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Preface

(Updated as of March 1, 2019)

About AICPA Guides

This AICPA Guide has been developed by the AICPA State and Local Government Audit Guide Revision Task Force (task force) to assist practitioners in performing and reporting on their audit engagements and to assist management in the preparation of their financial statements in conformity with U.S. generally accepted accounting principles (GAAP).

An AICPA Guide containing auditing guidance related to generally accepted auditing standards (GAAS) is recognized as an interpretive publication as defined in AU-C section 200, Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance With Generally Accepted Auditing Standards.1 Interpretive publications are recommendations on the application of GAAS in specific circumstances, including engagements for entities in specialized industries.

Interpretive publications are issued under the authority of the AICPA Auditing Standards Board (ASB) after all ASB members have been provided an opportunity to consider and comment on whether the proposed interpretive publication is consistent with GAAS. The members of the ASB have found the auditing guidance in this guide to be consistent with existing GAAS.

Although interpretive publications are not auditing standards, AU-C section 200 requires the auditor to consider applicable interpretive publications in planning and performing the audit because interpretive publications are relevant to the proper application of GAAS in specific circumstances. If the auditor does not apply the auditing guidance in an applicable interpretive publication, the auditor should document how the requirements of GAAS were complied within the circumstances addressed by such auditing guidance.

Throughout this guide, when appropriate, reference is made to Q&A sections in Technical Questions and Answers (Q&A). Q&A sections are other auditing publications. AU-C section 200 indicates that in applying the auditing guidance included in an other auditing publication, the auditor should, exercising professional judgment, assess the relevance and appropriateness of such guidance to the circumstances of the audit. Other auditing publications have no authoritative status; however, they may help the auditor understand and apply GAAS. The auditor is not expected to be aware of the full body of other auditing publications. Although the auditor determines the relevance of these publications in accordance with AU-C section 200, paragraph .28, the auditor may presume that other auditing publications published by the Association of International Certified Professional Accountants that have been reviewed by the Audit and Attest Standards staff are appropriate. These other auditing publications are listed in AU-C appendix F, “Other Auditing Publications.”

The ASB is the designated senior committee of the AICPA authorized to speak for the AICPA on all matters related to auditing. Conforming changes made to the auditing guidance contained in this guide are approved by the ASB Chair (or his or her designee) and the Director of the AICPA Audit and Attest Standards Staff. Updates made to the auditing guidance in this guide exceeding that of conforming changes are issued after all ASB members have been provided an opportunity to consider and comment on whether the guide is consistent with existing GAAS.

Any auditing guidance in a guide appendix or chapter appendix in a guide, or in an exhibit, although not authoritative, is considered an “other auditing publication.” In applying such guidance, the auditor should, exercising professional judgment, assess the relevance and appropriateness of such guidance to the circumstances of the audit. Although the auditor determines the relevance of other auditing guidance, auditing guidance in a guide appendix or exhibit has been reviewed by the AICPA Audit and Attest Standards staff and the auditor may presume that it is appropriate.

An AICPA Guide containing attestation guidance is recognized as an interpretive publication as defined in AT-C section 105, Concepts Common to All Attestation Engagements.2 Interpretive publications are recommendations on the application of Statements on Standards for Attestation Engagements (SSAEs or attestation standards) in specific circumstances, including engagements for entities in specialized industries. Interpretive publications are issued under the authority of the ASB. The members of the ASB have found the attestation guidance in this guide to be consistent with existing SSAEs.

A practitioner should be aware of and consider the guidance in this AICPA Guide applicable to his or her attestation engagement. If the practitioner does not apply the attestation guidance included in an applicable interpretive publication, the practitioner should document how the requirements of the SSAE were complied within the circumstances addressed by such attestation guidance.

Any attestation guidance in a guide appendix or chapter appendix in a guide, or in an exhibit, although not authoritative, is considered an “other attestation publication.” In applying such guidance, the practitioner should, exercising professional judgment, assess the relevance and appropriateness of such guidance to the circumstances of the engagement. Although the practitioner determines the relevance of other attestation guidance, such guidance in a guide appendix or exhibit has been reviewed by the AICPA Audit and Attest Standards staff and the practitioner may presume that it is appropriate.

