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CAQ offers blueprint for asking auditors about Form AP filings

Tammy Whitehouse | June 20, 2017

The Center for Audit Quality is offering audit committees some talking points on how to engage external auditors and company management on a new filing requirement with auditing regulators.

The tool for audit committees explains the new Form AP filing that audit firms are required to provide to the Public Company Accounting Oversight Board. Form AP compels audit firms to name some key participants in the audit, namely the engagement partner and any outside firms that contributed a certain portion of the audit work.

The PCAOB has developed a searchable database of Form AP filings to make it easy for investors and other with an interest in the audit to identify who is overseeing public company audit engagements and how much those firms rely on outside participants to get the audit work done. The PCAOB settled on the Form AP filing when it hit legal roadblocks to its original idea to require engagement partners to sign audit reports, or at least put their names in them.

Audit firms began providing Form AP filings in 2017, so the PCAOB has already amassed thousands of listings in its Auditor Search database. Effective dates for the disclosure requirement differed, however, for the engagement partner compared with the other participants in the audit.

The CAQ tool for audit committees explains the Form AP filing, including the various filing deadlines for specific pieces of information that must be given to the PCAOB. It also suggests some lines of questioning audit committees might want to consider with management and auditors based on the information contained in the audit firm’s filings.

The tool suggests, for example, that audit committees consider whether the information they find in Form AP filings is consistent with the committee’s understanding of the work being done on its own audit. Committees might like to know if the other accounting firms who participated in the company’s audit are members of the principal audit firm’s global network.

Audit committees should consider asking external auditors about their system of quality control over work performed outside the principal firm, the CAQ advises. How connected are things like tone at the top, focus on audit quality, ethics, independence, and other factors that are important to U.S. audit integrity and compliance?

Audit committees could probe further into exactly how principal audit firms oversee outside accounting firms, the CAQ says. How does the firm know that the work has been performed to professional standards? Who on the engagement team met with the outside firm, and how often? When was the last in-person visit? Is the firm subject to inspection? How has that worked out?