Report on 2014 Inspection of PricewaterhouseCoopers ... · Ribeirao Preto, Rio de Janeiro, ... in...

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1666 K Street, N.W. Washington, DC 20006 Telephone: (202) 207-9100 Facsimile: (202) 862-8433 www.pcaobus.org Report on 2014 Inspection of PricewaterhouseCoopers Auditores Independentes (Headquartered in Sao Paulo, Federative Republic of Brazil) Issued by the Public Company Accounting Oversight Board July 28, 2016 PCAOB RELEASE NO. 104-2016-168 THIS IS A PUBLIC VERSION OF A PCAOB INSPECTION REPORT PORTIONS OF THE COMPLETE REPORT ARE OMITTED FROM THIS DOCUMENT IN ORDER TO COMPLY WITH SECTIONS 104(g)(2) AND 105(b)(5)(A) OF THE SARBANES-OXLEY ACT OF 2002

Transcript of Report on 2014 Inspection of PricewaterhouseCoopers ... · Ribeirao Preto, Rio de Janeiro, ... in...

Page 1: Report on 2014 Inspection of PricewaterhouseCoopers ... · Ribeirao Preto, Rio de Janeiro, ... in all material respects, ... Inspection of PricewaterhouseCoopers Auditores Independentes.

1666 K Street, N.W.Washington, DC 20006

Telephone: (202) 207-9100Facsimile: (202) 862-8433

www.pcaobus.org

Report on

2014 Inspection ofPricewaterhouseCoopers Auditores Independentes

(Headquartered in Sao Paulo, Federative Republic of Brazil)

Issued by the

Public Company Accounting Oversight Board

July 28, 2016

PCAOB RELEASE NO. 104-2016-168

THIS IS A PUBLIC VERSION OF A PCAOB INSPECTION REPORT

PORTIONS OF THE COMPLETE REPORT ARE OMITTEDFROM THIS DOCUMENT IN ORDER TO COMPLY WITH

SECTIONS 104(g)(2) AND 105(b)(5)(A)OF THE SARBANES-OXLEY ACT OF 2002

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PCAOB Release No. 104-2016-168

2014 INSPECTION OF PRICEWATERHOUSECOOPERSAUDITORES INDEPENDENTES

Preface

In 2014, the Public Company Accounting Oversight Board ("PCAOB" or "theBoard") conducted an inspection of the registered public accounting firmPricewaterhouseCoopers Auditores Independentes ("the Firm") pursuant to theSarbanes-Oxley Act of 2002 ("the Act").

Inspections are designed and performed to provide a basis for assessing thedegree of compliance by a firm with applicable requirements related to issuer auditwork. For a description of the procedures the Board's inspectors may perform to fulfillthis responsibility, see Part I.C of this report (which also contains additional informationconcerning PCAOB inspections generally). Overall, the inspection process includedreviews of portions of two issuer audits performed by the Firm and the Firm's audit workon one other issuer audit engagement in which it played a role but was not the principalauditor. These reviews were intended to identify whether deficiencies existed in thoseportions of the inspected audit work, and whether such deficiencies indicated defects orpotential defects in the Firm's system of quality control over audit work. In addition, theinspection included a review of policies and procedures related to certain quality controlprocesses of the Firm that could be expected to affect audit quality.

The Board is issuing this report in accordance with the requirements of the Act.The Board is releasing to the public Part I of the report and portions of Part IV of thereport. Part IV of the report consists of the Firm's comments, if any, on a draft of thereport. If the nonpublic portions of the report discuss criticisms of or potential defects inthe firm's system of quality control, those discussions also could eventually be madepublic, but only to the extent the firm fails to address the criticisms to the Board'ssatisfaction within 12 months of the issuance of the report.

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PROFILE OF THE FIRM1

Number of offices 18 (Barueri, Belo Horizonte,Brasilia, Campinas, Caxias do Sul,Curitiba, Florianopolis, Goiania,Maringa, Porto Alegre, Recife,Ribeirao Preto, Rio de Janeiro,Salvador, Sao Jose dos Campos,Sao Paulo, and Sorocaba,Federative Republic of Brazil)

Ownership structure Partnership

Number of partners 86

Number of professional staff2 1,707

Number of issuer audit clients 8

Number of other issuer audits inwhich the Firm plays a role3

90

1 The information presented here is as understood by the inspection team,generally as of the outset of the inspection, based on the Firm's self-reporting and theinspection team's review of certain information. Additional information, includingadditional detail on audit reports issued by the Firm, is available in the Firm's filings withthe Board, available at http://pcaobus.org/Registration/rasr/Pages/RASR_Search.aspx.