The ASB and AICPA Accounting and Review Services Committee (ARSC) are the designated senior committees of the AICPA authorized to speak for the AICPA on all matters related to attestation in their respective areas of responsibility. Conforming changes made to the attestation guidance contained in this guide are approved by the ASB Chair (or his or her designee) and the Director of the AICPA Audit and Attest Standards Staff. Updates made to the attestation guidance in this guide exceeding that of conforming changes are issued after all ASB members have been provided an opportunity to consider and comment on whether the guide is consistent with the SSAEs.

The Financial Reporting Executive Committee (FinREC) is the designated senior committee of the AICPA authorized to speak for the AICPA in the areas of financial accounting and reporting. Conforming changes made to the financial accounting and reporting guidance contained in this guide are approved by the FinREC Chair (or his or her designee). Updates made to the financial accounting and reporting guidance in this guide exceeding that of conforming changes are approved by the affirmative vote of at least two-thirds of the members of FinREC.

This guide does the following:

     Identifies certain requirements set forth in GAAP for governmental entities.

     Describes FinREC’s understanding of prevalent or sole industry practice concerning certain issues. In addition, this guide may indicate that FinREC expresses a preference for the prevalent or sole industry practice, or it may indicate that FinREC expresses a preference for another practice that is not the prevalent or sole industry practice; alternatively, FinREC may express no view on the matter.

     Identifies certain other, but not necessarily all, industry practices concerning certain accounting issues without expressing FinREC’s views on them.

     Provides guidance that has been supported by FinREC on the accounting, reporting, or disclosure treatment of transactions or events that are not set forth in GAAP for governmental entities.

Accounting guidance for governmental entities included in an AICPA Guide, and cleared by GASB, is a source of authoritative GAAP described in category B of the hierarchy of GAAP for state and local governmental entities as defined in GASB Statement No. 76, The Hierarchy of Generally Accepted Accounting Principles for State and Local Governments. The accounting provisions of this guide that have been cleared by GASB are formatted in orange font for the reader within the text of the guide and are noted in appendix B, “Category B Guidance.” AICPA members should be prepared to justify departures from GAAP as discussed in the “Accounting Principles Rule” (ET sec. 1.320.001 and 2.320.001).3

AICPA Guides may include certain content presented as “Supplement,” “Appendix,” or “Exhibit.” A supplement is a reproduction, in whole or in part, of authoritative guidance originally issued by a standard setting body (including regulatory bodies) and applicable to entities or engagements within the purview of that standard setter, independent of the authoritative status of the applicable AICPA Guide. Both appendixes and exhibits are included for informational purposes and have no authoritative status.

Purpose and Applicability

The AICPA developed this guide to help auditors understand the GAAP applicable to the financial statements of state and local governments and audit and report on those financial statements in accordance with GAAS. This guide is designed as a tool for auditors of governmental entities of all sizes. The nature, timing, and extent of auditing procedures in a particular engagement are matters of professional judgment and will vary depending upon numerous factors, including the size of the entity and its organizational structure and internal control, materiality considerations, the auditor’s assessment of risk, and applicable laws, regulations, and provisions of grants and contracts.

This guide applies to all state and local governments as defined in chapter 1, "Overview and Introduction." Certain other AICPA Guides also apply to audits of certain state and local governments, as discussed in chapter 1. In particular, auditors who perform audits under Government Auditing Standards, the Single Audit Act Amendments of 1996, and Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, should refer to the AICPA Audit Guide Government Auditing Standards and Single Audits.

Limitations and Coverage

This guide is designed to provide guidance to auditors who are new to state and local governmental accounting and auditing as well as to auditors experienced in state and local governmental accounting and auditing. This guide assumes that the auditor has expertise in accounting and auditing, in general, but not necessarily in the specialized accounting and auditing practices applicable to state and local governments. Therefore, the guide concentrates on the accounting standards and auditing procedures that are unique to or significant for those governments. This guide also is intended to be useful in providing accounting and financial reporting guidance to preparers of governmental financial statements. The guidance presented here is not all inclusive; it is limited to certain matters that warrant special emphasis or that experience has indicated may be useful. Although this guide does not incorporate, repeat, or summarize all authoritative pronouncements that apply to state and local governments, it does consider relevant guidance contained in authoritative pronouncements through those indicated in this preface.

Authoritative pronouncements should be applied based on the effective dates in the pronouncements. The AICPA staff will make conforming changes to this guide annually to incorporate relevant guidance in new accounting and auditing pronouncements. Users of this guide should consider pronouncements issued after those listed in this preface to consider their effect on state and local governments.

