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Why the PCAOB and External Auditors Should be Concerned about Substantive Only Audits
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In evaluating how to approach an audit, in general, and specific business processes within any audit, in particular, external
auditors sometimes choose to audit around the system. That is, they ignore the way systems are designed and test the given
process or control without regards to how the system is designed. They do so by identifying a population of transactions related
to the process and testing the activity through sampling as required by their internal standards and consistent with the
regulator(s) that oversee their audits (PCAOB, OCC, various government agencies, etc).

There are consistent gaps in the approach that external audit firms take that could leave the chosen populations incomplete.
Therefore, I will make the argument that a substantive-only audit is a flawed approach and one about which external audit
partners and regulators should be concerned.

To illustrate this flaw, I will use arguably the most important control related to the integrity of the financial statements; the control
over manual (non-standard) journal entries. Manual journal entries inherently pose a high risk to the integrity of the financial
statements because they can move any balance between any account within the trial balance. In my experience, most external
auditors don't know how to properly identify a population of journal entries that equate to a manual journal entry.

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