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Issue 3 | March 2015
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At-A-Glance
Last month we reported how big data
is transforming the audit and accounting
world. Accountants need to embrace
continuing technological changes or face
future irrelevance. In this issue, our
first article focuses on related, and
equally urgent, technological threats to
the security of accounting information.
A new report from COSO, the internal
control agency, offers a structured
approach for managing cyber risks.
Next, we turn to the landmark new
standards that change the look and
content of audit reports. The
pronouncements of the International
Auditing & Assurance Board (IAASB) call
for unprecedented depth and transparency
in the auditor’s report. Bearing
similarities to standards already in
place for the United Kingdom, and under
consideration by the PCAOB, the new
International Standards on Auditing
(ISAs) will be implemented widely in
2016.
Finally, Canadian accountants are
celebrating the new CPA Canada
designation. For Canada, the CPA
initials stand for Chartered
Professional Accountant, and consolidate
the three previously independent
organizations known by the CA, CMA and
CGA acronyms. Our third article
describes the multi-year process that
brought 40 regional and national
jurisdictions into agreement with this
forward-looking achievement.
Editor Gerald E. Herter, CPA |
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In This Issue
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Is Your Accounting Data Secure?
New report, COSO in the Cyber Age, offers
blueprint for bolstering cyber security
With almost daily reports of major new
internet attacks and identity thefts, we live in
a world paranoid as to when, not if, data
precious to us will be stolen. Recently on 60
Minutes, a weekly US news program, a segment
titled “DARPA: Nobody’s Safe on the Internet,”
featured Dan Kaufman, former video game
executive, who now heads up the information
innovation division at DARPA, the Defense
Advanced Research Projects Agency.
DARPA developed the internet back in the
sixties, and is responsible for maintaining the
US’s military technological superiority. Kaufman
showcased a video board map of the world that
displayed numerous continual flashes resembling
meteor trails in the sky. He explained that each
flash was a real time internet attack on a US
installation somewhere around the world. More
impressive was his remark that US technology was
automatically detecting and responding to the
attacks within microseconds. That information
relieved my fears a little, but only a little.
Though we don’t have the sophistication of
Mr. Kaufman’s video board in the accounting
world, COSO (Committee of Sponsoring
Organizations of the Treadway Commission) offers
tools that can help address cyber security
threats that we face. The new report, COSO in
the Cyber Age, issued in January, 2015, applies
the guidelines published in the 2013 COSO
pronouncement, Internal Control — Integrated
Framework (2013 Framework), to the technology
realm of accounting.
The report opens describing the business
world at the time the first version of the 2013
Framework was issued in 1992. The examples from
that era are eye opening, in showing just how
far technology has come in little more than 20
years. Back then:
- There were less than 14 million
Internet users worldwide in 1992, compared to
nearly 3 billion today;
- America Online (AOL)
for Microsoft DOS had been recently released;
- Microsoft Internet Explorer did not exist;
- Some of the most popular cell phones were “bag
phones”;
- Telephone and fax were the
predominant ways businesses communicated.
By contrast today, the report states:
- Customers’ orders are now processed
over electronic data interchanges on the
Internet with little or no human intervention;
- Business processes are often outsourced to
service providers, who are enabled by
interconnected networks;
- More and more
corporate personnel work remotely or from home,
with little need to come into the office;
- Inventory is tracked in warehouses through the
use of radio-frequency identification (RFID)
tags;
- Online only banks exist, and nearly all
banks offer Internet banking to customers.
As these examples show, business capabilities
have made colossal advances. However, while
savoring these gains, my fears started to rise
again when I read the report’s profound
statement: “The reality is that cyber risk is
not something that can be avoided; instead, it
must be managed.”
The 2013 Framework specifies the five
components of internal control: control
environment, risk assessment, control
activities, information and communication, and
monitoring activities. The report considers the
control environment and monitoring activities as
foundational, without which “it is likely that
an organization will be unable to understand
cyber risks sufficiently, deploy effectively
designed control activities, and respond
appropriately to address the cyber risks.”
