Proposed revisions clarify responsibilities for Accountants in Miami

Proposed revisions clarify responsibilities for Accountants in Miami.

In accordance with recently proposed revisions to professional standards, Accountants in Miami who prepare financial statements for clients would consider that a non attest bookkeeping services in Miami and would no longer be required to perform a compilation service with respect to those financial statements unless engaged to do so.

The changes, proposed in June by two AIAccountant committees, would require Accountants in Miami who prepare financial statements but are not engaged to perform a compilation, review, or audit, to request that management include a label or notation that makes clear that the financial statements were not compiled, reviewed, or audited. Alternatively, Accountant in Miami can attach a disclaimer to the financial statements to indicate when they have not been compiled, reviewed, or audited.

It is anticipated that the proposed changes would have minimal impact on Accountants who prepare financial statements for their clients, except with regard to the requirements to perform a compilation service, which will undergo significant revision under the proposal.

In accordance with current rules, a Accountants in Miami who prepares and presents financial statements to a client or third party must also perform the compilation service, whether or not the client has engaged the Accountant in Miami for the compilation.

The proposed standard would dictate that Accountants who prepare financial statements would perform a compilation only if they are engaged by their client to do so. The compilation would be a “read and report” service separate from the preparation. Once engaged to perform a compilation service, the Accountant would read the financial statements to see if there are obvious mistakes or flaws, and then issue an accountant’s compilation report on the financial statements.

This change is contained in a proposed Statement on Standards for Accounting and Review Services (SSARS) exposed for public comment by the AIAccountant Accounting and Review Services Committee (ARSC). ARSC has also exposed for public comment a proposed standard that addresses the accountant’s association with financial statements that the accountant has not compiled, reviewed, or audited.

The proposal that would make preparing financial statements and performing certain bookkeeping services Miami non attest services is contained in an exposure draft issued June 29 by the AIAccountant Professional Ethics Executive Committee (PEEC), the technical committee charged with interpreting and enforcing the AIAccountant Code of Professional Conduct. The nonattest services would be subject to the provisions of an AIAccountant professional standard on independence. The standard is Interpretation No. 101-3, “Performance of Nonattest Services,” under Rule 101, Independence (AIAccountant, Professional Standards, ET sec. 101 par. 05).

This proposed change would harmonize the ethical standards with the views of some Accountants in Miami who already consider the financial statement preparation to be a non-attest bookkeeping service in Miami. The proposal also would conform the standards to the revised independence standard issued in August 2011 by the U.S. Government Accountability Office (GAO), which indicates that financial statement preparation is not part of the audit service.

Specifically, the GAO’s revised standard includes a provision stating that non-attest bookkeeping service Miami, such as preparation of financial statements, cash-to-accrual conversions, and reconciliations, would be considered non-attest services, not routine services related to the performance of an audit. This standard is inconsistent with a nonauthoritative frequently asked question (FAQ) published by the Professional Ethics Division.

In this FAQ, the division took the position that preparing financial statements as part of an attest engagement would not be considered a non-attest service, provided the client’s records are substantially complete and current in order to conduct the attest engagement on those books and records. The FAQ further stated that if the member performed a service to bring those books and records current or complete, the service would be considered outside the scope of the normal attest engagement and, therefore, a Accountants in Miami subject to the requirements of Interpretation No. 101-3.

PEEC reconsidered the position taken in the FAQ and agreed to conform to the GAO position.

Interpretation No. 101-3 has been under review since November 2009, when PEEC learned of confusion and diversity in practice related to a provision within the interpretation that concluded independence would be impaired if a member established or maintained internal controls for a client. PEEC was advised that some members believed this provision prohibited certain activities for an attest client, such as preparing financial statements or reconciling accounts, because under the Committee of Sponsoring Organizations of the Treadway Commission’s Internal Control-Integrated Framework, such activities could be viewed as part of the system of internal control over financial reporting.

This belief conflicted with PEEC’s intention on how the provision governing establishing or maintaining internal controls should be applied. PEEC intended that the establishing-or-maintaining-of-internal-controls provision should apply to situations whereby the member, in effect, manages the internal audit activities of the client or situations when the member accepts responsibility for designing, implementing or maintaining internal controls for his or her clients. PEEC believed its intention was supported by the fact that 101-3 provides that independence can be maintained when Accountants assist clients with performing bookkeeping services, including financial statement preparation, and reconciling a client bank account when certain safeguards are in place.

