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AICPA issues Technical Questions and Answers (TQA's) on use of inappropriate accounting standards


AICPA Technical Questions and Answers

TQA Section 9160.31–.35 discusses:
  • Whether an entity is a state or local government for purposes of determining whether it is using the appropriate set of accounting standards.
  • How to report on the entity’s financial statements when the entity elects to follow either a different set of standards or a special-purpose framework.
Section 9160, Other Reporting Issues are as follows
.35 Reporting on Indian Tribe Financial Statements Prepared in Accordance With Accounting Standards as Promulgated by FASB

Inquiry—an Indian tribe (or a component thereof, such as a business component functioning like a commercial entity) that meets the GAAP definition of a state or local government prepares its financial statements in accordance with accounting standards as promulgated by FASB. In such situations, may an auditor report on whether the entity’s financial statements are presented, in all material respects, in accordance with both the appropriate GAAP framework (that is, accounting standards as promulgated by GASB) and accounting standards as promulgated by FASB? Reply—Generally accepted auditing standards do not prohibit an auditor from issuing a report containing two opinions—one opinion on whether the financial statements are presented fairly, in all material respects, in accordance with the appropriate GAAP, and a second opinion on whether the financial statements are presented fairly, in all material respects, in accordance with the accounting standards as promulgated by FASB. An illustrative report that an auditor may issue on a tribe’s financial statements when the entity has prepared its financial statements in accordance with accounting standards as promulgated by FASB follows:

Reply—Generally accepted auditing standards do not prohibit an auditor from issuing a report containing two opinions—one opinion on whether the financial statements are presented fairly, in all material respects, in accordance with the appropriate GAAP, and a second opinion on whether the financial statements are presented fairly, in all material respects, in accordance with the accounting standards as promulgated by FASB. An illustrative report that an auditor may issue on a tribe’s financial statements when the entity has prepared its financial statements in accordance with accounting standards as promulgated by FASB follows:

Report on the Financial Statements
We have audited the accompanying financial statements of XYZ Entity, which comprise the balance sheet as of December 31, 20X1, and the related statements of income, changes in stockholders’ equity, and cash flows for the year then ended, and the related notes to the financial statements.
 Management’s Responsibility for the Financial Statements
Management is responsible for the preparation and fair presentation of these financial statements in accordance with accounting principles generally accepted in the United States of America; this includes the design, implementation, and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error.

Auditor’s Responsibility
 Our responsibility is to express an opinion on these financial statements based on our audit. We conducted our audit in accordance with auditing standards generally accepted in the United States of America. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free from material misstatement. An audit involves performing procedures to obtain audit evidence about the amounts and disclosures in the financial statements. The procedures selected depend on the auditor’s judgment, including the assessment of the risks of material misstatement of the financial statements, whether due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to the entity’s preparation and fair presentation of the financial statements in order to design audit procedures that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the entity’s internal control. Accordingly, we express no such opinion. An audit also includes evaluating the appropriateness of accounting policies used and the reasonableness of significant accounting estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that the audit evidence we have obtained is sufficient and appropriate to provide a basis for our audit opinions.

Basis for Adverse Opinion on U.S. Generally Accepted Accounting Principles for Governmental Entities
 As described in Note X of the financial statements, XYZ Entity is a governmental entity as defined by the Governmental Accounting Standards Board (GASB). Accordingly, the standards as promulgated by GASB are the appropriate accounting standards for XYZ Entity to follow. However, XYZ Entity has prepared its financial statements in accordance with accounting standards as promulgated by the Financial Accounting Standards Board (FASB) even though the entity meets the “governmental” criteria. The effects on the financial statements of the variances between the accounting policies described in Note X and generally accepted accounting principles for governmental entities, although not reasonably determinable, are presumed to be material.

Adverse Opinion on U.S. Generally Accepted Accounting Principles for Governmental Entities
In our opinion, because of the significance of the matter discussed in the "Basis for Adverse Opinion on U.S. Generally Accepted Accounting Principles for Governmental Entities,” the financial statements referred to above do not present fairly, in accordance with accounting principles generally accepted in the United States of America for governmental entities, the financial position of XYZ Entity as of December 31, 20X1, or changes in financial position or cash flows thereof for the year then ended

Opinion on Accounting Standards as Promulgated by the Financial Accounting Standards Board
In our opinion, the financial statements referred to above present fairly, in all material respects, the financial position of XYZ Entity as of December 31, 20X1, and the results of its operations and its aicpa.org/FRC cash flows for the year then ended in accordance with accounting standards as promulgated by FASB.
 [Auditor’s signature]

 [Auditor’s city and state]

 [Date of the auditor’s report]

[Issue Date: July 2017.]

Visit aicpa.org/FRC for more details

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