April 4, 2011
Technical Director
International Auditing and Assurance Standards Board
545 Fifth Avenue, 14th Floor
New York, New York 10017 USA
Submitted electronically at: www.iasb.org
Re: IAASB Consultation Paper –
Proposed IAASB Strategy and Work Program for 2012–2014
The New York State Society of Certified Public Accountants, representing more
than 28,000 CPAs in public practice, industry, government and education, welcomes the
opportunity to comment on the above captioned consultation paper.
The NYSSCPA’s Auditing Standards and International Accounting and Auditing
Committees deliberated the consultation paper and prepared the attached comments. If
you would like additional discussion with us, please contact Jan C. Herringer, Chair of
the Auditing Standards Committee at (212) 885-8133, or Ernest J. Markezin, NYSSCPA
staff, at (212) 719-8303.
Sincerely,
NYSSCPA
NYSSCPA
Margaret A. Wood
President
Attachment
NEW YORK STATE SOCIETY OF
CERTIFIED PUBLIC ACCOUNTANTS
COMMENTS ON
IAASB CONSULTATION PAPER – PROPOSED IAASB STRATEGY AND
WORK PROGRAM FOR 2012–2014
April 4, 2011
Principal Drafters
Jan C. Herringer
Julian E. Jacoby
Renee Mikalopas-Cassidy
NYSSCPA 2010 – 2011 Board of Directors
Margaret A. Wood,
President
Richard E. Piluso,
President-elect
Joseph M. Falbo Jr.,
Secretary/Treasurer
Scott M. Adair,
Vice President
David R. Herman,
Vice President
Martha A. Jaeckle,
Vice President
Gail M. Kinsella,
Vice President
Joanne S. Barry,
ex officio
John Barone
Cynthia D. Barry
S. David Belsky
Ian J. Benjamin
Robert W. Berliner
Anthony Cassella
Sherry L. DelleBovi
Adrian P. Fitzsimons
Stephen E. Franciosa
Jennifer R. George
Rosemarie A. GiovinazzoBarnickel
Mitchell L. Gusler
John B. Huttlinger Jr.
Nancy A. Kirby
J. Michael Kirkland
Mark G. Leeds
Pei-Cen Lin
Heather Losi
Anthony J. Maltese
Barbara A. Marino
David J. Moynihan
Avery E. Neumark
Joel C. Quall
Robert R. Ritz
Erin Scanlon
Robert E. Sohr
George I. Victor
Charles J. Weintraub
Jesse J. Wheeler
F. Michael Zovistoski
NYSSCPA 2010 – 2011 Accounting & Auditing Oversight Committee
Rita M. Piazza, Chair
Anthony S. Chan
Sharon S. Fierstein
Jay H. Goldberg
Jan C. Herringer
Edward P. Ichart
Elliot A. Lesser
Mark Mycio
Michael A. Pinna
William M. Stocker III
NYSSCPA 2010 – 2011 Auditing Standards Committee
Jan C. Herringer, Chair
Kamel Abouchacra
Robert Berliner
Roberto Bolanos
Sharon Campbell
Santo Chiarelli
Steven Connors
Robert Cordero
Ryan Crowe
J. Roger Donohue
John Georger
Fred Goldstein
Menachem Halpert
Julian Jacoby
Michael Kayser
Elliot Lesser
Moshe Levitin
Ralph Lucarello
Mark Mycio
Lawrence Nalitt
Wayne Nast
Bernard Newman
John Parcell
William Prue
John Sacco
Mark Springer
Stephen Tuffy
Robert Waxman
NYSSCPA 2010 – 2011 International Accounting and Auditing Committee
William M. Stocker III, Chair
Renee Mikalopas-Cassidy,
Vice-Chair
Ma. Efleda Almadin
Timothy Andrews
Gudmundur Atlason
Sidney Barclais
Francesco Bellandi
Oliver Binns
Kenneth Bosin
Lori Catapano
Andreas Chrysostomou
Remi Forgeas
John Galiski
James Hadfield
Jan Herringer
Richard Jeffreys
Richard Jones
Hisham Kader
Steven Kahn
Steve Lehrer
Rosario Manco
NYSSCPA Staff
Ernest J. Markezin
John McCurdy
Michael McMurtry
Matthew Redente
Bhoj Raj Rijal
Weiran Song
Elizabeth Venuti
George Victor
Lynn Wayne
Patrick Yaghdjian
Eric Yu
Yan Zhang
New York State Society of Certified Public Accountants
Comments on
IAASB Consultation Paper –
Proposed IAASB Strategy and Work Program for 2012–2014
The New York State Society of Certified Public Accountants is pleased to submit
the following comments in response to the request by the International Auditing and
Assurance Standards Board (IAASB) for comments on the proposed IAASB Strategy and
Work Program for 2012 - 2014.
Overall Comments
Overall, we support the proposed IAASB strategy and work program for 2012 –
2014 (“proposed strategy and work program”) set out in the consultation paper that
focuses to a large extent on monitoring the effective implementation of the International
Standards on Auditing (ISAs), including assisting small and medium sized practitioners
in this regard, and responding to the needs of the investing community as the accounting
standards become more complex. We believe such monitoring is essential to ensure the
clarified ISAs are clear and understandable by practitioners across multiple jurisdictions.
While we are supportive of the proposed strategy and work program, we have the
following over-arching comments for your consideration, followed by our responses to
the specific questions posed in the consultation paper.
We support the focus of the IAASB proposed strategy and work program to
monitor the implementation of the clarified ISAs, as we believe anecdotal evidence
indicates that smaller firms may require assistance in implementing risk assessments
appropriately. Further, since smaller firms often use the audit methodologies and work
programs developed by third party providers, we encourage the IAASB to monitor not
only the implementation of the clarified ISAs by firms, but also the development of the
audit methodologies by these third party providers to ensure compliance with the clarified
ISAs.
As part of the monitoring process, we believe one area of focus should be to
understand how firms and third party providers have incorporated the application
guidance into their audit methodologies. Our understanding is that the application
guidance is essential to understanding how to apply the requirements. However, we
believe that there is confusion about the authority of such guidance, and how this
guidance is meant to fit into a firm’s audit methodology.
In addition to the areas of focus set out in the consultation paper, we believe that
certain of the clarified ISAs should be revisited to enhance practice in the areas of audit
1
sampling1 and materiality2 and ensure consistent application. There is a short window of
opportunity for the IAASB to enhance these standards, and we encourage the IAASB to
take advantage of this opportunity, since once the clarified ISAs are adopted into law in
those jurisdictions that require such adoption, any revisions will likely be difficult.
Another area of focus that we believe is critical is the need to work with the
accounting standard setters to ensure the provisions within the accounting standards are
auditable and susceptible to measurement. While additional ISAs or requirements to the
clarified ISAs may not be necessary to address the challenges facing auditors in
addressing the provisions in accounting standards that rely increasingly on estimates and
judgments, we believe additional guidance in the form of application guidance, staff
Q&As, or practice aids is appropriate.
Our responses to the specific questions posed in the consultation paper are set out
below.
Specific Questions Posed to Respondents
(per Guide for Respondents, p. 20 of Consultation Paper)
15. The IAASB invites comments on any aspect of the proposed strategy and
possible actions to implement the proposed strategy and specifically:
Are the IAASB’s three areas of strategic focus noted in paragraphs 7-11
appropriate?
