Auditing Revenue In Certain Industries, New Edition As Of June 1 . - CORE

1Overview: Audit Issues in Revenue RecognitionChapter 1Overview: Audit Issues inRevenue RecognitionResponsibility for Reliable Reporting1.01 This chapter discusses the responsibilities of management, boards ofdirectors, and audit committees for reliable financial reporting. It also providesan overview of the key accounting guidance relevant to revenue recognition forsales of goods and services, identifies circumstances and transactions that maysignal improper revenue recognition, and summarizes key aspects of theauditor’s responsibility to plan and perform an audit under generally acceptedauditing standards (GAAS).1.02 Management is responsible for the preparation and fair presenta tion of financial statements, including reported revenues. Among the finan cial reporting objectives relevant to assertions about revenue are thefollowing. Recorded sales during the accounting period represent actual ship ments of goods or rendering of services to customers who havemade firm, enforceable commitments to purchase such goods orservices. Deferred revenues are recognized in the appropriate period whenshipments are made, services are rendered, or other conditions requir ing deferral are no longer present. Estimated amounts of reserves for sales returns, provision for cus tomer rebates and dealer or customer discounts, and allowances foruncollectible receivables are reasonable. Policies for revenue recognition are adequately disclosed.11.03 Misstatements in reported revenue may result from error or fromfaulty judgment in the application of accounting principles. Revenue recog nition principles sometimes are difficult to apply, especially in complex orunusual transactions, and often vary by industry. Management may inap propriately use “aggressive” accounting policies that reflect their under standing of the economic substance of the transactions and of industrypractice. Misstatements in revenue also may arise when entity personnel atvarious levels participate in schemes, frequently with the collusion ofothers within the entity or with customers or suppliers, to overstate reve nues intentionally. Intentional misstatement of the financial statements isfraudulent financial reporting.1.04 This section of chapter 1, “Responsibility for Reliable Reporting,”discusses the factors and conditions within an enterprise that may mitigate therisk that improper revenue recognition will occur, whether it is caused by erroror fraud.1Revenue recognition in this Guide is understood to be in accordance with generally acceptedaccounting principles (GAAP).AAG-REV 1.04

2Auditing Revenues in Certain IndustriesDeterrents to Improper Revenue Recognition1.05 The National Commission on Fraudulent Financial Reporting,called the Treadway Commission (the Commission) after its Chairman, JamesC. Treadway, Jr., undertook a study from 1985 to 1987 to identify causalfactors that can lead to fraudulent financial reporting and to develop recom mendations to reduce its incidence. The Commission’s recommendations alsoare relevant for reducing the incidence of misstatements in financial reportingthat result from errors, including the unintentional misapplication of account ing principles. Some of the Commission’s recommendations for public com panies, including recommendations that address the tone set by topmanagement, the audit committee, the internal audit function, and internalcontrol, are discussed in the following paragraphs.Tone at the Top1.06 The Commission stated the following:The tone set by top management—the corporate environment or culture withinwhich financial reporting occurs—is the most important factor contributing tothe integrity of the financial reporting process. Notwithstanding an impressiveset of written rules and procedures, if the tone set by management is lax,fraudulent financial reporting is more likely to occur.21.07 The Commission recommended that top management and the boardof directors develop, communicate, and enforce a code of corporate conduct tofoster a strong ethical climate within the entity.Audit Committee of the Board of Directors1.08 The Commission recommended that the audit committee of theboard of directors be composed of independent (outside) directors. It alsorecommended that a written charter set forth their duties and responsibilities,and that they be given adequate resources and authority to fulfill their role ofinformed, vigilant, and effective overseers of the financial reporting processand the company’s internal controls. An effective audit committee can helpdeter improper conduct by management. The important role of the auditcommittee in corporate governance also has been discussed in reports by thePublic Oversight Board of the Securities and Exchange Commission (SEC)Practice Section of the AICPA.3 In 1998, Arthur Levitt, chairman of the SEC,and Lynn Turner, its chief accountant, reiterated the call for the empowermentof audit committees that function as qualified, independent, committed, andtough-minded guardians of investor interests and corporate accountability. Inresponse, the New York Stock Exchange (NYSE) and the National Associationof Securities Dealers (NASD) sponsored a Blue Ribbon Committee (BRC)drawn from the various constituencies of the financial community to studythe effectiveness of audit committees and to make concrete recommendationsfor improving audit committee oversight of the financial reporting process.The Report and Recommendations of the Blue Ribbon Committee on Improvingthe Effectiveness o f Corporate Audit Committees was issued in February1999. It included recommendations that the NYSE, the NASD, the SEC, and the2 Report of the National Commission on Fraudulent Financial Reporting, October 1987, p. 32.3 These reports are In the Public Interest: Issues Confronting the Accounting Profession, publish ed in March 1993, and Strengthening the Professionalism of the Independent Auditor, a Report to thePublic Oversight Board of the AICPA Securities and Exchange Commission (SEC) Practice Section,from the Advisory Panel on Auditor Independence, published in September 1994.AAG-REV 1.05

