Category: Ideas

31 October 2023

Many audit firms have their own internal policies and methodologies for setting materiality. However many of our smaller firms struggle with a consistent approach. What is best practice?

ISA 320 (para 2) describes materiality as follows:

“Misstatements, including omissions, are considered to be material if they, individually or in the aggregate, could reasonably be expected to influence the economic decisions of users taken on the basis of the financial statements.“

This implies that we identify who are the likely users of the financial statements. In the case of Not-for-Profits (NPFs) this is likely to be the members of the organisation, recipients of the services provided, and those who are likely to be external funders: grant providers and perhaps lending institutions.

What will users be concerned about in NFPs?

Certainly the ongoing viability of the entity, perhaps risks around income understatement or expense overstatement. Retention of value for assets will also be important. What will not be so important? Profit may indicate the ability to continue and grow, but it is not the primary reason the entity exists. So what parts of the financial statements will most influence the economic decisions of the users?

The important element is likely to be the costs of operating the entity. If the entity is able to deliver its services in a cost-effective and sustainable manner then stakeholders will continue to support it through their membership, grants, and other investments of time and funds.

What benchmark?

This emphasis on expenditure is reflected in how, in NZ, our four-tier NFP framework is measured – based on expenditure from the prior two years. So it makes sense to use this as our benchmark. Examples of benchmarks in ISA 320 (A5) include profit before tax, total revenue, gross profit and total expenses, and total equity or net asset value. Note that some firms use an average of the benchmark over the last three years to smooth out variations. This is worth considering if there are in fact such variations.

What about a new entity?

If the entity is new, and the first period is less than twelve months, can the auditor gross up the benchmark to twelve months for the calculation? No, because materiality applies to the particular financial statements being audited – regardless of the period length. Paragraph A7 is explicit about this.

What percentage should be applied to the benchmark?

ISA 320 (A4) states that “A percentage is often applied to a chosen benchmark as a starting point in determining materiality for the financial statements as a whole.”

This is where judgment must be applied. What percentage should we use? Commonly auditors choose between 0.5% and 3.0% of revenue or expenditure for overall materiality. However, the standard makes it clear that it is a matter of professional judgement and the auditor should not be confined to specific limits.

What is performance materiality?

Paragraph A13 tells us that “Performance materiality (which, as defined, is one or more amounts) is set to reduce to an appropriately low level the probability that the aggregate of uncorrected and undetected misstatements in the financial statements exceeds materiality for the financial statements as a whole.“

Some firms refer to this as giving materiality a “haircut.” The theory is that pure materiality is what would influence the economic decisions of the users, but what if we miss something close to materiality, or a combination of factors tips us over into materiality? So performance materiality (PM) gives us some headroom for this – providing a buffer between our theoretical critical value and working materiality so some slack is built in.

Typically firms use 75-80% of overall materiality, but the standard suggests that the auditor considers that this may be assessed on a class, balance and disclosure basis, as related to risk, previous experience, and our understanding of the entity. Commonly related parties will need to be considered with a lower PM given this disclosure is generally regarded as being qualitatively material.

How about relating to audit risk?

There is a relationship between materiality and the level of audit risk. Simply put, the higher the audit risk, the lower the materiality level that should be applied. When there is a higher risk we should be turning the magnitude of our microscope up to a higher level i.e. reducing materiality.

Risk can be different for different elements of the financial statements, so how can our materiality levels reflect this? We can do this by applying different performance materiality as above. This can also be achieved by using separate benchmarks.

For instance, an NPF has relatively low income and expenditure but high-value land and buildings. Risk is assessed as low for the assets as they do not change and are valued at cost, but expenditure has a higher risk profile. It may be appropriate to use 5% of fixed assets for those balances but 1% of expenditure for everything else.

Another method of recognising different levels of risk on different balances is applying confidence levels to testing. So for instance, the overall risk is set at 2% of expenditure, but when testing revenue and expenditure a confidence level of 0.5 is applied to reduce the sampling interval to half of PM, doubling the sample size. Conversely, a confidence level of 2.0 is applied to increase the sampling interval to twice PM to look at fewer items, because there is less perceived risk. Or we could create a combination of all of the above in a more complex job.

How is materiality applied?

There are three areas where materiality is applied as per paragraph A1.

Firstly, identifying and assessing risks of material misstatement. This involves what we look at in terms of risk. This ties into the discussion of inherent risk and control risk. We only need to consider risks that affect the financial statements, not all business risks. Then we don’t need to consider all classes, balances and disclosures, just those with a risk of material misstatement.