Overall, we agree that the three areas of strategic focus: (1) developing and
revising standards and pronouncements, (2) monitoring and facilitating adoption of those
standards, and (3) responding to concerns about the consistent implementation of the
standards, remain appropriate. In addition, as mentioned earlier, we encourage the
IAASB, as part of its implementation and monitoring process, to more fully communicate
to users that the application guidance included within the clarified ISAs, while not
requirements, are essential to understanding how to apply the requirements.
We have noted that in certain instances, practitioners have not fully considered
the application guidance in the ISAs, in part because of a misunderstanding of the
importance of the application guidance to the proper application of the ISA requirements.
We note that the International Standard on Quality Control (ISQC) 1, Quality Controls
for Firms that Perform Audits and Reviews of Financial Statements, and Other
Assurance and Related Engagements, paragraph 8, explains the authority of the
application guidance as follows:
1
ISA 530, Audit Sampling
2
ISA 320, Materiality in Planning and Performing an Audit
2
Where necessary, the application and other explanatory material provide
further explanation of the requirements and guidance for carrying them out. In
particular it may:


Explain more precisely what a requirement means or is intended to
cover; and
Include examples of policies and procedures that may be appropriate
in the circumstances
While such guidance does not in itself impose a requirement it is relevant to
the proper application of the requirements. [Emphasis added.]
Additionally, paragraph 19 of ISA 200, Overall Objectives of the Independent
Auditor And the Conduct of an Audit in Accordance with International Standards on
Auditing, states that:
The auditor shall have an understanding of the entire text of an ISA, including
its application and other explanatory material, to understand its objectives and
apply its requirements properly.
To ensure the appropriate consideration of the guidance set out in ISQC 1 and the
ISAs, we recommend developing further communications explaining its importance in
implementing the ISAs.
Does the list of anticipated projects likely to commence in 2012-2014 (Column B)
adequately address issues currently facing the accounting and auditing professions?
Generally, we believe the list of anticipated projects likely to commence in 20122014 (Column B) are appropriate. In addition to these projects, as noted above, we
believe that, in conjunction with the Implementation Monitoring Project, the auditing
standards on audit sampling and materiality should be revisited. Including such projects
would enhance audit quality.
While the concept of statistical sampling has been part of the auditor’s toolkit for
many years (in the United States, the original standard on audit sampling was issued in
1982), statistical sampling has continued to be somewhat of a mystery to many auditors.
We believe that the increased availability of statistical sampling tools, coupled with
additional education about the benefits of statistical sampling in evaluating the
sufficiency of audit evidence and a revised standard that promotes the use of statistical
sampling, would provide the resources necessary to advance its use. The ability of the
auditor to measure the precision of an audit procedure is a significantly better outcome
for the evaluation of the sufficiency of audit evidence and the Board’s objective to
improve audit quality.
On May 29, 2009, the NYSSCPA commented on the AICPA Auditing Standards
Board’s corresponding proposed standard on Audit Sampling. Its content continues to be
3
applicable, and we invite you to review the points made in that letter regarding statistical
sampling and materiality for incorporation into the clarified ISAs. We have attached that
letter as an appendix for your convenience.
Additionally, with respect to materiality, we believe that the discussion in ISA
320, Materiality in Planning and Performing an Audit, is incomplete. While the concept
of materiality as it relates to the evaluation of findings is well developed and understood,
the application of the concept of materiality to planning and scoping is less so. For
example, in certain circumstances, materiality benchmarks determined using performance
measures are not practical when a statistical sampling approach is used to audit
significant assertions.
We believe there should be a better distinction in the ISA between materiality
used for planning (scoping) procedures and materiality used to determine a threshold for
adjustment (evaluation purposes). To illustrate this, if an entity is on the cusp of a debt
covenant, the guidance in the clarified ISA is unclear about how materiality for scoping
purposes would work. Accordingly, we recommend including guidance in the ISA to
explain that the appropriate solution would be to use a normal level of materiality to
scope work and to use zero as an adjustment threshold. In other words, an auditor would
not significantly expand scope to identify misstatements (how much you look for), but
instead propose adjustments for all misstatements found.
Further, when materiality is determined using a benchmark approach that results
in a small value, the resulting planning materiality value (used to determine the extent of
work) is not reasonable. This occurs because materiality needs to contain a factor for
sampling precision (the difference between tolerable error and projected error) at the
financial statement level. This is not discussed in the sampling literature or in ISA 320.
For this reason, we suggest clarifying the difference between accounting materiality (used
in the evaluation of misstatements) and audit materiality (used to plan and scope the
audit) in the ISA.
(i) Do respondents support the IAASB undertaking work in these areas (Column B)
and, if not, the reasons why a particular project(s) would not be supported?
We support the IAASB undertaking work in the areas noted within Column B, in
addition to the projects described above.
(ii) Do respondents believe these projects are consistent with the IAASB’s three
areas of strategic focus?
Yes, we believe the projects are consistent with the three areas of strategic focus.
(iii) How should these anticipated projects be prioritized in light of the current
projects (Column A)?
4
We believe that the more significant projects in Column B, in addition to the
projects described earlier, in order of importance, are as follows:
B.1 Undertake new project(s) to respond to findings of the ISA Implementation
Monitoring project, in consultation with the IAASB CAG – output in the form of
a revised ISA(s), new ISS, IAPS, or other form, as deemed appropriate.
B.4 Through the ISA Implementation Monitoring project and other outreach
activities, take a proactive role in identifying implementation challenges and seek
to develop materials aimed at addressing these challenges, working with NSS,
IFAC member bodies and others.
B.5 Seek feedback from service organizations, service auditors, user entities, user
auditors, and others on their experiences with the implementation of ISAE 3402,
Assurance Reports on Controls at a Service Organization.
We have no particular preference to the prioritization of projects B.2, B.3, or B.6.
(c) With respect to the additional projects (Column C):
Which of the suggestions, if any, should be considered for inclusion on the future
work program, and how should these be prioritized in light of the current projects
(Column A) and anticipated projects likely to commence in 2012-2014 (Column B)?
We believe that the following three projects, listed in order of importance, should
be considered for inclusion on the future work program. Further, we believe that work on
project C.1 should begin as soon as possible due to (1) the importance of banking
institutions to the effective functioning of international markets and (2) the recent
withdrawal of the extant IAPSs. While we acknowledge that such an undertaking by the
IAASB may require the assistance of others such as banking regulators and supervisors,
as well as audit firm experts, we believe such a project is essential.
C.1 In consultation with banking regulators and supervisors, consider undertaking
a project with regard to IAPS 1004, The Relationship between Banking
Supervisors and Banks’ External Auditors, and IAPS 1006, Audits of the
Financial Statements of Banks, for the audit of banks.
C.5 Evaluate whether to develop a new ISAE addressing assurance on corporate
governance statements.
C.4 Evaluate whether to develop a new ISAE addressing assurance on
sustainability reporting.
Whether any particular project(s) in Column C would not be supported and
whether there are additional actions or projects that respondents believe should be
5
addressed, and, if so, how these should be prioritized in relation to the projects
identified in Columns B and C?
In the longer term, the development of additional industry specific guidance
would be helpful in areas such as banking, as mentioned above, ecommerce, and
insurance.
Further, we believe it would be appropriate to monitor developments related to
XBRL Reporting, as it relates to users’ expectations that such data be subject to some
form of auditor reporting.
16. The IAASB intends to devote the majority of its efforts on the projects in
Column A through 2011 and into 2012 and beyond to progress these projects on a
timely basis. If respondents support commencing the majority of the anticipated
projects (Column B), the IAASB currently anticipates it will have resources and
time to commence 3 further new projects, although substantive activity for these
new projects would not be expected to commence before 2013.