2 The number of partners and professional staff is provided here as anindication of the size of the Firm, and does not necessarily represent the number of theFirm's professionals who participate in audits of issuers.

3 The number of other issuer audits encompasses audit work performed bythe Firm in engagements for which the Firm was not the principal auditor, includingaudits, if any, in which the Firm plays a substantial role as defined in PCAOB Rule1001(p)(ii).

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PART I

INSPECTION PROCEDURES AND CERTAIN OBSERVATIONS

Members of the Board's inspection staff ("the inspection team") conductedprimary procedures for the inspection from October 13, 2014 to October 24, 2014 andfrom November 10, 2014 to November 21, 2014.4

A. Review of Audit Engagements

The inspection procedures included reviews of portions of two issuer auditsperformed by the Firm and the Firm's audit work on one other issuer audit engagementin which it played a role but was not the principal auditor. The inspection team identifiedmatters that it considered to be deficiencies in the performance of the work it reviewed.

The descriptions of the deficiencies in Part I.A of this report include, at the end ofthe description of each deficiency, a reference to specific paragraphs of the auditingstandards that relate to those deficiencies. The text of those paragraphs is set forth inAppendix A to this report. The references in this sub-Part include only standards thatprimarily relate to the deficiencies; they do not present a comprehensive list of everyauditing standard that applies to the deficiencies. Further, certain broadly applicableaspects of the auditing standards that may be relevant to a deficiency, such asprovisions requiring due professional care, including the exercise of professionalskepticism; the accumulation of sufficient appropriate audit evidence; and theperformance of procedures that address risks, are not included in any references to theauditing standards in this sub-Part, unless the lack of compliance with these standardsis the primary reason for the deficiency. These broadly applicable provisions aredescribed in Part I.B of this report.

Certain of the deficiencies identified were of such significance that it appeared tothe inspection team that the Firm, at the time it issued its audit report, had not obtainedsufficient appropriate audit evidence to support its opinion that the financial statements

4 For this purpose, "primary procedures" include field work, other review ofaudit work papers, and the evaluation of the Firm's quality control policies andprocedures through review of documentation and interviews of Firm personnel. Primaryprocedures do not include (1) inspection planning, which is performed prior to primaryprocedures, and (2) inspection follow-up procedures, wrap-up, analysis of results, andthe preparation of the inspection report, which extend beyond the primary procedures.

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were presented fairly, in all material respects, in accordance with the applicablefinancial reporting framework and/or its opinion about whether the issuer hadmaintained, in all material respects, effective internal control over financial reporting("ICFR"). In other words, in these audits, the auditor issued an opinion withoutsatisfying its fundamental obligation to obtain reasonable assurance about whether thefinancial statements were free of material misstatement and/or the issuer maintainedeffective ICFR.

The fact that one or more deficiencies in an audit reach this level of significancedoes not necessarily indicate that the financial statements are misstated or that thereare undisclosed material weaknesses in ICFR. It is often not possible for the inspectionteam, based only on the information available from the auditor, to reach a conclusion onthose points.

Whether or not associated with a disclosed financial reporting misstatement, anauditor's failure to obtain the reasonable assurance that the auditor is required to obtainis a serious matter. It is a failure to accomplish the essential purpose of the audit, and itmeans that, based on the audit work performed, the audit opinion should not have beenissued.5

The audit deficiencies that reached this level of significance are describedbelow–

Issuer A

(1) the failure, in an audit of ICFR, to perform sufficient procedures totest the design and operating effectiveness of controls over the evaluationof goodwill for impairment (AS No. 5, paragraphs 39, 42, and 44);

(2) the failure to perform sufficient procedures to evaluate goodwill forimpairment (AU 342, paragraph .11);

5 Inclusion in an inspection report does not mean that the deficiencyremained unaddressed after the inspection team brought it to the Firm's attention.Depending upon the circumstances, compliance with PCAOB standards may requirethe Firm to perform additional audit procedures, or to inform a client of the need forchanges to its financial statements or reporting on internal control, or to take steps toprevent reliance on its previously expressed audit opinions. The Board expects thatfirms will comply with these standards, and the inspections staff may include in itsprocedures monitoring or assessing a firm's compliance.

