The Season of ICFR

(Our apologies, the post is longer than usual, but it’s an important one)

Pumpkins, glorious foliage, and frost signal the arrival of Fall in NH, as well as hunting season.  Alas for many accountants, Fall signals the beginning of the assessment of internal control over financial reporting as calendar-year companies and their auditors start their interim testing and hunt for material weaknesses.  This year will likely be especially challenging due to recent PCAOB inspection report ICFR findings and guidance such as Staff Audit Practice Alert No. 11: Considerations for Audits of Internal Control over Financial Reporting, issued in October 2013.  The SEC has weighed in over the last year as well.  So, we thought it might be helpful as we start the ICFR season to increase your awareness of the PCAOB and SEC concerns over ICFR assessments and audits and point you to some resources worth reading.

Let’s start with the PCAOB.  It is no secret that the PCAOB inspection staff has focused on ICFR audits and has not been happy with a lot of them.  If this is news to you, just take a look at the inspection reports issued to the Big 4 over the last few years. The inspections staff expects the firms to show progress in addressing inspection findings in the next audit cycle, so the pressure is on.  As a result, it is very likely that your auditors will be changing their audit methodology in some way this year, which will ultimately trickle down to what you do.  So our recommendation to registrants is to be pro-active: read the last 2 inspection reports your auditor received (you can find them at, read Staff Alert No. 11 (find it at, and talk to your auditors about anticipated changes in your audit and their expectations.  And if you have an appetite for more, see an interesting speech by Board Member Jeanette Franzel at

The SEC has also expressed concern that some of the PCAOB’s inspection findings “are likely indicators of similar problems with management’s evaluation” (see Deputy Chief Accountant Brian Croteau’s speech last December at

For years, the SEC has voiced its concern that material weakness findings are lagging indicators, discovered as a result of a restatement, and not a leading indicator discovered in the ICFR assessment in time to prevent a restatement.  Case in point is the recent SEC Enforcement case against JDA Software Group.  The SEC investigation found that the company had inadequate internal controls over financial reporting, specifically in the area of revenue recognition, resulting in a multi year restatement.  And from Mr, Croteau’s remarks cited above there are more ICFR enforcement cases in the pipeline…

We hope this helps – happy hunting!

As always, we would love to hear your comments!

3 thoughts on “The Season of ICFR

    1. . I really do not see how these two propasols from PCAOB will result in greater audit transparency. Releasing the name of the engagement partner in the audit report will just allow the public knowledge of where to point the finger if something were to go wrong; it will not result in greater transparency. The only beneficial aspect that I can fathom would result from this proposal is that these auditors will use extra caution when issuing the audit report since their name is on it. While this is beneficial to the public because it may increase their confidence in the audit report, it will not do anything to increase their knowledge through transparency.

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