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PCAOB supplements guidance on remediation process

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The Public Company Accounting Oversight Board released a supplement Wednesday to its staff guidance on the remediation process for auditing firms that have deficiencies in quality control that need to be fixed.

The supplement gives firms more advice, including making the most of the remediation period, the potential influence of nontechnical factors on persistent quality control criticisms, and more. 

Under the Sarbanes-Oxley Act of 2002 and PCAOB rules, the board can’t disclose its criticisms of an audit firm’s quality control systems for at least 12 months after the PCAOB’s initial publication of its inspection report of the firm. During that year-long period, the audit firm is expected to remediate the quality control criticisms identified by PCAOB inspectors. If the firm fails to address any identified quality control criticisms to the PCAOB’s satisfaction, the board will then disclose those criticisms to the public. The revelations can prove to be embarrassing, especially for large firms, and remediating the problems helps firms claim they’re addressing the findings.

“Making sure audit firms remedy defects in their quality control systems is an important way for the PCAOB to drive improvement in audit quality and protect investors,” said PCAOB chair Erica Williams in a statement Thursday. “The PCAOB encourages audit firms to apply this supplement to the staff guidance when addressing quality control criticisms.”

PCAOB chair Erica Williams speaking at the 2024 International Institute on Audit Regulation, in Washington, D.C.

PCAOB chair Erica Williams speaking at the 2024 International Institute on Audit Regulation, in Washington, D.C.

The original staff guidance was published over a decade ago, in 2013, and needed updating, especially amid the tougher stance that the PCAOB has taken in recent years under Williams and a new set of board members. The document offers information for audit firms receiving a final inspection report from the PCAOB that includes any criticism of the firm’s system of quality control. It discusses considerations that the PCAOB’s inspections staff has identified as relevant to its recommendations to the board concerning the sufficiency of firms’ remediation efforts.  

While the update doesn’t change or supersede the 2013 staff guidance, the new supplement draws from the PCAOB staff’s experience since the 2013 staff guidance was issued.  

This isn’t the PCAOB’s first effort to update the guidance. In February 2023, the PCAOB issued a Spotlight document, “Additional Insights on the Remediation Process,” outlining the factors that the staff considers, especially regarding design, implementation and effectiveness of a firm’s actions to remediate quality control deficiencies. Leveraging insights gleaned from the PCAOB’s years of evaluating remediation efforts, the Spotlight pointed out that PCAOB Inspections staff was reviewing the staff guidance to determine if any changes might be needed. 

Following up on the 2023 Spotlight, the new staff guidance supplement recommends that audit firms, when addressing quality control criticisms, can benefit by considering the following:  

  • Beginning the remediation process sooner to take advantage of the full remediation period; 
  • Planning ahead in order to gain the benefit of inspections staff feedback;  
  • Implementing actions early enough to be able to monitor their operation and include them in the submission evidence that they are effective;  
  • Considering whether certain quality control criticisms persist due to the influence of nontechnical factors, such as a firm’s culture; and,  
  • Understanding the limits of acceptable supplemental submissions after the submission deadline. 

The PCAOB’s Remediation page includes the latest staff guidance, the 2023 Spotlight providing extra insights into the remediation process, and other materials regarding remediation. 

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Accounting

Aiwyn raises $113M in funding from KKR, Bessemer

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Aiwyn, a provider of technology solutions for accountants and CPA firms, has closed a $113 million funding round.

The money will help the company continue its evolution from its original focus on payments and collections for accounting firms into a more comprehensive tool for practice management.

Among other things, that will include building a universal client experience portal, where accountants can access all of their engagements in one place.

Justin Adams, CEO of Aiwyn

Aiwyn CEO Justin Adams

The funding will also be used to accelerate product development on both the company’s practice management platform, and on a tax solution that it is working on.

“Aiwyn is committed to empowering CPA firms to elevate their operations and client relationships,” said chairman and CEO Justin Adams, in a statement. “With this investment, we are poised to redefine how firms manage their operations from the CRM to the general ledger, while setting a new benchmark for client experiences. For too long, firms have had to decide between a legacy vendor or modern point solutions. We are proud that Aiwyn is a trusted platform for CPA firms.”

The round was led by global investment firm KKR and Bessemer Venture Partners. KKR is funding this investment primarily from its Next Generation Technology III Fund.

“The accounting industry represents a large market that has long been served by legacy players. Aiwyn is solving a clear functionality gap in the market with a solution that is easily adopted and rapidly delivers tangible enhancements to the customer experience, most noticeably through significant reductions in days sales outstanding,” said Jackson Hart, a principal on KKR’s technology growth team, in a statement.

“Aiwyn’s product suite is already quite impressive, but the company is really just getting started on its quest to deliver compelling technology to the accounting industry,” added Bessemer partner Jeremy Levine, in a statement.

Cooley LLP served as legal advisor to Aiwyn; Latham & Watkins LLP served as legal advisor to KKR; and Arnold & Porter Kaye Scholer LLP served as legal advisor to Bessemer.

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Millions to get bigger Social Security checks if Biden signs new bill

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Millions of Americans may see their Social Security benefits increase under a bill headed to President Joe Biden’s desk — though critics warn that the measure comes at the cost of pushing the fund further toward insolvency.

If signed by the president before the new Congress convenes on Jan. 3, the law would boost Social Security payments to more than 2 million beneficiaries, according to the Congressional Research Service. The increases — as much as $550 a month for some retirees — would be retroactive to December 2023.

Those beneficiaries are mostly those who have received foreign pensions or government workers such as police officers, firefighters and teachers who contributed to a federal or state pension plan but didn’t pay Social Security taxes.