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(3) the failure, in an audit of ICFR, to perform sufficient procedures totest controls over the existence and completeness of property, plant andequipment ("PPE") (AS No. 5, paragraph 39), and, in the financialstatement audit, as a result of the unsupported level of reliance oncontrols, the failure to perform sufficient procedures to test the existenceof PPE due to the use of sample sizes that were too small (AS No. 13,paragraphs 16, 18, and 37; AU 350, paragraphs .19, .23, and .23A);

(4) the failure, in an audit of ICFR, to perform sufficient procedures totest the design and operating effectiveness of controls over the valuationof accounts receivable (AS No. 5, paragraphs 42 and 44); and

(5) the failure to perform sufficient procedures to test the valuation ofaccounts receivable, including the failure to perform procedures to extendaudit conclusions from the date of the Firm's interim testing to the end ofthe year under audit (AS No. 13, paragraph 45; AS No. 15, paragraph 10;AU 342, paragraph .11).

Issuer B

(1) the failure, in an audit of ICFR, to perform sufficient procedures totest the design and operating effectiveness of controls over revenue andaccounts receivable (AS No. 5, paragraphs 39, 42, and 44); and

(2) the failure, in an audit of ICFR, to perform sufficient procedures totest the design and operating effectiveness of controls over long-livedassets (AS No. 5, paragraphs 42 and 44).

B. Auditing Standards

Each deficiency described above could relate to several applicable provisions ofthe standards that govern the conduct of audit work, including both the paragraphs ofthe standards that are cited at the end of each description of the deficiency included inPart I.A of this report and one or more of the specific paragraphs discussed below.

Many audit deficiencies involve a lack of due professional care. AU 230, DueProfessional Care in the Performance of Work ("AU 230"), paragraphs .02, .05, and .06,requires the independent auditor to plan and perform his or her work with dueprofessional care and sets forth aspects of that requirement. AU 230, paragraphs .07through .09, and Auditing Standard ("AS") No. 13, The Auditor's Responses to the Risks

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of Material Misstatement ("AS No. 13"), paragraph 7, specify that due professional carerequires the exercise of professional skepticism. These standards state thatprofessional skepticism is an attitude that includes a questioning mind and a criticalassessment of the appropriateness and sufficiency of audit evidence.

AS No. 13, paragraphs 3, 5, and 8, requires the auditor to design and implementaudit responses that address the risks of material misstatement, and AS No. 15, AuditEvidence ("AS No. 15"), paragraph 4, requires the auditor to plan and perform auditprocedures to obtain sufficient appropriate audit evidence to provide a reasonable basisfor the audit opinion. Sufficiency is the measure of the quantity of audit evidence, andthe quantity needed is affected by the risk of material misstatement (in the audit offinancial statements) or the risk associated with the control (in the audit of ICFR) andthe quality of the audit evidence obtained. The appropriateness of evidence ismeasured by its quality; to be appropriate, evidence must be both relevant and reliablein support of the related conclusions.

The table below lists the specific auditing standards that are referenced for eachdeficiency included in Part I.A of this report. See the descriptions of the deficiencies inPart I.A for identification of the specific paragraphs, in addition to those noted above,that relates to the individual deficiencies. Standards discussed above are cited again inthe table only if the particular deficiency relates to aspects of the standard that are notdiscussed above.

PCAOB Auditing Standards Issuers

AS No. 5, An Audit of Internal Control OverFinancial Reporting That Is Integrated with AnAudit of Financial Statements

A and B

AS No. 13, The Auditor's Responses to the Risksof Material Misstatement

A

AS No. 15, Audit Evidence A

AU 342, Auditing Accounting Estimates A

AU 350, Audit Sampling A

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C. Information Concerning PCAOB Inspections Generally Applicable to TrienniallyInspected Firms

Board inspections include reviews of certain portions of selected audit workperformed by the inspected firm and reviews of certain aspects of the firm's qualitycontrol system. The inspections are designed to identify deficiencies in audit work anddefects or potential defects in the firm's system of quality control related to the firm'saudit work. The focus on deficiencies, defects, and potential defects necessarily carriesthrough to reports on inspections and, accordingly, Board inspection reports are notintended to serve as balanced report cards or overall rating tools. Further, the inclusionin an inspection report of certain deficiencies, defects, and potential defects should notbe construed as an indication that the Board has made any determination about otheraspects of the inspected firm's systems, policies, procedures, practices, or conduct notincluded within the report.

