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SYSTEM OF QUALITY CONTROL FOR A CPA FIRM’S ACCOUNTING AND AUDITING
1.01 This chapter describes how a CPA firm that has multiple offices (Multi-Office CPA Firm) implements each element of quality control in its accounting and auditing practice. Multi-Office CPA Firm is a hypothetical firm that has 10 offices in 3 states and is centrally managed. Multi Office CPA Firm has 15 partners, 100 professionals, and a concentration of financial institution clients for which it performs audit and attest services. The firm uses practice aids that have been subjected to peering review in accordance with standards established by the AICPA. These practice aids are supplemented by oral and written communications from the firm’s partners. It has no issuer clients.
QUALITY CONTROL POLICIES AND PROCEDURES
1.02 The firm’s system of quality control consists of policies designed to achieve the objectives of the system and the procedures necessary to implement and monitor compliance with those polices. The policies and procedures are required to be documented. Multi-Office CPA Firm documents its system of quality control by preparing a document that comprehensively describes policies and procedures established and maintained for each element of quality control. Multi Office CPA Firm reviews the documentation at least annually and updates it as necessary.
1.03 The firm should communicate its quality control policies and procedures to its personnel. Effective communication includes the following:
• A description of quality control policies and procedures and the objectives they are designed to achieve
• The message that each individual has a personal responsibility for quality
1.04 Multi-Office CPA Firm communicates these policies and procedures in writing and makes the documentation available electronically to all professional personnel. Multi-Office CPA Firm requires each individual to be familiar with and to comply with these policies and procedures. Multi-Office CPA Firm also includes procedures for personnel to communicate their views or concerns on quality control matters to partners.
If Multi-Office CPA Firm were to be engaged to perform audit services for an issuer, it might need to revise its quality control policies and procedures to comply with PCAOB (Public Company Accounting Oversight Board) standards and to reflect SEC (Securities and Exchange Commission) requirements applicable to audits of issuers.
LEADERSHIP RESPONSIBILITIES FOR QUALITY WITHIN THE FIRM
(THE “TONE AT THE TOP”)
1.05 The objective of the leadership responsibilities element of a system of quality control is to promote an internal culture based on the recognition that quality is essential in performing engagements. Multi-Office CPA Firm satisfies this objective by establishing and maintaining the policies and procedures described in paragraphs 2.06–2.10.
1.06 Policy 1: The firm’s managing partner assumes ultimate responsibility for the firm’s system of quality control. Multi-Office CPA Firm implements this policy through the following procedures:
• Having the managing partner accept overall responsibility for the firm’s system of quality control and promoting a quality-oriented culture by sending clear, consistent, and frequent messages through e-mails, letters, and recordings
• Having a mission statement that includes the firm’s core values and the importance of quality
• Informing personnel that failure to adhere to the firm’s policies and procedures regarding performance quality and commitment to ethical principles may result in disciplinary action
1.07 Policy 2: The firm assigns management responsibilities so that commercial considerations do not override the quality of the work performed. Multi-Office CPA Firm implements this policy through the following procedures:
• Having the managing partner continually evaluate client relationships and specific engagements so that commercial considerations do not override the objectives of the system of quality control
• Emphasizing to all personnel that fee considerations and scope of services should not infringe upon quality work
1.08 Policy 3: The firm assigns operational responsibility for the firm’s quality control system to personnel who have sufficient and appropriate experience and ability to identify and understand quality control issues and to develop appropriate policies and procedures, as well as the necessary authority to implement those policies and procedures. Multi-Office CPA Firm implements this policy through the following procedures:
• Designating a quality control partner with overall operational responsibility for developing and implementing appropriate policies and procedures for the firm’s quality control system
• Designating a quality control individual for each office
1.09 Policy 4: The firm designs procedures addressing performance evaluation, compensation, and advancement (including incentive systems) with regard to personnel to demonstrate the firm’s overarching commitment to the objectives of the system of quality control. Multi-Office CPA Firm implements this policy through the following procedures:
• Designing and implementing performance evaluation and advancement systems that (a) reward partners and staff involved in the accounting and auditing practice for the quality of their work and their compliance with professional standards and (b) include partner performance peer evaluations.
• Establishing a compensation system that provides incentives to accounting and auditing partners and senior-level employees for the quality of their accounting and auditing work.
1.10 Policy 5: The firm devotes sufficient and appropriate resources for the development, communication, and support of its quality control policies and procedures. Multi-Office CPA Firm implements this policy through the following procedures:
• Providing the designated quality control partner with sufficient time, authority, and resources to develop, implement, and maintain the firm’s quality control policies and procedures
• Providing the firm’s quality control documentation to personnel when they are initially hired and reviewing the documentation with them
• Reviewing the firm’s quality control policies and procedures with personnel at firm training sessions at least annually
RELEVANT ETHICAL REQUIREMENTS
1.11 The objective of the relevant ethical requirements element of a system of quality control is to provide the firm with reasonable assurance that the firm and its personnel comply with relevant ethical requirements when discharging professional responsibilities. Relevant ethical requirements include independence, integrity, and objectivity. Multi-Office CPA Firm satisfies this objective by establishing and maintaining the policies and procedures described in paragraphs 1.12–1.16.
