
indicate the possibility that the financial statements or a suspected fraud, or error to the appropriate level
may contain a material misstatement resulting from of management on a timely basis is important because
fraud, except it enables management to take action as necessary.
a. Missing documents. Ordinarily, the appropriate level of management is
b. Documents that appear to have been altered. a. At least equal to level of persons who appear to be
c. Unavailability of other than photocopied or involved with misstatements or suspected fraud
electronically transmitted documents when b. At least one level above persons who appear to be
documents in original form are expected to exist. involved with the misstatement or suspected fraud
d. Significant explained items on reconciliations. c. The audit committee of the board of directors
d. The head of internal audit department
19. Which of the following is most likely to be presumed to
represent fraud risk on an audit? 25. The auditor least likely obtains written representations
from management that:
d. Neither a nor b.
38. In assessing whether management has overlooked
34. According to PSA 250 (Consideration of Laws and relevant laws and regulations, the auditor would
Regulations in an Audit of Financial Statements), the perform all of the following except
following are indications that noncompliance may have a. Obtain written representations from management.
occurred, except b. Review relevant portions of grant and loan
a. Investigation by government departments or agreements.
payment of fines or penalties c. Confirm grant arrangements with granting
b. Adverse media comment agencies.
c. Authorized transactions or properly recorded d. Discuss laws and regulations with the entity's chief
transactions financial officer and legal counsel.
d. Purchasing at prices significantly above or below
market price 39. When an auditor becomes aware of a possible illegal act
by a client, the auditor should obtain an understanding
35. Examples of the type of information that may come to of the nature of the act to
the auditor's attention that may indicate that a. Increase the assessed level of control risk.
noncompliance with laws or regulations has occurred b. Recommend remedial actions to the audit
least likely include committee.
a. Payments for unspecified services or loans to c. Determine the reliability of management’s
consultants, related parties, employees or representations.
government employees. d. Evaluate the effect on the financial statements and
b. Payments for goods or services made other than to may consider seeking legal advice especially when
the country from which the goods or services involving members of senior management,
originated. including members of the board of directors.
c. Unauthorized transactions or improperly recorded
transactions. 40. Which of the following is the auditor least likely to do
d. Payments with proper exchange control when aware of an illegal act?
documentation. a. Discuss the matter with the client’s legal counsel.
b. Obtain evidence about the potential effect of the
36. When an auditor identifies or suspects instances of non- illegal act on the financial statements.
compliance with laws and regulations in relation to audit c. Consider the impact of the illegal act on the
of financial statements, the auditor shall relationship with the company’s management.
a. b. c. d. d. Contact the local law enforcement officials
Obtain understanding of the regarding potential criminal wrongdoing.
nature of the act. Yes Yes Yes No
Evaluate possible effect of End of AT.3215
noncompliance on financial
statements. Yes No Yes Yes
Discuss the matter with
management and TCWG. Yes Yes No Yes
Consider obtaining legal Yes Yes No No
advice.
Evaluate other audit
implications. Yes Yes No No