An effective control environment and
monitoring activities in the technology arena
are considered by the report to require:
- Clear tone from the top regarding the
importance of protecting information systems;
- A program of ongoing and separate evaluations to
assess the design and operating effectiveness of
controls that are intended to reduce potential
cyber exposures;
- Assistance and involvement of
qualified cyber risk professionals;
- Appropriate monitoring of cyber risk and
controls related to outsourced service
providers;
- Proper and timely communication of
cyber deficiencies;
- Holding control owners
accountable to help protect information systems.
From the start, a proper attitude is needed
that drives a continual systematic approach.
Also, leaders need to recognize their own
limitations and bring in the expertise that can
competently address this highly technical area.
Once appropriate measures are in place,
consistent follow-up must occur that holds all
participants responsible, to minimize damaging
breaches.
In the risk assessment component,
perpetrators of cyber-attacks are variously
categorized as:
- Nation-states and spies;
- Organized criminals;
- Terrorists;
- Hacktivists;
- Insiders.
A retailer, such as Target Corporation, was
likely the “target” of organized criminals,
while Sony Pictures may have been hit by the
nation-state of North Korea, or possibly even
disgruntled insiders. Identifying the potential
threats helps to focus the type and scale of
protections needed.
Control activities can be developed both to
prevent and slow down attacks, while also
detecting on a timely basis, breaches that get
through. The report points out that while the
2013 Framework provides general guidelines, the
following are examples of cyber-focused
standards and frameworks with a more specific
focus:
- COBIT - Control Objectives for
Information and Related Technology is a
framework created by ISACA (formerly Information
Systems Audit and Control Association) that
enables managers to bridge the gap between
control requirements, technical issues and
business risks;
- ISO 27000 – Standards
developed by The International Organization for
Standardization (ISO) to enable organizations to
implement processes and controls that support
the principles of information security;
- Framework for Improving Critical Infrastructure
Cybersecurity is a framework released by
National Institute of Standards and Technology
of the U.S. Department of Commerce (NIST) that
builds on existing standards, guidelines, and
practices to guide organizations in practices
that reduce the potential impacts of cyber
risks.
With regards to the information/communication
component, information must be relevant and of
high quality, which is then communicated
effectively both internally and externally. In
last month’s Alert, we discussed the
implications of Big Data to the accounting
profession. In a cyber context, there needs to
be a capability to deal with the massive
quantities of data in order to filter out
irrelevant and inaccurate data. In addition to
internal efforts analysis and control of data,
the report points to industrial, governmental
and outsourced service providers as resources of
other data warranting consideration.
With the challenges of cyber security so
daunting, we all may wish we had a Dan Kaufman
from DARPA on our team. Since that is a luxury
most of us can only dream about, the next best
thing may be to develop a robust, structured
approach such as that outlined by COSO in the
Cyber Age. If the cost or effort required
appears too great, consider this ominous warning
from the report:
“If being secure, vigilant, and resilient has
not been a priority for your organization, it
will be eventually. If cyber risks are addressed
by reactive management, the damage from a cyber
attack could potentially be so severe that the
organization could cease to exist and operate.
Cyber risk will only continue to be more
difficult to manage as time passes, technology
evolves, and hackers become more sophisticated.
Invest now and make cyber risk management a
priority that receives similar attention as
other objectives that are strategic to the
organization.”
For further information, see
COSO in the Cyber Age.
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Audit Reports to Have a New Look
International Board issues groundbreaking
standards
The International Auditing & Assurance Board
(IAASB) was founded by the International
Federation of Accountants (IFAC) in 1978, as an
independent body for the purpose of producing
high quality auditing, quality control, and
other related standards, and for facilitating
the convergence of international and national
standards around the world. Currently, over 100
countries are using IAASB’s International
Standards on Auditing (ISA) or are committed to
implementing them in the near future. The work
of the IAASB is overseen by a group of 18
members from around the world, headed up by
Chairman Arnold Schilder from the Netherlands,
and Deputy Chair Charles Landes from the United
States.
