The Public Company Accounting Oversight Board is rolling out a new series of staff publications targeted at auditors of small public companies, starting with one on critical audit matters, as board members face the likelihood of a deregulatory emphasis under the incoming Trump administration and probable changes in board composition.
The PCAOB released the first of the new series of staff publications, “Audit Focus: Critical Audit Matters,” which aims to provide easy-to-digest information to auditors, especially those who audit smaller public companies. With an eye toward protecting investors and improving audit quality, each edition of Audit Focus reiterates applicable auditing standards and staff guidance and offers reminders and good practices tailored to PCAOB-registered auditors of smaller public companies.
The PCAOB staff is continuing to identify a great many deficiencies related to critical audit matters. CAMs are a relatively new requirement from the PCAOB. A CAM is defined as any matter arising from the audit of the financial statements that was communicated or required to be communicated to the audit committee and that relates to accounts or disclosures that are material to the financial statements; and involved especially challenging, subjective or complex auditor judgment.
This edition of Audit Focus highlights key reminders on determination, communication and documentation of CAMs, along with the PCAOB staff’s perspectives on some of the common deficiencies, such as not accurately describing how a CAM was addressed in the audit, plus good practices that the staff has observed related to CAMs, such as use of practice aids.
PCAOB board members George Botic and Christina Ho discussed the recent inspection findings during a panel discussion Wednesday during Financial Executives International’s Current Financial Reporting Insights conference.
“When you think about where our inspectors see repeated observations, deficiencies, if you will, particularly in Part I.A, which are for the firms not obtaining sufficient appropriate audit evidence, things like revenue recognition, inventory, allowance for credit losses in the financial sector, areas around business combinations, allowance for allocation of purchase price, things such as that, as well as long-lived assets, goodwill, intangibles, evaluation, those are some of the more frequent areas,” said Botic. “ICFR certainly is one as well in the internal control space. But those areas, those themes, really haven’t changed. Sometimes we’ll see more of one versus another.”
During its inspections last year, the PCAOB saw some improvements at the largest firms, even though audit deficiency rates still appear to be high, with 46% of the engagements reviewed in 2023 having at least one deficiency significant enough to be included in Part I.A of the inspection report, excluding broker-dealer audit inspections, according to a staff spotlight publication that was released in August.
“There appears to be some improvement in terms of the deficiency rate trend for the largest firms,” said Ho. “It’s probably too soon to tell whether that is going to be the ongoing trend. Also for triennial firms, the spotlight also highlighted the fact that the deficiency rates are not improving.”
She pointed out that financial restatements are another way to look at the situation. “Obviously, the deficiency rate is not the only measurement of audit quality,” said Ho. “We also look at restatements, which I think for many of the preparers and audit committees that I talk to, and even investors, they focus on that metric a lot. The multiple metrics paint a picture.”
PCAOB board member Christina Ho speaking at the FEI CFRI virtual conference
Botic sees advantages in having several such metrics. “The audit process is one of the most complex processes, probably in business,” said Botic. “When you think about all the judgments that you all go through for your financial statements and preparing them, then the auditor makes his or her own risk assessment judgments, it’s an incredibly complex process. So I agree, not one metric necessarily is the only metric for sure. We’re inspecting the audit, so our inspectors are looking at what the auditor did or didn’t do, as the case may be, and as part of that, we may identify the accounting was wrong. That is one possibility, as Christina mentioned, the categorization of the reports. But in my view and from my prior life as well, and spending a lot of time in inspections, I actually think that the spread from the inspection deficiency rates for the filers that we looked at compared to the restatement number, I think that’s actually … reflective of the success of our inspection program.”
Ho recently found herself singled out in a letter from a pair of Senate Democrats, Elizabeth Warren of Massachusetts and Sheldon Whitehouse of Rhode Island, for painting an overly rosy picture of the problems plaguing auditing firms, and she complained in a LinkedIn post that they were “persecuting” her and trying to “stifle” her from “expressing views inconsistent with their false narrative.”
