What will the IPSA Audit report look like?
The DFCM final rule does not specify the format, or level of detail for the content of a IPSA Audit Report. So, it’s up to the auditor and the client to decide. There are many types of audit reports, each with different framework, level of detail, and look and feel. When DFCMAudit.com begins work with a client, we discuss this with our clients in kick-off and audit planning sessions.
Will we get a draft report first?
It is common practice for auditors to provide some content in draft form before issuing a final report. The DFCM rule does not specify this; make sure you discuss this with your IPSA Auditor.
Where does the IPSA Audit report go?
The IPSA Audit report is included with the filer’s Conflict Minerals Report. This is submitted as part of the Form SD (Special Disclosure).
When do we get the IPSA Audit report?
This is between the filer and the IPSA Auditor. Allow plenty of time to understand gaps (and correct them, if possible), incorporate IPSA Audit findings into related documents, and to route all applicable DFCM reporting information for internal review and signatures. At DFCMAudit.com, we suggest that filers plan on getting their IPSA Audit report no later than March 31, 2014. Earlier would be better.
When is the IPSA Audit Report due?
The IPSA Audit Report itself does not have a due date. Filers must submit their Form SD by May 31, 2013. The Form SD will include the Conflict Minerals Report, and (if applicable) the independent audit of the due diligence efforts. As a financial filing, these reports will require signatures by executives at the company. As a filing being submitted for the first time, the people signing off on their respective reviews are likely to have questions.
Can we hire the IPSA Auditor to help us close gaps they identified in the audit?
You may. However, this could preclude you from using the same auditor (or their firm) for the IPSA Audit the following year. If the IPSA Auditor provides a range of advisory services, they may offer some services (such as training) that would be helpful, but do not create independence concerns. Discuss this with your IPSA Auditor on a case-by-case basis. The company’s policies on this matter as applied to financial auditors and internal audit service providers would be useful resources.