So when we are considering risk we should have materiality in mind. For instance, it was traditional to qualify for cash income, however with less use of cash this qualification may not be automatic. Yes, there is still a risk, but if cash receipts only. make up a tiny proportion of income, it is probably not material.

When identifying classes of transactions, a group of balances may be material in total, but not individually – for instance a series of grants. It makes sense to group these items and apply risk assessment to the group. By definition, all material balances or classes form a risk, so these should be identified and their risk profiles assessed. Even if they are low risk, if they are material they should be flagged and considered.

Don’t forget about balances or classes that are not presenting as material but have the potential to be material – understated accruals or creditors are the common examples.

Secondly, materiality is applied when determining the nature, timing and extent of further audit procedures. This is most likely to be applied when selecting a sample for testing. Again, the microscope metaphor works well. We look at a dataset through a microscope, but if that is set too low at 40x we may miss potentially material items. If it is set too high at 1000x we will be looking in too much detail – getting lost in the job and spending way too much time.

Some firms will consider all transactions over performance materiality, however, a better application of materiality to sampling is using a cumulative sampling tool with an interval based on performance materiality (adjusted for confidence level if required) to arrive at a sensible, statistically robust sample size for detailed substantive testing. Note too that the sampling interval may be adjusted if reliance is being placed on controls that have been tested, or on analytical procedures. These decisions should all be documented.

Thirdly, materiality is to be considered when evaluating the effect of misstatements on the financial statements and in forming the opinion in the auditor’s report. When we have done our testing and accumulated our audit adjustments and disclosure errors, we assess these for their materiality. If there are misstatements that the client will not adjust, then we use materiality to assess whether we need to modify our opinion in some way.

Summary – practical applications for small NFPs

Typically, in a small non-complex NFP, audit firms set an overall materiality based on expenditure and apply a materiality percentage of 2-3% unless there are serious pervasive risks. A PM of 80% is used in most cases. Then they apply PM to their substantive testing using it for their sampling interval, unless there are good reasons to adjust it – say if reliance is being placed on controls testing or analytical procedures. Balances that are already ‘proved in total’ should be excluded from this kind of sampling. So to summarise:

• Consider the users of the financial statements and what their motivations and interests are when setting materiality.
• Use expenditure as your main benchmark for materiality in NFPs.
• Consider benchmark averaging – including prior years – if there have been major changes.
• Using standard percentages of the benchmark is okay, but make sure you relate this to assessed risk.
• Use separate confidence levels or performance materiality to adjust testing when risk is assessed as lower or higher, or reliance is being placed on controls or analytical procedures.
• Don’t forget to document your decisions and your rationale for those decisions.
• Balances or classes that are material – or potentially material – represent risks, so make sure they are identified and addressed.
• Don’t over-audit by choosing materiality that is so low that nothing is being proven by your extra work.
• Don’t under-audit by setting materiality too high – or forgetting to apply it throughout the job – so that you miss important details.
• Document.
• Document.
• Document.

30 May 2023

So we have a typical small not for profit: poor division of duties, no real controls apart from two signatories for payments, a review of financial results at irregular board meetings, and the annual Performance Report prepared by external accountants.

We know we are not relying on controls for our audit work, but that pesky ISA 315 tells us that we still have to document controls, such as they are. We must – according to paragraph 25 – obtain an understanding of the entity’s information system and communication relevant to the preparation of the financial statements, including:

• how information flows through the entity’s information system, including how transactions are initiated, and how information about them is recorded, processed, corrected as necessary, incorporated in the general ledger and reported in the financial statements, and
• how information about events and conditions, other than transactions, is captured, processed and disclosed in the financial statements;
• understanding how the entity communicates significant matters that support the preparation of the financial statements and related reporting responsibilities in the information system and other components of the system of internal control so that we may
• evaluate whether the entity’s information system and communication appropriately support the preparation of the entity’s financial statements.

How do we obtain this information? Para A136 tells us it is through various ways that may include:

• enquiries of relevant personnel about the procedures used to initiate, record, process and report transactions or about the entity’s financial reporting process;
• inspection of policy or process manuals or other documentation of the entity’s information system;
• observation of the performance of the policies or procedures by the entity’s personnel; or
• selecting transactions and tracing them through the applicable process in the information system (i.e., performing a walk-through).

Optional or required?

So does this mean that walk-through tests are one option among many? Yes and no. We are required to document the identified controls that are relevant to inherent risks that we have identified. Paragraph A125 states that we must “evaluate the design and determine whether the controls have been implemented.” Here is the catch. How can we assess whether the controls have been implemented unless we perform some sort of walk-through test?

