The Auditor’s Approach

The IPSA Audit is different from what many filers have experienced.  It’s also different from what auditors have done before.  Filers have questions about the IPSA Auditor’s approach. 


What will be the auditor’s approach to the audit? 

This will vary from auditor to auditor – and it’s a very good question.  At, our approach is to work with our clients and obtain an excellent audit outcome.   If you’ve worked with auditors before, you’ve probably encountered some who won’t quit until they find a “gotcha.”  That’s not us.   We stick to the objectives in the DFCM rule.  We believe in the value of audit planning – by the time we begin our field procedures, there should be no surprises for your team.  


The audit must be done according to “the Yellow Book.”  What’s that?  Can anybody use it? 

In the IPSA final rule, SEC specified that the IPSA Audit must be conducted to the performance standard (not an attest standard) as outlined in the Generally Accepted Government Auditing Standards (GAGAS), commonly known as the “Yellow Book”.   The Yellow Book is designed for government auditors (government entities at all levels), but anybody can use it. 


How much of this is left up to the IPSA auditor? 

Much of this is left up to the IPSA Auditor.  For example, the auditor must select samples to evaluate.  The auditor has some discretion as to how s/he selects samples.  One of the audit objectives includes the phrase “in all material aspects.”  Materiality is also a matter of some professional judgment.  These are just a couple reasons why filers should have meaningful discussions with prospective IPSA Auditors, and select them with care. 


Will the IPSA auditors go to the Congo?

Although most audits involve field visits, we do not expect the IPSA Audits to involve site visits to the Congo or to Covered Countries. 

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