What information do we need to gather related to an identified control deficiency

What information do we need to gather related to an identified control deficiency

There are three levels of deficiencies that the auditor will report on in regard to the assessment of an organization’s internal controls. The three types include:

What information do we need to gather related to an identified control deficiency

Control deficiencies – A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. Control deficiencies are less severe than significant deficiencies.

Significant deficiencies – A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a material weakness, yet important enough to merit attention by those charged with governance.

Material Weakness – A material weakness is a deficiency, or combination of deficiencies, in internal control, such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented or detected and corrected on a timely basis.


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  • May 2022

    Management is responsible for maintaining a system of internal control over financial reporting (ICFR) that provides reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements in accordance with the applicable accounting principles framework. The Securities and Exchange Commission (SEC) rules require management of registrants to evaluate on an annual basis whether ICFR is effective at providing reasonable assurance and to disclose its assessment to investors. In supporting its assessment, management is responsible for maintaining evidential matter, including documentation.

    Our guide Management Mini Guide for Evaluating Control Deficiencies was developed to assist management in evaluating identified control deficiencies individually and in the aggregate. While the guide focuses on SEC requirements and the responsibilities of management and the audit committee in the assessment and documentation of an identified control deficiency, this guide is also relevant for private companies, as the deficiency evaluation process is consistent.

      The guide will assist management through the process, including:

    1. Identification of the deficiency
    2. Considerations over the magnitude and likelihood of a potential misstatement
    3. Identification of compensating controls
    4. Assessment of deficiencies for potential aggregation
    5. Conclusions on the severity of the deficiency
    6. Documentation of conclusions and reporting considerations
     

    Additionally, this guide includes important reminders related to the remediation of identified control deficiencies.

      
     

    This guide focuses on the responsibilities and key issues management must consider when evaluating and identifying control deficiencies within their businesses. We will discuss a six-step system that can be applied to the evaluation process. The goals for this process are to help us discover which control(s) failed and why; identify the potential impact that the deficiency may have on financial statements; gather and analyze information about the deficiency including the root cause of the control failure; and finally, once a conclusion is reached as to the severity of the control deficiency, step back and reflect whether the conclusion reached properly supports, documents, and communicates the necessary information concerning a deficiency.

    DEFINITIONS

    Control Deficiency: The design or operation of a control over your financial reporting that does not allow management or employees, in the normal course of performing their assigned duties, to prevent or detect misstatements in a timely manner.

    Material Weakness: A deficiency, or a combination of deficiencies, in internal control over financial reporting such that there is a reasonable possibility that a material misstatement of the company’s annual or interim financial statements will not be prevented or detected in a timely manner.

    Significant Deficiency: A deficiency, or a combination of deficiencies, in internal control over financial reporting that is less severe than a material weakness, yet important enough to merit attention by those responsible for oversight of the company's financial reporting.

    RESPONSIBILITY OF MANAGEMENT IN EVALUATING CONTROL DEFICIENCIES

    The Securities Exchange Act of 1934 outlines that it is management’s responsibility to assess the severity of any deficiencies discovered, whether identified by you as management, an internal audit, or external auditors. It’s important to keep in mind that the severity of a control deficiency is not limited to whether misstatement has occurred, but the potential of misstatement occurring in the future if it’s not addressed. Management must address and communicate deficiencies in a timely manner. Proper evaluation of control deficiencies can assist you in determining how deficiencies may affect your records and financial statements, as well as how you might improve control processes to address any identified deficiencies. Now let’s look at the steps of the evaluation process.

    CONTROL DEFICIENCY EVALUATION PROCESS

    STEP 1: Identify the deficiency and matters to be considered

    Once a deficiency has been identified, you should begin to determine the nature and cause of the deficiency. Was there a misstatement identified as part of the deficiency? Was the period the deficiency was taking place during the current fiscal year? And questions concerning who is responsible for the operation of control and additional facts regarding any implementation and operation of controls in the deficiency should be considered as well.

    STEP 2: Analyze the facts: consider the magnitude and likelihood of potential misstatement

    It’s very important in this step to remember to account for the future as well as the present impacts when determining the potential magnitude of a deficiency on your financial statements. In this step we should also ask: what is the reasonable possibility that a deficiency, individually or in aggregate, will result in a misstatement?

    STEP 3: Identify compensating controls

    The severity of a deficiency may be offset by the presence of effectively designed, implemented, and operating controls. Questions that help to identify if a control could offset a deficiency are: did it help or could it help in identifying the deficiency, were the controls operating effectively during the period the deficiency was present, and are there other compensating controls that help reduce the overall impact of the deficiency?

    STEP 4: Assess deficiencies for potential aggregation

    When determining whether deficiencies should be combined due to potentially impacting the same area on your financial statements, you should look for any noted commonalities or differences in the deficiencies identified. This includes details like the nature, the underlying root cause, and component of internal control of the deficiencies.

    STEP 5: Conclude on severity of the deficiency

    Once you have gathered and analyzed the relevant facts, a judgment is to be made on the severity of a deficiency individually and in the aggregate with other deficiencies, as needed. Using the information and determinations made in the previous steps, you should determine whether it is a control deficiency, significant deficiency, or a material weakness.

    STEP 6: Document conclusions and reporting considerations

    Once a judgment has been made as to the severity of the deficiency, you should document your process for its conclusions to support the final assessment. This documentation may also be used by an external auditor to evaluate your conclusions. Additionally, management must consider the reporting implications depending on the severity of the deficiency and communicate accordingly. Material weaknesses should be reported by management on the Internal Control over Financial Reporting document for all public entities. Private companies do not have such a reporting requirement.

    The final step is to evaluate and implement a change to your internal control system to correct the deficiency. Doing so not only alleviates the possibility of incorrect financial reporting but can also reduce the likelihood that an employee will exploit the deficiency to perpetrate fraud. The professionals at HHM can assist you in this endeavor.

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    What information do we need to gather related to an identified control deficiency

    What are the considerations an auditor must take into account when deciding whether a control deficiency is severe or a material weakness?

    Furthermore, in determining whether a control deficiency, or combination of deficiencies, is a significant deficiency or a material weakness, the auditor should evaluate the effect of compensating controls and whether such compensating controls are effective.

    What is the first step in the three step process for identifying and evaluating control deficiencies?

    Evaluating Internal Control Deficiencies Guide.
    STEP 1: Identify the deficiency and matters to be considered. ... .
    STEP 2: Analyze the facts: consider the magnitude and likelihood of potential misstatement. ... .
    STEP 3: Identify compensating controls. ... .
    STEP 4: Assess deficiencies for potential aggregation..

    What factors does management consider when assessing identified control deficiencies?

    Define the terms significant deficiency and material weakness. What factors does management consider when assessing identified control deficiencies?.
    Higher Audit Risk..
    Higher Control Risk..
    Higher Detection Risk..
    Higher Inherent Risk..

    When should we communicate control deficiencies to management?

    The written communication should be made prior to the issuance of the auditor's report on the financial statements. The auditor's communication should distinguish clearly between those matters considered significant deficiencies and those considered material weaknesses, as defined in paragraphs 2 and 3.