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Corporate Compliance Seminars (CCS) is the source for continuing professional education (CPE) credits concerning internal audit training, external audit training, internal control training, Cybersecurity training, COSO training, PCAOB Audit Standards training and project management training.


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PCAOB 2019 Inspection Part 1.B Non-compliance Items



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PCAOB Broker Dealer Inspection SEC AS CPE CPA CIA IIA External Audit risk training course compliance SOX 404 COSO ICFR ITGC Auditing Standard Audit standard report best workpapers NASBA

Corporate Compliance Seminars (CCS) has recently completed an analysis of the 2019 PCAOB inspection reports covering the "Big 12" audit firms.

This page provides some of the detial information we compiled to create our training event on these reports. This information should be useful to an audit staff to understand the risks presented in providing audit services.

This list of Non-compliance was compiled from the following 2019 PCAOB inspection reports:
- BDO USA, LLP
- Cohen & Company, Ltd.
- Crowe LLP
- Deloitte & Touche LLP
- Ernst & Young LLP
- Grant Thornton LLP
- KPMG LLP
- MaloneBailey, LLP
- Marcum LLP
- Moss Adams LLP
- PricewaterhouseCoopers LLP
- RSM US LLP

Non-Compliance Statements by PCAOB Auditing Standard or Rule:

PCAOB AS 1205, Part of the Audit Performed by Other Independent Auditors

In three of 14 audits reviewed, the firm was the principal auditor but did not obtain, and review and retain, letters of representation from management that its foreign affiliates had obtained for certain of the issuer's non-U.S. components. In these instances, the firm was non-compliant with AS 1205, Part of the Audit Performed by Other Independent Auditors.

Deloitte

In three of 14 audits reviewed, the firm was the principal auditor but did not obtain, and review and retain, letters of representation from management that its foreign affiliates had obtained for certain of the issuer's non-U.S. components. In these instances, the firm was non-compliant with AS 1205, Part of the Audit Performed by Other Independent Auditors.

E&Y

PCAOB AS 1215, Audit Documentation

In seven of 14 audits reviewed, the firm did not include all relevant work papers in the final set of audit documentation it was required to assemble. In these instances, the firm was non-compliant with AS 1215, Audit Documentation.

Crowe

In seven of 55 audits reviewed, the firm did not include all relevant work papers in the final set of audit documentation it was required to assemble. In these instances, the firm was non-compliant with AS 1215, Audit Documentation.

Deloitte

AS 1301, Communications with Audit Committees

In four of 16 audits reviewed, the firm did not make certain required communications to the issuer's audit committee related to the names, locations, and planned responsibilities of other independent public accounting firms that performed audit procedures in the current period audit. In these instances, the firm was non-compliant with AS 1301, Communications with Audit Committees.

PWC

In two of four audits reviewed, the firm did not document its required communication to the issuer's audit committee related to the basis for its conclusion that substantial doubt about the issuer's ability to continue as a going concern was alleviated, including the elements it identified within management's plans that were significant to overcoming the adverse effects of the conditions and events identified. In these instances, the firm was noncompliant with AS 1301, Communications with Audit Committees.

BDO

In one of 12 audits reviewed, the firm did not make certain required communications to the issuer's audit committee related to the names, locations, and planned responsibilities of other independent public accounting firms that performed audit procedures in the current period audit. In this instance, the firm was non-compliant with AS 1301, Communications with Audit Committees.

BDO

In six of 12 audits reviewed, the firm did not make certain required communications to the issuer's audit committee, or equivalent, related to (1) the significant risks identified through its risk assessment procedures and (2) a draft of the firm's audit report. In these instances, the firm was non-compliant with AS 1301, Communications with Audit Committees.

Malone Bailey

In five of 12 audits reviewed, the firm did not make required communications to the issuer's audit committee, or equivalent, related to the implications that the corrected misstatements might have on the issuer's financial reporting process. In these instances, the firm was non-compliant with AS 1301, Communications with Audit Committees.

Malone Bailey

In five of 12 audits reviewed, the firm did not communicate the results of the audit to the issuer's audit committee, or equivalent, in a timely manner. In these instances, the firm was non-compliant with AS 1301, Communications with Audit Committees.

Malone Bailey

In three of 12 audits reviewed, the firm did not make a required communication to the issuer's audit committee, or equivalent, related to the basis for the determination that the uncorrected misstatements were immaterial, including the qualitative factors considered. In these instances, the firm was non-compliant with AS 1301, Communications with Audit Committees.

Malone Bailey

In two of 12 audits reviewed, the firm did not provide to the issuer's audit committee, or equivalent, the management representation letter prior to the issuance of the firm's audit report. In these instances, the firm was non-compliant with AS 1301, Communications with Audit Committees and AS 2805, Management Representations.

