9.24 In this scenario, the broker-dealer initiates trades under a discre tionary arrangement with Lane and also executes the trades and holds and services securities purchased.
The Understanding of Controls the Auditor Needs
to Plan the Audit
9.25 In order to plan the audit, the auditor obtains the following under
standing of controls.
• The broker-dealer initiates trades within parameters set by Lane
and also executes the trades.
• The broker-dealer sends a confirmation of each trade to Lane,
which Lane usually receives within three business days.
• Lane records the trade in general ledger accounts when it receives
the trade confirmation.4
• Monthly, the broker-dealer sends Lane a statement that shows
trades, servicing transactions, a description of the securities held, and the fair value o f each o f those securities.
• Monthly, Lane compares the information about trades and the
components o f its securities portfolio that is shown in its account ing records with the broker-dealer's monthly statement and inves tigates significant differences.
• Monthly, Lane records servicing transactions and changes in unre
alized holding gains and losses based on information in the broker- dealer's monthly statement. Lane compares the broker-dealer in formation with its expectations based on published information and investigates significant differences.
9.26 Following the guidance in paragraphs 12 and 13 o f AU section 332,a
the auditor concludes that—
• Initiating trades, servicing securities, and providing fair value in
formation are broker-dealer services that are part o f Lane's infor mation system.
• The broker-dealer's execution o f trades and holding o f securities
are not part o f Lane's information system.
9.27 With respect to whether obtaining an understanding o f the broker-
dealer's controls is necessary to plan the audit, the auditor concludes that— • Since the broker-dealer initiates and executes trades, all of the
information about trades that is available to Lane comes from the broker-dealer. Accordingly, the broker-dealer's controls over initi ation o f trades are significant to Lane's controls, and information
4 In this scenario, recording trades when Lane receives the broker-dealer's monthly statements may also be an effective control for Lane. In addition, since the broker-dealer initiates and executes trades, no adjustment is necessary for trades that have been initiated but not executed.
a See footnote a in paragraph 9.19.
about the manner in which trades are initiated is needed to plan the audit. The auditor decides that an effective broker-dealer con trol over initiation o f trades would be—
— Establishing independent departments that provide the investment advisory services and the holding and servic ing of securities.
— Reconciling the information about the securities that is provided by each department.
Based on available information, the auditor believes the broker-dealer has such controls.5
• The broker-dealer's controls over servicing securities and provid
ing fair value information are not significant to Lane's controls because Lane—
— Compares broker-dealer information about servicing and fair values with its expectations based on published in formation.
— Investigates significant differences.
Accordingly, obtaining an understanding o f the broker- dealer's controls over those services is not necessary to plan the audit.
• Since the broker-dealer's execution o f trades and holding of se
curities are not part o f Lane's information system, obtaining an understanding o f the broker-dealer's controls over those securities is not necessary.
The Auditor's Assessment of Control Risk
9.28 As discussed in paragraph 20 of AU section 332b, in this arrangement,
where the broker-dealer both initiates and executes trades, the broker-dealer provides all of the information about trades that is available to the auditor. In addition, the broker-dealer's initiation and execution services are largely pro vided electronically. Accordingly, the auditor concludes that audit risk cannot be limited sufficiently without obtaining evidential matter about the operating effectiveness of the broker-dealer's controls of—6
• Establishing independent departments that provide the invest
ment advisory services and the holding and servicing o f securities.
• Reconciling the information about the securities that is provided
by each department.
9.29 If the evidential matter about the operating effectiveness of these controls supports an assessment o f control risk below the maximum, the auditor may also be able to reduce the number of trades tested. The resulting audit efficiencies will become more noticeable as the number o f trades increases.
5 To help plan the audit, the auditor may gather information about broker-dealer controls over existence and completeness assertions from a variety o f sources. Examples are a SAS No. 70 report, manuals provided by the broker-dealer, and inquiries o f broker-dealer personnel.
b Paragraph 20 o f AU section 332 can be found in AICPA Professional Standards and PCAOB Standards and Related Rules.
6 As a practical matter, Lane's management should view information about the operating effec tiveness o f the broker-dealer's controls as an important part o f its risk management considerations.
The Auditor's Design of Procedures
9.30 The auditor gathers evidential matter that the broker-dealer has
implemented the controls described in paragraph 9.28 and that those controls are operating effectively.7 The auditor then identifies the objectives for the audit of assertions about securities and securities transactions and designs related procedures.8
Audit Objective Procedure
The recorded securities exist and Lane has the rights and obligations associated with ownership o f the recorded securities.
The recorded securities transactions occurred.
All of the securities that Lane owns and all of its securities transactions have been recorded.
The securities are recorded at their fair value determined following the requirements of FASB Statement No. 115.
Realized and unrealized holding gains and losses are properly reported as earnings or other comprehensive income.
The securities are properly classified.
Disclosures about securities and securities transactions are adequate.
Confirm with the broker-dealer the name of the investee, the number of shares, whether the shares are pledged, and that Lane is the owner.
Inspect supporting documentation such as trade confirmations or entries in the broker-dealer's monthly statements. Perform analytical procedures on dividends and realized and unrealized gains and losses.
Obtain the per-share price quoted by the exchange at the balance sheet date and compare the quoted price with the price Lane used.
Test the extension o f the number of shares at the quoted price.
Evaluate management's considerations in ensuring that the requirements o f FASB Statement No. 115 were satisfied.
Review journal entries for propriety. Gather evidential matter about the classification of the securities as available-for-sale.
Read the financial statements and compare the disclosures about securities and securities transactions with the requirements o f FASB Statement No. 115.
7 The evidential matter can be obtained a variety o f ways, such as a type 2 SAS No. 70 report or special procedures performed by the broker-dealer's internal or external auditors.
8 In scenarios A and B, the auditor concludes that audit risk can be reduced to an acceptable level without identifying controls placed in operation and gathering evidential matter about their operating effectiveness. In this scenario, however, the auditor concludes that identifying broker-dealer controls over the existence and completeness assertions and gathering evidential matter about their operating effectiveness is necessary to reduce audit risk to an acceptable level. The only difference in the nature o f substantive procedures is that in this scenario, analytical procedures are the only procedures performed to determine whether all o f the securities Lane owns and all o f its securities transactions have been recorded. However, in Scenarios A and B, reconciliation procedures are also performed.