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Assessing credit losses in financial statement audits: A guide for auditors

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Credit losses represent a significant area of focus in financial statement audits. As economic conditions fluctuate and accounting standards evolve, auditors face increasing challenges in evaluating how organizations estimate and report credit losses, and in providing a comprehensive overview of credit loss assessment in financial statement audits. 

This article will explore the concept of credit losses, examine relevant regulatory frameworks, discuss vital challenges auditors encounter, and offer best practices for effectively auditing credit loss estimates. In addition, it will also describe key emerging trends and technologies shaping the future of credit loss auditing.

Credit losses occur when a borrower fails to repay a debt according to the initial agreement. These losses are typically reported as allowances for credit losses or loan loss provisions in financial statements. They represent the estimated amount of debt that may not be collected, reflecting the credit risk associated with a company’s financial assets.

For auditors, understanding how companies calculate and report credit losses is crucial. This process often involves complex estimates and judgments, as companies must forecast future economic conditions and borrower behavior. The shift toward more forward-looking models, such as the Current Expected Credit Loss model in the United States, has further increased the complexity of these estimates.

Auditors must evaluate whether these estimates are reasonable and supported by appropriate evidence, ensuring that financial statements accurately reflect the company’s credit risk exposure.

Regulatory framework and standards

Various standards and regulations govern the accounting for credit losses, which have undergone significant changes in recent years. In the United States, the Financial Accounting Standards Board introduced Accounting Standards Update 2016-13, which implemented the CECL model. Internationally, the International Accounting Standards Board has issued IFRS 9, which includes a similar expected credit loss model.

These standards require companies to recognize expected credit losses over the life of a financial asset rather than waiting for a loss event to occur. This forward-looking approach aims to provide financial statement users with more timely and relevant information about credit risk.

Auditors must stay current with these standards and any related interpretations or guidance issued by regulatory bodies. They must also understand how these standards apply to different types of financial assets and industries to effectively audit credit loss estimates.

Critical challenges in auditing credit losses

Auditing credit losses presents several challenges:

  • Complexity of models: Credit loss models often involve complex statistical techniques and numerous assumptions. Auditors must assess whether these models are appropriate and whether the assumptions used are reasonable.
  • Data quality and availability: The accuracy of credit loss estimates depends heavily on the quality and completeness of historical and current data. Auditors must evaluate the reliability of data sources and the processes used to collect and maintain this information.
  • Judgment and estimation uncertainty: Credit loss estimates involve significant judgment, particularly in forecasting future economic conditions. Auditors must evaluate the reasonableness of these judgments and ensure appropriate disclosure of estimation uncertainty.
  • Rapidly changing economic conditions: Economic volatility can quickly render historical data and assumptions obsolete. Auditors must consider how companies have incorporated recent economic trends and events into their estimates.
  • Internal controls: Assessing the effectiveness of internal controls over the credit loss estimation process is crucial but can be challenging due to the complexity and judgment involved.
  • Potential management bias: Given the subjective nature of credit loss estimates, there’s a risk of management bias. Auditors must remain skeptical and alert to potential manipulations of these estimates.

Best practices for auditors 

To effectively audit credit losses, auditors should consider the following best practices:

  • Develop a thorough understanding: Gain in-depth knowledge of the company’s business model, credit risk management practices and the specific credit loss estimation methodology.
  • Assess model appropriateness: Evaluate whether the credit loss model aligns with accounting standards and suits the company’s specific circumstances. When dealing with complex models, consider involving specialists.
  • Test key assumptions: Critically evaluate the reasonableness of key assumptions used in the credit loss model. This may involve comparing assumptions to industry benchmarks, historical data, and economic forecasts from reliable sources.
  • Perform sensitivity analyses: Assess how changes in key assumptions impact the credit loss estimate to understand the model’s sensitivity and identify potential areas of concern.
  • Evaluate data integrity: Test the completeness and accuracy of data used in the credit loss model. This includes both historical data and current information used to inform forward-looking estimates.
  • Review disclosures: Ensure financial statement disclosures adequately explain the credit loss estimation process, key assumptions and areas of uncertainty.
  • Assess internal controls: Thoroughly evaluate internal controls’ design and operating effectiveness over the credit loss estimation process.
  • Consider management bias: When selecting assumptions or data used in the estimation process, remain alert to potential indicators of management bias.
  • Document thoroughly: Maintain clear and comprehensive documentation of audit procedures performed, evidence obtained, and conclusions regarding credit loss estimates’ reasonableness.
  • Stay updated: Continuously monitor changes in accounting standards, regulatory guidance, and industry practices related to credit loss estimation and auditing.