Respondents are therefore specifically asked to select the top three projects either
from, or in addition to, the list of suggestions for additional projects (Column C)
that they believe would best meet the IAASB’s public interest mandate. However,
outreach activities, the findings of the ISA Implementation Monitoring project, the
fundamental debates about the role of the auditor, and unforeseen events beyond
the IAASB’s control may require the IAASB to amend its Work Program or
reprioritize its agenda.
In addition to the projects relating to audit sampling and materiality, please also
refer to our response to question 15 (c).
17. The IAASB notes that, depending on the priorities identified by respondents, the
balance of the IAASB’s future time spent on auditing and implementation of the
ISAs as compared to development of new assurance standards may vary
significantly. For this reason, it would also be helpful to understand which one
project (either from Column B, Column C or an additional action not included in
either column) respondents would identify as the IAASB’s top priority, in order for
the IAASB to consider how each of the three areas of strategic focus would be
addressed in the future Work Program.
We believe that the revision of the standards on audit sampling and materiality
should be a top priority of the Board for the reasons set out earlier in our letter.
18. In addition, the IAASB would welcome comments from respondents as to the
following:
(a) What types of publications or further implementation guidance may be of most
use to facilitate the adoption and implementation of the IAASB’s pronouncements?
6
In addition to the matters described in our response to question 15 above, we
believe additional implementation guidance in the form of a staff bulletin or Q&A around
the use of substantive analytical procedures would be helpful to practitioners. We have
noted that some audit methodologies have been developed that place reliance on
substantive procedures to address the risk of material misstatement when such reliance
may not be warranted. While substantive analytical procedures may be efficient and
effective in reducing audit risk at the assertion level to an acceptably low level in certain
situations, we believe that practitioners may be inappropriately applying the guidance in
ISA 520, Analytical Procedures, and placing undue reliance on such procedures.
Accordingly, we encourage the IAASB to include an assessment of the implementation
of this particular standard as part of the monitoring and implementation project (see
project B.1).
(b) What opportunities may exist for the IAASB to partner with others to facilitate
implementation of the clarified ISAs (for example, IFAC member bodies, NSS,
training organizations, and others)?
We have no comments on this matter.
7
Appendix
May 29, 2009
Ms. Sherry Hazel
AICPA
1211 Avenue of the Americas
New York, N.Y. 10036-8775
By e-mail: [email protected]
Re: Proposed Statement on Auditing Standards, Audit Sampling (Redrafted)
Dear Ms. Hazel:
The New York State Society of Certified Public Accountants, representing 30,000 CPAs
in public practice, industry, government and education, welcomes the opportunity to comment on
the above captioned exposure draft.
The NYSSCPA’s Auditing Standards Committee deliberated the exposure draft and
prepared the attached comments. If you would like additional discussion with us, please contact
Robert N. Waxman, Chair of the Auditing Standards Committee at (212) 755-3400, or Ernest J.
Markezin, NYSSCPA staff, at (212) 719-8303.
Sincerely,
N Y S S C P A
Sharon Sabba Fierstein
President
Attachment
NEW YORK STATE SOCIETY OF
CERTIFIED PUBLIC ACCOUNTANTS
COMMENTS ON
PROPOSED STATEMENT ON AUDITING STANDARDS, AUDIT SAMPLING
(REDRAFTED)
May 29, 2009
Principal Drafters
Neal B. Hitzig
Julian E. Jacoby
Paul D. Warner
NYSSCPA 2008 – 2009 Board of Directors
Sharon Sabba Fierstein,
President
David J. Moynihan,
President-elect
Richard E. Piluso,
Secretary/Treasurer
Barbara S. Dwyer,
Vice President
Joseph M. Falbo Jr.,
Vice President
Elliot L. Hendler,
Vice President
Margaret A. Wood,
Vice President
Louis Grumet, ex officio
Scott M. Adair
Edward L. Arcara
Cynthia D. Barry
John Barone
Susan M. Barossi
S. David Belsky
Anthony Cassella
Robert L. Goecks
David R. Herman
Scott Hotalen
John B. Huttlinger, Jr.
Martha A. Jaeckle
Suzanne M. Jensen
Lauren L. Kincaid
Gail M. Kinsella
Nancy A. Kirby
J. Michael Kirkland
Kevin Leifer
Elliot A. Lesser
David A. Lifson
Anthony J. Maltese
Mark L. Meinberg
Avery E. Neumark
Robert A. Pryba, Jr.
Joel C. Quall
Ita M. Rahilly
Judith I. Seidman
Thomas M. VanHatten
Liren Wei
Charles J. Weintraub
NYSSCPA 2008 – 2009 Accounting & Auditing Oversight Committee
Mitchell J. Mertz, Chair
Michael J. Aroyo
Robert W. Berliner
Edward P. Ichart
Thomas O. Linder
Rita M. Piazza
William M. Stocker III
Bruce I. Sussman
Ira M. Talbi
George I. Victor
Robert N. Waxman
NYSSCPA 2008 – 2009 Auditing Standards Committee
Robert N. Waxman, Chair
Gillad C. Avnit
Robert W. Berliner
Karin Blaney
Rosanne G. Bowen
Sharon M. Campbell
Robert Cordero
Vincent Gaudiuso
Fred R. Goldstein
John F. Georger, Jr.
Menachem M. Halpert
Jan C. Herringer
Neal B. Hitzig
Anil Kumar
Elliot A. Lesser
Moshe S. Levitin
Ralph Lucarello
Michael R. McMurtry
Mark Mycio
Lawrence E. Nalitt
Wayne Nast
Bernard H. Newman
NYSSCPA Staff
Ernest J. Markezin
William R. Lalli
John C. Parcell IV
William J. Prue
Andrew W. Reiss
Michael A. Sabatini
John M. Sacco
Mark Springer
Stephen P. Tuffy
Richard T. Van Osten
Paul D. Warner
Anna Zubets
New York State Society of Certified Public Accountants
Auditing Standards Committee
Comments on
Proposed Statement on Auditing Standards, Audit Sampling (Redrafted)
The New York State Society of Certified Public Accountants welcomes the opportunity
to comment on the AICPA Auditing Standards Board’s (ASB) Proposed Statement on
Auditing Standards, Audit Sampling, (Redrafted).
General Comments
We support the ASB’s efforts to improve the audit testing procedures undertaken during
an audit and to converge the proposed standards with International Standards on Auditing
(ISAs). However, we believe that the ASB missed an opportunity to strengthen SAS 39,
Audit Sampling. A stated objective of the proposal is to improve the clarity of ASB
standards. Yet, as discussed below, we find that the exposure draft (ED) perpetuates two
of the most serious deficiencies of SAS 39. First, it places “nonstatistical” sampling on an
equal evidentiary footing with statistical sampling despite the fact that the reasons for
doing so have evaporated long ago; second, it permits the auditor to disregard readily
obtainable and statistically valid results from a probability sample by the expedience of
labeling such a sample “nonstatistical.”
The ED does not provide a clear approach to the evaluation of samples by stressing the
relationship of the sample point estimate to risk. The appropriate measurement instrument
for any sample that satisfies the “representativeness” requirement should be a confidence
interval that is universally accepted. Statement on Audit Procedures Number 54, and
Statistical Auditing, by Donald M. Roberts (AICPA, 1978) provide such guidance. The
incorporation of much of the verbiage of ISA 530 in the interest of “convergence” will
result in a document that will contain the technical errors that exist in SAS 39 and the
deletion of significant, relevant items.