The client may complete our internal controls checklist, send us their procedures manual, and tell us sweet stories, but as we all know, what they say they do or think they do may not be what they actually do. These procedures may have existed at some point in the past, but internal controls, like most systems, are subject to entropy over time.

Part of our work is therefore to look for changes. Paragraph A41 states that we are required to determine whether information obtained from our previous experience with the entity and from audit procedures performed in previous audits remains relevant and reliable. If circumstances have changed information from prior periods may no longer be relevant or reliable. The standard suggests that enquiries and other appropriate audit procedures, such as walk-throughs of relevant systems should be carried out.

What form can a walk-through take?

We document the system at a level appropriate to the entity, especially noting the controls. Then we check to see if the system as described is actually what they do. For instance, journals must always be given close attention. How are they initiated? Who can create journals? Who approves them? What reviews are carried out? What other means are there of making adjustments to the ledger – editing transactions say?

In this case, we would document the process, then follow one journal through from initiation to ledger, ensuring that all levels of approval and checking have in fact been followed and there is evidence of this.

This is different to a test of controls which would be spread across the period. The walk-through does not give us reliance that the controls are effective, just that we have documented them correctly. In a simple small entity, we could add this walk-through test as a narrative comment. In a more complex entity, it would make sense to create a diagram and then perhaps a spreadsheet following the transaction through the key steps and controls.

You may wish to carry out the walk-through as you have someone explaining the system and you are documenting it. For instance, you are visiting the client – a sports club say – and you ask them – show me the process for recording a bar sale? Using your phone camera you could record how a sale is initiated, how it is recorded and batched, banked, and reconciled back to the bank details in their software, and the checks and approvals required at each step. Then you could use the photos to build a visual record of how the revenue system works, with suitable narration and assessment, and attach that to your systems documentation page.

As part of going through the system with a staff member remember to be curious and ask things like: What if the bar staff are away? Who does this approval when the manager is on holiday? Do those security cameras actually work? Why is the till left open? What is done when a transaction includes more than one revenue type?

Conclusion

ISA 315 (revised 2019) focuses first on inherent risk. However, control risk is also important, especially when it relates to journals and IT systems. These must be documented at an appropriate level for the entity whether we intend to rely on the controls or not. And describing controls is not enough – we must have confidence that we are describing what actually happens. In my view, walk-through tests are the only real way to achieve this, and many audit files are lacking this important element.

17 May 2023

So, you are preparing financial statements for a Tier 3 charity – or auditing them – and the board have come up with the bright idea that they will use a revalued amount for land and buildings. The financial position will look better, so funders and members will feel that the entity is secure. What could possibly go wrong?

Quite a bit, actually. I’ve been asked to review a few of these lately and there are a number of potential pitfalls to explore. If you are auditing these kinds of statements, I hope this is a helpful guide to what to look out for.

Tier 3 – the basic rules of engagement

Table 3 of PBE SFR-A (NFP) (the Tier 3 reporting standard) states that Property, Plant and Equipment are to be recorded when purchased or donated, at cost if purchased or at current value if donated. Impairment is to be recognised if the market price of the asset falls below its carrying (book) value, or when the value of the asset to the entity is less than its carrying value if the asset is to be retained.

It is anticipated that depreciation will be charged to spread the cost of the asset – we’re talking buildings – over its useful life. Land is not to be depreciated.

There is a common misconception that buildings are not required to be depreciated – probably a carry-over from tax accounting. But Charities don’t fall under tax rules. PBE SFR-A (NFP) assumes depreciation will be charged on buildings.

Tier 3 – what to do with revaluations

PBE SFR-A (NFP) Paragraph A113 says that ‘an entity may elect to revalue a class of property, plant and equipment.’ It suggests that this will be the case where there is the likelihood of increases in value over the asset’s life – i.e. for land and buildings. If this is to be done, PBE SFR-A (NFP) tells us that we must apply the relevant requirements of PBE IPSAS 17 Property, Plant and Equipment.

What is PBE IPSAS 17? It is an international standard that applies, in New Zealand, to Tier 1 and 2 entities. So we’re playing with the big boys now. We going to have to read a ‘proper’ accounting standard. The only slight exception from the full PBE allowed under PBE SFR-A (NFP) is that the entity may use the current rateable or government valuation rather than ‘fair value’ as required by PBE IPSAS 17 when revaluing.