1.12 Policy 1: Personnel adhere to relevant ethical requirements such as those in regulations, interpretations, and rules of the AICPA, state CPA societies, and state boards of accountancy, statutes, the U.S. Government Accountability Office (GAO), and any other applicable regulators. Multi-Office CPA Firm implements this policy through the following procedures:
• Assigning one of its partners the responsibility of responding to questions, resolving matters, and determining the circumstances for which consultation with sources outside the firm is required for matters related to independence, integrity, and objectivity
• Identifying circumstances for which documentation of the resolution of matters is appropriate
• Maintaining a current list of all entities with which firm personnel are prohibited from having a financial or business relationship and all activities in which the firm is prohibited from engaging, as defined in the firm’s independence policies
• Establishing clear and concise written independence guidance covering relationships and activities that impair independence, including but not limited to investments, loans, brokerage accounts, business relationships, employment relationships, and fee arrangements
1.13 Policy 2: The firm establishes procedures to communicate independence requirements to firm personnel and, where applicable, others subject to them. Multi-Office CPA Firm implements this policy through the following procedures:
• Having the managing partner (through e-mails, letters, or recordings) emphasize the concepts of independence, integrity, and objectivity in the firm’s professional development meetings, in the acceptance and continuance of clients and engagements, and in the performance of engagements. Because Multi-Office CPA Firm has a concentration of financial institution clients, this also includes discussing the applicability of these concepts to engagements for financial institutions, such as the prohibition against any member of the engagement team having a “non-grandfathered” loan with the institution, and the types of notates services that could affect independence.
• Requiring periodic independence and ethics training for all professional personnel. Such training covers the firm’s independence and ethics policies and the independence and ethics requirements of all applicable regulators.
• Providing frequent reminders of professional responsibilities to personnel, such as avoiding behavior that might be perceived as impairing their independence or objectivity.
• Informing personnel on a timely basis of those entities to which independence policies apply by doing the following:
— Preparing and maintaining a list of entities with which firm personnel are prohibited from having a financial or business relationship
— Making the list available to personnel so they may evaluate their independence (including personnel new to the firm or an office)
— Notifying personnel of changes in the list
Examples of prohibited activities include providing certain valuation and information technology services to an audit client. See the rules of specific standard-setters to determine the extent and relevance of any prohibition.
1.14 Policy 3: The firm establishes procedures to identify and evaluate possible threats to independence and objectivity, including the familiarity threat that may be created by using the same senior personnel on an audit or attest engagement over a long period of time, and to take appropriate action to eliminate those threats or reduce them to an acceptable level by applying safeguards. Multi-Office CPA Firm implements this policy through the following procedures:
• Assigning a partner who is not otherwise associated with the engagement, or who practices in an office other than the office that performs the attest engagement, to review the engagement
• Requiring approval of the assignment of engagement personnel by another partner or manager
• Rotating engagement partners periodically
• Establishing additional procedures that provide safeguards when the firm performs audit or other attest work for (a) significant clients or (b) clients at which partners or other senior personnel are offered key management positions, or accept offers of employment, by utilizing the procedures contained in the AICPA Code of Professional Conduct, ET section 100.01 and 100.04, Conceptual Framework for AICPA Independence Standards (AICPA, Professional Standards, vol. 2)
• Designating a senior-level partner to be responsible for overseeing the adequate functioning of the firm’s independence policies
• Implementing a system to identify investment holdings of partners and managers that might impair independence
• Requiring all professionals to report, on a timely basis when identified, apparent violations of independence, integrity, or objectivity policies involving themselves, their spouses, or their dependents and the corrective actions taken or proposed to be taken
• Establishing a requirement for all professional personnel to notify the managing partner in each office of any potential activities that might impair independence or violate ethics rules, including services provided to entities with which firm personnel are prohibited from having a business relationship
• Establishing a program that protects professional personnel who report potential ethics or independence violations to the proper parties in compliance with firm policy
• Requiring the managing partner in each office, or a person designated by the managing partner, to periodically review unpaid fees from clients to ascertain whether any outstanding amounts impair the firm’s independence
• Developing guidance that sets forth the consequences for professional personnel who violate the firm’s independence policies and procedures, including engaging in activities with entities with which firm personnel are prohibited from having a business relationship Requiring all professional personnel to review the list of entities with which firm personnel are prohibited from having a business relationship before a professional or the spouse or dependent of a professional obtains a security or financial interest in an entity
• Establishing criteria that determine the need for safeguards for engagements where monitoring procedures or peer review have identified weaknesses in previous years or the same senior personnel have been used for five years or more on an audit or attestation engagement
• Documenting any safeguards applied to eliminate threats to independence or reduce them to an acceptable level
• Promptly communicating identified breaches of these policies and procedures, and the required corrective actions, to the engagement partner who, with the firm, needs to address the breach and other relevant personnel in the firm and those subject to the independence requirements who need to take appropriate action
• Obtaining confirmation from the engagement partner and other relevant personnel that the required corrective actions have been taken
1.15 Policy 4: The firm withdraws from engagements if effective safeguards to reduce threats to independence to an acceptable level cannot be applied. Multi-Office CPA Firm implements this policy through the following procedures:
• Consulting within the firm and, if necessary, with legal counsel and other parties when the firm believes that effective safeguards to reduce threats to independence to an acceptable level cannot be applied
• Withdrawing from engagements when effective safeguards to reduce threats to independence to an acceptable level cannot be applied
1.16 Policy 5: The firm obtains written confirmation, at least annually, of compliance with its policies and procedures on independence from all firm personnel required to be independent by relevant requirements. Multi-Office CPA Firm implements this policy through the following procedures:
• Obtaining written repr
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