This ED does not contain any indication of any results of an audit sample that can
provide a basis for proposing an adjusting journal entry to correct for misstatements. The
orientation of this ED appears to provide a basis for rationalizing or disregarding adverse
sample results.
The conceptual errors in and omissions from the proposed standard, if adopted as written,
could result in practitioners who are inexperienced in statistical theory being exposed to
serious risk of liability when faced by knowledgeable and credible experts in adversarial
proceedings.
1
Further, we believe that it would have been helpful if the AICPA Audit and Accounting
Guide, Audit Sampling, had been published subsequent to the publication of the final
standard so that it would have been derived from the ultimate guidance provided by this
ED.
We suggest that this ED be revised as indicated in our comments.
Requested responses
1. Are the auditor’s objectives appropriate?
The auditor’s objective, as expressed in paragraph 4 of the ED, is appropriate.
2. Are the revisions made to converge the existing standard with ISA No. 530
(Redrafted) appropriate?
The revisions are not appropriate because we believe that ISA No. 530
(Redrafted) is flawed. International convergence should not be an end in itself,
especially if there are problems with the standard toward which convergence is
directed.
3. Are the differences between the proposed SAS and ISA No. 530 (Redrafted)
identified in the exhibit, and other language changes, appropriate?
Where there are differences between the ED and ISA No. 530, they are frequently
inappropriate, as discussed below.
Specific Comments
All ED text is in italics, followed by our comments.
Definitions
Haphazard selection. The approximation of random selection without the use of a
structured selection technique, such as a random number generator. It is the selection of
sampling units without any intentional bias; that is, without any special reason for
including or omitting items from the sample. Haphazard selection does not consist of
selecting sampling units in a careless manner and is implemented in a manner such that
the auditor expects the resulting sample to be representative of the population.
Despite its common usage, “haphazard” is an unfortunate choice of words,
notwithstanding the “careless manner” sentence. A better choice of terms is
“informal.” If substituted for “haphazard,” the use of “informal” would obviate the
need for the last sentence.
2
Population. The entire set of data from which a sample is selected and about which the
auditor wishes to draw conclusions.
This is factually incorrect and, consequently, misleading. The data from which the
sample is selected and the data about which the auditor wishes to draw conclusions
may not be congruent. The latter data is the population; but the former data comprise
the “frame.” Ideally, there should be no difference between the two data sets.
However, this is frequently not the case in practice. In most audit applications, the
frame is a list or file from which the selected items are identified. If there are items in
the population that are not in the frame, the list is incomplete (a failure of a key
transactions or account balance assertion) and the test yields invalid results. If, there
are items in the frame that do not belong to the population of interest, those items
need to be identified and treated accordingly. For example, in a substantive test of
details, such items, if not extracted before sampling, would be assigned a monetary
misstatement value of zero; the average misstatement would be projected to the
frame, yielding an unbiased estimate (the projection) of the total misstatement.
In order to improve practice, the ED should distinguish between the population and
the frame by defining both terms. By doing so, the ED would more effectively guide
auditors to perform procedures to address appropriately differences that may exist.
Sampling risk. The risk that the auditor’s conclusion based on a sample may be different
from the conclusion if the entire population was subjected to the same audit procedure.
Sampling risk can lead to two types of erroneous conclusions:
a. In the case of a test of controls, that controls are more effective than they
actually are or, in the case of a test of details, that a material misstatement does not
exist when in fact it does. The auditor is primarily concerned with this type of
erroneous conclusion because it affects audit effectiveness and is more likely to lead
to an inappropriate audit opinion. [Emphasis added.]
The ED implies that a test of controls might not be a test of details and vice versa.
This is incorrect and is contrary to long-standing usage in practice. The term “test
of details,” when intended to exclude a test of controls, has always been expressed
with the adjective “substantive” preceding it. A test of details (of transactions or
balances), whether intended to test for misstatement or for compliance with
controls (or both) is a term that may be used for any test that involves inspection
of the individually selected sampling units. In the case of a test of controls, this
might involve, for example, inspecting documents to determine that appropriate
approvals were given or reviews were performed. Moreover, AU 350.44
specifically and correctly recognizes the dual nature of tests of details.
The dropping of the adjective “substantive” is inappropriate in light of a recent
ASB decision to add that adjective when referring to analytical procedures.
3
b. In the case of a test of controls, that controls are less effective than they actually
are or, in the case of a test of details, that a material misstatement exists when in
fact it does not. This type of erroneous conclusion affects audit efficiency as it
would usually lead to additional work to establish that initial conclusions were
incorrect. [Emphasis added.]
The statement that “[t]his type of erroneous conclusion affects audit efficiency as
it would usually lead to additional work to establish that initial conclusions were
incorrect” (which is a carryover from AU 350) is appropriate for a test of controls.
For a substantive test of details, however, the risk of incorrect rejection is also
equal to estimation risk. Estimation risk measures the chance that a confidence
interval will fail to contain the actual amount of misstatement within its calculated
range. The purpose of an audit sample is to provide a basis for an audit decision.
An unfavorable (or undesirable) result in a substantive test of details does not
necessarily lead to additional work. In fact, the results may be sufficiently precise
to provide for the proposal of a materially correct adjusting journal entry. A
confidence interval and its associated risk provide an objective basis for
proposing an adjusting journal entry should the sample results indicate that risk of
intolerable misstatement is unacceptable. The risk addressed in b. is the risk that
the audited account (post adjustment) is not materially (tolerably) correct.
The statement that “[t]his type of erroneous conclusion affects audit efficiency as
it would usually lead to additional work” is inappropriate because (1) the auditor
does not know if the sample findings are incorrect, and (2) the findings may be
sufficiently precise for the auditor to propose an adjusting journal entry.
We suggest that the last sentence be replaced with the following:
While this risk is a consideration and might result in additional work, this
risk is identical to the risk that an account balance, subsequent to any
adjusting entry, is misstated by an amount that exceeds the tolerable
amount.
See our comment relative to paragraph A2 below.
________________________________________________________________________
Sampling unit. The individual items constituting a population. (Ref: par. A4)
The sampling unit is the item that is actually examined by an auditor. It may be, for
example, an account, a transaction, or a line item within a transaction. It is not a
“monetary” unit (not withstanding popular usage; see further comment regarding
paragraph A4, below). As stated above, whether or not the sampling units constitute
the population of interest depends on the relationship of the frame to that population.
Statistical sampling. An approach to sampling that has the following characteristics:
4
a. Random selection of the sample items (Ref: par. A5)
b. The use of an appropriate statistical technique to evaluate sample results
including measurement of sampling risk
A sampling approach that does not have characteristics (a) and (b) is considered
nonstatistical sampling.
Random sampling is statistical sampling. Statistical evaluation of a randomly selected
sample is a best practice and is always appropriate. Accordingly, characteristic b.
above should be eliminated. See our comment regarding paragraph A7. We suggest
the following definition be substituted:
Statistical sampling. Statistical sampling is probability sampling, in
which each item in the frame has a known chance of selection. A
probability sample is evaluated by appropriate statistical techniques.
We recognize that auditors may seek to avoid random selection entirely if statistical
evaluation of random samples is to be required. Some auditors may decide to apply
“haphazard” sampling in order to avoid the need to perform an appropriate statistical
evaluation. For this reason, the ASB should express a preference for random sampling
(that is, statistical sampling). There are few situations in which some form of random
selection is impracticable. Client data which is not readily amenable to computeraided selection can usually be subjected to informal selection techniques that
approximate equal probability random selection. An informal sample is one that is
selected without conscious bias and without random numbers or computerized
random selection. See our comment to paragraph A7 for an example of an informal
selection procedure.
