AUD · Ethics and Professional Responsibilities and General Principles · 11 practice questions
AICPA Independence: Nonattest Services for Audit Clients
For nonissuer audit clients, the CPA may prepare accounting work, but management must make decisions and provide qualified oversight. Below, compare a depreciation entry with versions that change who decides, who approves, or who oversees.
Try one first
Hint
Focus on whether any requested service would require the auditor to make accounting-policy or estimate decisions that management must retain.
Answer B. For a nonissuer, auditors may provide nonattest services if management assumes responsibility, designates an individual to oversee the work, evaluates the results, and accepts responsibility for the financial statements. Auditors must not assume management responsibilities such as selecting accounting policies or making accounting estimates. Here, requesting the firm to choose the depreciation method and useful lives would require the auditor to make management decisions, so independence is impaired.
Why not A: This is tempting because a designee need not personally perform the technical tasks; however, management must retain responsibility for accounting-policy and estimate decisions and must be willing and able to oversee and accept the results. In this scenario the designee is not willing to make those decisions, so delegating them to the auditor would impair independence.
Why not C: Drafting statements and posting client-approved entries can be permissible if management retains responsibility and performs appropriate oversight, but that permissibility does not extend to the auditor making accounting-policy or estimate decisions. The additional request that the firm select depreciation method and useful lives would cross into management responsibilities and impair independence.
Why not D: The issue is not the title of the designee; independence is affected when the auditor is asked to perform management functions. A suitable designee need not be the CFO or controller, provided management is prepared to make and accept responsibility for the decisions in question.
Same scenario, one fact changes
Base case
Ridge, a nonissuer, has its auditor prepare a depreciation schedule and proposed entry for a new machine. Ridge's designated controller has suitable skill, knowledge, and experience, chooses the depreciation method and useful life, oversees and evaluates the work, approves the entry, and accepts responsibility. The required understanding is documented; other independence threats are at an acceptable level.
Answer: No impairment. The auditor may prepare the schedule and proposed entry under these facts.
The auditor prepares information without taking over management's decisions. Ridge's qualified controller chooses the method and useful life, evaluates the work, approves the entry, and accepts responsibility.
Before you open each one, predict the answer.
Change 1Ridge designates its equally qualified CFO instead of its controller to perform all stated management duties.
Answer: No impairment. The qualified CFO may oversee the service and perform the stated management duties.
The title change does not matter. Suitable qualifications and retained management duties matter, not whether the designee is the controller or CFO.
Change 2The auditor, rather than Ridge's controller, selects the depreciation method and useful life.
Answer: Independence is impaired. The auditor makes management's accounting decisions.
Selecting the method and useful life assumes management responsibilities. The controller's oversight and later approval do not cure that role.
Change 3The controller lacks the qualifications needed to evaluate the work; no other qualified individual is designated.
Answer: Independence is impaired. Ridge lacks qualified oversight of the nonattest service.
Accepting responsibility and approving the entry are insufficient when no designated individual can meaningfully oversee and evaluate the work.
Change 4The auditor, rather than Ridge's controller, approves the depreciation entry for posting.
Answer: Independence is impaired. The auditor authorizes an accounting entry on Ridge's behalf.
Drafting an entry is assistance. Approving it for posting is a management responsibility that qualified client oversight cannot make permissible.
Key points
- Remember: Preparing or recommending is assistance; choosing or authorizing is management's job.
- Job title does not determine qualification; the designee must be able to oversee and evaluate the work.
- Document the service understanding, management's responsibilities, and the designated individual's suitability.
- Evaluate independence threats before accepting the service; oversight cannot make a management function permissible.
How the exam traps you
- Treating management's later sign-off as a cure for the CPA's decision. Management must make the decision; later review does not undo the CPA's management role.
- Assuming all proposed entries impair independence. Preparing an entry can be allowed; approving it for posting is management's responsibility.
- Treating a signed responsibility letter as a substitute for qualified oversight. Management must designate someone able to evaluate the service and its results.
Now the same facts as questions
Each question changes one fact from the one before. Watch which change flips the answer.
Question 1
Answer A. Correct. Management provides qualified oversight and retains decisions, approval, and responsibility.