What are the implications? Firstly that disclosure must be made that PBE IPSAS 17 has been adopted for land and buildings. There should also be a change in accounting policy note when first adopted. Auditors should also note in their report that the Performance Report is prepared using PBE SFR-A (NFP) with PBE IPSAS 17 applied to the revaluation of land and buildings.

PBE IPSAS 17 – what’s required?

Paragraph 44 tells us that the carrying value of a revalued asset shall be its revalued amount, less any subsequent depreciation and impairment losses. Revaluations are to be made ‘with sufficient regularity to ensure that the carrying amount does not differ materially from that which would be determined using fair value at the reporting date.’

As we have said, many Tier 3 charities will use current rateable or government valuation. This is fine. If not the standard allows market-based appraisals to be used. In some cases depreciated replacement cost may be appropriate – say where there is a building on leasehold land. Some additional points to note:

• If an item of property is revalued, the entire class of property to which that asset belongs shall be revalued. (para 51)
• Land is one class, and Buildings are another class. (para 52)
• This means that you can’t just value one bit of land or one building – you have to revalue all land holdings or all buildings at the same time. (para 53)
• The increase from the revaluation must be recognised in ‘other comprehensive revenue and expense’ and accumulated in ‘net assets/equity’ under the heading of revaluation surplus. (para 54)

Remember that land is not to be depreciated, but buildings are – including depreciating the revaluation of buildings. So you will need to identify which part of the revaluation relates to land and which part to buildings.

The accounting treatment of the revaluation

A couple of problems arise here for Tier 3 entities. One is that they do not have an ‘other comprehensive revenue and expense’ category. The other relates to revaluation reserves.

PBE SFR-A (NFP) A143 states that there are two kinds of reserves; ‘Restricted reserves’ which may be used only for a particular purpose such as terms agreed with a donor, and ‘Discretionary reserves’ created by a transfer from accumulated funds to set aside resources for a particular purpose. Neither of these could pass as revaluation reserves.

There are two options. One is to bury the revaluation in accumulated funds. The second is to assume that if we are applying PBE IPSAS 17 it’s okay for us to break the letter of the Tier 3 law and make a revaluation reserve. I think this is the most sensible option, and the proposed changes to the Tier 3 standard obviously recognise the problem and assume the use of a revaluation reserve.

What about whether to record the revaluation through the Statement of Financial Performance or put it directly to Equity? Again I think that we are justified in adding to our Tier 3 rules by including an additional section in our Statement of Financial Performance – below the operating surplus or deficit – for the revaluation gain. Charities Services encourage this treatment. However, the updates to Tier 3 will allow the transfer of the surplus directly to reserves. So for now it is probably more correct to put through the Statement of Financial Performance – but ‘below the line.’

To revalue or not?

For entities who decide to use valuations for land and buildings, there will be some extra complexity and disclosure required. Extra notes will be needed, including details of the valuer, their qualifications, the date of valuation and the revaluation cycle. Depreciation will need to be calculated from the date of revaluation on the amount attributed to buildings. And auditors will need to assess all these things.

Note that there are proposed changes to the Tier 3 standard that do allow for revaluation to be done without having to move to PBE IPSAS 17. These are not far away.* See our commentary here. So if you are preparing financial statements for a Tier 3 entity you might want to consider waiting a while before revaluing, and just disclose the latest valuation by way of note.

*The new Tier 3 (NFP) Standard sets out the requirements that Tier 3 NFP entities are required to follow when preparing their annual performance reports. This Standard is required to be applied for accounting periods that begin on or after 1 April 2024. Earlier application is permitted for accounting periods that end after the Standard takes effect on 15 June 2023.

26 August 2022

Kaizen, also known as continuous improvement, is a long-term approach to work that systematically seeks to achieve small, incremental changes in processes in order to improve efficiency and quality.

Kaizen can be applied to any kind of work, but it is perhaps best known for being used in lean manufacturing and lean programming. If a work environment practices kaizen, continuous improvement is the responsibility of every worker, not just a selected few.

Kaizen can be roughly translated from Japanese to mean ‘good change.‘ The philosophy behind kaizen is often credited to Dr W. Edwards Deming. Dr Deming was invited by Japanese industrial leaders and engineers to help rebuild Japan after World War II. He was honoured for his contributions by Emperor Hirohito and the Japanese Union of Scientists and Engineers.