The ED’s definition perpetuates an erroneous concept: that a random sample need not
be evaluated by “the use of an appropriate statistical technique.” This is an invitation
to an auditor to act inappropriately by ignoring readily available statistical evaluation
methods. “Professional” judgment in this instance is an inferior substitute for
measurement.
Tolerable misstatement. A monetary amount set by the auditor in respect of which the
auditor seeks to obtain an appropriate level of assurance that the monetary amount set by
the auditor is not exceeded by the actual misstatement in the population.
This is a substantial and inappropriate definitional departure from what is presented in
AU 350.18. The wording is ungainly and is not a definitional improvement.
Moreover, this definition does not include those situations in which monetary
misstatement exceeds the tolerable amount. Although somewhat difficult to apply, the
original definition of AU 350.18 is superior. See our comment on paragraph A6.
5
Tolerable rate of deviation. A rate of deviation from prescribed internal control
procedures set by the auditor in respect of which the auditor seeks to obtain an
appropriate level of assurance that the rate of deviation set by the auditor is not exceeded
by the actual rate of deviation in the population.
See immediately preceding comment.
________________________________________________________________________
Sample Design, Size, and Selection of Items for Testing
8. The auditor should select items for the sample in such a way that the auditor can
reasonably expect the sample to be free of intentional bias and thus will be representative
of the relevant population and likely to provide the auditor a reasonable basis for
conclusions about the population. (Ref: par. A16-A18)
This text is a carryover from AU 350 and continues to confuse the meaning of bias
within the context of sampling procedures. Bias is an estimation issue; not a selection
issue. Selection with probability proportional to size is clearly biased toward selection
of the larger items, yet, it is the application of an appropriate estimator that eliminates
bias. There are common estimators (such as the ratio estimators) that are biased. The
bias can be estimated and be applied to provide a correction for the estimator. The
following wording is preferable because it correctly encompasses both selection and
evaluation of a sample:
The selection and evaluation of a sample should be performed in such
a way that the resulting estimates are unbiased.
____________________________________________________________
Performing Audit Procedures
10. If the audit procedure is not applicable to the selected item, the auditor should
perform the procedure on a replacement item. (Ref: par. A19)
This guidance is incorrect and should be removed because it will lead to invalid
results. As stated above, there are situations in which the population is only a subset
of the frame. Items deemed to be “not applicable” are, nevertheless, members of the
frame from which the sample was selected. If such items are removed from the
sample and are replaced only with “applicable” items, the expected occurrence rate of
“applicable” items will be greater than their occurrence rate in the frame. Estimates
(projections) obtained from such samples will be biased. It is especially important in a
substantive test of details that such items, if selected, are assigned misstatement
values of zero and must remain in the sample. Only if the exact number of “not
6
applicable” items in the population is known may a “not applicable” item be replaced.
Otherwise, and this is generally the case, the total number of “not applicable” items is
unknown. See our comments on paragraphs A19 and A20.
11. If the auditor is unable to apply the designed audit procedures, or suitable alternative
procedures, to a selected item, the auditor should treat that item as a deviation from the
prescribed control, in the case of tests of controls, or a misstatement, in the case of tests
of details. (Ref: par. A20-A21) [Emphasis added.]
Treating those items for which the auditor is unable to apply test procedures as
deviations from prescribed controls is reasonable and conservative because the result
is less reliance on the controls for purposes of determining the scope of substantive
tests.
However, the same is not true for a substantive test of details. In such a case, the
inability to apply audit procedures is a scope limitation that must be evaluated and
considered for its effect on the audit opinion as per AU 508.20-32. Whether or not the
potential impact of such a limitation is intolerable can be estimated and assessed by
projecting the recorded amounts of such items. However, to consider such items to be
misstated is not only inconsistent with other literature that speaks to such limitations
(AU 508.20-32), but it raises the risk that an auditor will propose an adjusting journal
entry that will create rather than correct a material misstatement (see our comment to
A.20). Moreover, considering untested items as misstatements requires the auditor to
specify the amounts by which such items are presumed to be misstated and, for tests
of valuation and accuracy assertions, the algebraic signs of those presumed
misstatements. The emphasized text is inappropriate and should be deleted.
The following two sections, entitled “Projecting Misstatements” and “Evaluating the
Results of Audit Sampling,” present separately what is actually a unified topic: Sample
projection is integral to evaluation.
Projecting Misstatements
13. For tests of details, the auditor should project misstatements found in the sample to
the population. (Ref: par. A25–A26)
This paragraph should be eliminated and combined with paragraph 14. The current
wordings of AU 350.26 (for substantive tests of details) and AU 350.41 (for tests of
controls) are superior to the above sentence. Further, the referenced paragraphs A25A26 fail to provide necessary amplification. The point estimate obtained from a
sample (referred to in the ED as the projection) provides little information regarding
the risk that material (or intolerable) misstatement exists. In probability sampling, a
7
calculated confidence interval provides such information. See our comment on
paragraph 14 below.
Evaluating Results of Audit Sampling
14. The auditor should evaluate
a. the results of the sample and (Ref: par. A27–A29)
b. whether the use of audit sampling has provided a reasonable basis for conclusions
about the population that has been tested. (Ref: par. A28–A29)
The evaluation of the results of a sample includes the calculation of a point
estimate (a projection in the case of a substantive test of details, and deviation rate
in the case of a test of controls) and confidence interval (to use statistical
sampling terminology). The latter provides a measure of the risk that the actual,
but unknown, misstatement or deviation rate is beyond the calculated confidence
limits. The foregoing can be expressed in a number of ways, including using the
existing verbiage of AU 350.26 and .41.
The language of ED paragraph 14 (including the referenced A27-A29) fails to
provide appropriate guidance and might unintentionally cause the commission of
malpractice by suggesting that an auditor simply decide that audit sampling has
not provided a reasonable basis for conclusions without stating, in accordance
with AU 339, what enables the auditor to make such a decision. In fact, the only
objective basis for such a decision to be made, given a properly executed sample,
is an imprecise confidence interval. We believe that even an imprecise confidence
interval indicates that planning assumptions need to be revised and additional
testing is needed.
The words of AU 350.26, “appropriate consideration should be given to sampling
risk” (and similar guidance in AU 350.41 for a test of controls), are proposed to
be deleted, leaving the auditor with neither a standard nor even unambiguous
guidance as to an appropriate evaluation methodology. We believe that this
deletion is inappropriate.
As stated in the introductory comments, the confidence interval is a universally
accepted methodology for the evaluation of a probability sample (and even a
sample whose selection may reasonably be assumed to be the functional
equivalent of a random sample). Such a methodology, whether presented as a
method of estimation or as a test of hypothesis, should be an explicitly required
approach.
8
Sampling Risk (Ref: par. 5)
A2. The risk of incorrect rejection and the risk of assessing control risk too high relate
to the efficiency of the audit. For example, if the auditor’s evaluation of an audit sample
leads the auditor to the initial erroneous conclusion that a balance is materially
misstated when it is not, the application of additional audit procedures and consideration
of other audit evidence might lead the auditor to the correct conclusion. Similarly, if the
auditor’s evaluation of a sample leads him or her to unnecessarily assess control risk too
high for an assertion, the auditor might increase the scope of substantive procedures to
compensate for the perceived ineffectiveness of the controls. Although the audit may be
less efficient in these circumstances, the audit is, nevertheless, effective. [Emphasis
added.]