Malone Bailey

In one of 27 audits reviewed, the firm did not communicate to the issuer's audit committee a complete list of the uncorrected misstatements that were required to be provided. In this instance, the firm was non-compliant with AS 1301, Communications with Audit Committees.

Grant Thornton

In three of 19 audits reviewed, the firm did not make certain required communications to the issuer's audit committee related to the names, locations, and planned responsibilities of other independent public accounting firms that performed audit procedures in the current period audit. In these instances, the firm was non-compliant with AS 1301, Communications with Audit Committees.

KPMG

In six of 12 audits reviewed, the firm did not make certain required communications to the issuer's audit committee related to the significant risks identified through its risk assessment procedures. In these instances, the firm was non-compliant with AS 1301, Communications with Audit Committees.

Marcum

In one of 12 audits reviewed, the firm did not make a required communication to the issuer's audit committee related to uncorrected misstatements. In this instance, the firm was non-compliant with AS 1301, Communications with Audit Committees.

Marcum

In one of 12 audits reviewed, the firm did not make a required communication to the issuer's audit committee related to a draft of the firm's audit report. In this instance, the firm was non-compliant with AS 1301, Communications with Audit Committees.

Marcum

In four of 16 audits reviewed, the firm did not make certain required communications to the issuer's audit committee related to the names, locations, and planned responsibilities of other independent public accounting firms that performed audit procedures in the current period audit. In these instances, the firm was non-compliant with AS 1301, Communications with Audit Committees.

PWC

AS 2201, An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements

In one of 23 audits reviewed, the firm's audit report on the issuer's financial statements included incorrect explanatory language related to the audit of the issuer's ICFR. In this instance, the firm was non-compliant with AS 2201, An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements.

Grant Thornton

In one of 18 audits reviewed, the firm did not include in its report on ICFR a disclosure regarding the exclusion of acquired businesses from the scope of both management's assessment and the firm's audit of ICFR. In this instance, the firm was non-compliant with AS 2201, An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements.

E&Y

In one of 18 audits reviewed, the firm did not include in its report on ICFR a disclosure regarding the exclusion of acquired businesses from the scope of both management's assessment and the firm's audit of ICFR. In this instance, the firm was non-compliant with AS 2201, An Audit of Internal Control Over Financial Reporting That Is Integrated with An Audit of Financial Statements.

E&Y

AS 2805, Management Representations

In one of 28 audits reviewed, the firm did not provide management with a complete list of uncorrected misstatements to be included in or attached to the management representation letter. In this instance, the firm was non-compliant with AS 2805, Management Representations.

Grant Thornton

In two of 12 audits reviewed, the firm did not provide to the issuer's audit committee, or equivalent, the management representation letter prior to the issuance of the firm's audit report. In these instances, the firm was non-compliant with AS 1301, Communications with Audit Committees and AS 2805, Management Representations.

Malone Bailey

AS 3101, The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion

In one of 15 audits reviewed, the firm's audit report did not include statements that (1) the audit was conducted in accordance with the standards of the PCAOB and (2) PCAOB standards require that the auditor plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. In this instance, the firm was non-compliant with AS 3101, The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion.

RSM

In one of three audits reviewed, the communication of a CAM in the audit report included inaccurate language in the description of (1) the principal considerations that led the firm to determine that the matter was a CAM and (2) how that CAM was addressed in the firm's audit. In this instance, the firm was non-compliant with AS 3101, The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion.

KPMG

In one of 12 audits reviewed, the firm's audit report contained inaccurate information for the year the firm began serving consecutively as the issuer's auditor. In this instance, the firm was non-compliant with AS 3101, The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion.

Marcum

In one audit, the firm's audit report contained inaccurate information about the year the firm began serving consecutively as the company's auditor. In this instance, the firm was non-compliant with AS 3101, The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion.

Malone Bailey

In one of 15 audits reviewed, the firm's audit report did not include statements that (1) the audit was conducted in accordance with the standards of the PCAOB and (2) PCAOB standards require that the auditor plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. In this instance, the firm was non-compliant with AS 3101, The Auditor's Report on an Audit of Financial Statements When the Auditor Expresses an Unqualified Opinion.

RSM

PCAOB Rule 3211, Auditor Reporting of Certain Audit Participants

In one of 12 audits reviewed, the firm did not file its report on Form AP by the relevant deadline. In this instance, the firm was non-compliant with PCAOB Rule 3211, Auditor Reporting of Certain Audit Participants.

Marcum

In one of 13 audits reviewed, the firm's report on Form AP omitted information related to the participation in the audit by certain other accounting firms. In this instance, the firm was non-compliant with PCAOB Rule 3211, Auditor Reporting of Certain Audit Participants.