Recognition

2019 Guide Edition

AICPA Senior Committees

Auditing Standards Board
Michael J. Santay, Chair
Marcia L. Marien, Member

Financial Reporting Executive Committee
Jim Dolinar, Chair

The AICPA gratefully acknowledges John Good for his valuable assistance in updating the 2019 edition of the guide.

The AICPA also gratefully acknowledges those members of the AICPA State and Local Government Expert Panel who reviewed or otherwise contributed to the development of this edition of the guide: Corey Arvizu, Joel Black, David Bullock, Edward Chait, Sharon Edmundson, Michelle Horaney, Jeff Markert, Tamara Miramontes, Flo Ostrum, Chris Pembrook, Reem Samra, Walker Wilkerson, and the chair of the Expert Panel, Heather Acker.

AICPA Staff

Shavonn R. Pegram
Manager
Product Management and Development — Public Accounting

Laura Hyland
Senior Manager
Governmental Auditing and Accounting — Public Accounting
and Staff Liaison to the
AICPA State and Local Government Expert Panel

Guidance Considered in This Edition

This edition of the guide has been modified by the AICPA staff to include certain changes necessary due to the issuance of authoritative guidance since the guide was originally issued, and other revisions as deemed appropriate. Relevant guidance issued through March 1, 2019, has been considered in the development of this edition of the guide. However, this guide does not include all audit, accounting, reporting, and other requirements applicable to an entity or a particular engagement. This guide is intended to be used in conjunction with all applicable sources of relevant guidance.

Relevant guidance that is issued and effective on or before March 1, 2019, is incorporated directly in the text of this guide. Relevant guidance related to GASB Statement No. 84, Fiduciary Activities, effective for reporting periods beginning after December 15, 2018, is also presented directly in the text of the guide, but shaded gray and accompanied by a footnote indicating the effective date of the new guidance. The distinct presentation of this content is intended to aid the reader in differentiating content that may not be effective for the reader’s purposes (as part of the guide’s “dual guidance” treatment of applicable new guidance).

Relevant guidance issued but not yet effective as of the date of the guide and not becoming effective until after June 30, 2019, is referenced in a “guidance update” box; that is, a box that contains summary information on the guidance issued but not yet effective.

In updating this guide, all guidance issued up to and including the following was considered, but not necessarily incorporated, as determined based on applicability:

     GASB Statement No. 90, Majority Equity Interests—an amendment of GASB Statements No. 14 and No. 61

     GASB Interpretation No. 6, Recognition and Measurement of Certain Liabilities and Expenditures in Governmental Fund Financial Statements—an interpretation of NCGA Statements 1, 4, and 5; NCGA Interpretation 8; and GASB Statements No. 10, 16, and 18

     GASB Technical Bulletin No. 2008-1, Determining the Annual Required Contribution Adjustment for Postemployment Benefits

     GASB Concepts Statement No. 6, Measurement of Elements of Financial Statements

     GASB Implementation Guide No. 2018-1, Implementation Guidance Update—2018

     Statement on Auditing Standards (SAS) No. 133, Auditor Involvement With Exempt Offering Documents (AU-C sec. 945)

     Statement of Position 13-2, Performing Agreed-Upon Procedures Engagements That Address the Completeness, Mapping, Consistency, or Structure of XBRL-Formatted Information (AUD sec. 55)4

     SSAE No. 18, Attestation Standards: Clarification and Recodification

Users of this guide should consider guidance issued subsequent to those items listed previously to determine their effect, if any, on entities covered by this guide. In determining the applicability of recently issued guidance, its effective date should also be considered.

The changes made to this edition of the guide are identified in the Schedule of Changes appendix. The changes do not include all those that might be considered necessary if the guide were subjected to a comprehensive review and revision.

GASB standards quoted are from the GASB Statements, Concepts Statements, Interpretations, and Technical Bulletins, ©2018, Financial Accounting Foundation. All rights reserved. Used by permission.

Terms Used to Define Professional Requirements in This AICPA Guide

Any requirements described in this guide are normally referenced to the applicable standards or regulations from which they are derived. Generally, the terms used in this guide describing the professional requirements of the referenced standard setter (for example, the ASB) are the same as those used in the applicable standards or regulations (for example, must or should).

Readers should refer to the applicable standards and regulations for more information on the requirements imposed by the use of the various terms used to define professional requirements in the context of the standards and regulations in which they appear.