The legislation, called the Social Security Fairness Act, eliminates two formulas that reduced benefits for these workers who receive foreign and government pensions in addition to Social Security. Those provisions, known as the Windfall Elimination Provision and the Government Pension Offset, were enacted more than 40 years ago in response to an increase in retirees who hadn’t fully paid into Social Security and to more dual-income couples retiring.

Sponsors of the law say the old Congress over-corrected, and unfairly withheld earned benefits from retirees and their spouses. 

While the White House hasn’t said whether Biden would sign the bill, it passed both chambers with bipartisan majorities: 327-75 in the House last month and 76-20 in the Senate early Saturday morning.

The Congressional Budget Office estimated that the bill would hasten Social Security’s insolvency — now projected to come by 2034 — by another six months and add $196 billion to budget deficits over the next 10 years. As a result, a typical couple retiring in 2033 may see lifetime benefit cuts of $25,000, according to the Committee for a Responsible Federal Budget. 

The Senate rejected an amendment from Senator Rand Paul, a Republican from Kentucky, that would have pushed back the retirement age to 70. Only three senators supported the amendment.

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Accounting

Art of Accounting: A template for hiring an experience manager

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Complimentary Access Pill

Enjoy complimentary access to top ideas and insights — selected by our editors.

Firms that hire experienced people do not usually get what they expect or are paying for. Here is a template to help you maximize your investment in such people.

Usually, but not always, experienced people leave a job because they are not growing in their experience. Yet many firms hire these people expecting to capitalize on their “experience.” This makes no sense and seems to be illogical. However, it happens all the time. The following is a template to assist you in getting what you need or think you are getting. 

Salary level: The salary you will be paying will be the market rate. Not much higher or much lower, so regardless of what you are getting from your new employee, get over it! You will not be overpaying. You might not be getting what you think you are paying for, but you will be paying the market rate for that person.

Profile of new hire: You hired someone who has been specializing in the area that you hired them for. You also hired someone that probably had three or four jobs previously, with the last one or two (or more) in that specialization. What you do not know is the depth of their experience, how well they managed their workload or the people reporting to them, and what desire they have to grow further. If they had that desire, and they weren’t growing, then they “wasted” time in their growth trajectory trying to decide when they should leave. Further, their impression of their experience will not be the same as your expectations of their experience. Get over it!

Experience: I can almost guarantee that the new hire will not be able to perform at the level you expect them to, and my advice is to get over it. What you need to do is to evaluate their experience and figure out where they stand on the curve line of the scale that you expect. Not where you want them to be, but where they actually are. Once you figure that out, start your training and mentoring and everything else you do to move that staff person forward at the level they are at on your scale.

Getting what you are paying for: You will be not getting what you really need, but what the market has available. And whatever that is, you will likely be better off with that person than without that person, if you do not screw it up.

How to not screw it up: Do not give them work that you know they could not handle without training, supervising and being watched over closely. Start off with pretty easy work at a higher level, not the lower levels, and see how they do. Use that to guide you in where they need to go to help you. Go easy, but do it with steady forward movements. But do it slowly and deliberately. Consider your investment in a long-term relationship with that manager-level person. If they are the right person, it will become evident within a couple of months. If they’re not the right person, get rid of them quickly (see next item). 

Hire carefully, but fire quickly: I know of a very successful practice that used a headhunter for staffing and was provided with a two-month guarantee, so their timetable was seven weeks. I know this because someone who left me for a higher-level position called and asked me if he could have his job back seven weeks after he left. That person was not growing with me (for various reasons that I am not getting into now) and I told him so. We liked him and explained a program that we developed to have him grow sufficiently. He immediately started to look for a job, which he got. His job was filled by us with a three-year level staff person we hired out of school and who was ready to be moved up to that position. We did not miss a beat. That shows you how “valuable” he was to us, and how invaluable he was to his next employer. 

Be nice: It’s probably not all their own fault they haven’t grown. I’m sure the firms they worked at contributed immensely to that lack of growth. Be nice. Do not tell them how you feel about where you think they are on your scale of development or what your current expectations are. Just focus on using them to move you forward by helping them grow. Compliment them frequently and never disparage them. Be nice!

The past, present and future: Their lack of experience is in the past and is the present situation. Fuggeddaboudit! You hired this person so you could move your practice forward into the future. Focus on that future and getting there as easily as you can. You can do it with this person if you do not over-anticipate their ability or over-expect their output and production. 

Natural tendency: A natural tendency is to be upset with them and then to use them as best you can to clean up past due work, move things out and work on slightly higher lower-level engagements. You won’t be anxious to have them train anyone so they will become lone rangers. That is not how you will be able to grow and you will doom yourself to restart with someone very similar when that person leaves “because they are not getting good experience.” And then you will start over with someone who is a mirror image of the person who just left you. Your efforts become dissipated replacing someone who left rather than concentrate on nurturing staff so they will grow and stay. 

Set expectations to a lower level: When they start, do not expect more of them than is realistic. If you get more than you expect, you will be happy. If you get less than you expect, you will be miserable and probably make them, and everyone else around you, miserable. You can’t lose with lower expectations and might lose with the higher expectations. Choose can’t lose instead of might lose

The above is not really a template, but if I added three lines to each item and asked you to write what you think or will do and perhaps include a chart (for No. 3 above), it will be a template. Figure it out for yourself, but if you believe I make sense and you are stuck in a can’t win position unless you face reality, then get over it and make the best of it to move forward. And I just showed you how to approach that.

Do not hesitate to contact me at [email protected] with your practice management questions or about engagements you might not be able to perform.

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