Trusted Professional

New PCAOB Taking 'Clean Sheet' Approach to Inspections

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Board member Duane M. DesParte said that, overall, the board wishes to put more emphasis on prevention, with enforcement becoming only a final resort when all other avenues for improvement have been exhausted. With this in mind, he said that stakeholders can expect the board next year to focus particularly hard on firms' quality control systems, explaining that looking at quality control systems and helping firms build quality into their overarching control environment will ideally reduce deficiencies in the future. This emphasis also places the PCAOB in a more collaborative, versus adversarial, role with regard to the firms it inspects. 

"Increased focus on quality control systems is an indicator that we are not trying to play 'gotcha' in terms of how many deficiencies we can find," he said. "Our overall objective is to raise the bar on audit quality, and our goal is to be giving counsel to the firms and giving them observations where they can improve quality control."

One way this will be done is a new kind of inspection that he said the board plans to start this year: a horizontal cross-firm thematic review. It will involve putting together a specialized team that will look at specific issues across firms and issue a report. Historically, he said, teams focused on a specific firm rather than a particular audit issue, but he thought this form of inspection could do well to help entities better head off potential problem areas before they become an inspection deficiency. 

The board is also considering a standards project explicitly devoted to quality control. J. Robert Brown, another board member, noted that the PCAOB's current quality control standards were set in 2003, and he said that, 15 years later, it is now time to re-examine them. He said that such a re-examination can not only improve audit quality systems at firms but also provide a new avenue for firms to compete with each other on the basis of quality, given the rising number of proxy statements referencing such systems. 

"Already quality control is an issue of great importance to audit committees and issuers," said Brown. "The importance is growing. That would be another place we, as an organization, can make a difference in the dynamics out there."

Another area where this board aims to be different is communication—how it communicates and with whom it communicates. Brown said that the audience for PCAOB communications may be different now than it was back in the early 2003-2005 period. He said the board needs to take a harder look at who exactly its audience is, and tailor its communications to that audience so that the communications can be a better source of decision-useful information. With this in mind, board member James G. Kaiser said that the PCAOB plans in the next year to consider expanding the number of advisory groups from the Investment Advisory Group and Standing Advisory Group  that it currently has, adding that it is in the process of evaluating what formal groups the PCAOB needs for further advice. Along similar lines, DesParte said that the board plans to put more emphasis on engaging with audit committees. In contrast to previous years, he said that the PCAOB plans to engage with audit committee chairs of every issuer it inspects, which he said had previously been done on a more limited basis.  

DesParte also said that the board, in recognition that its audience is more than just auditors, wants to make the language it uses more accessible and less technical so a wider variety of people can find value in its communications. 

"We're also looking at how we communicate our findings, really wanting the findings to be more than just inspectors talking to auditors, to make them more accessible for all stakeholders. So less technical jargon, more plain English. Maybe more use of executive summaries. More use of charts and graphs. Those are some things we're looking at and can expect next year," he said. 

The PCAOB also plans to focus heavily on the ways that technology has changed the auditing process and, consequently, how the inspection process must change too. Board member Kathleen M. Hamm said that accounting and auditing are undergoing rapid change due to the rise of big data and data analytics, and will be further changed by the proliferation of machine learning, blockchain and robotics. She said the board is assessing how people are using these technologies now, and whether PCAOB standards are impeding the adoption of innovative new technology. Hamm, so far, was confident that potentially disruptive new technologies can still fit within the PCAOB's standards framework. 

"Our standards currently appear flexible enough to allow for appropriate innovations," she said. 

Center for Audit Quality Executive Director Cindy Fornelli, who was moderating the discussion, said that despite this flexibility, many firms are fearful if a particular form of technology is not explicitly mentioned in the standards. While Mann said that the standards don't appear to be an impediment, she noted that the wording does not appear to allow certain technologies. Hamm said that stakeholders should inform the PCAOB of standards when it would appear the wording does, in fact, stand as an impediment to technological innovation. 

"We're trying to get feedback," she said. "We're open to getting feedback directly one on one, and in larger groups. If people believe one of our programs is impeding the use of innovative technology, we want to hear about it to make sure we can assess that and, if we determine we are [causing an impediment] because we're not explicitly allowing something, we can give some comfort."