Certain exceptions apply to these general rules, particularly in those circumstances where the guide describes prevailing and preferred industry practices for the application of a standard or regulation. In these circumstances, the applicable senior committee responsible for reviewing the guide’s content believes the guidance contained herein is appropriate for the circumstances.

Applicability of Quality Control Standards

QC section 10, A Firm’s System of Quality Control,5 addresses a CPA firm’s responsibilities for its system of quality control for its accounting and auditing practice. A system of quality control consists of policies that a firm establishes and maintains to provide it with reasonable assurance that the firm and its personnel comply with professional standards, as well as applicable legal and regulatory requirements. The policies also provide the firm with reasonable assurance that reports issued by the firm are appropriate in the circumstances.

QC section 10 applies to all CPA firms with respect to engagements in their accounting and auditing practice. In paragraph .13 of QC section 10, an accounting and auditing practice is defined as “a practice that performs engagements covered by this section, which are audit, attestation, compilation, review, and any other services for which standards have been promulgated by the AICPA ASB or the ARSC under the “ General Standards Rule” (ET sec. 1.300.001) or the “Compliance With Standards Rule” (ET sec. 1.310.001) of the AICPA Code of Professional Conduct. Although standards for other engagements may be promulgated by other AICPA technical committees, engagements performed in accordance with those standards are not encompassed in the definition of an accounting and auditing practice.”

In addition to the provisions of QC section 10, readers should be aware of other sections within AICPA Professional Standards that address quality control considerations, including the following provisions that address engagement level quality control matters for various types of engagements that an accounting and auditing practice might perform:

     AU-C section 220, Quality Control for an Engagement Conducted in Accordance With Generally Accepted Auditing Standards

     AT-C section 105

     AR-C section 60, General Principles for Engagements Performed in Accordance With Statements on Standards for Accounting and Review Services6

Because of the importance of engagement quality, this guide includes an appendix, “Overview of Statements on Quality Control Standards,” which summarizes key aspects of the quality control standard. This summarization should be read in conjunction with QC section 10, AU-C section 220, AT-C section 105, and AR-C section 60, as applicable.

AICPA.org Website

The AICPA encourages you to visit its website at aicpa.org, the Governmental Audit Quality Center (GAQC) website at www.aicpa.org/gaqc, and the Financial Reporting Center at www.aicpa.org/frc. The “GASB Matters” page on the GAQC website will be of particular interest to auditors of state and local governments.

The GAQC is a voluntary membership center for CPA firms and state audit organizations designed to improve the quality and value of governmental audits. For the purposes of the GAQC, governmental audits are performed under Government Auditing Standards and are audits and attestation engagements of federal, state, or local governments; not-for-profit entities; and certain for-profit organization, such as housing projects and colleges and universities that participate in governmental programs or receive governmental financial assistance. The GAQC website provides information and resources to those performing governmental audits.

The Financial Reporting Center supports members in the execution of high-quality financial reporting. Whether you are a financial statement preparer or a member in public practice, this center provides exclusive member-only resources for the entire financial reporting process and timely and relevant news, guidance, and examples supporting the financial reporting process. Another important focus of the Financial Reporting Center is keeping those in public practice up to date on issues pertaining to preparation, compilation, review, audit, attestation, assurance, and advisory engagements. Certain content on the AICPA’s websites referenced in this guide may be restricted to AICPA members only.

Risk Assessment — Enhancing Audit Quality (EAQ) Areas of Focus

Identifying, assessing, and responding to risks of material misstatement are the core of every audit. However, there is evidence that a high percentage of audit engagements do not reflect proper assessment of risk or linkage of the assessment to planned further audit procedures in accordance with AU-C section 315, Understanding the Entity and Its Environment and Assessing the Risks of Material Misstatement, and AU-C section 330, Performing Audit Procedures in Response to Assessed Risks and Evaluating the Audit Evidence Obtained.

In connection with its EAQ initiative, the AICPA has developed a webpage dedicated to risk assessment resources intended to help auditors perform more effective risk assessment and appropriately link the risk assessment to further audit procedures in compliance with professional standards. Certain resources are available at no cost, including a risk assessment template, an internal inspection aid, and staff training workshop. These and other current risk assessment resources can be accessed at www.aicpa.org/content/aicpa/eaq/aicpa-risk-assessment-resources.html.