Accounting Today asked Ho during a press conference after the FEI CFRI session about the political pressure she faced, especially with President-elect Trump’s administration coming in and perhaps replacing PCAOB board members as happened during his first administration as well as the Biden administration.
“Like I said in my LinkedIn post, I’m not a political person,” Ho responded. “When I was at Treasury, I worked under two different administrations as a career person, and I always feel like accounting shouldn’t be political. But obviously, elections have consequences, and I’m not living in a cocoon that I’m not aware of what’s going on. I really do think that it’s in the best interest of the capital markets for political influence to be minimized to technical areas that require expertise, and that’s how I operate, whether I was in Treasury or even at the board here. I often feel like the areas we work in, auditing and accounting, are specialized and require expertise and I hope that the experts can always be allowed to voice their views and also do their job well.”
The PCAOB has been facing pushback on some of its proposed standards, such as the so-called NOCLAR standard on the auditor’s responsibility to detect noncompliance with laws and regulations, as well as proposed standards on firm and engagement metrics. The Securities and Exchange Commission has already approved and adopted one of the PCAOB’s more far-reaching standards, on a firm’s quality control system, Ho pointed out. However, she recognizes the criticisms that the PCAOB has been hearing about some of the other proposed standards, even though NOCLAR and the other standards are still scheduled on the agenda this year.
“One of the really important things that regulators should do is to listen,” said Ho. “We should take comments very seriously and we should not rush into adopting standards or rules when we don’t have enough evidence to support the benefits and also the effectiveness of those proposals.”
She acknowledged that the increased risks and responsibilities of auditors, as well as the potential penalties, may be one factor that’s making it harder to attract young people to the accounting and auditing profession.
“I have certainly heard many anecdotal comments about the regulatory environment making the profession less attractive,” said Ho. “I’ve heard from people who talk about how they don’t want to do public company audits because of the inspections, and also our posture on enforcement. If you are not allowed to get indemnified, you know, as an individual, if something happened and there’s in your sanction, certainly people consider that as an increased risk for what they do. I think these things have an impact on the attractiveness of the profession and certainly impact talent. That is some of the anecdotal information I’ve heard. I’ve also heard from smaller firms that they are trying to stay under the 100 number because that will move them into annually, inspected so that they can stay under 100 so they don’t have to be inspected every year. Those kind of comments certainly concern me, because I don’t think this audit marketplace can afford less competition and also less talent. These are things that I think about and I’m concerned about.”
The PCAOB typically inspects each firm either annually or triennially (i.e., once every three years). If a firm provides audit opinions for more than 100 issuers, the PCAOB inspects them annually. If a firm provides audit opinions for 100 or fewer issuers, the PCAOB, in general, inspects them at least every three years.
Ho was also asked about the PCAOB’s relationship with the Institute of Internal Auditors after the two organizations clashed over the PCAOB’s exposure draft for its audit confirmation standard initially seemed to blame internal auditors before it was revised following a protest by the IIA. Ho met with the IIA and established a better understanding.
“I have a good relationship with the IIA organization, and I actually have been an internal auditor before,” said Ho. “I understand what they do and their values and why it’s important. I certainly think that they play a key role in fostering the trust of the capital markets, because they are in the company. Different data that have been published that the external auditor, they come in and focus on the financial statements and the internal control over financial reporting. Their scope is limited to that, whereas the internal auditors are covering the entire company and the operations and and they have access to much more information and people than external auditors, so they play a key role in facilitating the trust. It looks like they are also focusing a lot on modernizing their standards. They have done that, and then they have been really focusing on AI as well. So I think that it’s important to make sure that all the key players in the financial report ecosystem are working together so that we can collectively ensure the quality of the financial reporting and the audit.”
