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Audit teams missed risks of material misstatement by banks

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The Public Company Accounting Oversight Board staff released a report Monday on how during 2022 and 2023, several firms’ engagement teams working on audits in the banking sector did not adequately identify the risks of material misstatement ahead of the high-profile implosion of several banks.

The Spotlight report, “Bank Financial Reporting Audits, discusses the PCAOB’s inspection response to bank failures in early 2023 and the continued effects of these bank failures on the banking industry and includes an overview of survey responses outlining how dozens of U.S. firms responded to disruptions in the banking industry, including impacts from rising interest rates. It also includes some observations from the PCAOB’s inspection activities, along with a description of good practices at audit firms in key focus areas.

The PCAOB encouraged firms to consider some of the potential risks, including increased volatility in financial and commodity markets due to fluctuations in interest rates and inflationary trends in an earlier Spotlight report, “Staff Overview for Planned 2022 Inspections,” which was published in June 2022.

PCAOB logo - office - NEW 2022

Then, after vulnerabilities in the banking sector were exposed in early 2023 as high-profile banks such as Silicon Valley Bank and Signature Bank went under, the PCAOB revised its inspection plan to respond in real time, including sending a questionnaire to survey 40 U.S. firms that audit at least one bank, with additional emphasis on the 13 U.S. firms that audit 10 or more banks. The survey was designed to provide insight into how firms evaluated emerging and evolving risks in the sector.

In reviewing the survey responses, the PCAOB found that over 70% of the engagement teams it surveyed did not identify a risk of material misstatement due to rising interest rates. Over 95% did not identify a risk of material misstatement related to liquidity. Over 95% did not identify a risk of material misstatement through reviewing information from short sellers, analysts, or other publicly available information, and over 65% did not identify any risk of material misstatement related to concentration risks. Finally, over 95% of the engagement teams did not identify a risk of fraud related to investments or related disclosures. A few firms indicated rising interest rates were a “business-only” risk, relating to the operations of the bank without directly influencing financial reporting.

As they reviewed the banking sector audits completed in early 2023 for financial statements dated in late 2022, PCAOB inspectors noticed a variety of deficiencies. In some instances, for example, engagement teams did not revisit initial risk assessments performed earlier in the year as interest rates continued to rise. Inspectors also observed instances of interest rate volatility being documented as an operational or business issue – with no financial reporting or internal control over financial reporting considerations.

As a result, some engagement teams did not identify in their audits certain risks of material misstatement despite changes in bank-specific or macroeconomic conditions that indicated increased risk in certain audit areas.

In response to the survey results, the PCAOB adjusted its inspection plan, telling its target team to perform procedures on interim reviews of banks in order to provide real-time perspective on important risks. Inspectors also chose additional bank audits for inspection, and worked to ensure emerging banking and economic trends, and banking issues or common deficiencies, were appropriately considered in our selections.

In addition to some common observations from the PCAOB’s inspection activities, the Spotlight report provides a description of good practices observed at audit firms that may enhance audit quality if broadly adopted. The Spotlight provides these insights in in four focus areas: investment securities, allowance for credit losses, deposit liabilities, and loans and related accounts.

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Accounting

FASB proposes guidance on accounting for government grants

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The Financial Accounting Standards Board issued a proposed accounting standards update Tuesday to establish authoritative guidance on the accounting for government grants received by business entities. 

U.S. GAAP currently doesn’t provide specific authoritative guidance about the recognition, measurement, and presentation of a grant received by a business entity from a government. Instead, many businesses currently apply the International Financial Reporting Standards Foundation’s International Accounting Standard 20, Accounting for Government Grants and Disclosure of Government Assistance, by analogy, at least in part, to account for government grants.

In 2022 FASB issued an Invitation to Comment, Accounting for Government Grants by Business Entities—Potential Incorporation of IAS 20, Accounting for Government Grants and Disclosure of Government Assistance, into GAAP. In response, most of FASB’s stakeholders supported leveraging the guidance in IAS 20 to develop accounting guidance for government grants in GAAP, believing it would reduce diversity in practice because entities would apply the guidance instead of analogizing to it or other guidance, thus narrowing the variability in accounting for government grants.

Financial Accounting Standards Board offices with new FASB logo sign.jpg
FASB offices

Patrick Dorsman/Financial Accounting Foundation

The proposed ASU would leverage the guidance in IAS 20 with targeted improvements to establish guidance on how to recognize, measure, and present a government grant including (1) a grant related to an asset and (2) a grant related to income. It also would require, consistent with current disclosure requirements, disclosure about the nature of the government grant received, the accounting policies used to account for the grant, and significant terms and conditions of the grant, among others.

FASB is asking for comments on the proposed ASU by March 31, 2025.