Why not B: Incorrect. Preparing a schedule can be permissible when the nonattest service requirements are met.
Why not C: Incorrect. Documentation cannot authorize the auditor to assume management responsibilities.
Why not D: Incorrect. The auditor may propose entries for management to evaluate and approve.
Question 2
Answer B. Correct. Only the designee's identity changes; qualified management still performs every required duty.
Why not A: Incorrect. The rules require suitable qualifications, not a controller title.
Why not C: Incorrect. Replacing one qualified designee with another does not itself impair independence.
Why not D: Incorrect. No management title permits the auditor to approve entries on the client's behalf.
Question 3
Answer C. Correct. The auditor may recommend alternatives but cannot make these decisions for Ridge.
Why not A: Incorrect. Choosing accounting policies and estimates is management's responsibility, even when technical expertise is involved.
Why not B: Incorrect. Later approval does not undo the auditor's assumption of management responsibilities.
Why not D: Incorrect. Discussing and recommending alternatives is permitted when management makes the decision.
Question 4
Answer D. Correct. Ridge must designate someone capable of overseeing and evaluating the service and its results.
Why not A: Incorrect. Acceptance of responsibility does not replace suitable skill, knowledge, and experience.
Why not B: Incorrect. The auditor's expertise cannot substitute for qualified oversight on the client's behalf.
Why not C: Incorrect. A documented understanding cannot cure the absence of qualified oversight.
Question 5
Answer A. Correct. Authorizing an entry on the client's behalf places the auditor in a management role.
Why not B: Incorrect. Qualified oversight does not permit the auditor to assume management responsibilities.
Why not C: Incorrect. Drafting the entry can be permissible; approving it causes the impairment.
Why not D: Incorrect. Immateriality does not make assuming this management responsibility permissible.
Question 2
Hint
Don't stop at management responsibility or technical competence, consider how attending meetings would be perceived by a reasonable, informed outsider.
Answer B. Under the AICPA Code's nature-and-scope evaluation, legality, technical competence, and management acceptance of responsibility for a nonattest service are necessary but not sufficient; the firm must also assess whether the engagement creates independence or objectivity threats, including appearances of advocacy. Attending lender meetings could reasonably be perceived as promoting the client's position, so Lane must evaluate those threats and decline or modify the engagement if safeguards cannot reduce them to an acceptable level.
Why not A: This choice is tempting because management acceptance of responsibility and the firm not making management decisions are required conditions for nonattest services. It is wrong because those conditions alone do not address whether a public-facing role (attending lender meetings) creates appearance or advocacy threats that impair independence or objectivity.
Why not C: This is tempting if a candidate thinks only services that directly affect the audited statements threaten independence. It fails because independence and objectivity also depend on how third parties perceive the firm's role; preparing projections and participating in lender meetings can create advocacy or perception threats even if the work is outside the audit.
Why not D: This overstates the rules and is tempting for those who recall limits on prospective financial information. It is incorrect because preparing prospective information for an attest client is not categorically prohibited when management accepts responsibility and safeguards exist; the central issue here is the additional appearance/advocacy threat from attending lender meetings.
Question 3
Hint
Consider the AICPA client preconditions for nonattest services, does management both accept responsibility and provide a qualified individual with sufficient skill, knowledge, and experience to oversee judgmental accounting work?
Answer B. Under the AICPA preconditions for providing nonattest services to an attest client, management must accept responsibility for the financial statements and must designate an individual with suitable skill, knowledge, and experience (SKE) to oversee and evaluate the services and results. Here, Bright's owner-manager lacks the necessary understanding of GAAP disclosures and the expected-credit-loss methodology and no qualified designee is present to evaluate Clay's judgment; therefore the SKE precondition is not met and independence is impaired.
Why not A: Tempting because management approval is a required element, but approval alone is insufficient when management cannot meaningfully oversee and evaluate the CPA's work. If management has not provided a qualified designee with the needed SKE to evaluate judgmental matters, independence is impaired despite final approval.
Why not C: Tempting because a written acceptance of responsibility is a necessary precondition, but such an acknowledgment does not replace the requirement that management designate an individual with sufficient skill, knowledge, and experience to oversee and evaluate the CPA's judgmental work. An engagement letter cannot cure the absence of a qualified client designee.
