Going Old School: The GAAP is Back (in PCAOB Inspection Reports)!
old school man screaming

Going Old School: The GAAP is Back (in PCAOB Inspection Reports)!

We are about to release the 5th edition of our eBook Learn from PCAOB Inspections – Your Prescription for Better Audits. The findings set out in our eBook are based on our review of the PCAOB Inspection reports for the annually inspected firms over the last ten inspection cycles, focusing on Part I.A deficiencies. We publish this eBook to help auditors:

  • Learn from PCAOB inspection findings,
  • Prevent recurring audit deficiencies,
  • Improve audit training, and
  • Strengthen the quality of their audits.

I’ll let you dive into the data later this week when it is published, but I wanted to give you sneak peek at some of the high-level findings. Our analysis of the 2021 inspection reports for annually inspected firms shows:

  • The combined audit deficiency rate is 26%, an increase of 6 percentage points from 2020.
  • The difference between the combined audit deficiency rate of the Big 4 firms (16%) as compared to other annually inspected firms (39%) has grown substantially over the past few years.
  • The lowest audit deficiency rate among the annually inspected firms was 4%. The highest was a whopping 76%!
  • Unfortunately, the types of audit deficiencies, including the related auditing standards and audit areas, remain unchanged.

So, what auditing standards are causing the deficiencies noted by PCAOB inspectors? Where are the auditors messing up? Well, for the most part, it’s the same old stuff:

  • Internal control over financial reporting (AS 2201)
  • Risk assessment (AS 2301)
  • Auditing estimates (AS 2501)

However, there was something new that was a bit unexpected! The most frequently identified Part I.A deficiency related to audits of financial statements was:

Did not sufficiently evaluate the appropriateness of the issuer’s accounting method or disclosure for one or more transactions or accounts

In layman’s terms, it means the engagement team did not properly evaluate the application of generally accepted accounting principles (U.S. GAAP).

This made me very happy, shouting, “The GAAP is back, baby!” Not because I delight in others’ misfortunes, but rather because it validates the entire purpose of our company. GAAP Dynamics was founded on the premise that we believe that you cannot audit what you don’t understand. This means that to be an effective auditor, you must understand the underlying financial reporting framework that the company is using to prepare their financial statements, either U.S. GAAP or IFRS.

So, what are the GAAP areas auditors are messing up?

old school

If you are looking to improve audit quality and reduce inspection findings, focus your efforts on the test work surrounding revenue and related accounts. Why? It is by far the number one area for both ICFR and financial statement deficiencies, accounting for one-third of all deficiencies in both categories!

Percentages of total ICFR deficiencies by audit area based on the number of comment forms (% of deficiencies in 2021 inspections):

  1. Revenue and related accounts (33%)
  2. Expected credit losses (15%)
  3. Inventory (13%)
  4. Business combinations (1%)
  5. Investment securities (5%)
  6. Long-lived assets (5%)
  7. Information technology (5%)
  8. Goodwill and intangible assets (5%)
  9. Other (18%)

Percentages of total financial statement deficiencies by audit area, excluding ICFR, based on the number of comment forms (% of deficiencies in 2021 inspections):

  1. Revenue and related accounts (35%)
  2. Inventory (9%)
  3. Expected credit losses (9%)
  4. Equity and equity-related accounts (8%)
  5. Business combinations (8%)
  6. Long-lived assets (6%)
  7. Goodwill and intangible assets (4%)
  8. Cash and cash equivalents (3%)
  9. Investment securities (2%)
  10. Accruals and other liabilities (2%)
  11. Leases (1%)
  12. Other (13%)

Here are some of the actual findings noted by the PCAOB in their inspection reports related to revenue and related accounts:

Identifying the contract with the customer (Step 1)

The firm did not perform sufficient substantive procedures to evaluate whether one type of revenue was appropriately recognized because the firm did not review certain customer contracts, which was necessary in order to identify performance obligations and evaluate whether this revenue was appropriately recognized. (AS 2301.08)

Identifying performance obligations (Step 2)

The issuer recorded certain revenue at the time services were provided to its customers. The firm did not perform any substantive procedures to test whether the performance obligations for these services had been satisfied when revenue was recognized. (AS 2301.08)

Determining the transaction price (Step 3)

The firm did not identify and test any controls that addressed whether the estimated transaction prices for certain types of contracts included in this disclosure were determined in conformity with FASB ASC Topic 606, Revenue from Contracts with Customers. (AS 2201.39) The firm did not identify, and evaluate the significance to the financial statements of, misstatements in this disclosure under FASB ASC Topic 606. (AS 2810.30 and .31)

Allocating the transaction price to performance obligations (Step 4)

The firm did not perform substantive procedures to evaluate the issuer’s determination and disclosure of whether it used observable prices to determine the standalone selling prices for these performance obligations in conformity with FASB ASC Topic 606, Revenue from Contracts with Customers. (AS 2810.30 and .31)

Evaluating whether the performance obligations were satisfied (Step 5)

For certain of the transactions selected for testing, which included multiple services provided to the customer, the firm did not evaluate whether multiple performance obligations existed in the associated contract that would affect whether this revenue was appropriately recognized. (AS 2301.08)

If you need help understanding the 5-step model within ASC 606 Revenue from Contracts with Customers, be sure to download our free step-by-step guide or check out our ASC 606 eLearning collection.

I’d be remiss if I didn’t mention the other area contributing to the deficiencies in the application of GAAP.

old school

If you follow our blogs, webinars, or podcast, you know that we’ve discussed the restatement issues associated with special purpose acquisition companies (SPACs), specifically the restatements associated with the classification of warrants and redeemable shares. Here are a few of the actual PCAOB findings in this area:

During the audit, the firm did not identify, and appropriately address, that the issuer’s accounting for warrants as equity was not in conformity with FASB ASC Topic 815, Derivatives and Hedging. (AS 2810.30)

During the audit, the firm did not identify, and appropriately address, that the issuer’s accounting for certain redeemable shares as permanent equity was not in conformity with FASB ASC Topic 480, Distinguishing Liabilities from Equity. (AS 2810.30)

In a nutshell, the warrants issued by the SPACs were originally classified as equity but should have been classified as liabilities. Also, certain redeemable shares should have been classified as temporary equity as opposed to permanent equity.

If you’d like further insights into recent PCAOB inspection reports, I’d encourage you to download our PCAOB eBook. It’s over 50 pages of awesomeness and it’s completely free!

About GAAP Dynamics  

We’re a DIFFERENT type of accounting training firm. We don’t think of training as a “tick the box” exercise, but rather an opportunity to empower your people to help them make the right decisions at the right time. Whether it’s U.S. GAAP training, IFRS training, or audit training, we’ve helped thousands of professionals since 2001. Our clients include some of the largest accounting firms and companies in the world. As lifelong learners, we believe training is important. As CPAs, we believe great training is vital to doing your job well and maintaining the public trust. We want to help you understand complex accounting matters and we believe you deserve the best training in the world, regardless of whether you work for a large, multinational company or a small, regional accounting firm. We passionately create high-quality training that we would want to take. This means it is accurate, relevant, engaging, visually appealing, and fun. That’s our brand promise. Want to learn more about how GAAP Dynamics can help you? Let’s talk!


This post is published to spread the love of GAAP and provided for informational purposes only. Although we are CPAs and have made every effort to ensure the factual accuracy of the post as of the date it was published, we are not responsible for your ultimate compliance with accounting or auditing standards and you agree not to hold us responsible for such. In addition, we take no responsibility for updating old posts, but may do so from time to time.

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