"True & Fair" Auditing – An Insight!

[Submitted by CA. Harsh R. Rathi,
M.B.A.(Nirma), ACA, DISA,
Ahmedabad, Gujarat]

February 17, 2009

Imagine the following scenario:

A multinational multilocational Fortune 500 company is being audited by one of the top auditing firms in the country. The turnover of the Auditee is Rs. 10,000 crore plus. The number of locations is 50 plus and 10000 plus staff. For accomplishing such a gigantic task, the person appointed is ONE single Auditing firm, having a strong brand name and goodwill!! Can we really expect the audit firm to check all details, given the limited time and cost resources?

It is really not possible and practical to frame an opinion of true and fair in such case, and if it is done, it is bound to be infected by anomalies and imperfections as evident in the recent “Satyam” episode.

Audit has now become a compilation of details and verifications with accounts, without bothering about source of entries and truthfulness of the transaction. Gone are the days when each and every item of fixed assets ranging from a simple calculator worth Rs. 100/- to all higher and valuable assets were physically checked by auditors at year end, and stock was taken in presence of auditors. Direct confirmations were obtained by Auditors for outstanding debts and creditors and other balances in the balance sheet. That served the real essence and purpose of auditing and in context of increasing frauds in balance sheet, the need is now felt for that level of audit in place of just documentation of audit files, and taking management representation and cerfication for stock, debts and other outstanding balances.

The above is possible if and only when a single auditor or a couple of auditors are not entrusted with such a voluminous assignment of audit of accounts of multilocational companies but for each separate location a separate auditor is appointed, as in the case of bank branch audits, which is locally placed and a guarantee or level of reliability of correctness of accounts is desired from the Auditor in place of an opinion on true and fair. The audit system of nationalized banks is a good model of such system. For each location, a local firm is allotted the audit assignment. There may be a central auditor who can frame the guidelines, can monitor the local audit work, and if need may be, can re-audit the doubtful locations as a surprise check. The purpose of the central auditor will be to compile the audit work of all local auditors and compile the same for the consolidated balance sheet of the entire company. This will ensure the dual advantage of delegation of work, and management by exception. Also level of reliance will be increased as cross check of audit findings is possible, and audit mistakes/omissions can be located/traced. The huge audit fees paid by the clients can also be justified by ensuring the same. A classic example is the recent “Satyam” episode, where audit fees were near to Rs. 4.5 crores. Now consider, had the audit fees been say Rs. 10 lacs for a particular branch auditor of the same company, apparently the auditor would not have been tempted to complete the audit without a reasonable degree of reliance and correctness. Moreover, the branch auditor would have the fact at the top of the mind that its work can be re-checked and monitored by a much larger and resourceful audit firm having the latest technology and an armory of resources at its disposal.

Just have a glance at the following table:

According to a survey of Audit Quality of Big Firms in 2002, following findings were observed:

Table I

Source: WEISS RATING 2002, TABLE I.

Large audit and assurance firms such as Price Waterhouse Coopers (PwC) have also had a chequered past which should be considered which framing such system. It is a known fact that PwC has had admitted its mistake in at least two cases of tax evasion, amounting to huge amounts of money. “The question is not the amount of evasion, but the fact that a top accounting firm, which provides tax advisory and audits the accounts, had involved in tax evasion is a matter of concern” said a Revenue Department Official.

Prof. Abraham Briloff (Professor Emeritus of CUNY Baruch) for years wrote a column for Barron’s that constantly analyzed breaches of ethics and audit professionalism among leading CPA firms. His most famous book is called “Unaccountable Accounting”. What he advocated has been forced on the industry as an aftermath of Enron Scandal through the Sarbanes-Oxley Act.

Subject to confirmation and reconciliation words should not be allowed to be mentioned in Notes to Accounts, except in exceptional cases. In case where confirmations are not received or receivable, specific instances should be pointed out in the audit report, maybe as an annexure. This will really ensure to get a correct picture of the balance sheet. But all this is possible only in the system of delegation of audit work to separate local firms for separate locations who can utilize their local resources to the best possible use. This will infact save a lot of cost to the Auditee say by saving on huge travelling allowances, boarding and lodging expenditure incurred on the audit, and can result into a huge savings year on year in terms of out of pocket expenses payable to the auditors.

By location we mean not only location of a particular plant but all places where branches, depots or administrative offices are placed, where company may have assets such as stocks, debtors and other working assets. Like a bank branch audit, local and central statutory auditors should also be made to follow a policy of rotation every year, by compulsion. Audit completion should not be made too early, but at least 3 months should be allowed, post completion of financial year, before which no audited accounts should be finalized. Changes should be made accordingly in Company Law Rules related to AGM also, regarding the same.

Also, the premiere accounting body, The Institute of Chartered Accountants of India (ICAI) should become more strict and vigilant regarding disciplinary cases involving professional misconduct of auditors. It was decided in Council of ICAI vs. R. Ayyavoo {2005} 123 Comp. Cas. 345 (Mad.), a complaint was made by the company that the auditors who were internal and statutory auditors failed to check the cash and bank balances records due to which defalcation that occurred was not brought to light. It was held that it was a serious professional misconduct. Following instances have been held to be professional misconduct in terms of Schedule II to the ICAI Act:

1. Certification of a report or statement without examination of the statement and/or related records.
    
2. Failing to disclose in the report a material mis-statement known to the auditor to appear in a financial statement.
    
3. Not exercising due diligence or being grossly negligent in conduct of professional duties.
    
4. Failing to obtain sufficient information which is necessary for expression of an opinion or its exceptions which are sufficiently material to negate the expression of an opinion.
    

The punishments for the said professional misconduct can range from a simple reprimand to the member upto removal of the member for a certain period and fine upto Rs. 5 lacs.

Last but not the least; it should be known that the auditor is a “watchdog” and not a “bloodhound” (Re: Kingston Cotton Mills Ltd. Case). He is not expected to be a CID officer, who sees every transaction with a jaundiced eye. But, the dog must bark and chase when something is found suspicious or wrong. He must be aware and vigilant to “blow the whistle” as and when required.

[The author, CA. Harsh Ramniwas Rathi, is a practicing Chartered Accountant based at Ahmedabad, and a visiting faculty at various B-Schools.]

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