C.1. Reviews of Audit Work

Inspections include reviews of portions of selected audits of financial statementsand, where applicable, audits of ICFR, and the firm's audit work on other issuer auditengagements in which it played a role but was not the principal auditor. For these auditengagements, the inspection team selects certain portions of the engagements forinspection, and it reviews the engagement team's work papers and interviewsengagement personnel regarding those portions. If the inspection team identifies apotential issue that it is unable to resolve through discussion with the firm and anyreview of additional work papers or other documentation, the inspection team ordinarilyprovides the firm with a written comment form on the matter and the firm is allowed theopportunity to provide a written response to the comment form. If the response doesnot resolve the inspection team's concerns, the matter is considered a deficiency and isevaluated for inclusion in the inspection report.

The inspection team selects the audit engagements, and the specific portions ofthose audit engagements, that it will review, and the inspected firm is not allowed anopportunity to limit or influence the selections. Audit deficiencies that the inspectionteam may identify include a firm's failure to identify, or to address appropriately, financial

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statement misstatements, including failures to comply with disclosure requirements,6 aswell as a firm's failures to perform, or to perform sufficiently, certain necessary auditprocedures. The inspection may not involve the review of all of a firm's audit work, noris it designed to identify every deficiency in the reviewed audit engagements.Accordingly, a Board inspection report should not be understood to provide anyassurance that a firm's audit work, or the relevant issuers' financial statements orreporting on ICFR, are free of any deficiencies not specifically described in aninspection report.

In some cases, the conclusion that a firm did not perform a procedure may bebased on the absence of documentation and the absence of persuasive other evidence,even if the firm claimed to have performed the procedure. AS No. 3, AuditDocumentation ("AS No. 3"), provides that, in various circumstances including PCAOBinspections, a firm that has not adequately documented that it performed a procedure,obtained evidence, or reached an appropriate conclusion, must demonstrate withpersuasive other evidence that it did so, and that oral assertions and explanations alonedo not constitute persuasive other evidence. In reaching its conclusions, the inspectionteam considers whether audit documentation or any persuasive other evidence that afirm might provide to the inspection team supports a firm's contention that it performed aprocedure, obtained evidence, or reached an appropriate conclusion. In the case ofevery matter cited in the public portion of a final inspection report, the inspection teamhas carefully considered any contention by the firm that it did so but just did notdocument its work, and the inspection team has concluded that the available evidencedoes not support the contention that the firm sufficiently performed the necessary work.

6 When it comes to the Board's attention that an issuer's financialstatements appear not to present fairly, in a material respect, the financial position,results of operations, or cash flows of the issuer in conformity with applicableaccounting principles, the Board's practice is to report that information to the Securitiesand Exchange Commission ("SEC" or "the Commission"), which has jurisdiction todetermine proper accounting in issuers' financial statements. Any description in thisreport of financial statement misstatements or failures to comply with SEC disclosurerequirements should not be understood as an indication that the SEC has considered ormade any determination regarding these issues unless otherwise expressly stated.

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Identified deficiencies in the audit work that exceed a significance threshold(which is described in Part I.A of the inspection report) are summarized in the publicportion of the inspection report.7

The Board cautions against extrapolating from the results presented in the publicportion of a report to broader conclusions about the frequency of deficienciesthroughout the firm's practice. Individual audit engagements and areas of inspectionfocus are most often selected on a risk-weighted basis and not randomly. Areas offocus vary among selected audit engagements, but often involve audit work on the mostdifficult or inherently uncertain areas of financial statements. Thus, the audit work isgenerally selected for inspection based on factors that, in the inspection team's view,heighten the possibility that auditing deficiencies are present, rather than through aprocess intended to identify a representative sample.

C.2. Review of a Firm's Quality Control System

QC 20, System of Quality Control for a CPA Firm's Accounting and AuditingPractice ("QC 20"), provides that an auditing firm has a responsibility to ensure that itspersonnel comply with the applicable professional standards. This standard specifiesthat a firm's system of quality control should encompass the following elements: (1)independence, integrity, and objectivity; (2) personnel management; (3) acceptance andcontinuance of issuer audit engagements; (4) engagement performance; and (5)monitoring.