E&Y

In seven of 32 audits reviewed, the firm's report on Form AP either contained inaccurate information or omitted information related to the participation in the audit by certain other accounting firms. In one audit reviewed and in three other audits, the firm did not file its report on Form AP by the relevant deadline. In these instances, the firm was non-compliant with PCAOB Rule 3211, Auditor Reporting of Certain Audit Participants.

PWC

In one of 12 audits reviewed, the firm's report on Form AP contained inaccurate information and omitted information related to the participation in the audit by certain other accounting firms. In this instance, the firm was non-compliant with PCAOB Rule 3211, Auditor Reporting of Certain Audit Participants.

BDO

In five of 12 audits reviewed, the firm did not document the computation of total audit hours it used in its report on Form AP. In these instances, the firm was non-compliant with PCAOB Rule 3211, Auditor Reporting of Certain Audit Participants.

BDO

In one of 11 audits reviewed, the firm's report on Form AP omitted information related to the participation in the audit by an other accounting firm. In this instance, the firm was non-compliant with PCAOB Rule 3211, Auditor Reporting of Certain Audit Participants.

Moss Adams

In one audit, the firm's report on Form AP contained inaccurate information related to the participation in the audit by an other accounting firm. In this instance, the firm was non-compliant with PCAOB Rule 3211, Auditor Reporting of Certain Audit Participants.

Malone Bailey

In two of 14 audits reviewed, the firm's report on Form AP contained inaccurate information and/or omitted information related to the participation in the audit by certain other accounting firms. In these instances, the firm was non-compliant with PCAOB Rule 3211, Auditor Reporting of Certain Audit Participants.

Grant Thornton

In two of 20 audits reviewed, the firm's report on Form AP omitted information related to the participation in the audit by certain other accounting firms. In these instances, the firm was non-compliant with PCAOB Rule 3211, Auditor Reporting of Certain Audit Participants.

KPMG

PCAOB Rule 3524, Audit Committee Pre-Approval of Certain Tax Services

In one of 10 audits reviewed, the firm's required written communications to the audit committee were insufficient as the firm did not include a description of the nature and scope of certain tax services. In this instance, the firm was non-compliant with PCAOB Rule 3524, Audit Committee Pre-approval of Certain Tax Services.

E&Y

In one of 12 audits reviewed, the firm's required written communications to the audit committee were insufficient as the firm did not include a description of the nature and scope of certain tax services to the audit committee. In this instance, the firm was non-compliant with PCAOB Rule 3524, Audit Committee Pre-approval of Certain Tax Services.

PWC

In five of 11 audits reviewed, the firm did not document the substance of its discussions with the audit committee about the potential effects of certain permissible tax services on the independence of the firm. In these instances, the firm was non-compliant with PCAOB Rule 3524, Audit Committee Pre-Approval of Certain Tax Services.

Grant Thornton

In one of 10 audits reviewed, the firm did not document the substance of its discussions with the audit committee about the potential effects of certain permissible tax services on the independence of the firm. In this instance, the firm was non-compliant with PCAOB Rule 3524, Audit Committee Pre-Approval of Certain Tax Services.

KPMG

PCAOB Rule 3526, Communication with Audit Committees Concerning Independence

In one of 12 audits reviewed, the firm did not describe in writing to the audit committee all relationships that, as of the date of the firm's communication, may have been thought to bear on the independence of the firm. In this instance, the firm was non-compliant with PCAOB Rule 3526, Communication with Audit Committees Concerning Independence.

PWC

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Corporate Compliance Seminars (CCS) was created by experts who enjoy providing CPE training events. All our experts have years of experience in providing training courses, workshops and consulting on internal controls, internal auditing, information technology, cybersecurity and accounting related subjects. We have focused on SOX, COSO, PCAOB, COBIT, CMMI, GRC, GAAP, IFRS, AICPA, GAO, NAIC, ISO, and IIA Standards. We are your best source for continuing professional education (CPE).

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Corporate Compliance Seminars presents CPE to a range of professionals, auditors, accountants, finance staff, compliance personnel, information technology (IT) professionals, Boards of Directors and Audit Committees. We examine the details of risk management, Sarbanes-Oxley Act compliance, Model Audit Rule (MAR) compliance, auditing, internal controls, cybersecurity and compliance, and fraud prevention and detection.

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Our instructors have had direct experience in the following industries: financial activities, bank, insurance, healthcare, construction, leisure and hospitality, professional and business services, mining and oil & gas extraction, manufacturing, educational, government agencies, transportation, software, technical, hi-tech and agricultural.

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Our events are targeted at members of the IIA, AICPA, ISACA, ACFE and other professional groups that recognize the National Registry of CPE Sponsors CPE credits.