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AUDITING - US Chamber of Commerce

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Auditing: A Pr<strong>of</strong>ession at Risk14Enterprises need a chance to beheard before indictments are handeddown — including an opportunityto object to the appropriateness <strong>of</strong> athreatened indictment in light <strong>of</strong> therespective roles <strong>of</strong> individuals versusthe institution.CLARIFY PCAOB STANDARDSAuditing Standard #2, the primaryimplementing standard for Section 404<strong>of</strong> Sarbanes-Oxley, is a large, expansive,principles-based document. While itprovides a great deal <strong>of</strong> room for auditorsto exercise judgment and to determinethe meaning <strong>of</strong> words like “significant”and “relevant,” it doesn’t provide muchguidance as to when “enough is enough”with respect to the auditing <strong>of</strong> internalcontrols. Auditors must be allowed toexercise pr<strong>of</strong>essional judgment, but thelack <strong>of</strong> specific guidance subjects themto substantial second guessing — by theplaintiffs’ bar, the inspection staff <strong>of</strong> thePCAOB, and others — that their auditsdid not go far enough.Senior PCAOB <strong>of</strong>ficials have stated thatthey can’t identify overauditing. If theprimary regulator doesn’t know the outerlimits <strong>of</strong> the standards, then how canaudit firms or their clients be expectedto? The PCAOB’s own inspection process— without a standard for determiningexcessive auditing — encourages auditors,

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