The highlighted text, which modified the original AU 350 term, “risk of
underreliance,” in a previous change to AU 350 does not provide clarity to the
concepts discussed. The original term is the meaningful expression of risk.
It is especially inappropriate that the ED ignores the risk of overreliance, which is
expressed in the current text of AU 350 as the risk of assessing control risk too low,
and is clearly the more important risk for a test of controls.
In an earlier revision of SAS 39, the ASB introduced “risk of assessing risk too low
(too high)” as replacements for “risk of overreliance (underreliance).” The
substitution has no practical meaning in statistics. In fact, the performance of an audit
sample to test controls provides a direct and incontrovertible measure of risk. If, for
example, an auditor selects a random sample of 100 items, which discloses no control
deviations, the auditor can conclude that there is only a 5% risk that the deviation rate
in the population exceeds 3%. If 3% is the tolerable deviation rate, 5% is the
appropriate control risk. The risk of assessing control risk too low is (in the context of
the current and proposed jargon), mathematically, zero. We recommend that the ED
be revised to restore the control risk definitions in the original SAS 39 text.
The statement that the risk of incorrect rejection …relate[s] to the efficiency of the
audit (AU 350.13) is misleading and incomplete regarding substantive tests of details.
The risk of incorrect rejection is, in fact, estimation risk. It is the risk that the actual
misstatement amount is not within the two-sided confidence interval that is calculated
from the sample results. If sufficiently precise, such an interval provides a reliable
basis for proposing a materially correct adjusting journal entry without the need to
perform additional procedures. See our comment on the sampling risk in paragraph 5
above.
Sampling Unit (Ref: par. 5)
A4. The sampling units might be physical items (for example, checks listed on deposit
slips, credit entries on bank statements, sales invoices, or debtors’ balances) or monetary
units. [Emphasis added.]
9
We believe that it is incorrect to equate monetary units with sampling units, however
popular that usage may be. In practice, the smallest auditable data source (line item,
invoice, account) is the sampling unit. Some writers on the subject of sampling have
addressed this fact by creating the notion of the monetary unit serving as a “hook”
that enables the auditor to identify the actual item (i.e., sampling unit) to be vouched,
traced, or otherwise inspected. That “hooked” item (sometimes also referred to in
auditing literature as “physical unit”) is the sampling unit. For engagement
documentation purposes, it is far better to identify the sampling unit properly. We
recommend deleting the last prepositional phrase, “or monetary units.”
A5. Random selection techniques include the following:
a. Simple random
b. Systematic random
c. Monetary unit
d. Probability weighted
Item d. should be eliminated because monetary unit sampling is a probability
weighted random selection technique. The text should read:
c. Probability weighted, including monetary unit.
Tolerable Misstatement (Ref: par. 5)
A6. The auditor is required by paragraph 11 of the proposed SAS Materiality in Planning
and Performing an Audit (Redrafted) to determine performance materiality. Performance
materiality is determined in order to address the risk that the aggregate of individually
immaterial misstatements may cause the financial statements to be materially misstated
and provide a margin for possible undetected misstatements. Tolerable misstatement is
the application of performance materiality to a particular sampling procedure. Tolerable
misstatement may be the same amount or an amount lower than performance materiality
(for example, when the sample population is lower than the account balance).
It is unclear what this paragraph accomplishes and why the introduction of a new
term, “performance materiality,” is an improvement over AU 350’s definition of
“tolerable misstatement” (which is a difficult concept to implement properly and not
improved by the proposed alternative). We recommend that the ED be revised to
retain the original definition of tolerable misstatement.
Sample Design, Size, and Selection of Items for Testing
Sample Design (Ref: par. 6)
10
A7. Audit sampling enables the auditor to obtain and evaluate audit evidence about some
characteristic of the items selected in order to form or assist in forming a conclusion
concerning the population from which the sample is drawn. Audit sampling can be
applied using either nonstatistical or statistical sampling approaches. [Emphasis
added.]
The definitions of statistical and nonstatistical sampling approaches require
substantial revision.
As previously stated, any probability sample is a statistical sample. A probability
sample is one in which item selection is left strictly to the laws of chance. The
principal property of such a sample is measurability. The results can be measured by
applying appropriate statistical procedures. If results can be measured, they should be
measured; those results should not be assessed solely by professional judgment. A
secondary property of a properly documented probability sample is that it can be
replicated by a reviewer.
Well-organized and computerized client files provide natural frames for probability
(statistical) sampling. In cases in which a client’s files do not readily lend themselves
to the formal methods associated with probability sampling, informal methods may be
applied, taking care not to introduce any unintended bias. Such populations may be
thoroughly mixed (as in the case of a shuffled deck of cards) or their frames may
provide no indication to the auditor as to whether the items identified in the frames
are misstated or have associated control deviations. For example, a frame might
consist of index cards in a file drawer, from which the auditor selects cards
throughout the drawer without inspecting them. Informally selected samples may be
evaluated as though they had been randomly selected provided that the working
papers describe the frame and the selection method. An informal sample emulates a
simple random or systematic random sample (that is, an equal probability sample)
because it is selected without conscious bias and because the organization of the
frame does not cause unintended bias.
There are situations in which the auditor employs judgment to decide which items to
select because the auditor believes the selected items to be of greater audit interest
than items that are passed over for selection. Those situations involve nonstatistical
sampling and can be evaluated only by the exercise of sound, rational auditor
judgment.
A8. When designing an audit sample, the auditor’s consideration includes the specific
purpose to be achieved and the combination of audit procedures that is likely to achieve
that purpose.
We believe that this sentence does not add any substantive guidance to considerations
that are applicable to other audit test procedures and should be removed.
11
Consideration of the nature of the audit evidence sought and possible deviation or
misstatement conditions or other characteristics relating to that audit evidence will assist
the auditor in defining what constitutes a deviation or misstatement and what population
to use for sampling
This sentence is unclear and does not provide meaningful guidance. We suggest that
the entire paragraph be replaced by the following:
When planning an audit sample, the auditor decides the classes of
transactions or accounts that are of audit significance. The auditor’s
understanding of the client’s information systems and the records that the
client maintains enables the auditor to decide on a suitable frame for
selection of a sample. The auditor also decides which assertions are to be
tested (which lead to the auditor’s decisions as to the defining of deviations or
misstatement conditions).
In fulfilling the requirement of paragraph 8 of the proposed SAS, Audit Evidence,
(Redrafted), when performing audit sampling, the auditor is required to perform audit
procedures to obtain evidence that the population from which the audit sample is drawn
is complete.
This appears to be the only section of the ED that addresses the frame/population
issue. We suggest expanding the guidance and presenting it in a separate paragraph.
A10. The auditor’s consideration of the purpose of the audit procedure, as required by
paragraph 6, includes a clear understanding of what constitutes a deviation or
misstatement so that all, and only, those conditions that are relevant to the purpose of the
audit procedure are included in the evaluation of deviations or projection of
misstatements. For example, in a test of details relating to the existence of accounts
receivable, such as confirmation, payments made by the customer before the
confirmation date but received shortly after that date by the client are not considered a
misstatement. Also, an incorrect posting between customer accounts does not affect the
total accounts receivable balance. Therefore, it may not be appropriate to consider this
a misstatement in evaluating the sample results of this particular audit procedure, even
though it may have an important effect on other areas of the audit, such as the
assessment of the risk of fraud or the adequacy of the allowance for doubtful accounts.