The inspection team's assessment of a firm's quality control system is derivedboth from the results of its procedures specifically focused on the firm's quality controlpolicies and procedures, and also from inferences that can be drawn from deficienciesin the performance of individual audit engagements. Audit deficiencies, whether aloneor when aggregated, may indicate areas where a firm's system has failed to providereasonable assurance of quality in the performance of audit work. Even deficienciesthat do not result in an insufficiently supported audit opinion or a failure to obtain

7 The discussion in this report of any deficiency observed in a particularaudit engagement reflects information reported to the Board by the inspection team anddoes not reflect any determination by the Board as to whether the Firm has engaged inany conduct for which it could be sanctioned through the Board's disciplinary process.In addition, any references in this report to violations or potential violations of law, rules,or professional standards are not a result of an adversarial adjudicative process and donot constitute conclusive findings for purposes of imposing legal liability.

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sufficient appropriate audit evidence to fulfill the objectives of its role in an audit mayindicate a defect or potential defect in a firm's quality control system.8 If identifieddeficiencies, when accumulated and evaluated, indicate defects or potential defects inthe firm's system of quality control, the nonpublic portion of this report would include adiscussion of those issues. When evaluating whether identified deficiencies inindividual audit engagements indicate a defect or potential defect in a firm's system ofquality control, the inspection team considers the nature, significance, and frequency ofdeficiencies;9 related firm methodology, guidance, and practices; and possible rootcauses.

Inspections also include a review of certain of the firm's practices, policies, andprocesses related to audit quality, which constitute a part of the firm's quality controlsystem. This review addresses practices, policies, and procedures concerning auditperformance and the following eight functional areas (1) tone at the top; (2) practices forpartner evaluation, compensation, admission, assignment of responsibilities, anddisciplinary actions; (3) independence implications of non-audit services; businessventures, alliances, and arrangements; personal financial interests; and commissionsand contingent fees; (4) practices for client acceptance and retention; (5) practices forconsultations on accounting, auditing, and SEC matters; (6) the Firm's internalinspection program; (7) practices for establishment and communication of audit policies,procedures, and methodologies, including training; and (8) the supervision by the Firm'saudit engagement teams of the work performed by foreign affiliates.

END OF PART I

8 Not every audit deficiency suggests a defect or potential defect in a firm'squality control system.

9 An evaluation of the frequency of a type of deficiency may includeconsideration of how often the inspection team reviewed audit work that presented theopportunity for similar deficiencies to occur. In some cases, even a type of deficiencythat is observed infrequently in a particular inspection may, because of somecombination of its nature, its significance, and the frequency with which it has beenobserved in previous inspections of the firm, be cause for concern about a qualitycontrol defect or potential defect.

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PARTS II AND III OF THIS REPORT ARE NONPUBLICAND ARE OMITTED FROM THIS PUBLIC DOCUMENT

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PART IV

RESPONSE OF THE FIRM TO DRAFT INSPECTION REPORT

Pursuant to section 104(f) of the Act, 15 U.S.C. § 7214(f), and PCAOB Rule4007(a), the Firm provided a written response to a draft of this report. Pursuant tosection 104(f) of the Act and PCAOB Rule 4007(b), the Firm's response, minus anyportion granted confidential treatment, is attached hereto and made part of this finalinspection report.10

10 The Board does not make public any of a firm's comments that address anonpublic portion of the report unless a firm specifically requests otherwise. In somecases, the result may be that none of a firm's response is made publicly available. Inaddition, pursuant to section 104(f) of the Act, 15 U.S.C. § 7214(f), and PCAOB Rule4007(b), if a firm requests, and the Board grants, confidential treatment for any of thefirm's comments on a draft report, the Board does not include those comments in thefinal report at all. The Board routinely grants confidential treatment, if requested, for anyportion of a firm's response that addresses any point in the draft that the Board omitsfrom, or any inaccurate statement in the draft that the Board corrects in, the final report.

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APPENDIX A

AUDITING STANDARDS REFERENCED IN PART I

This appendix provides the text of the auditing standard paragraphs that arereferenced in Part I.A of this report. Footnotes that are included in this appendix, andany other Notes, are from the original auditing standards that are referenced. While thisappendix contains the specific portions of the relevant standards cited with respect tothe deficiencies in Part I.A of this report, other portions of the standards (including thosedescribed in Part I.B of this report) may provide additional context, descriptions, relatedrequirements, or explanations; the complete standards are available on the PCAOB'swebsite at http://pcaobus.org/STANDARDS/Pages/default.aspx.