Select Recent Developments Significant to This Guide

Changes to the Auditor’s Report

At its January 2019 meeting, the ASB voted to issue as final SAS No. 134, Auditor Reporting and Amendments, Including Amendments Addressing Disclosures in the Audit of Financial Statements, aimed at enhancing the relevance and usefulness of the auditor’s report. SAS No. 134 was developed in consideration of the following issues identified by the PCAOB and the International Auditing and Assurance Standards Board:

     Although users value the "pass/fail" nature of the auditor’s opinion, they would like the auditor’s report to provide greater transparency into the audit.

     Users would like the auditor’s report to include more information about areas with higher assessed risks of material misstatement, areas that involve significant judgement by management and the auditor, and areas that relate to significant events or transactions.

     To address the long-standing "expectations gap," users and other stakeholders would like the auditor’s report to expand the descriptions of the auditor’s responsibilities in financial statement auditing and management’s responsibilities in financial statement preparation.

The following are the sections in SAS No. 134 and a summary of their key changes.

SAS No. 134, Auditor Reporting and Amendments, Including Amendments Addressing Disclosures in the Audit of Financial Statements

Forming an Opinion and Reporting on Financial Statements (AU-C section 700). The following summarizes what the ASB believes are the most significant changes from extant AU-C section 700:

     Requires the "Opinion" section to be presented first in the auditor’s report, followed by the "Basis for Opinion" section

     Requires the "Basis for Opinion" section of the auditor’s report to include a statement that the auditor is required to be independent and to meet the auditor’s other ethical responsibilities

     Requires the auditor to report in accordance with AU-C section 570, The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern, when applicable (See discussion of AU-C section 570 that follows.)

     Provides a framework for auditors of nonissuers to communicate key audit matters (KAMs). Although communication of KAMs is not required for audits of nonissuers, if the terms of the audit engagement include reporting KAMs, the auditor would be required to communicate KAMs in accordance with new AU-C section 701, Communicating Key Audit Matters in the Independent Auditor’s Report.

     Expands the description of the responsibilities of management for the financial statements to include management’s responsibility to evaluate whether there are conditions or events that raise substantial doubt about the entity’s ability to continue as a going concern, when required by the applicable financial reporting framework.

     Expands the description of the responsibilities of the auditor and key features of an audit, including references to the auditor’s responsibilities under AU-C section 570 to conclude whether conditions or events exist that raise substantial doubt about the entity’s ability to continue as a going concern, and to the auditor’s responsibility to communicate with those charged with governance.

Communicating Key Audit Matters in the Independent Auditor’s Report (New AU-C section 701). As discussed earlier, AU-C section 700, Forming an Opinion and Reporting on Financial Statements, does not require the communication of KAMs for audits of nonissuers but, if done as part of the terms of the audit engagement, the auditor would be required to communicate KAMs in accordance with new AU-C section 701, which closely converges with ISA 701, Communicating Key Audit Matters in the Independent Auditor’s Report.

Modifications to the Opinion in the Independent Auditor’s Report (AU-C section 705). This section is intended to converge with ISA 705 (Revised), Modifications to the Opinion in the Independent Auditor’s Report. The principal changes to extant AU-C section 705 relate to the form and content of the auditor’s report when the opinion is modified consistent with the requirements in AU-C section 700, Forming an Opinion and Reporting on Financial Statements.

Emphasis-of-Matter and Other-Matter Paragraphs in the Independent Auditor’s Report (AU-C section 706). This section is intended to converge with ISA 706 (Revised), Emphasis of Matter Paragraphs and Other Matter Paragraphs in the Independent Auditor’s Report. The principal changes to extant AU-C section 706 relate to clarifying the relationship between emphasis-of-matter paragraphs and the communication of KAMs in the auditor’s report. When AU-C section 701, Communicating Key Audit Matters in the Independent Auditor’s Report, applies, the use of an emphasis-of-matter paragraph is not a substitute for a description of individual KAMs. AU-C section 706, also requires the auditor to use an appropriate heading for an emphasis-of-matter paragraph. This heading should include the term "Emphasis of Matter" when KAMs are communicated in the auditor’s report. The auditor would be able to add additional context to the heading to further describe the nature of the matter (for example, "Emphasis of Matter — Subsequent Event").