On January 15, 2015, the IAASB issued
Reporting on Audited Financial Statements – New
and Revised Auditor Reporting Standards and
Related Conforming Amendments, which includes
new ISA 701, Communicating Key Audit Matters in
the Independent Auditor’s Report, and a number
of revised ISAs, including ISA 700 (Revised),
Forming an Opinion and Reporting on Financial
Statements, and ISA 570 (Revised), Going
Concern.
In a press release, Chairman Schilder stated:
"These changes will reinvigorate the audit, as
auditors substantively change their behavior and
how they communicate about their work. Informed
by extensive research and global outreach to
investors, regulators, audit oversight bodies,
national standard setters, auditors, preparers
of financial statements, audit committee
members, and others, the final International
Standards on Auditing (ISAs) represent a
momentous—and unprecedented—first step. Now, we
must study, promote, and plan for the effective
implementation of the new and revised
standards.”
The new standards generally follow the points
of the Exposure Draft issued in July, 2013, as
reported in the October, 2013 Audit & Accounting
Alert:
- Prominent placement of the auditor’s
opinion and other entity-specific information in
the auditor’s report;
- Auditor reporting on
“Key Audit Matters;”
- Auditor reporting on
going concern;
- An explicit statement that the
auditor is independent of the entity and has
fulfilled the auditor’s other relevant ethical
responsibilities, with disclosure of the
source(s) of those requirements;
- Disclosure
of the name of the engagement partner;
- Improved description of the responsibilities of
the auditor and key features of the audit.
Further details in the final standard
elaborate on these items:
- The opinion section is required to be
presented first, followed by the basis for
opinion section, unless law or regulation
prescribe otherwise;
- Key Audit Matters (KAM)
are those matters that, in the auditor’s
judgment, were of most significance in the audit
of the current period financial statements;
- Enhanced auditor reporting on going concern,
including: a) Description of the respective
responsibilities of management and the auditor
for going concern; b) A separate section when a
material uncertainty exists and is adequately
disclosed, under the heading “Material
Uncertainty Related to Going Concern.” If
disclosures are inadequate, a modified opinion
is to be rendered and placed at the front of the
auditor’s report; c) New requirement to
challenge adequacy of disclosures for “close
calls“ in view of the applicable financial
reporting framework when events or conditions
are identified that may cast significant doubt
on an entity’s ability to continue as a going
concern.
- Affirmative statement about the
auditor’s independence and fulfillment of
relevant ethical responsibilities, with
disclosure of the jurisdiction of origin of
those requirements or reference to the
International Ethics Standards Board for
Accountants’ Code of Ethics for Professional
Accountants;
- Disclosure of the name of the
engagement partner;
- Certain components of the
description of the auditor’s responsibilities
may be presented in an appendix to the auditor’s
report or, where law, regulation or national
auditing standards expressly permit, by
reference in the auditor’s report to a website
of an appropriate authority.
The United Kingdom is ahead of the
international community, with its Financial
Reporting Council (FRC) already having put new
audit report requirements in effect back in
October, 2013. As we reported then, the FRC
rules require auditors to:
- Describe the risks that had the
greatest effect on the overall audit strategy,
the allocation of resources in the audit, and
directing the efforts of the engagement team;
- Provide an explanation of how they applied the
concept of materiality in planning and
performing the audit;
- Provide an overview of
the scope of the audit, showing how this
addressed the risk and materiality
considerations.
The FRC applauded the new IAASB standards,
noting that “these changes are broadly
consistent with the amendments to the FRC’s
auditing standards to introduce extended auditor
reporting, in 2012 and 2013, which responded to
the same calls for change and have been widely
welcomed.”
Melanie McLaren, FRC Executive Director,
Codes and Standards added:
“The IAASB is to be congratulated on leading
change to the international standards for
auditor reporting. They represent the most
significant changes to the auditor reporting
model at international level for decades. They
have the potential to enhance investor
engagement about the audit and to provide a
catalyst for audit innovation in the interest of
investors and the public. We hope they will be
embraced enthusiastically by auditors and
investors internationally, as our recent changes
to auditor reporting have been in the UK and
Ireland. If so, they should herald in an era of
greater transparency about the audit for
investors in many of the world’s largest capital
markets.”