AS No. 5, An Audit of Internal Control Over Financial Reporting That Is Integratedwith An Audit of Financial Statements

Selecting Controls to Test

AS No. 5.39 The auditor should test those controls that areimportant to the auditor's conclusion about whether thecompany's controls sufficiently address the assessed riskof misstatement to each relevant assertion.

Issuers A and B

TESTING CONTROLS

Testing Design

Effectiveness

AS No. 5.42 The auditor should test the design effectiveness ofcontrols by determining whether the company's controls, ifthey are operated as prescribed by persons possessing thenecessary authority and competence to perform the controleffectively, satisfy the company's control objectives andcan effectively prevent or detect errors or fraud that couldresult in material misstatements in the financial statements.

Note: A smaller, less complex company mightachieve its control objectives in a different mannerfrom a larger, more complex organization. Forexample, a smaller, less complex company mighthave fewer employees in the accounting function,limiting opportunities to segregate duties andleading the company to implement alternativecontrols to achieve its control objectives. In suchcircumstances, the auditor should evaluatewhether those alternative controls are effective.

Issuers A and B

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AS No. 5, An Audit of Internal Control Over Financial Reporting That Is Integratedwith An Audit of Financial Statements

Testing Operating

Effectiveness

AS No. 5.44 The auditor should test the operating effectivenessof a control by determining whether the control is operatingas designed and whether the person performing the controlpossesses the necessary authority and competence toperform the control effectively.

Note: In some situations, particularly in smallercompanies, a company might use a third party toprovide assistance with certain financial reportingfunctions. When assessing the competence ofpersonnel responsible for a company's financialreporting and associated controls, the auditor maytake into account the combined competence ofcompany personnel and other parties that assistwith functions related to financial reporting.

Issuers A and B

AS No. 13, The Auditor's Responses to the Risks of Material Misstatement

Testing Controls

TESTING CONTROLS INAN AUDIT OF FINANCIALSTATEMENTS

AS No. 13.16 Controls to be Tested. If the auditor plans toassess control risk at less than the maximum by relying oncontrols,12/ and the nature, timing, and extent of plannedsubstantive procedures are based on that lowerassessment, the auditor must obtain evidence that thecontrols selected for testing are designed effectively andoperated effectively during the entire period ofreliance.13/ However, the auditor is not required to assesscontrol risk at less than the maximum for all relevantassertions and, for a variety of reasons, the auditor maychoose not to do so.

Issuer A

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AS No. 13, The Auditor's Responses to the Risks of Material Misstatement

Footnotes to AS No. 13.16

12/ Reliance on controls that is supported by sufficient and appropriate audit evidence allows theauditor to assess control risk at less than the maximum, which results in a lower assessed risk of materialmisstatement. In turn, this allows the auditor to modify the nature, timing, and extent of planned substantiveprocedures.

13/ Terms defined in Appendix A, Definitions, are set in boldface type the first time they appear.

AS No. 13.18 Evidence about the Effectiveness of Controls inthe Audit of Financial Statements. In designing andperforming tests of controls for the audit of financialstatements, the evidence necessary to support theauditor's control risk assessment depends on the degreeof reliance the auditor plans to place on the effectivenessof a control. The auditor should obtain more persuasiveaudit evidence from tests of controls the greater thereliance the auditor places on the effectiveness of acontrol. The auditor also should obtain more persuasiveevidence about the effectiveness of controls for eachrelevant assertion for which the audit approach consistsprimarily of tests of controls, including situations in whichsubstantive procedures alone cannot provide sufficientappropriate audit evidence.

Issuer A

Substantive Procedures

AS No. 13.37 As the assessed risk of material misstatementincreases, the evidence from substantive procedures thatthe auditor should obtain also increases. The evidenceprovided by the auditor's substantive procedures dependsupon the mix of the nature, timing, and extent of thoseprocedures. Further, for an individual assertion, differentcombinations of the nature, timing, and extent of testingmight provide sufficient appropriate evidence to respondto the assessed risk of material misstatement.

Issuer A

TIMING OF SUBSTANTIVEPROCEDURES

AS No. 13.45 When substantive procedures are performed atan interim date, the auditor should cover the remainingperiod by performing substantive procedures, orsubstantive procedures combined with tests of controls,that provide a reasonable basis for extending the audit

Issuer A

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AS No. 13, The Auditor's Responses to the Risks of Material Misstatementconclusions from the interim date to the period end.Such procedures should include (a) comparing relevantinformation about the account balance at the interimdate with comparable information at the end of theperiod to identify amounts that appear unusual andinvestigating such amounts and (b) performing auditprocedures to test the remaining period.