Emerging trends and technologies

The field of credit loss auditing is evolving rapidly, driven by technological advancements and changing regulatory landscapes. Emerging trends include:

  • Increased use of artificial intelligence and machine learning in credit loss modeling;
  • Greater emphasis on real-time data analysis and continuous auditing techniques;
  • Enhanced data analytics tools for identifying patterns and anomalies in large datasets;
  • Growing focus on climate-related risks and their potential impact on credit losses; and,
  • Increased regulatory scrutiny of credit loss estimates, particularly during economic uncertainty.

The impact of AI on auditing credit losses

Artificial intelligence is revolutionizing how credit losses are estimated and audited. Its ability to quickly process vast amounts of data and identify complex patterns is particularly valuable in this field. 

Here are some key areas where AI is making a significant impact:

1. Enhanced pattern recognition. AI algorithms can analyze historical data to identify subtle patterns indicating increased credit risk. For example, an AI system might detect that customers who make frequent small purchases followed by large purchases are more likely to default. This pattern might need to be more nuanced for traditional analysis methods to catch.

Example: An auditor reviewing a bank’s credit loss estimates could use AI to analyze the transaction patterns of thousands of credit card holders. The AI might identify a correlation between certain spending behaviors and the likelihood of default that the bank’s model hasn’t accounted for, prompting the auditor to question the completeness of the bank’s risk assessment.

2. Improved forecasting. AI models can incorporate a broader range of variables and data sources to improve the accuracy of credit loss forecasts. This includes nontraditional data such as social media posts, online behavior, or macroeconomic indicators.

Example: When auditing a mortgage lender’s expected credit losses, an AI system could analyze not just traditional factors like credit scores and income but also incorporate data on local real estate trends, employment statistics, and even climate change projections for coastal properties. The auditor could assess whether the lender’s forecasting model is sufficiently comprehensive.

3. Real-time risk assessment. AI systems can continuously update risk assessments as new data becomes available, allowing for more dynamic credit loss estimates.

Example: An auditor reviewing a company’s accounts receivable might use an AI tool that continuously monitors customer payment behaviors, news about customer companies, and industry trends. This could help the auditor assess whether the company’s credit loss allowances are updated frequently enough to reflect current risks.

4. Anomaly detection. AI can quickly identify unusual patterns or transactions that might indicate errors in credit loss calculations or potential fraud.

Example: When auditing an extensive portfolio of loans, an AI system could flag individual loans or groups with risk characteristics that don’t align with their assigned risk ratings. This could help auditors focus on areas where the credit loss estimates might need to be more accurate.

5. Automation of routine tasks. AI can automate many routine aspects of auditing credit losses, such as data gathering, reconciliations, and basic calculations. This allows auditors to focus more on complex judgments and risk assessments.

Example: An AI system could automatically gather loan data, calculate expected loss rates based on historical performance, and compare these to the client’s estimates. The auditor could then focus on evaluating the reasonableness of any differences and assessing the qualitative factors that might justify them.

6. Enhanced scenario analysis. AI can rapidly run multiple complex economic scenarios to stress-test credit loss models, providing auditors with a more comprehensive view of potential risks.

Example: When auditing a bank’s loan loss provisions, an AI system could quickly generate and analyze hundreds of potential economic scenarios, considering factors like interest rates, unemployment and GDP growth. This could help the auditor assess whether the bank’s scenario analysis is sufficiently robust and comprehensive.

While AI offers significant benefits, it’s important to note that it also introduces new challenges for auditors. These include ensuring the reliability and appropriateness of AI models, understanding the “black box” nature of some AI algorithms, and maintaining professional skepticism when working with AI-generated insights. Auditors must develop new skills to effectively leverage AI tools while still applying their professional judgment to the audit process.