One version of the ten basic Kaizen principles is as follows (my comments are added in italics):

1. Throw out all your old fixed ideas on how to do things. Start with a clean slate every day, don’t get stuck in your old assumptions.
2. No blame – treat others as you want to be treated. Encourage and affirm others in the team including yourself.
3. Think positive – don’t say can’t. Lean into grace – there is always a way forward.
4. Don’t wait for perfection – 50% improvement now is fine. Don’t get stuck waiting for perfection, keep moving forward and over time results will come. A few mistakes show that you are taking risks and that’s okay.
5. Correct mistakes as soon as they are found. Be willing to admit mistakes and fix them in a timely way. It keeps your clients happy, encourages feedback and makes a better product.
6. Don’t substitute money for thinking – Creativity before Capital. When you have the money you may not be more creative. Limits are great for new ideas.
7. Keep asking “why?” until you get to the root cause. Don’t settle for overly simplistic solutions, or you will be treating the fruit instead of the root.
8. Better the wisdom of 5 people than the expertise of 1. Group wisdom will see through the simplistic answers – you can’t beat the wisdom of experience.
9. Base decisions on data not opinions. Make sure you have real evidence not just hearsay or guesses – check out your hunches and feelings against reality.
10. Improvement is not made from a conference room! Be out there among the people – staff and clients asking them where improvement can be made. Test theory in the real world.

Dr Deming was one of the key originators of these principles, and reading his original ideas is refreshing and somewhat surprising in their timelessness, bluntness and practicality – and also in their wide application to almost any kind of business enterprise. 

In his book Out of the Crisis, Dr Deming shared his philosophy of continuous improvement (again my comments are added in italics):

1. Create constancy of purpose toward improvement of product and service, with the aim to become competitive and to stay in business and to provide jobs. Have a clear philosophy – not just about money but about sustainability and job creation.
2. Adopt the new philosophy. We are in a new economic age. Western management must awaken to the challenge, must learn their responsibilities, and take on leadership for change. Just do it – keep revisiting.
3. Eliminate the need for inspection on a mass basis by building quality into the product in the first place. Do it the right first time as much as possible.
4. End the practice of awarding business on the basis of price tag. Instead, minimise total cost. Move towards a single supplier for any one item, on a long-term relationship of loyalty and trust. Use local firms where possible, and use organisations and people that fit well – the overall result will be lower cost.
5. Improve constantly and forever the system of production and service to improve quality and productivity and thus constantly decrease costs. Be constantly aware of how processes and systems may be improved and write these things down.
6. Institute training on the job. Give time to this – don’t rely on external training, learning on the job will give greater satisfaction to staff as their skills increase. Don’t expect them to ‘just know’.
7. Institute leadership. The aim of supervision should be to help people and machines and gadgets to do a better job. Be present and give and receive feedback on a regular basis.
8. Drive out fear so that everyone may work effectively for the company. Be approachable, admit fault, be fair and empower others – it will win respect.
9. Break down barriers between departments. People in research, design, sales and production must work as a team to foresee problems of production and use of the product or service. Communicate with co-workers, and treat everyone as of equal value. It will encourage work satisfaction, and team cohesion and so honesty and creativity will increase.
10. Eliminate slogans, exhortations, and targets for the work force asking for zero defects and new levels of productivity. Such exhortations only create adversarial relationships, as the bulk of the causes of low quality and low productivity belong to the system and thus lie beyond the power of the work force.
    • Eliminate work standards (quotas) on the factory floor. Substitute with leadership.
    • Eliminate management by objective. Eliminate management by numbers and numerical goals. Instead substitute with leadership.
    • Encourage one another and accept mistakes as normal to learning and developing new, good things.
11. Remove barriers that rob the hourly worker of his right to pride of workmanship. The responsibility of supervisors must be changed from sheer numbers to quality. Quality comes from focus and teamwork, not just pumping out work.
12. Remove barriers that rob people in management and in engineering of their right to pride of workmanship. This means, inter alia, abolishment of the annual or merit rating and of management by objectives. Let people enjoy coming up with their own solutions, and taking responsibility for projects themselves.
13. Institute a vigorous program of education and self-improvement. Encourage everyone to take time to ‘sharpen their saw.’
14. Put everybody in the company to work to accomplish the transformation. The transformation is everybody’s job. Involve everyone, as much as possible in the wide view – talk about sales and marketing with engineering people, and help salespeople understand the technical challenges.

I like to review these steps periodically. Adding my own twist on the basic principles helps me stick with my “why” – the values that define my personal business philosophy.

When we start losing our “why” we start feeling uncomfortable in our work. Reviewing this helps us see where we are perhaps getting pulled off the track and what we have been neglecting. I can see a couple right now I need to work on. A great reality check!