3Overview: Audit Issues in Revenue RecognitionAuditing Standards Board (ASB) take various actions to strengthen the inde pendence of the audit committee and make it more effective, and to addressmechanisms for accountability among the audit committee, the outside audi tors, and management.4Internal Audit Function1.09 The Commission recommended that companies maintain an effec tive internal audit function that is adequately staffed with qualified personnelappropriate to the size and nature of the company. To enhance the objectivityof the internal audit function, the chief internal auditor should have directaccess and report regularly to the company’s chief executive officer and to theaudit committee. An important responsibility of the internal audit function isto monitor the performance of an entity’s controls.Internal Control1.10 The Commission also recommended that a framework of internalcontrol be developed to enable management to identify and assess the risks offraudulent financial reporting, and to design and implement internal controlsthat will provide reasonable assurance that fraudulent financial reporting willbe prevented or subject to early detection. The outcome of this recommendationis Internal Control—Integrated Framework, a report published in 1992 by theCommittee of Sponsoring Organizations (COSO) of the Treadway Commission(the COSO Report). The COSO Report describes internal control as a processconsisting of five interrelated components that are necessary for entity objec tives, including reliable financial reporting, to be achieved. The five compo nents of internal control are the control environment, risk assessment, controlactivities, information and communication, and monitoring. Echoing the Com mission’s conclusion, the COSO Report states that the control environmentsets the tone of an organization, influencing the control consciousness of itspeople, and is the foundation for all other components of internal control.1.11 In addition, the Foreign Corrupt Practices Act of 1977 establishes alegal requirement that every SEC registrant devise and maintain a system ofinternal accounting controls sufficient to provide reasonable assurance thatcertain objectives are met, including that transactions are recorded as neces sary to permit preparation of financial statements in conformity with generallyaccepted accounting principles (GAAP). Some companies document the policiesthat management has established to comply with requirements of the ForeignCorrupt Practices Act and also require their employees, including the sales andmarketing organizations, to certify that they have read and complied with thecompany’s policies.Internal Control and Assertions About Revenue1.12 The significant financial statement accounts relating to manage ment’s assertions about revenue include sales, sales returns and allowances,4In December 1999, the Auditing Standards Board (ASB) issued Statement on Auditing Stand ards (SAS) No. 90, Audit Committee Communications (AICPA, Professional Standards, vol. 1, A Usecs. 380 and 722), in response to recommendations of the Blue Ribbon Committee (BRC). SAS No. 90amends SAS No. 61, Communications With Audit Committees (AICPA, Professional Standards, vol. 1,A U sec. 380) and SAS No. 71, Interim Financial Information (AICPA, Professional Standards, vol. 1,AU sec. 722). Among other things, SAS No. 90 requires an auditor of SEC registrants to discuss withaudit committees the auditor’s judgments about the quality, not just the acceptability, of the com pany’s accounting principles and underlying estimates. It encourages a three-way discussion amongthe auditor, the management, and the audit committee.AAG-REV 1.12

4Auditing Revenues in Certain Industriesservice revenue, accounts receivable and related allowance accounts, deferredrevenues, and cash. Management is responsible for the design, implementa tion, and effective operation of internal control over transactions in theseaccounts, including the development of significant accounting estimates anddisclosures, in order to achieve the financial reporting objectives that werediscussed in paragraph 1.02. Internal control with respect to assertions aboutrevenue is a process that involves management’s— Identification, analysis, and management of risks that may causemisstatements of accounts involving assertions about revenue, includ ing a consideration of how significant estimates are developed, thepossibility that unauthorized transactions may be recorded, and thepossibility that authorized transactions may be recorded erroneouslyor omitted. Design and implementation of an information system, which includesthe accounting system, and the methods and records established toaccurately record, process, summarize, and report transactions, aswell as the processes used to prepare significant accounting estimatesand disclosures, regarding assertions about revenue. Design and implementation of control activities, including docu mented policies and procedures applied in the processing of transac tions that flow through the accounting system in order to prevent, orpromptly detect, misstatements in revenue. Monitoring of the design and operating effectiveness of internal con trols over assertions about revenue to determine if they are operatingas intended, and if not, to take corrective action.1.13 Underlying the above, the control environment is the most signifi cant factor influencing the integrity of reported revenue. The control environ ment includes such factors as integrity and ethical values, management’sphilosophy and operating style, board of directors or audit committee participa tion, commitment to competence, and assignment of authority and responsibility.1.14 The COSO Report notes that internal control has inherent limita tions. The benefits of controls must be considered relative to costs due toresource constraints. Another limiting factor is faulty human judgment indecision making, or mistakes in application, on the part of a person responsiblefor establishing or performing a control. Furthermore, controls can be circum vented by the collusion of two or more people and by management override.1.15 Both the Treadway Commission and the COSO Report stress theimportance of management establishing and maintaining an appropriate toneat the top. An effective control environment fosters and in turn is reinforced byan effective audit committee, internal audit function, and internal controlprocess. Collectively, these functions support management in achieving itsobjective of fair presentation of financial information.Summary of Selected Accounting Literature onRevenue Recognition1.16 As noted previously, revenue recognition for purposes of this Guideis understood to mean in accordance with GAAP. This section of chapter 1summarizes some of the key authoritative accounting literature relevant torevenue recognition for sales of goods and services, including the conceptualAAG-REV 1.13

5Overview: Audit Issues in Revenue Recognitionbasis for revenue recognition and also specific revenue recognition guidance forright of return, bill and hold, contract accounting, and sales of software, amongothers. The following paragraphs are not intended to be a substitute for theoriginal pronouncements.Conceptual Basis for Revenue Recognition1.17 The conceptual basis for revenue recognition is contained in Finan cial Accounting Standards Board (FASB) Statement of Financial AccountingConcepts No. 5, Recognition and Measurement in Financial Statements ofBusiness Enterprises. Paragraph 83 states that recognition of rev

AICPA Auditing Revenues Steering Task Force to assist auditors in auditing assertions about revenue. The AICPA Auditing Standards Board has found the descriptions of auditing standards, procedures, and practices in this Audit Guide to be consistent with existing standards covered by rule 202 of the AICPA Code of Professional Conduct.