Auditors should stay informed about these trends and consider how they might impact their audit approaches and methodologies.

Final word

Auditing credit losses remains a complex and challenging task. By staying informed, applying best practices, and leveraging emerging technologies, auditors can enhance the effectiveness and efficiency of their work, ultimately contributing to the reliability and transparency of financial reporting.

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IRS and Treasury propose regs on 401(k) and 403(b) automatic enrollment, Roth IRA catchup contributions

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The Treasury Department and the Internal Revenue Service issued proposed regulations Friday for several provisions of the SECURE 2.0 Act, including ones related to automatic enrollment in 401(k) and 403(b) plans, and the Roth IRA catchup rule.

SECURE 2.0 Act passed at the end of 2022 and contained an extensive list of provisions related to retirement planning, like the original SECURE Act of 2019, with some being phased in over five years.

One set of proposed regulations involves provisions requiring newly-created 401(k) and 403(b) plans to automatically enroll eligible employees starting with the 2025 plan year. In general, unless an employee opts out, a plan needs to automatically enroll the employee at an initial contribution rate of at least 3% of the employee’s pay and automatically increase the initial contribution rate by one percentage point each year until it reaches at least 10% of pay. The requirement generally applies to 401(k) and 403(b) plans established after Dec. 29, 2022, the date the SECURE 2.0 Act became law, with exceptions for new and small businesses, church plans and governmental plans.

The proposed regulations include guidance to plan administrators for properly implementing this requirement and are proposed to apply to plan years that start more than six months after the date that final regulations are issued. Before the final regulations are applicable, plan administrators need to apply a reasonable, good faith interpretation of the statute.

Roth IRA catchup contributions

The Treasury and the IRS also issued proposed regulations Friday addressing several SECURE 2.0 Act provisions involving catch-up contributions, which are additional contributions under a 401(k) or similar workplace retirement plan that generally are allowed with respect to employees who are age 50 or older.

That includes proposed rules related to a provision requiring that catch-up contributions made by certain higher-income participants be designated as after-tax Roth contributions.

The proposed regulations provide guidance for plan administrators to implement and comply with the new Roth catch-up rule and reflect comments received in response to Notice 2023-62, issued in August 2023. 

The proposed regulations also provide guidance relating to the increased catch-up contribution limit under the SECURE 2.0 Act for certain retirement plan participants. Affected participants include employees between the ages of 60-63 and employees in newly established SIMPLE plans.

The IRS and the Treasury are asking for comments on both sets of proposed regulations. 

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IRS to start 2025 tax filing season on Jan. 27

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The Internal Revenue Service said tax season will begin on Monday, Jan. 27, 2025, with newly expanded and improved tools available.

The IRS anticipates over 140 million individual tax returns for tax year 2024 will be filed ahead of the Tuesday, April 15 federal deadline. Over half of all tax returns are expected to be filed this year with the help of a tax professional, and the IRS is urging taxpayers to use a trusted tax professional to avoid potential scams and schemes.

The IRS is also planning to open its new Direct File program on Jan. 27, even though the program has come under attack from Republicans in Congress. On the first day of the filing season, Direct File will open to eligible taxpayers in 25 states to file their taxes directly with the IRS for free: 12 states that were part of the pilot last year, plus 13 new states where Direct File will be available in 2025. During last year’s pilot, Direct File was available in Arizona, California, Florida, Massachusetts, Nevada, New Hampshire, New York, South Dakota, Tennessee, Texas, Washington State and Wyoming. For the 2025 tax filing season, Direct File will also be available in Alaska, Connecticut, Idaho, Illinois, Kansas, Maine, Maryland, New Jersey, New Mexico, North Carolina, Oregon, Pennsylvania and Wisconsin.

In addition to covering taxpayers claiming the standard deduction and deductions for student loan interest and educator expenses, this year, Direct File will support taxpayers claiming deductions for Health Savings Accounts. The Treasury Department estimates that more than 30 million taxpayers will be eligible to use Direct File across the 25 states.

The 2025 tax season will reflect continued IRS progress to modernize and add new tools and features to help taxpayers. Since last tax season, improvements include more access to tax account information from text and voice virtual assistants, expanded features on the IRS Individual Online Account, more access to dozens of tax forms through cell phones and tablets and expanded alerts for scams and schemes that threaten taxpayers.

