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International Standards on Auditing
with a focus on Cayman Funds
David Walker
Candice Czeremuszkin
Etienne Jensen-Fontaine
22 August 2018
Helping you grow PRECISE. PROVEN. PERFORMANCE.
1
DisclaimerStandards on Auditing
CIIPA and the presenters disclaim any responsibility or liability
resulting from the use and application of this presentation.
2
1. Audit Planning Considerations
2. Internal Controls & Risk Assessment
Considerations
3. Auditing Specific Accounting Cycles
4. Audit Completion, New & Revised Auditor
Reporting Standards
5. Auditing Crypto Funds
Agenda
3
1. Audit Planning Considerations
4
Audit Planning Considerations
Engagement
(Re-)
Acceptance
Requirements
& Deliverables
Audit Planning
&
Documentation
5
• Fraud/Non-Compliance Risk Assessments
• Accounting Cycles Risk Assessments
• Materiality
• Expected Modification of the Audit Opinion
6
Audit Planning Considerations
Audit Planning Considerations
• Prior year audit issues
• Changes in the Fund’s operations
• Estimated values and assumptions
• Errors and restatements
• Going concern assessment
• Communication with Those Charged with
Governance
7
Audit Planning Considerations
Laws & Regulations (ISA 250)
RiskResponse
ReportingRiskAssessment
• Is material non-compliance disclosed/reported if required?
• Report to Those Charged with Governance
• Obtain management representations
• Identify any non-compliance
• Discuss with management, if
appropriate
• Evaluate impact
• Legal & regulatory
framework for funds
• How entity is complying?
• Inquire about compliance
• Review regulatory
correspondence
8
Audit Planning Considerations
Laws & Regulations
• IAASB Handbook of International Quality Control…
• Companies Law
• Mutual Funds Law & Annual Returns Regulations
• Proceeds of Crime Law
• Anti-Money Laundering Regulations
• Confidential Information Disclosure Law
• www.cima.ky/investment-funds-regulatory-measures
• https://www.ciipa.ky/page-18225
9
Audit Planning Considerations
Related Parties
RiskResponse
ReportingRiskAssessment
• Has sufficient appropriate evidence been obtained?
• Does a material misstatement exist?
• Is financial statement disclosure adequate?
• Obtain management representations. Report on any findings
• Any indication of undisclosed related
parties?
• Obtain support for management’s
assertions about the nature, extent,
and purpose of transactions
• If consider significance, measurement
and recognition of transactions, as
well as any fraud risk
• Identify related parties, including and
any changes
• Understand nature, extent, & purpose
of transactions
• Consider potential for fraud
• Remain alert for undisclosed related-
party transactions
10
Audit Planning Considerations
• Involves different Audit Practitioners at
different locations:
 Cayman “Principal Auditor” signs
audit report, where the Fund is
domiciled;
 “Other Auditor” in different jurisdiction
where management or records based.
• Cayman Practitioner:
 Sign the Engagement Letter
 Supervises Other Auditor
 Review Other Auditor’s work
• Cayman auditor involvement in audit
planning, risk assessment and review:
 Which auditor is responsible for
communication to the Directors?
 Can the auditors effectively
collaborate to meet the client
deadline?
 Does the “Other auditor” have
adequate funds audit experience?
Working with other Auditors
11
1. Audit Planning Considerations
Questions?
12
2. Internal Controls & Risk Assessment
Considerations
13
Internal Control & Risk Assessment
If placing reliance on an internal controls assurance report:
• What is the nature of the report?
• Consider the report’s findings
• Are the critical controls being relied upon by the auditor sufficiently
tested and are these free from findings?
• Document the audit risk assessment and resultant audit approach
AND/OR: Perform controls reliance testing.
REMEMBER: Consider prior year audit adjustments and any other
significant deficiencies.
14
Internal Control & Risk Assessment
Only rely on documented controls that are evidenced to work
• May we rely on
controls?
• Service
organisation
controls report?
• Risks of fraud?
• Risks of errors?
• Walkthroughs
• Tests of control
• Substantive
procedures
• Confirmations
• Proof-in-total roll-
forward
calculations
• Substantive
analytical review
procedures
• Substantive tests
of detail
15
Internal Control & Risk Assessment
Management Override
Procedures to Address Management Override Risk
Examine:
Journal Entries
Estimates
Significant Transactions
Revenue Recognition
Management override and fraudulent revenue recognition are presumed to be
significant risks and as a result, there are certain audit procedures that would be
performed in every audit.
16
2. Internal Controls & Risk Assessment
Considerations
Questions?