[Emphasis added.]
It is incorrect to suggest that the highlighted example may not describe a relevant
deviation or misstatement. In fact, it describes a failure of internal control regarding
the transactions-based assertion that transactions are properly classified. The fact that
this example is used in the context of a substantive test of details refutes any notion
that a test of details may not also serve as a test of controls, particularly when
apparent control failures are identified. The highlighted text should be deleted.
12
A11. In considering the characteristics of a population for tests of controls, the auditor
makes an assessment of the expected rate of deviation based on the auditor’s
understanding of the relevant controls or on the examination of a small number of
items from the population. [Emphasis added.]
The highlighted text presents an impracticable approach to planning. A small sample
is unlikely to detect relatively infrequent control deviations and, thus, will provide no
useful planning information. Moreover, such an approach unnecessarily extends the
elapsed time needed to complete the test of controls in that it involves the selection of
two samples. Finally, such a procedure is in fact a sequential sampling procedure,
which entails greater complexity in evaluation [see Roberts, op cit, pp. 59-61]. The
highlighted text should be deleted.
This assessment is made in order to design an audit sample and to determine sample size.
For example, if the expected rate of deviation is unacceptably high, the auditor will
normally decide not to perform tests of controls. Similarly, for tests of details, the
auditor makes an assessment of the expected misstatement in the population. If the
expected misstatement is high, 100 percent examination or use of a large sample size
may be appropriate when performing tests of details. [Emphasis added.]
The emphasized text is potentially misleading. A 100 percent examination is rarely
practicable and, even then, only for small populations. It is inappropriate to suggest
that undefined “large” sample sizes should be viewed by auditors as the evidential
equivalent of a risk-free 100 percent examination. While the expected misstatement is
a sufficient parameter for monetary unit sampling and tests for overstatement
(assuming that tolerable misstatement and risk of incorrect acceptance are specified),
it would be insufficient for stratified random sampling, (e.g., inventory price tests, if
misstatements in both directions are deemed likely). In general, it is population
volatility, as measured by the standard deviation of misstatements (including zero
amounts), which is the appropriate term to use. Volatility is a function of both the
proportion of non-zero misstated items and variability of those non-zero
misstatements. If the standard deviation is small or can be controlled by adequate
stratification, large sample sizes may not be necessary.
The emphasized text should be deleted and replaced by the planning considerations,
such as those described in AU 350 pars. 16-17 & 21-22.
A12. In considering the characteristics of the population from which the sample will be
drawn, the auditor may determine that stratification or value-weighted selection is
appropriate.
This sentence is insufficiently informative to provide an auditor with a useful basis
for making an audit sampling decision. For example, cluster sampling (both single
and multi-stage) is not mentioned. See the previous comment. This paragraph should
be elaborated upon or deleted.
13
A14. The sample size can be determined by the application of a statistically based
formula or through the exercise of professional judgment. Various factors typically
influence determination of sample size, as follows:
For substantive tests of details:

The auditor’s desired level of assurance (complement of risk of incorrect acceptance)
that tolerable misstatement is not exceeded by actual misstatement in the population;
A more straightforward statement is:
The auditor’s desired level of assurance (the complement of the risk of
incorrect acceptance) that actual misstatement is no greater than
tolerable misstatement




Tolerable misstatement
Expected misstatement for the population
Stratification of the population when performed
For some sampling methods, the number of sampling units in each stratum.
While the text for describing planning considerations for tests of controls is
reasonable, these bullets are inelegantly worded. We suggest the following as a
replacement for the four bulleted items above:
Sample size is sensitive to auditor-specified factors and population
characteristics.


Auditor-specified factors
o tolerable misstatement
o risk of incorrect acceptance
Population characteristics
o proportion of misstatements in the population
o volatility of the misstatements (i.e., their standard deviation)
o population size, for small and stratified populations
A15. The decision whether to use a statistical or nonstatistical sampling approach is a
matter for the auditor’s judgment; however, sample size is not a valid criterion to decide
between statistical and nonstatistical approaches. An auditor who applies statistical
sampling uses tables or formulas to compute sample size based on the judgments in
paragraph A14. [Emphasis added.]
The statistical/nonstatistical issue is addressed in the comment relative to A7.
However, the highlighted text contains an error that requires correction.
Sample sizes can always be arbitrarily or judgmentally determined (even for
statistical sampling). There are situations in which an auditor does not have
14
information deemed adequate for computation of a sample size or in which time or
budget restrictions limit the extent of testing. The sufficiency of such a sample size
(or the lack thereof) will be evident upon evaluation of the sample. The highlighted
text should be deleted.
An auditor who applies nonstatistical sampling uses professional judgment to relate the
same factors used in statistical sampling in determining the appropriate sample size.
Ordinarily, this would result in a sample size comparable to the sample size resulting
from an efficient and effectively designed statistical sample, considering the same
sampling parameters. This guidance does not suggest that the auditor using
nonstatistical sampling also compute a corresponding sample size using an appropriate
statistical technique. [Emphasis added.]
We believe that it is inappropriate for the ED to fail to suggest “that the auditor using
nonstatistical sampling also compute a corresponding sample size using an
appropriate statistical technique,” if such a technique is available. However, as
previously stated, sample sizes can always be arbitrarily specified. The highlighted
text should be deleted.
Selection of Items for Testing (Ref: par. 8)
A16. To be considered representative, an audit sample is selected in a manner such that
the auditor can reasonably expect that the sample is free of intentional bias or
preference.
See comment in regard to paragraph 8 above.
A17. With statistical sampling, sample items are selected in a way that each sampling
unit has a known probability of being selected. With nonstatistical sampling, haphazard
or random-based selection is used to select sample items. [Emphasis added.]
Random sampling is measurable by appropriate statistical methods and is, therefore,
statistical sampling. The highlighted text should be deleted or replaced with:
With nonstatistical sampling, the auditor uses judgment to decide
which items are to be selected from the frame.
A18. The principal methods of selecting samples are the use of random selection,
systematic selection, and haphazard selection.
See the comment relative to the Definitions section, above, regarding the use of the
term “haphazard.”
A18 is redundant and is covered by A17. It should be deleted.
15
Performing Audit Procedures (Ref: par. 10–11)
A19. An example of when it is necessary to perform the procedure on a replacement
item is when a voided check is selected while testing for evidence of payment
authorization. If the auditor is satisfied that the check has been properly voided such
that it does not constitute a deviation, an appropriately chosen replacement is
examined. Another example is a telephone expense item selected as part of a sample
for which a deviation has been defined as a transaction not supported by receiving
report; telephone expense may not be expected to be supported by a receiving report. If
the auditor has obtained assurance that the transaction is not applicable and does not
represent a deviation from the prescribed control, the auditor would replace the item
with another transaction for testing the relevant control. [Emphasis added.]
This paragraph should be deleted because both examples present invalid approaches
to sampling. It can easily be proved that, for both examples, replacing items in the
manner suggested will result in biased estimates. Such samples will have higher rates
of deviations or misstatements than exist in the sampled populations because the
“applicable” items will be over-represented in the sample. Projections resulting there
from will be based on projections to populations that include all other non-applicable
items whereas the samples will not include those items. See the comment regarding
paragraph 10 above.
The second example does not define a deviation properly. A receiving report is just
one piece of evidence that applies only to a subcategory of some, but not all,
expenditures. Its presence is relevant only when it is expected to be present, and its
absence is not an exception, nor does it make the sample item not applicable with
regard to the underlying characteristic being tested, that is, the validity of the
expenditure (not the presence of a receiving report).
