The Institutes guidance on client representations had a good 20-year run, but its been replaced by a new model with a few changes and even some custom features. The new SAS no. 85, Management Representations , supersedes SAS no. 19, Client Representations , and its interpretation no. 2, Management Representations When Current Management Was Not Present During the Period Under Audit . The new SAS acknowledges the changes in auditing practice and the audit environment over the past two decades. Show
Reliance On Management Representations However, SAS no. 85 includes new guidance requiring the auditor to investigate the circumstances and consider the reliability of a representation made if other audit evidence contradicts that representation. In such a case, an auditor should consider whether the reliance placed on other management representations is appropriate and justified. Obtaining Written Representations The new statement includes a list of specific management representations that are consistent with representations auditors are obtaining in current practice. These include information concerning fraud as referred to in SAS no. 82, Consideration of Fraud in a Financial Statement Audit , and significant estimates and material concentrations required under SOP 94-6, Disclosure of Certain Significant Risks and Uncertainties . Also required now is a management representation stating it is managements belief that the financial statements are fairly presented in conformity with GAAP (or a comprehensive basis of accounting other than GAAP). An illustrative management representation letter provides an example of how management could present this. Small, privately owned companies with no accounting staff and limited knowledge of GAAP may place a certain level of reliance on the auditors for the fair presentation of the financial statements. Such clients often are reluctant to make representations regarding GAAP without mentioning their reliance on the auditors. In such a case, an auditor may suggest that the client include wording in the representation letter similar to the following: I am responsible for the fair presentation in the financial statements of financial position, results of operations, and changes in financial position in conformity with generally accepted accounting principles. Because of my limited expertise with generally accepted accounting principles, including financial statement disclosure, I have engaged you to advise me in fulfilling that responsibility. Tailoring Materiality Dating The ASB noted a wide diversity in practice for dating the letter, so it added language in SAS no. 85 as guidance when the client signs the letter after the date of the auditors report. Since the auditor is concerned with events that have occurred through the date of the reportwhich may require adjustment to or disclosure in the financial statementsthe managements representations should be made as of a date no earlier than the date of the report. The illustrative management representation letter includes the following wording management could use when dating the representations: We confirm, to the best of our knowledge and belief, [as of (date of auditors report),] the following representations made to you during your audit(s). This wording is appropriate when the letter is dated subsequent to the date of the auditors report. Also, if the audit report is dual dated, the auditor should consider whether a representation regarding the subsequent event is appropriate. The auditor is referred to the guidance found in paragraph .05 of AU section 530, Dating of the Independent Auditors Report, in AICPA Professional Standards . Updating Representations Letters
SAS no. 85 also describes the matters to include in an updating management representation letter. The letter should say whether
SAS no. 85 includes an illustrative updating management representation letter in Appendix C. Appendix D, Amendment to SAS No. 58, Reports on Audited Financial Statements includes a revision to AU sec. 508.71 which reflects the above guidance now found in SAS no. 85. Scope Limitations
If management does not allow the auditor to perform necessary procedures during the audit, even if management provides a representation regarding the matter, the auditor should consider this a scope limitation and either issue a qualified opinion or disclaim an opinion. Effective Date What are the audit implications if management refuses to give a representation letter?(c) If the management refuses to provide written representation, the auditor will issue a qualified report or disclaimer. As part of the audit process, the management provides written representation to confirm certain matters in connection with the audit.
What type of opinion may be expressed if the auditor is unable provide an opinion on financial statements due to an independence issue?Qualified Opinion vs.
A qualified opinion is a reflection of the auditor's inability to give an unqualified, or clean, audit opinion. An unqualified opinion is issued if the financial statements are presumed to be free from material misstatements.
What is the type of audit opinion to be expressed if the auditor does not have enough sufficient appropriate audit evidence?A disclaimer of opinion is expressed by an Auditor when the possible effect of limitation on the scope of the audit is so material and pervasive that the auditor has not been able to obtain sufficient appropriate audit evidence.
What type of opinion is issued by the auditor if he or she is unable to determine the overall fairness of the financial statements?If the auditor is unable to obtain sufficient appropriate audit evidence to have a reasonable basis to conclude about whether the financial statements as a whole are free of material misstatement, AS 3105 indicates that the auditor should express a qualified opinion or a disclaimer of opinion.
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