17
3. Auditing Specific Accounting Cycles
18
Auditing Specific Accounting Cycles
Investments
19
Valuation techniques
Market approach
Cost approach
Income approach
Auditing Specific Accounting Cycles
Investments
20
Valuation techniques
Market approach
Cost approach
Income approach
Uses prices and other relevant information generated by
market transactions involving an identical or comparable
(similar) asset or liability
Auditing Specific Accounting Cycles
Investments
21
Valuation techniques
Market approach
Cost approach
Income approach
Reflects the amount that would be required currently to
replace the service capacity of an asset (current replacement
cost)
Auditing Specific Accounting Cycles
Investments
22
Valuation techniques
Market approach
Cost approach
Income approach
Converts future amounts (cash flows or income and
expenses) to a single current (discounted) amount
Auditing Specific Accounting Cycles
Investments
Level 1 – unadjusted quoted
prices in active markets for
identical assets or liabilities
23
Auditing Specific Accounting Cycles
Investments
24
Auditing Specific Accounting Cycles
Investments
25
Level 2 – inputs other than
quoted prices include within
Level 1 that are observable for
the asset or liability, either
directly or indirectly
Auditing Specific Accounting Cycles
Investments
26
Level 3 – inputs for the assets or
liability that are not based on
observable market data,
including assumptions in
determining the fair value of
investments
Auditing Specific Accounting Cycles
Investments
Audit the valuation,
classification, levelling
and risk disclosures
• ?
Obtain sufficient and
appropriate audit
evidence for Level 3
investments especially
• ?
Consider additional
procedures for
significant related party
transactions
• ?
DOCUMENT
WHETHER
ADDITIONAL
WORK IS
REQUIRED
Review post-year end portfolio
• ?
Confirm observable prices
independently
Audit any valuation techniques
• ?
Confirm quantities with custodian
• ?
Review any breaches of
restrictions/policy/strategy
Query any unusual investments or
investment transactions
• ?
Assess any
Management Estimates
for reasonableness and
related FS disclosures
• ?
Perform analytical
review Investment roll
forward calculation
• ?
27
Auditing Specific Accounting Cycles
Investments
Auditing the Statement of
comprehensive income
• Interest & dividend income
• Other net changes in FV on
financial assets and
liabilities at FVTPL
• Qualitative & quantitative
risk disclosures
• Management’s methods to
monitor & mitigate risk
28
• Offsetting disclosure
requirements
Auditing Specific Accounting Cycles
Investments
• Side pockets or other designated investments
29
• Document, justify any
reliance on controls
• Reconcile balances to
lead schedules, FS and
audit confirmations
• Investigate reconciling or
unusual items and FX
rates
Auditing Specific Accounting Cycles
Agree Review Evaluate
Opening Balances
30
Auditing Specific Accounting Cycles
Cash and Cash Equivalents
Due from/ to Brokers
Recalculate cash flow
statement workings
• ?
Review post year end
statements
• ?
Review any offsetting
disclosures for validity and
transparency
• ?
DOCUMENT
WHETHER
ADDITIONAL
WORK IS
REQUIRED
Justify any reliance on controls
• ?
Reconcile balances to Lead
schedules, Audit Confirmations and
Financial Statements
• ?
Investigate reconciling or unusual
items
• ?
Verify credit facility limits
Are there any breaches
Look at renewal dates
• ?
Verify FX rates
• ?
Document an understanding
of controls
• ?
31
Evidence any charges
over assets, restricted
balances, collateral &
related Financial
Statement Disclosures
• ?
Auditing Specific Accounting Cycles
Sample:
• Subs, Reds & Transfers
• Signed investor
instructions
• Transaction authorisation
• Recalculate using
NAV/share at transaction
date
• Agree bank
receipt/payment/in-kind
transfer
• Verification of investors?
DOCUMENT
WHETHER
ADDITIONAL
WORK IS
REQUIRED
Share capital roll-forward
recalculation:
• Agree opening to prior
year
• Agree movement and
closing amounts to an
audit confirmation
• Agree FS disclosures
Recalculate where applicable:
• NAV/share at Y/E
• Analytical review of
NAV/share per class
• Financial Highlights
Document & test allocation of income/expenses between share classes.
Only rely on documented controls that are evidenced to work.
Review any gates, suspensions, or investor lock-in agreements.
Share Capital
32
Auditing Specific Accounting Cycles
NAV-Based Fees
• Recalculate a sample or total based on the service-agreement or prospectus
• Fees payable at year-end might be verified to after date settlement
• Review breakdown of payments during the year and consider analytical techniques
Other Expenses
• Review any significant legal fee invoices
• Directors’ fees to be compared with FS disclosures, OM, directors’ service
agreements
• Consider whether any expenses are contrary to the offering document
Other Payables/Receivables
For significant balances, obtain adequate support, e.g.:
• Any post year end settlement
• Outstanding invoices
• Settlement terms and consider documenting reasons for any undue delay
Disclosure of Related Party Transactions
Expenses & Other Receivables/Payables
33
Auditing Specific Accounting Cycles
Going concern basis of accounting
The auditor report’s now includes:
• Description of management’s responsibility and whether the use of the
going concern basis of accounting is appropriate
• The auditor’s responsibilities are to conclude on the appropriateness of
management’s use of the going concern basis of accounting, based
on the audit evidence obtained, whether a material uncertainty exists
related to events or conditions that may cast significant doubt on the
entity’s ability to continue as a going concern.