Why not D: This lures candidates who focus on posting entries as the decisive act. Actual posting can create an independence problem, but an impairment can arise earlier when management fails to provide a qualified designee to evaluate the CPA's judgment, even if the CPA only prepares proposed entries and does not record them.
Question 4
Hint
Do not stop after identifying one safeguard. Ask what broader judgment the Code requires a CPA firm to make about the kind of service it is willing to provide to an audit client.
Answer A. The AICPA Code's nature-and-scope principle requires a member in public practice to decide whether a proposed service is consistent with professional principles such as integrity, objectivity, and the public interest. Management oversight, acceptance of responsibility, and a fixed fee are relevant safeguards but do not automatically make the service acceptable. Because Loft would later audit amounts affected by the metric, it must evaluate whether providing the consulting service is compatible with its role as auditor.
Why not B: Tempting because management responsibility is an important safeguard, but the Code requires a broader judgment about compatibility with professional principles; those safeguards alone do not end the analysis.
Why not C: Using separate staff can reduce some threats, but it does not eliminate the need to assess whether providing the service at all is consistent with the firm's responsibilities as the auditor.
Why not D: This is too narrow: a service may impair objectivity or create a self-review threat even if it does not mechanically set a recorded amount, so the firm must judge broader compatibility issues.
Question 5
Hint
Separate helping management prepare information from making management's decisions about that information.
Answer D. Under AICPA independence rules for a nonissuer attest client, a firm may draft proposed journal entries as a nonattest service if management has suitable skill, knowledge, and experience, accepts responsibility, and properly oversees the work. However, authorizing or approving entries for posting is a management responsibility; if the firm assumes that role independence is impaired.
Why not A: This choice overstates the rule. Drafting proposed entries can be permissible when management (with suitable SK&E) accepts responsibility and oversees the work. The prohibition applies when the firm performs management functions, such as authorizing entries for posting.
Why not B: Management oversight is necessary for permissibility, but this answer ignores that the firm is being asked to authorize entries for posting without client approval, an actual management function that would impair independence.
Why not C: Materiality is not the decisive factor here. The independence issue hinges on whether the firm performs a management function (authorizing/posting entries), which impairs independence regardless of dollar amount.
Question 6
Hint
Distinguish services that assist or prepare from services that implement or operate the client's systems; AICPA guidance treats implementing internal control as a management function.
Answer A. Under AICPA nonissuer independence rules, many nonattest services (for example, drafting financial statements, preparing proposed journal entries, or performing analyses using management-selected assumptions) may be provided if management designates a competent individual, evaluates the results, and accepts responsibility. However, performing management functions, specifically implementing or operating internal control, places the firm in a management role and impairs independence. In this fact pattern, configuring the client's revenue-cycle control settings is the management-function issue that impairs independence.
Why not B: This is tempting because the AICPA framework does permit many nonattest services when management assumes responsibility and oversight. However, those safeguards do not allow the firm to perform management functions; configuring control settings is an implementation activity that places the firm in a management role and impairs independence.
Why not C: This distractor appeals to candidates who conflate nonissuer rules with stricter issuer/SEC prohibitions. For nonissuer audit clients under current AICPA guidance, drafting financial statements and proposing entries can be permissible if management retains responsibility and oversight, so these services alone are not the basis for impairment here.
Why not D: Valuation-related work can create self-review threats, but when management selects the assumptions and a competent client official oversees and accepts responsibility, such threats can often be mitigated. The clearly dispositive independence problem in this scenario is the firm's potential implementation of internal control by configuring system settings.
Common questions
Can an auditor prepare journal entries for an audit client?
Yes, under AICPA nonissuer rules, if the nonattest service requirements are met. Management must oversee and evaluate the work, approve the entries, and accept responsibility; the auditor cannot authorize entries on management's behalf.
Can an auditor recommend a depreciation method?
Yes. The auditor may explain alternatives and recommend a method, but management must evaluate the alternatives, choose the method, and accept responsibility.
Does the person overseeing nonattest services have to be a CPA or controller?
No particular title or credential is required. The designee needs suitable skill, knowledge, and experience to oversee and evaluate the work, but need not personally perform or reperform it.
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