AS No. 15, Audit Evidence

Sufficient Appropriate

Audit Evidence

USING INFORMATIONPRODUCED BY THECOMPANY

AS No. 15.10 When using information produced by the companyas audit evidence, the auditor should evaluate whether theinformation is sufficient and appropriate for purposes of theaudit by performing procedures to:3/

Test the accuracy and completeness of theinformation, or test the controls over theaccuracy and completeness of thatinformation; and

Evaluate whether the information is sufficientlyprecise and detailed for purposes of the audit.

Issuer A

AU 342, Auditing Accounting Estimates

Evaluating Accounting

Estimates

EvaluatingReasonableness

AU 342.11 Review and test management's process. In manysituations, the auditor assesses the reasonableness of anaccounting estimate by performing procedures to test theprocess used by management to make the estimate. Thefollowing are procedures the auditor may consider performingwhen using this approach:

a. Identify whether there are controls over the

Issuer A

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PCAOB Release No. 104-2016-168Inspection of PricewaterhouseCoopers

Auditores IndependentesJuly 28, 2016

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AU 342, Auditing Accounting Estimatespreparation of accounting estimates andsupporting data that may be useful in theevaluation.

b. Identify the sources of data and factors thatmanagement used in forming the assumptions,and consider whether such data and factors arerelevant, reliable, and sufficient for the purposebased on information gathered in other audittests.

c. Consider whether there are additional keyfactors or alternative assumptions about thefactors.

d. Evaluate whether the assumptions areconsistent with each other, the supporting data,relevant historical data, and industry data.

e. Analyze historical data used in developing theassumptions to assess whether the data iscomparable and consistent with data of theperiod under audit, and consider whether suchdata is sufficiently reliable for the purpose.

f. Consider whether changes in the business orindustry may cause other factors to becomesignificant to the assumptions.

g. Review available documentation of theassumptions used in developing the accountingestimates and inquire about any other plans,goals, and objectives of the entity, as well asconsider their relationship to the assumptions.

h. Consider using the work of a specialist regardingcertain assumptions (section 336, Using theWork of a Specialist).

i. Test the calculations used by management totranslate the assumptions and key factors intothe accounting estimate.

AU 350, Audit Sampling

Sampling in SubstantiveTests of Details

Planning Sampling

AU 350.19 The second standard of field work states, "Asufficient understanding of the internal control structure is to

Issuer A

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PCAOB Release No. 104-2016-168Inspection of PricewaterhouseCoopers

Auditores IndependentesJuly 28, 2016

Page A-6

AU 350, Audit Samplingbe obtained to plan the audit and to determine the nature,timing, and extent of tests to be performed." After assessingand considering the levels of inherent and control risks, theauditor performs substantive tests to restrict detection riskto an acceptable level. As the assessed levels of inherentrisk, control risk, and detection risk for other substantiveprocedures directed toward the same specific auditobjective decreases, the auditor's allowable risk of incorrectacceptance for the substantive tests of details increasesand, thus, the smaller the required sample size for thesubstantive tests of details. For example, if inherent andcontrol risks are assessed at the maximum, and no othersubstantive tests directed toward the same specific auditobjectives are performed, the auditor should allow for a lowrisk of incorrect acceptance for the substantive tests ofdetails. fn 3 Thus, the auditor would select a larger samplesize for the tests of details than if he allowed a higher risk ofincorrect acceptance.

AU 350.23 To determine the number of items to be selected ina sample for a particular substantive test of details, theauditor should take into account tolerable misstatement forthe population; the allowable risk of incorrect acceptance(based on the assessments of inherent risk, control risk,and the detection risk related to the substantive analyticalprocedures or other relevant substantive tests); and thecharacteristics of the population, including the expected sizeand frequency of misstatements.

Issuer A

AU 350.23A Table 1 of the Appendix describes the effects of thefactors discussed in the preceding paragraph on samplesizes in a statistical or nonstatistical sampling approach.When circumstances are similar, the effect on sample sizeof those factors should be similar regardless of whether astatistical or nonstatistical approach is used. Thus, when anonstatistical sampling approach is applied properly, theresulting sample size ordinarily will be comparable to, orlarger than, the sample size resulting from an efficient andeffectively designed statistical sample.

Issuer A