Going Concern – ISA 570 (Revised)
34
Auditing Specific Accounting Cycles
Going Concern
RiskResponse
ReportingRiskAssessment
Determine:
• Does a material uncertainty exists in relation to the identified issue?
• Is the going concern basis of accounting appropriate?
• Are the FS disclosures sufficient?
Obtain management representations
For any issues identified:
• Review management’s
assessment
• Remain alert for possible
conditions or events
Consider management’s
assessment of issues that may cast
doubt on the going concern basis
of accounting:
• Review management’s
assessment
• Remain alert for possible
conditions or events
35
Auditing Specific Accounting Cycles
Going Concern
Any events that
may cast significant
doubt on entity's
ability to continue
as a going
concern?
Ask management
for a preliminary
assessment of the
entity’s ability to
continue as a going
concern
Conclude if a
material uncertainty
exists or if the going
concern basis of
accounting is
inappropriate
Remain alert throughout
audit for evidence of
events/conditions that
may cast significant doubt
on entity's ability to
continue as a going
concern.
Discuss any issues
with management
and obtain their
response
Evaluate
management’s plan
of action and
supporting
documentation
Identify any events/
conditions and
obtain
management’s
action plans in
response
NO
36
Auditing Specific Accounting Cycles
Use of Going Concern
Basis of Accounting
Inappropriate
Express a qualified or
adverse opinion, and
state material
uncertainty exists
Do financial statements
fully describe events/
conditions and disclose
existence of material
uncertainty?
• ?
Determine the impact of identified events/conditions on the audit report and communicate the decision to
management and those charged with governance, where applicable:
Going Concern
Use of Going Concern
Basis of Accounting
Appropriate but a
Material Uncertainty
Exists
• ?
Unmodified opinion
plus “Material
Uncertainty Related to
Going Concern”
• ?
Express an adverse
opinion
37
Auditing Specific Accounting Cycles
Risks:
• Erroneous disclosure or missing financial statement disclosures
• Incorrect valuations at year-end
Procedures to include:
• Document the date to which we have identified all material subsequent events
• Review post year end activities
• Obtain Management confirmation of no undisclosed subsequent events
Subsequent Events - Overview
38
Auditing Specific Accounting Cycles
Subsequent Events - Timeline
Date of
Financial
Statements
Timeline
Obtain evidence about subsequent events
Respond to new facts that
become known
Date of Management
Approval of Financial
Statements
Date of Auditor’s
Report on Financial
Statements
Date Financial
Statements Are
Issued
39
Auditing Specific Accounting Cycles
Document a review of the FS
Test material journal entries, including “top-side” journals
(ISA 330.20)
Perform a final analytical review
(ISA 520.6)
Address any additional risks identified
Discuss findings
Financial Statements Review Process
40
3. Auditing Specific Accounting Cycles
Questions?
41
4. Audit Completion, New & Revised
Auditor Reporting Standards
42
Audit Finalisation Considerations
The Directors Should Review and When Satisfied, Approve the
Audited Financial Statements (SoG 6.16) & Representation Letter
• Responsibilities
• Appropriate books &
records, minutes &
resolutions made
available
• Material transactions
properly recorded
• Responsibility for
establishing and
maintaining adequate
internal controls
• Responsibility for
assessing fraud risk
Seek General
Representations of:
• FS presented fairly
• Reflect ownership
• Investments, other
assets & liabilities,
valued per
prospectus, FS
disclosures and
accounting policies
complete and correct
• Subsequent events
are disclosed /
adjusted for
• All related party
transactions disclosed
Seek FS
Representations that:
• Breaches of law,
regulation, investment
restriction or
prospectus
• Investor complaints
• Contingent events and
or assets / liabilities
• Significant
deficiencies identified
• Internal control
weaknesses
• Adjusted & unadjusted
audit differences
• “Other Information” to
be appended to the FS
Seek Management
Representations of any:
43
New & Revised Auditor
Reporting Standards
• ISA 260 (Revised) Communication with Those Charged with Governance
• ISA 570 (Revised) Going Concern
• ISA 700 (Revised) Forming an Opinion and Reporting on Financial
Statements
• ISA 701 Communicating Key Audit Matters in the Independent
Auditor’s Report
• ISA 705 (Revised) Modifications to the Opinion in the Independent
Auditor’s Report
• ISA 706 (Revised) Emphasis of Matter Paragraphs and Other Matter
Paragraphs in the Independent Auditor’s Report
• ISA 720 (Revised) The Auditor’s Responsibilities Relating to Other
Information
• ISA 810 (Revised) Engagements to Report on Summary FS
• Conforming amendments to other ISA
ISA effective for periods ending on/after 15 December 2016
44
New & Revised Auditor
Reporting Standards
• The Auditor’s Responsibilities
• Overview of the planned scope, timing and significant risks
identified
• Qualitative Aspects of Accounting Practices
• Significant Difficulties Encountered
• Significant Matters Arising Relevant to Financial Reporting
• Written Representations
• Circumstances Affecting the Audit Report
• Key Audit Matters, if any
• Auditor Independence
ISA 260 (Revised) Communication with Those Charged With
Governance
45
New & Revised Auditor
Reporting Standards
• Audit opinion is at the start of the report.