Direct File will include new features this year. A data import tool will allow taxpayers to opt-in to automatically import data from their IRS account, including personal information, the taxpayer’s IP PIN and some information from the taxpayer’s W-2. Also, this year, Direct File will cover more tax situations. During the pilot, Direct File supported taxpayers claiming the Earned Income Tax Credit, Child Tax Credit and Credit for Other Dependents. This year, Direct File will also cover taxpayers claiming the   Child and Dependent Care Credit, Premium Tax Credit, Credit for the Elderly and Disabled, and Retirement Savings Contribution Credits.

“It’s important for everyone to realize that the filing season improvements we’re highlighting today, and many others, are all a reflection of our ongoing work to modernize our agency and the interactions that taxpayers have with us,” said IRS Commissioner Danny Werfel during a press conference Friday. “The multiyear funding provided by Congress continues to drive changes across the IRS, and taxpayers will continue to see this work in the months and years ahead.”

He predicted taxpayers would see a continuing improvement in the IRS in 2025 and beyond. “Brick by brick, or online tool by online tool, we are building a modern interface with taxpayers and tax professionals,” said Werfel. “We are moving steadily to accelerate these technology advancements for the benefit of everyone. These efforts are all about making the process of filing taxes easier and less stressful for taxpayers and also making it more cost efficient.”

Werfel made a case for continuing IRS funding as the agency faces the prospect of $20 billion in budget cuts as a result of the continuing resolution that Congress passed to keep the government open. Werfel said it should not be a partisan issue to provide continued funding for the IRS. He declined to answer questions about whether he has had any conversations with former Rep. Billy Long, who has been named as the next IRS commissioner by President-elect Trump, even though Werfel’s term doesn’t end until November 2027. Asked how long he plans to remain at the IRS, he insisted he has remained “laser focused” on his job and preparing for filing season.

“I spend every waking hour during the day and, quite frankly, at night, focused on one thing and one thing only, and that’s getting ready for this filing season,” said Werfel. “That has consumed all of my energy, and that is my sole focus.”

He stressed the need for Congress to provide continued funding for the IRS. “Thanks to the efforts of employees throughout the agency, we have a great deal of momentum right now on many improvements for taxpayers, more tools, more simplicity, less stress, less burden,” said Werfel. “That momentum is important because we still have a long way to go. Our ultimate goal is to have an IRS where all taxpayers can meet all of their responsibilities, including interactions with us, from questions to payments to resolutions in a completely digital manner if they prefer. For the IRS to continue to succeed, we must ensure we provide our employees with the right training and tools, as well as a modern technology infrastructure to help taxpayers. These are essential to allow the IRS to continue its modernization work to serve the nation today and in the future, and so our ability to continue making progress on all these fronts can only happen if the IRS receives a consistent, reliable funding stream. We also should not lose sight of the fact that we have accomplished so much on this journey to modernize our agency and improve service to taxpayers with the multiyear funding Congress has provided. The decision about whether to adequately fund the agency comes down to a fundamental choice, whether or not we can and should have an IRS that you can easily interact with to help meet your tax responsibilities, that can quickly and effectively address tax scams that exploit vulnerable populations, and that can deliver updated IT infrastructure and modern technology platforms capable of supporting our work to modernize the agency. For the IRS to be able to do all these things, adequate stable funding is essential, and we will continue making our case to Congress.”  

Although the IRS won’t start accepting tax returns until Jan. 27, starting today, nearly everyone can file electronically for free by using IRS Free File, available via IRS.gov. Now in its 23rd year, Free File includes free tax preparation software from eight companies in the public-private partnership between the IRS and Free File Inc. As part of this partnership, tax preparation and filing software partners offer their online products to eligible taxpayers for free. To access these tools, taxpayers should start from the IRS Free File page on IRS.gov.

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Accounting

On the move: HCVT adds to partnership

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Ericksen Krentel elects sixth MP; Yeo & Yeo, Grassi and BMSS move offices; IFRS Foundation appoints three new trustees; and more news from across the profession.

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