404(a) · United States
If auditor attestation goes away, management’s ICFR responsibility doesn’t.
The position
What changes, and what doesn’t
What changes
The required 404(b) auditor attestation may fall away for many filers. This is a proposal, not final.
What doesn’t
Management’s assessment of ICFR under Section 404(a).
The practical problem
Programmes built around the auditor’s requirements need management’s own methodology.
The sequence
What usually has to happen next
- Scoping
- Risk assessment
- Key control selection
- Testing approach
- Deficiency evaluation
- Remediation
- Annual effectiveness conclusion
- Evidence retention
- Audit committee reporting
Deliverables
What Ditton delivers
- Risk and Control Matrix extractThe backbone of the programme: each risk mapped to its assertions, the key control that addresses it, and the attributes needed to test it.
- Control design assessmentProduced after a walkthrough, to determine whether the control as designed addresses the stated risk and could prevent or detect a material misstatement.
- Testing workpaperRecords the population, sample, attributes tested, evidence examined and conclusion on a control’s operating effectiveness.
- Deficiency evaluation memoDocuments the severity assessment of a control exception, including aggregation and compensating controls, and the basis for classification.
- Programme status reportGives management a single view of programme progress, testing status, open deficiencies and risks to the timetable.
- Audit committee reporting extractSummarises ICFR status and deficiencies in the form an audit committee needs to exercise oversight.
Where to start
One fixed-fee review
Fixed-fee entry point
404(a) Management Assessment Readiness Review
A review of whether the current programme gives management its own basis for the 404(a) conclusion, with written findings and a defined scope for anything larger.
Fixed fee — confirmed at scopingContact
Discuss your situation
Tell us what’s happened or what’s coming. We’ll reply with whether and how we can help.