At its meeting in May, PEEC approved two sets of revisions to 101-3. One set of revisions was previously exposed for comment and will take effect on Aug. 31, 2012. The second set of revisions appears in an omnibus ED from the Professional Ethics Division dated June 29, 2012. The revisions that are effective Aug. 31 include clarification that independence would be impaired if members accept responsibility for designing, implementing, or maintaining controls for a client but would not impair independence if members perform certain nonattest services, including Accountants in Miami services such as preparation of financial statements or preparing account reconciliations, provided certain safeguards are in place.

IMPACT ON THE AUDITING, REVIEW, AND COMPILATION STANDARDS

Current auditing, review, and compilation standards permit the Accountants in Miami to prepare or draft financial statements, in whole or part, as part of the attest engagement:

Auditing standards (paragraph .03 of AU section 110, Responsibilities and Functions of the Independent Accountant [AIAccountant, Professional Standards]) state that the independent Accountant may make suggestions about the form or content of the financial statements or draft them, in whole or in part, based on the information from management during the performance of the audit.

Review standards are silent with respect to the preparation of financial statements, but it is understood that accountants often prepare financial statements as part of a typical review engagement.

Compilation standards (paragraph .01 of AR section 80, Compilation of Financial Statements [AIAccountant, Professional Standards]) state that the Accountants in Miami is required to comply with the provisions of AR section 80 whenever he or she is engaged to report on compiled financial statements or submits financial statements to a client or third parties. Paragraph .04 of AR section 60, Framework for Performing and Reporting on Compilation and Review Engagements (AIAccountant, Professional Standards), defines submission of financial statements as presented to management financial statements the accountant has prepared.

Because any financial statement preparation or drafting would be considered a non-attest service under the PEEC proposal, clarifications to these standards will be necessary. The audit and review standards can be easily clarified by including a footnote or other language that states that the provisions of 101-3 apply when the Accountant or accountant prepares financial statements. But the compilation standards will require more extensive revision, which is addressed in the proposed SSARS exposed by ARSC.

As a result of the PEEC and ARSC revisions, an engagement to prepare financial statements would be a non attest service and not subject to the compilation standard. To make clear the accountant’s responsibility when the accountant is engaged to prepare financial statements but is not engaged to perform a compilation engagement, ARSC has also exposed for public comment an additional proposed standard. That proposal addresses the accountant’s responsibilities when he or she is associated with financial statements that have not been compiled, reviewed, or audited. That proposed standard would require certain legends, notations, or disclaimer language to be placed on or with the financial statements when the accountant prepares financial statements but has not compiled, reviewed, or audited the financial statements. This association standard is in response to a public interest concern that anyone using financial statements that have been prepared, in whole or part, by Accountants in Miami understands that those financial statements have been prepared without audit, review, or compilation.

The proposed association standard would be effective for unaudited financial statements with which the accountant is associated on or after Dec. 15, 2014. The proposed revisions to the compilation standard would be effective for compilations of financial statements for periods ending on or after Dec. 15, 2014.

The proposed effective date of the revisions to Interpretation No. 101-3 would be two years from the date when the revision is published in the JofA. Early implementation of the proposed revisions to 101-3 and the new SSARSs would be permitted so that accountants can implement the revised standards simultaneously.

EXECUTIVE SUMMARY

Recently proposed revisions to professional standards would require Accountants who prepare financial statements for clients to consider that service a non-attest bookkeeping service in Miami. The Accountants would no longer be required to perform a compilation service with respect to those financial statements unless specifically engaged to do so. The proposed changes would consider all financial statement preparation to be a non-attest service, regardless of whether the accountant also is engaged to compile, review, or audit the financial statements.

Accountants who prepare financial statements would perform a compilation only if they are engaged by their client to do so in accordance with the proposed standard. The compilation would be a “read and report” service separate from the preparation of the financial statements. Once engaged to perform a compilation service, the Accountants in Miami would read the financial statements to see if there are obvious mistakes or flaws, and then issue an accountant’s compilation report on the financial statements.

The changes proposed would harmonize the professional standards with the views of some practitioners who already consider the financial statement preparation to be a non-attest service, and would confirm the standards to corresponding U.S. Government Accountability Office (GAO) literature.

Proposed changes include a standard addressing the accountant’s association with financial statements that he or she has not compiled, reviewed, or audited. The proposal would require Accountants in Miami who prepare financial statements but are not engaged to perform a compilation, review, or audit engagement, to request that management include a label or notation that makes clear that the financial statements were not audited, reviewed, or compiled. Alternatively, Accountants can attach a disclaimer to the financial statements to indicate when they have not compiled, reviewed, or audited the financial statements.

The proposed changes are expected to have minimal impact on Accountants who prepare financial statements for their clients, except with regard to the requirement to perform a compilation service, which would be revised significantly under the proposal.