A20. In some circumstances the auditor may not be able to apply the planned audit
procedures to selected sample items; because, for example, the entity might not be able to
locate supporting documentation. The auditor’s treatment of unexamined items will
depend on their effect on the auditor’s evaluation of the sample. If the auditor’s
evaluation of the sample results would not be altered by considering those unexamined
items to be misstated, it may not be necessary to examine the items. However, if
considering those unexamined items to be misstated would lead to a conclusion that the
balance or class contains material misstatement, the auditor may consider alternative
audit procedures that would provide sufficient appropriate audit evidence to form a
conclusion. AU section 316, Consideration of Fraud in a Financial Statement Audit
(AICPA, Professional Standards, vol. 1), also requires the auditor to consider whether
the reasons for the auditor’s inability to examine the items have implications in relation
to assessing risks of material misstatement due to fraud, the assessed level of control risk
that the auditor expects to be supported, or the degree of reliance on management
representations.
16
An auditor’s inability to examine items constitutes a scope limitation unless adequate
alternative evidence is obtained to meet the audit objective. The best one can do in a
substantive test, in the absence of adequate alternative procedures, is to project the
recorded amounts of the untested items in order to estimate the extent of the
limitation (that is, the estimated aggregate size of the effectively untested items) and
consider the effect on the audit report. We suggest the following be inserted between
the third and fourth sentences:
The auditor can assess the potential extent of unexamined items by
projecting their recorded amounts to the frame including an
appropriate allowance for sampling risk.
A24. A representative sample is expected to be representative of the population only
with respect to the incidence of misstatements or deviations and not necessarily with
respect to their nature. The auditor may not assume that the observed incidence of
misstatements or deviations in the sample is not representative of the population because
a misstatement or deviation included in the sample is caused by unusual circumstances
(sometimes referred to as an anomalous or isolated misstatement or deviation).
[Emphasis added.]
The first sentence should be deleted because it is incorrect. Any observable
characteristic, whether quantitative or qualitative, can be estimated or projected. In
the case of a probability sample, the precision of the estimate is measurable at any
specified level of confidence.
The second sentence, is correct, but does not follow from the first.
“Representative,” as used within the context of audit sampling, has referred to the
overall property of a sampling procedure in relation to the population and not to any
specific sample outcome. Failure to recognize this fundamental fact can lead to such
improper rationalizing and inherently risky decisions as discarding a sample or a
sampling result because it is not, in the auditor’s judgment, “representative.”
A25. The auditor is required by paragraph 13 to project misstatements for the population
to obtain a broad view of the scale of misstatement, but this projection may not be
sufficient to determine an amount to be recorded. [Emphasis added.]
The expression “a broad view” has no operational meaning in the context of audit
sampling. The projection is an estimate of the total amount of misstatement-- one
sample outcome obtained from a myriad of possible outcomes. The statistical term for
the projection is “point estimate.”
A25 is one of several instances in the ED that exhibits bias against using sample
results as a basis for audit decision-making. This paragraph does not provide any
indication of what constitutes an insufficiency. Thus, the text is merely an opportunity
for the auditor to disregard the objective results of a substantive test of details. If, in
17
fact, the auditor has satisfied the representativeness requirement with respect to
selection and evaluation, the only basis for considering the projection (that is, the
sample point estimate) to be insufficient is that the precision of the estimate, as
calculated at an auditor-specified confidence level (assurance), is too large to provide
a reasonable basis for a conclusion. The resultant quantifiable risk of drawing an
incorrect conclusion is too large for auditor comfort. The ED fails to discuss any
explicit requirement to perform the confidence interval estimation or hypothesis
testing that is common to other professions.
We suggest the following wording:
The auditor is required by paragraph 13 to project misstatements for the
population including an appropriate allowance for sampling risk. When
considered together, the projection and its associated allowance for sampling
risk might be sufficient to determine an amount to be recorded.
A28. In the case of tests of details, the projected misstatement is the auditor’s best
estimate of misstatement in the population. As the projected misstatement approaches or
exceeds tolerable misstatement, the more likely it is that actual misstatement in the
population may exceed tolerable misstatement. Also, if the projected misstatement is
greater than the auditor’s expectations of misstatement used to determine the sample
size, the auditor may conclude that an unacceptable sampling risk exists that the actual
misstatement in the population exceeds the tolerable misstatement. [Emphasis added.]
If the projected misstatement exceeds the tolerable amount, the auditor should
conclude that the risk is too high to be acceptable, because such risk would exceed 50
percent. The statement seems to be rationalizing an auditor’s decision to ignore
sampling results. The appropriate basis for an audit decision is, in probability
sampling, the confidence interval, which is calculated using appropriate statistical
techniques. In a judgmentally selected sample, the auditor must assess the risk of
potential exposure to intolerable misstatement, and decide accordingly. We suggest
replacement of the last sentence in the paragraph with the following, which is
partially adapted from AU 350.26:
The projected misstatement should be compared with the tolerable
misstatement, and appropriate consideration should be given to
sampling risk for both statistical and nonstatistical sampling. For
probability samples and for samples that may reasonably be
presumed to emulate random samples, the auditor applies
appropriate statistical methods. For other samples, the auditor
exercises professional judgment.
Considering the results of other audit procedures helps the auditor to assess the risk that
actual misstatement in the population exceeds tolerable misstatement; and, the risk may
be reduced if additional audit evidence is obtained. [Emphasis added.]
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The highlighted text should be deleted. Intolerable misstatements do exist in
accounting populations. Yet, the guidance in the ED is oriented toward finding
possible explanations that might refute the sample findings, and not toward guiding
an auditor when there is a high level of assurance that intolerable misstatement exists.
Neither inquiry nor analytical procedures can be shown to be superior to a properly
planned and executed substantive test of details. The only measurable approaches to
reducing risk are to select and examine additional sample items, or to propose an
adjusting journal entry. Moreover, extending a sample is more likely to confirm, not
refute, the initial sample results.
A29. If the auditor concludes that audit sampling has not provided a reasonable basis for
conclusions about the population that has been tested, the auditor may


request management to investigate misstatements that have been identified and the
potential for further misstatements and to make any necessary adjustments, or
tailor the nature, timing, and extent of those further audit procedures to best achieve
the required assurance. For example, in the case of tests of controls, the auditor
might extend the sample size, test an alternative control, or modify related substantive
procedures.
Proposed SAS Evaluation of Misstatements Identified During the Audit addresses
misstatements identified by the auditor during the audit.
This last paragraph sums up the ED’s contradictory guidance: Use samples because
they provide audit evidence, but do not make decisions based on those results if those
results do not support a favorable conclusion (i.e., that any potential misstatement is
tolerable). Either find other evidence that can be used to explain a sample result as
aberrant or ask management to investigate further.
A well-planned sampling procedure will provide a reasonable basis for both accepting
a population whose misstatement does not exceed the tolerable amount, and for
proposing appropriate action when a sample result leads to a decision that
misstatement may exceed the tolerable amount. One such action is the proposal of an
adjusting journal entry that will reduce any potentially remaining misstatement to an
amount that is unlikely to exceed the tolerable misstatement. A sample that fails to do
so is either poorly planned or is revealing a situation that is worse than even good
planning has led the auditor to believe
As stated previously there is no consideration in this ED for use of the universally
employed mechanism that enables a sampler to draw reliable conclusions from a
sample – the confidence interval (or its companion, the test of hypothesis).
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