Accounting Today also asked about the role of artificial intelligence and data analytics programs in auditing and if they could be degrading audit quality without the human element being present.
Ho pointed out that the PCAOB has published a staff spotlight report on generative AI. “What the staff is seeing from the firms and the issuers in terms of their use of AI, based on that, it’s pretty clear, and based on my understanding, too, that the use of AI in the audit and financial reporting is still very much focused on repetitive tasks and very low-level areas that do not involve human judgment,” she added. “And everything they were doing using AI still requires human supervision. At this point, I don’t see right now that AI is off doing its own thing. I know that the firms are making significant investments, and AI is evolving, and more and more companies are using them. There will be more maturity. And I think that there is an opportunity, which is why it’s very important for regulators to stay on top of that, to make sure that we’re proactive in thinking and to ensure that we put guardrails if needed to make sure that there is a responsible use of AI, but at the same time, not keep people from using technology to make audits more effective and efficient.”
Tens of millions of lower-income retirement savers could soon get up to $1,000 in matching contributions toward their nest eggs each year — but they’ll need financial advisors’ help.
That’s the key takeaway from a report last month by The Morningstar Center for Retirement & Policy Studies and interviews with four experts about the “saver’s match” program, which is a provision of the sweeping 2022 Secure 2.0 retirement law that’s slated to take effect in 2027. As the replacement for the current “saver’s credit,” the match provides up to 50% in annual matching contributions from the federal government on the first $2,000 flowing into a saver’s retirement account for those with modified adjusted gross income of $35,500 or less for individuals or a maximum of $71,000 for couples.
Financial advisors often focus on high net worth clients whose wealth stretches far beyond that eligibility. However, they also frequently work with clients whose businesses sponsor employer retirement plans that must adjust their systems and raise workers’ awareness to enable them to fully tap into their benefits. Many firms and advisors also regularly participate in pro bono planning that aids people of any means with volunteer services. Amid persistent racial disparities in retirement savings and the continuing flow of Secure 2.0 provisions taking effect across the retail wealth management industry, professionals will play a pivotal role in ensuring that the saver’s match reaches its potential to boost millennial and Generation Z nest eggs by a mean of 12%, the report said.
“The impact is intuitively the biggest when people are changing their behavior, taking full advantage,” said Spencer Look, an associate director of retirement studies with Morningstar’s retirement center and co-author of the report. “There could be a big impact if we do that well as an industry and we implement this well.”
Advisors, employers and other parts of the 401(k) and retirement-savings ecosystem require some time to “not only to get the infrastructure, the plumbing in place,” but try to “target the potentially eligible participants in their plans and make sure they understand this is free money to them,” said Jack VanDerhei, the director of retirement studies with Morningstar’s retirement center and the other co-author of the study. For example, some of the eligible workers who aren’t currently 401(k) plan participants may need to set up their first individual retirement account in order to receive the government matching contributions. At the very least, advisors should know that the saver’s match and other parts of Secure 2.0 are “certainly going to influence the entire landscape going forward,” VanDerhei said.
“It’s a given that, if the 2017 tax modifications are going to be salvaged in 2025, a number of retirement situations will come into play as far as taking looks at things like mandatory Rothification,” he said. “This is something that’s already been put in place and is going to be perceived by many as being a big help in terms of some of the retirement gaps going forward.”
What the study found
The current saver’s credit has reached fewer than 6% of filers due to design shortcomings like the requirement that they have an income-tax liability and a lack of knowledge among eligible savers, Morningstar’s report said. The researchers found “reasons to believe that the saver’s match will be more effective than the saver’s credit,” including the facts that savers will no longer be obligated to have federal income tax liability, that the money “will be directly deposited into their retirement accounts — a more tangible benefit that could encourage greater participation,” and that the law instructs agencies such as the Treasury Department to promote it, they wrote.