The Auditor’s Consideration of an Entity’s Ability to Continue as a Going Concern (AU-C section 570). The proposed amendments to AU-C section 570 (SAS No. 132) modify the requirements relating to auditor reporting on going concern to be consistent with the corresponding requirements in ISA 570 (Revised). When SAS No. 132 was issued in February 2017, it was contemplated that the reporting requirements would be assessed and potentially revised in connection with the ASB’s auditor reporting project. The underlying auditor performance requirements relating to going concern are not changing. If, after considering identified conditions or events and management’s plans, the auditor concludes that substantial doubt about the entity’s ability to continue as a going concern for a reasonable period of time remains, the auditor would include a separate section in the auditor’s report under the heading "Substantial Doubt About the Entity’s Ability to Continue as a Going Concern" instead of an emphasis-of-matter paragraph. The content of this separate section would be similar to that included in the emphasis-of-matter paragraph.

Communications With Those Charged With Governance (AU-C section 260). The most significant change to extant AU-C section 260 is a requirement for the auditor to communicate with those charged with governance about the significant risks identified by the auditor. This communication is part of the required communication of an overview of the planned scope and timing of the audit.

The amendments to AU-C section 260 add a requirement for the auditor to communicate with those charged with governance about circumstances that affect the form and content of the auditor’s report, if any. They also include application material that provide examples of matters for which communication with those charged with governance may be important to be made prior to issuance of the auditor’s report.

Terms of Engagement (AU-C section 210). The amendments to AU-C section 210 modify the application material relating to the form and content of the engagement letter and the example audit engagement letter to be consistent with the changes to the elements of the auditor’s report in the AU-C section 700

A new application material paragraph is added to provide guidance when management (and, as applicable, those charged with governance) has requested that the auditor communicate KAMs in the auditor’s report and to provide guidance regarding the acknowledgment of this in the engagement letter.

Amendments Addressing Disclosures in the Audit of Financial Statements. The amendments to address disclosures in an audit of financial statements are intended to focus the auditor’s attention on disclosures earlier in the process of auditing financial statements. The approach of amending specific AU-C sections, rather than a separate SAS on disclosures, is intended to encourage a holistic and integrated approach to auditing disclosures throughout the financial statement audit.

Effective Date. The SAS and related amendments are effective for audits of financial statements for periods ending on or after December 15, 2020, Early implementation is not permitted.

SAS Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA

In July 2018, the ASB voted to issue a new auditing standard, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA (EBP SAS). Although the ASB voted to issue the EBP SAS as a final standard, it was not issued immediately because the ASB was also deliberating SAS No. 134, Auditor Reporting and Amendments, Including Amendments Addressing Disclosures in the Audit of Financial Statements. SAS No. 134 was voted as a final standard at the January 2019 ASB meeting and conforming amendments have been made to the EBP SAS to align the reporting elements. The ASB is expected to approve the amendments at the May 2019 ASB meeting.

The EBP SAS addresses the auditor’s responsibility to form an opinion and report on the audit of financial statements of employee benefit plans subject to ERISA, and the form and content of the auditor’s report issued as a result of an audit of ERISA plan financial statements, including changes to the form and content of the auditor’s report when management elects to have an audit performed pursuant to ERISA Section 103(a)(3)(C). The EBP SAS also includes new requirements for engagement acceptance, audit risk assessment and response, communications with those charged with governance, procedures for an ERISA Section 103(a)(3)(C) audit, and considerations relating to the Form 5500. For audits of ERISA plan financial statements only, the EBP SAS would apply in place of AU-C section 700, Forming an Opinion and Reporting on Financial Statements, and paragraph .09 of AU-C section 725, Supplementary Information in Relation to the Financial Statements as a Whole. The EBP SAS also would amend various other AU-C sections in AICPA Professional Standards. The EBP SAS should not be adapted for plans that are not subject to ERISA.

The EBP SAS is effective for audits of financial statements for periods ending on or after December 15, 2020. Early implementation is not permitted.

This edition of the guide has not been updated to reflect this new SAS. As of March 2019, readers can access a copy of the final balloted draft at www.aicpa.org/content/dam/aicpa/research/exposuredrafts/accountingandauditing/downloadabledocuments/sas-13x-ballot-draft.pdf. This does not represent the final standard, and therefore it is important to follow further ASB actions at www.aicpa.org/interestareas/frc/auditattest.html until the standard is finalized. The Standards Tracker provides a quick reference to recently issued audit and attest standards, complete with effective dates, summaries, and links to the standards themselves and can be accessed at www.aicpa.org/interestareas/frc/auditattest/standardstracker-auditandattest.html.

Notes

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