The PCAOB recently published Staff guidance that sets out the Staff’s views relating to implementing the critical audit matters (CAMs) requirement. In its piece, “Implementation of Critical Audit Matters: the Basics,” the Staff notes that for large accelerated filers the CAMs requirement will become effective for audits of fiscal years ending on or after June 30, 2019. The requirements will apply to all other companies for audits for fiscal years ending on or after December 15, 2020. CAMs are not required for audits of EGCs or audits of investment companies other than BDCs. A CAM is required to relate to the accounts or disclosures that are material to the financial statements. The standard provides a list of non-exclusive factors to be taken into account by auditors in assessing CAMs. Each CAM must be identified, the auditors must explain why the matter involves a complex judgment, and must describe how the CAM was addressed. Auditors also must document their communications with the auditors and the considerations that led the auditors to conclude a matter was a CAM. In the Staff’s related paper, “Implementation of Critical Audit Matters: A Deeper Dive on the Determination of CAMs,” the Staff focuses on factors that may be taken into account in determining whether a matter is a CAM, and provides various questions and answers that may be helpful to audit committees. In the last paper, “Implementation of Critical Audit Matters: Staff Observations from Review of Audit Methodologies,” the Staff assesses materials submitted by ten audit firms relating to their methodologies for CAMs compliance and offers some observations for audit firms.
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