“That said, the success of the saver’s match will largely depend on how effectively it is implemented,” Look and VanDerhei wrote. “To maximize impact, the government and retirement industry should reduce barriers and minimize savings friction wherever possible, within limits. Clear and accessible communication and education — including an awareness campaign — are also critical to ensure qualified individuals understand and use the program effectively.”
The maximum match of $1,000 on top of the first $2,000 in retirement savings each year will go to taxpayers with modified adjusted gross income of $20,500 or less as individuals, $30,750 or lower for heads of households and as much as $41,000 among couples. For those with higher modified adjusted gross income, the matching contributions phase out at respective levels of $35,500, $53,250 and $71,000. Among millennials and Gen Z savers, roughly 49% of Hispanic households, 44% of Black Americans, 29% of white taxpayers and 26% of other racial and ethnic groups will qualify for some level of matching contributions.
Using census data on those generations in terms of gender, marriage status and race and a simulation model called the “Morningstar Model of U.S. Retirement Outcomes,” Look and VanDerhei predicted that single women’s wealth at retirement could jump 13%, that of Black savers could grow 15% and Hispanic households could surge by 12%. Those figures assume that they get the highest matching contribution in 2027 and retire when they’re 65 years old, and that the program spurs more people to open retirement accounts and save more in order to take advantage. But even without behavioral changes, the saver’s match could boost the generations’ retirement nest eggs by 8%.
“When looking at the results from different demographic perspectives, we found that single women, non-Hispanic Black Americans and Hispanic Americans see greater benefits compared with other groups,” Look and VanDerhei wrote. “Moreover, our results show that workers in industries with a higher risk of running short of money in retirement are projected to experience a more significant increase in their retirement wealth under the new program.”
Help needed
The match necessitates “buy-in from everyone” across employees, employers, advisors, recordkeepers and governments, plus ample financial wellness education, according to Pam Hess, the executive director of the Defined Contribution Institutional Investment Association’s Retirement Research Center, which has worked on prior research about the potential impact of the saver’s match as part of a joint effort with the Morningstar center and the Aspen Institute Financial Security Program called the Collaborative for Equitable Retirement Savings. In addition, the findings of the latest study explain why more employers are considering how they could provide emergency savings, paycheck advances or low-interest loans, she said.
“Peoiple need help meeting their short-term financial struggles,” Hess said. “Employers are coming up with other solutions to help their workforce. You put those together with the saver’s match, and it could be really meaningful.”
Until the policy starts in 2027, advisors could get a head start by trying to increase the number of households using the existing credit, according to Catherine Collinson, CEO and president of the nonprofit Transamerica Institute and its division Transamerica Center for Retirement Studies, which found in a survey earlier this month that only 51% of workers are aware of the saver’s credit. The match “essentially reimagines and replaces and takes the saver’s credit to the next level, and the saver’s credit is available right now,” she said.
“Most people don’t wake up in the morning thinking about taxes everyday, unless it’s April 14 — the day before everything is due,” Collinson said, noting that many people also push back on the idea that they are among the “low-to-moderate income retirement savers” eligible for the credit. “The general public does not relate to that messaging, so this is where it’s so critical for financial advisors who can help to get the word out.”
More ways to get involved
On the other side of the equation, the sponsors and recordkeepers could use a nudge from the advisors to ensure they’re giving the employees the means to get the biggest match “systematically, in a way that is doable and viable,” Hess said. Right now, many employers simply don’t “have all the information they need to know who’s eligible and who’s not,” based on their modified adjusted gross income, she noted.
“We know that engaging employees is really hard — getting that connection is increasingly hard in a noisy world,” Hess said. “First you have to figure out who qualifies, and then you have to get the dollars from the government into that account, which is not a connection that’s in place today.”
Advisors’ expertise could overcome some further barriers to participation based on the continuing problems that “there’s still a major trust issue going on any time the government gets involved” and some people may not understand how to open an IRA, VanDerhei said. They’ll also be able to point out that the match would benefit “a lot of people” to a certain extent, so it’s not just for those of the lowest means, Look said.