The PCAOB is still considering similar
changes that were proposed in August, 2013.
These would require:
- The communication of critical audit
matters as determined by the auditor;
- The
addition of new elements to the auditor's report
related to auditor independence, auditor tenure,
and the auditor's responsibilities for, and the
results of, the auditor's evaluation of other
information outside the financial statements;
and,
- Enhancements to existing language in the
auditor's report related to the auditor's
responsibilities for fraud and notes to the
financial statements.
An updated proposal from the PCAOB is
expected soon. While the details may differ from
the IAASB and FRC pronouncements, the new
standard should likewise call upon auditors to
provide more in depth information in audit
reports, and in the process to reexamine their
audit approaches.
For further information, see
The New Auditor's Report
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Canadian Accountants Unite
CAs, CMAs and CGAs join forces to become
Canadian CPAs
Recognizing the importance of projecting a
strong, united voice on the global stage, the
Canadian accountancy profession this past year
succeeded in combining its three diverse, yet
overlapping, accounting bodies into the new
Chartered Professional Accountants (CPA)
organization, CPA Canada. No easy task
considering that approvals were needed from 40
regional and national jurisdictions.
Nevertheless, the Chartered Accountants (CAs),
Certified Management Accountants (CMAs) and
Certified General Accountants (CGAs) agreed that
the timing and objectives were right, whereas
previous efforts had failed.
Among the challenges faced along the way was
finding a suitable name. The Chartered
Accountant designation is used by the British
Empire, a major player in Canada’s heritage.
However, Canada’s American neighbor to the south
employs the Certified Public Accountant title.
In a conciliatory gesture drawing from both
traditions, Chartered Professional Accountant
(CPA) was chosen.
In a 2011 position paper, the Canadian CA and
CMA organizations laid out a compelling case for
the consolidation, while carefully specifying
key practical steps necessary to gain support
from the independent groups. Increasingly,
international bodies are formulating accounting
and auditing standards. Global trade is
requiring more “inter-jurisdictional mobility,”
giving rise to new “global accounting
designations and strategic alliances among
accounting organizations.” With a fragmented
profession, Canada was not well positioned to
have a credible voice and play an effective role
on the world stage. Also, the overlapping bodies
were causing further confusion and inefficiency
within the country’s business community.
Eight guiding principles were laid out as the
merger process was pursued, and now provide the
framework for uniting the profession and
achieving CPA Canada’s vision of being the
pre-eminent, globally respected business and
accounting designation:
- Continued use of existing
designations – CA, CMA and CGA –along with the
new designation;
- Evolution to a new single
designation-CPA -over a period of time ending in
2022;
- Retention but no expansion of rights;
- Qualification - a new high-quality
certification program;
- Merged operations and
governance- of the existing bodies;
- Focus on
the CPA brand – and away from the prior
designations;
- Post qualification specialties
- optional certifications;
- Regulation and
licensing - a new uniform regulatory framework.
CPA Canada, with over 190,000 members, now
takes its place internationally as one of the
five largest national accounting organizations.
The next few years will bring even more
opportunities and challenges as the myriad of
international organizations and jurisdictions
strive to find ways to work more closely
together, while at the same time jockeying for
greater power in the standard setting arena.
In the near future, CPA Canada will work to
consolidate the Mutual Recognition Agreements
that the CA, CGA and CMA groups have with
accounting bodies regionally and in various
countries. Also, the CPA Canada certification
program will be offered directly in the
Caribbean and China.
For further information, see
CPA Canada.
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Audit & Accounting Alert
is a publication of Integra International intended
to highlight emerging issues in the profession.
The goal is to give Integra members an awareness
of developments impacting the practice of Audit &
Accounting, enabling them to stay on the forefront
of industry trends.
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Editor Gerald E. Herter •
HMWC CPAs & Business Advisors, 17501 E. 17th
Street, Suite 100, Tustin, CA 92780-7924
• Tel: 1 714 505-9000 • Fax: 1 714 505-9200 •
Email:
[email protected]
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