2017年-普华永道全球_PwC_responds_to_PCAOB’s_proposal_related_to_supervision_of_other_auditors_15页_446kb

PCAOB Rulemaking Docket Matter No. 042 Summary

Core Content

The document outlines the comments provided by a firm in response to the PCAOB's Supplemental Request for Comment (SRC) regarding proposed amendments to audit standards related to the supervision of audits involving other auditors. The firm supports the PCAOB's objective of improving audit quality and promoting consistency in audit supervision, but raises several concerns about the feasibility and effectiveness of the proposed changes.

Main Views and Key Points

1. General Concerns

• Lack of Specificity: The PCAOB's proposals lack detailed information on the intended objectives and specific problems to be addressed, making it difficult to provide targeted recommendations.
• Scalability Issues: The standard is not appropriately scalable and does not consider the varying needs of different audit firms, particularly large global networks versus smaller firms.
• Inefficiency and Cost: The proposed requirements could be costly and inefficient, especially for lead auditors who may not have the capacity to assess the processes of other auditors in detail.
• Confidentiality and Proprietary Information: When other auditors are not part of the same network, lead auditors may face practical challenges in obtaining detailed information due to confidentiality restrictions.

2. Independence and Ethics

• Written Representation: The firm supports the requirement for other auditors to provide written representations regarding compliance with independence and ethics requirements.
• Concerns with "Understanding Process": The firm does not support the requirement for lead auditors to gain an understanding of the other auditor's process for determining compliance with independence and ethics requirements, as it is neither effective nor efficient.
• Recommendation: Instead, the PCAOB should require a written statement from the other auditor confirming that their firm has appropriate policies and procedures to assess independence and ethics compliance.

3. Supervision and Review

• Supervisory Team Members: The firm recommends explicitly incorporating the guidance from the release into AS 1201.04 to clarify that supervisory team members can be from the lead auditor's firm or from other auditors.
• Knowledge, Skill, and Ability: The firm believes that the lead auditor can rely on network-level policies and procedures and previous experience with the other auditor to assess their knowledge, skill, and ability.
• Inquiries About Policies: The firm is concerned that firm-level inquiries about training and assignment policies may be unnecessary and inefficient, especially when the other auditor is not part of the same network.

4. Balance of Responsibilities

• Risk-Based Approach: The firm supports a risk-based approach to supervision, where the lead auditor's level of involvement is commensurate with the risk of material misstatement.
• Lead Auditor's Role: The lead auditor should focus on reviewing documentation and refining the other auditor's risk assessment, rather than conducting detailed risk assessments at the assertion level for each location.
• Summary Memorandum: The firm supports the use of a summary memorandum and recommends that it may include the documentation required by AS 1215.19.

5. Documentation and Review

• Flexibility in Documentation: The firm emphasizes the need for flexibility in the lead auditor's approach to obtaining, reviewing, and retaining documentation, especially in the context of cross-border audits and language requirements.
• Recommendation: The firm suggests deleting AS 1201.B2c and incorporating its content into AS 1201.B2d, allowing the lead auditor to determine the necessary level of detail in the summary memorandum.

Key Recommendations

• Reconsider the "Understanding Process" Requirement: The firm does not support the lead auditor gaining an understanding of the other auditor's process for determining compliance with independence and ethics requirements.
• Clarify Supervisory Team Composition: Incorporate the release's guidance into AS 1201.04 to clarify that supervisory team members can be from other auditors.
• Tailor Inquiries Based on Network Status: Inquiries about other auditors' policies and procedures should be based on whether they are part of the same network.
• Revise Documentation Requirements: Modify AS 1201.B2c to allow for more flexibility in the lead auditor's review of documentation, based on the risk level and the nature of the audit engagement.
• Provide Guidance for Non-Network Auditors: The PCAOB should provide guidance on how to handle situations where other auditors are not part of the same network, including confidentiality and communication challenges.

Conclusion

The firm acknowledges the importance of audit quality and the need for consistent supervision in multi-location audits, but urges the PCAOB to consider the practical challenges and varying firm structures before finalizing the standard. It recommends further outreach, clarification, and a more flexible and scalable approach to supervision and compliance with independence and ethics requirements.