There is, however, also considerable concern about costs and
counter-productive Section 404 impacts. As to some implementation
issues that have been raised --
- One charge is that companies can no longer look to their
auditors for advice on difficult accounting issues. AS No. 2 is not
intended to erect a wall between auditors and clients.
Auditor-management free and open communications concerning
financial reporting and internal control issues are still
permissible.
- AS No. 2 is not a “cookbook” of auditing procedures. It is not
possible -- or desirable -- to supplant auditor judgment with
detailed procedures, but the Board is committed to monitoring how
auditors exercise their judgment.
- While it is necessary for the auditor to understand the overall
control system and to “walk through” the operation of all
significant processes, the focus should be on what is material to
the financials, not on the trivial.
- Smaller, less complex businesses typically need less complex
controls, and the work of the auditor should reflect that fact.
Internal control auditing, like financial statement auditing, is
not a “one-size-fits-all” exercise. Board members have stated
publicly that we will also use our inspection program to make sure
that smaller companies are not subjected to needless cost and
burdens.
Section 404, like any other regulatory requirement, should be
able to stand the scrutiny of cost-benefit analysis. However,
several things should be borne in mind