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AUD · Performing Further Procedures and Obtaining Evidence · 9 practice questions

Management refuses to sign representation letter (AU-C 580)

If management refuses to provide required written representations, it is a scope limitation that ordinarily results in a disclaimer or withdrawal. Below: one scenario in judgment format with competing responses to choose from.

The ruleWritten representations under AU-C 580 are required audit evidence. If management refuses to provide them, the auditor treats it as a scope limitation, discusses the matter with management and those charged with governance, reassesses management’s integrity and the reliability of other evidence, and ordinarily disclaims an opinion or withdraws when permitted.

Try one first

In an audit of a nonissuer's financial statements under U.S. GAAS, the auditor has completed planned audit procedures and obtained substantial other audit evidence. Before the auditor's report is dated, the CEO and CFO refuse to sign the written representation letter, and they do not point to any specific statement in the letter that is inaccurate. Assume withdrawal from the engagement is not practical. What is the auditor's best course of action?
Hint

Think about whether written representations are optional support or required audit evidence under GAAS.

What should you do?

The situation

You are auditing a nonissuer under AICPA standards. Fieldwork is complete and other procedures yielded persuasive evidence. At report date, the CEO and CFO refuse to sign the requested AU-C 580 representation letter. The refusal is not due to timing or wording. Law permits withdrawal.

  1. Treat the refusal as a scope limitation; discuss with management and those charged with governance; reassess management integrity and the reliability of other evidence; and ordinarily disclaim an opinion or withdraw if permitted.

    Best AU-C 580 requires written representations. Refusal prevents obtaining required evidence, raises integrity concerns, and ordinarily leads to a disclaimer or withdrawal after appropriate discussions.

  2. Withdraw from the engagement because management refused to provide required written representations, after informing those charged with governance.

    Acceptable Withdrawal is an appropriate outcome when permitted. However, the best response also explicitly includes discussing the matter, reassessing integrity, and recognizing the alternative of a disclaimer.

  3. Issue a qualified opinion because the missing representation letter limits only one procedure.

    Wrong Refusal to provide required written representations is a severe scope limitation that ordinarily requires a disclaimer or withdrawal, not a qualification.

  4. Issue an unmodified opinion because other corroborating evidence was obtained and oral assurances were given.

    Wrong Written representations are required audit evidence. Other evidence and oral statements cannot replace the signed letter.

  5. Accept oral statements in place of the letter and proceed.

    Wrong Oral statements do not satisfy AU-C 580’s requirement for written representations.

  6. Have those charged with governance or only the CFO sign instead of management and issue the report.

    Wrong Required written representations must come from appropriate management with overall responsibility; signatures from others do not cure the refusal.

Key points

  • Written representations are required audit evidence; oral statements or other documents do not substitute.
  • Appropriate signers are those with overall responsibility for the financial statements (typically CEO and CFO).
  • Refusal indicates a scope limitation and raises questions about management integrity and the reliability of other evidence.
  • When withdrawal is permitted, consider withdrawal; if not, disclaim an opinion.
  • Do not resolve the refusal by obtaining signatures from those charged with governance in place of management.
  • Document the refusal, discussions with management and those charged with governance, and the effect on the report.

How the exam traps you

  • Issuing a qualified opinion for a refusal to provide required written representations. Treat it as a severe scope limitation that ordinarily requires a disclaimer of opinion or withdrawal.
  • Accepting oral assurances or other audit evidence instead of the signed letter. Do not substitute; written representations are required by AU-C 580.
  • Proceeding with an unmodified opinion because other evidence seems sufficient. Lack of required written representations precludes an unmodified opinion.
  • Having only the CFO or those charged with governance sign in place of management. Obtain required written representations from appropriate management; other parties cannot replace them.

8 more, each from a different angle

0 of 8 answered · 0 correct

Question 2

An auditor is engaged to audit 20X6 financial statements and report comparatively on 20X6 and 20X5. None of the current CEO, CFO, or controller served during 20X5. Current management accepts responsibility for the comparative financial statements and is willing to sign a written representation letter covering both years after reviewing 20X5 records and discussing significant matters with predecessor management. The former CFO, who served throughout 20X5, refuses to provide a separate written representation. Assume there are no other known integrity concerns. In evaluating the effect of the former CFO's refusal, which factor should govern the auditor's conclusion?
Hint

Distinguish who has ultimate responsibility for the financial statements from whether the auditor can obtain sufficient appropriate evidence about a prior period.