“Pro bono work, volunteering to help educate and talk through with people in the community who may be eligible is very, very important,” he said.
The Governmental Accounting Standards Board today published a post-implementation review report on GASB Statement No. 72, Fair Value Measurement and Application.
The report, issued by GASB staff, says the fair value standard met the three PIR objectives: The standards accomplish their stated purpose, costs and benefits are in line with expectations, and the Board followed its standard-setting process.
The report concludes that Statement 72 resolved the underlying need for the statement, which involved valuation issues from a financial reporting perspective. It also concludes that the statement was operational and its application provides financial-report users with decision-useful information such as fair value measurements used in the analysis of governmental financial information and fair value-related disclosures.
Statement 72 is eligible to undergo more extensive PIR procedures, culminating in a final report.
CohnReznick, a Top 25 Firm based in New York, is the latest accounting firm to receive a private equity investment, in this case from funds advised by Apax Partners, a private equity investment advisory firm also based in New York.
This represents the first institutional investment in CohnReznick. The firm plans to use the extra funding to accelerate its growth strategy, deliver more client services and attract talent. Apax will support CohnReznick in expanding service lines, developing technology for client solutions, entering new markets, developing talent and advancing its existing tech platform to drive further innovation and efficiency. Apax also plans to support CohnReznick in pursuing a targeted acquisitions strategy to further grow its client base. CohnReznick was the result of a merger in 2012 between JH Cohn and Reznick Group.
CohnReznick has over 5,000 global employees and more than 350 partners in 29 offices across the U.S. It earned $1.12 billion in revenue in fiscal year 2025. It ranked No. 16 on Accounting Today‘s 2024 list of the Top 100 Firms. The firm has clients in a variety of industries, including real estate, financial services and financial sponsors, private client services, consumer, manufacturing, renewable energy and government advisory.
“Our partnership with Apax is a milestone moment in CohnReznick’s history,” said CohnReznick CEO David Kessler in a statement Wednesday. “We have consistently delivered strong growth and cemented our position in the mid-market, thanks to our best-in-class talent, industry expertise, and comprehensive service offerings. This strategic investment from the Apax Funds will help us continue on our growth trajectory, expanding our solutions and geographic presence to meet client needs while continuing to create exciting career growth for our people. We were impressed by the Apax team’s track record in the professional services sector and their experience in driving operational excellence in complex businesses like ours, while continuing to create a best-in-class experience for employees and clients.”
Once the transaction closes, CohnReznick will operate in an alternative practice structure, as has become common with private equity funding of accounting firms CohnReznick LLP, a licensed CPA firm, will be led by Kelly O’Callaghan as CEO and provide attest services. CohnReznick Advisory LLC (which will not be a licensed CPA firm) will provide tax, advisory and other non-attest services, and will be led by Kessler as CEO.
“Over the past two years, we have built a strong relationship with the CohnReznick team and have been deeply impressed by the company’s culture, vision, and the consistent growth they have achieved,” Ashish Karandikar, a partner at Apax Partners, said in a statement. “We are excited to partner with David and the firm’s leadership team to fuel the next phase of growth. Together, we aim to accelerate service line expansion, explore new geographic opportunities, and drive innovation. We look forward to what we are confident will be a highly successful and rewarding partnership.”
Apax was advised by Guggenheim Securities, LLC and CohnReznick was advised by William Blair & Company, LLC. Koltin Consulting Group served as an additional financial advisor to both Apax and CohnReznick.
“It was love at first sight,” Allan Koltin, CEO of Koltin Consulting Group, said in a statement. “I can’t recall two firms and their leaders culturally and strategically aligning as fast as they did. When one side talked, the other side finished the sentence. No question in my mind, this combination will produce one of the next $2 billion firms in the accounting profession, but more importantly produce a lot of successful people and clients along the way.”