“It will not be a cut and paste of IAS 20,” said FASB technical director Jackson Day during a session at Financial Executives International’s Current Financial Reporting Insights conference last week. “First of all, the scope is going to be a little bit different, probably a little bit more narrow. Second of all, the threshold of recognizing a government grant will be based on ‘probable,’ and ‘probable’ as we think of it in U.S. GAAP terms. We’re also going to do some work to make clarifications, etc. There is a little bit different thinking around the government grants for assets. There will be a deferred income approach or a cost accumulation approach that you can pick. And finally, there will be different disclosures because the disclosures will be based on what the board had previously issued, but it does leverage IAS 20. A few other things it does as far as reducing diversity. Most people analogized IAS 20. That was our anecdotal findings. But what does that mean? How exactly do they do that? This will set forth the specifics. It will also eliminate from the population those that were analogizing to ASC 450 or 958, because there were a few of those too. So it will go a long way in reducing diversity. It will also head down a model that will be generally internationally converged, which we still think about. We still collaborate with the staff [of the International Accounting Standards Board]. We don’t have any joint projects, but we still do our best when it makes sense to align on projects.”

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Accounting

In the blogs: Questions for the moment

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Fighting scope creep; QCDs as the year ends; advising ministers; and other highlights from our favorite tax bloggers.

Questions for the moment

  • CLA (https://www.claconnect.com/en/resources?pageNum=0): One major question of the moment: What can nonprofits expect from future federal tax policies?
  • Mauled Again (http://mauledagain.blogspot.com/): Not long ago, about a dozen states would seize property for failure to pay property taxes and, instead of simply taking their share of unpaid taxes, interest, and penalties and returning the excess to the property owner, they would pocket the entire proceeds of the sales. Did high court intervention stem this practice? Not so much.
  • TaxConnex (https://www.taxconnex.com/blog-): What are the best questions to pin down sales tax risk and exposure?
  • Current Federal Tax Developments (https://www.currentfederaltaxdevelopments.com/): In Surk LLC v. Commissioner, the Tax Court was presented with the question of basis computations related to an interest in a partnership. The taxpayer mistakenly deducted losses that exceeded the limitation in IRC Sec. 704(d), raising the question: Should the taxpayer reduce its basis in subsequent years by the amount of those disallowed losses or compute the basis by treating those losses as if they were never deducted?

Creeping

On the table

  • Don’t Mess with Taxes (http://dontmesswithtaxes.typepad.com/): What to remind them, as end-of-year planning looms, about this year’s QCD numbers.
  • Parametric (https://www.parametricportfolio.com/blog): If your clients are using more traditional commingled products for their passive exposures, they may not know how much tax money they’re leaving on the table. A look at possible advantages of a separately managed account. 
  • Turbotax (https://blog.turbotax.intuit.com): Whether they’re talking diversification, gainful hobby or income stream, what to remind them about the tax benefits of investing in real estate.
  • The National Association of Tax Professionals (https://blog.natptax.com/): Q&A from a recent webinar on day cares’ unique income and expense categories.
  • Boyum & Barenscheer (https://www.myboyum.com/blog/): For larger manufacturers, compliance under IRC 263A is essential. And for all manufacturers, effective inventory management goes beyond balancing stock levels. Key factors affecting inventory accounting for large and small manufacturing businesses.
  • U of I Tax School (https://taxschool.illinois.edu/blog/): What to remind them — and yourself — about the taxation of clients who are ministers.
  • Withum (https://www.withum.com/resources/): A look at the recent IRS Memorandum 2024-36010 that denied the application of IRC Sec. 245A to dividends received by a controlled foreign corporation.

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Accounting

PwC funds AI in Accounting Fellowship at Bryant University

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PwC made a $1.5 million investment to Bryant University, in Smithfield, Rhode Island, to fund the launch of the PwC AI in Accounting Fellowship.

The experiential learning program allows undergraduate students to explore AI’s impact in accounting by way of engaging in research with faculty, corporate-sponsored projects and professional development that blends traditional accounting principles with AI-driven tools and platforms. 

The first cohort of PwC AI in Accounting Fellows will be awarded to members of the Bryant Honors Program planning to study accounting. The fellowship funds can be applied to various educational resources, including conference fees, specialized data sheets, software and travel.

PwC sign, branding

Krisztian Bocsi/Bloomberg

“Aligned with our Vision 2030 strategic plan and our commitment to experiential learning and academic excellence, the fellowship also builds upon PwC’s longstanding relationship with Bryant University,” Bryant University president Ross Gittell said in a statement. “This strong partnership supports institutional objectives and includes the annual PwC Accounting Careers Leadership Institute for rising high school seniors, the PwC Endowed Scholarship Fund, the PwC Book Fund, and the PwC Center for Diversity and Inclusion.”

Bob Calabro, a PwC US partner and 1988 Bryant University alumnus and trustee, helped lead the development of the program.

“We are excited to introduce students to the many opportunities available to them in the accounting field and to prepare them to make the most of those opportunities, This program further illustrates the strong relationship between PwC and Bryant University, where so many of our partners and staff began their career journey in accounting” Calabro said in a statement.

“Bryant’s Accounting faculty are excited to work with our PwC AI in Accounting Fellows to help them develop impactful research projects and create important experiential learning opportunities,” professor Daniel Ames, chair of Bryant’s accounting department, said in a statement. “This program provides an invaluable opportunity for students to apply AI concepts to real-world accounting, shaping their educational journey in significant ways.”

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