Question 3

During the Year 1 audit of Solis Corp., the auditor requests the standard year-end written representations. Solis's CEO is willing to sign. The CFO, who had overall responsibility for Solis's financial reporting throughout Year 1 and remains employed on the auditor's report date, refuses to sign because the auditor has already obtained supporting evidence for the account balances. Solis's controller prepared many of the schedules used in the audit but does not have authority equivalent to the CFO. Assume the requested representations are appropriate and otherwise standard. What is the auditor's most appropriate response?
Hint

Focus on two things: who must provide the representation letter, and whether other audit evidence can replace a required written representation.

Question 4

An auditor is completing an audit of a nonissuer's Year 2 financial statements. Management has provided access to records, responded to inquiries, and given oral assurances throughout the audit. However, at the end of fieldwork, management refuses to sign the written representation letter. Assume the refusal is not due to wording issues and management will not provide the requested written representations. Which action is most appropriate?
Hint

Focus on whether written representations are optional support or a required audit procedure, and then consider the reporting consequence if management refuses.

Question 5

In the audit of Pine Co., a nonissuer, Pine has no CFO. The president is responsible for overall management and approves the annual financial statements before issuance. The controller is Pine's highest-ranking finance employee. On the date of the auditor's report, the controller signs the written representation letter, but the president refuses, stating, "I delegate accounting matters to the controller, so I should not have to sign management representations." The auditor has obtained sufficient evidence from other audit procedures. Assume the auditor is legally permitted to withdraw from the engagement if necessary. Which action is most appropriate?
Hint

Focus on two issues: who is expected to sign written representations, and whether other audit evidence can replace a required written representation.

Question 6

In the final stage of an audit, management refuses to sign the written representation letter required by GAAS. The CEO says the auditor may rely on oral answers instead, and no law or regulation prevents the auditor from withdrawing. What is the auditor's required response if management continues to refuse?
Hint

Think about whether oral statements can replace a required written representation, and what type of opinion problem that creates.

Question 7

In a Year 2 audit conducted under U.S. GAAS, the auditor has completed all planned procedures and found no specific material misstatements. However, management refuses to provide the required written representation letter, stating that the accounting records should be sufficient on their own. Assuming withdrawal is legally permitted, which consequence is most appropriate for the auditor to consider?
Hint

Ask whether written representations are optional corroboration or required audit evidence under GAAS.

Question 8

During an audit of a nonissuer under AICPA auditing standards, the auditor obtained substantial corroborating evidence for significant account balances and disclosures from external and internal sources. At the end of the engagement, management refuses to sign the written representation letter that contains all representations requested by the auditor, saying the matters were discussed verbally and the financial statements should stand on their own. What is the most appropriate conclusion about the consequence of this refusal?
Hint

Decide whether this is an evidence limitation or proof of a misstatement; remember that written representations are required, not optional, even when other evidence is strong.

Question 9

In an audit performed under AICPA GAAS, the auditor has obtained substantial audit evidence from other procedures. The CFO is willing to sign the management representation letter, but the CEO refuses to sign because "the books and records already show everything." Assume the CEO and CFO are the members of management with appropriate responsibility for the financial statements. Which factor should most directly govern the auditor's evaluation of this refusal?
Hint

Focus on what makes written representations mandatory, not on whether other procedures covered similar ground.

Drill all 117 Written Representations questionsMixed across every rule in the topic, so you have to spot which one applies. That is how the exam does it.

Common questions

Are written management representations required, and who signs?

Yes. AU-C 580 requires written representations from appropriate management with overall responsibility for the financial statements, typically the CEO and CFO.

Can oral statements or other documentation replace the representation letter?

No. Oral assurances and other audit evidence do not substitute for the required signed written representations.

What report is appropriate if management refuses and withdrawal is not possible?

Disclaim an opinion. The refusal is a scope limitation that prevents obtaining required audit evidence.

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