• More explicit statement on independence, other ethical responsibilities, and
which standards or code were followed by the auditor.
• New section in the audit report when a material uncertainty over going concern
exists which refers to adequate disclosure in the FS.
• New section to cover the auditor’s work in relation to other information in the
annual report (ISA 720 (Revised))
• Going concern explanation wording clarified, referencing the going concern
“basis of accounting” concept (as separate from a “solvency” definition).
• Enhanced description of the responsibilities of management and the auditor,
(with an option to move text on certain responsibilities to an appendix or
website).
ISA 700 (Revised) Forming an Opinion and Reporting on Financial
Statements
46
New & Revised Auditor
Reporting Standards
Applies to Listed Entities or Voluntary Adopters
• A section in the audit report to explain key audit matters (KAM).
• A succinct description of the matter being included as a KAM, and a meaningful
summary of the audit procedures undertaken to address the matter.
• KAM are those of most significance in the audit, which are a subset of matters
communicated to TCWG:
 With a higher risk of material misstatement
 Requiring significant judgement, including accounting estimates
 Where there was a significant event or transaction in the year
 Required for any reason to have modified the Opinion
 Replaces any Emphasis of Matter / Other Matter paragraph except the new
“Material Uncertainty Related to Going Concern” paragraph, if applicable
• Wording must not imply discrete opinions on separate elements of the FS.
ISA 701 Communicating Key Audit Matters in the Independent
Auditor’s Report
47
Audit Finalisation Considerations
ISA 705 (Rev) Modifications to the Opinion in the Independent
Auditor’s Report
QUALIFIED:
Material Misstatement
QUALIFIED:
Material Inability to Obtain Audit
Evidence
ADVERSE:
Material & Pervasive Misstatement
DISCLAIMER:
Material & Pervasive Inability to
Obtain Audit Evidence
TYPES OF
MODIFICATIONS
48
New & Revised Auditor
Reporting Standards
Qualified Opinion [Illustrative Extract as an Example]
We have audited the financial statements…
In our opinion, except for the incomplete disclosure of the information referred to in the
Basis for Qualified Opinion section of our report, the accompanying financial
statements present fairly (or do give a true and fair view of), the financial position of the
Company as at December 31, 2018, and of its financial performance and its cash flows
for the year then ended in accordance with International Financial Reporting Standards
(IFRSs).
Basis for Qualified Opinion
As discussed in Note YY, the Company’s financing arrangements expire and the
amounts outstanding are payable on December 31, 2018. The Company has been
unable to conclude re-negotiations or obtain replacement financing. This situation
indicates that a material uncertainty exists that may cast significant doubt on the
Company’s ability to continue as a going concern. The financial statements do not
adequately disclose this matter.
ISA 705 (Revised) & ISA 570 (Revised)
49
Audit Finalisation Considerations
ISA 705 (Rev) Modifications to the Opinion in the Independent
Auditor’s Report
QUALIFIED:
Material Misstatement
QUALIFIED:
Material Inability to Obtain Audit
Evidence
ADVERSE:
Material & Pervasive Misstatement
DISCLAIMER:
Material & Pervasive Inability to
Obtain Audit Evidence
TYPES OF
MODIFICATIONS
50
New & Revised Auditor
Reporting Standards
Adverse Opinion [Illustrative Extract as an Example]
We have audited the financial statements…
In our opinion, because of the omission of the information mentioned in the Basis for
Adverse Opinion section of our report, the accompanying financial statements do not
present fairly (or do not give a true and fair view of), the financial position of the
Company as at December 31, 2018, and of its financial performance and its cash flows
for the year then ended in accordance with International Financial Reporting Standards
(IFRSs).
Basis for Adverse Opinion
The Company’s financing arrangements expired and the amount outstanding was
payable on December 31, 2018. The Company has been unable to conclude re-
negotiations or obtain replacement financing and is considering filing for bankruptcy.
This situation indicates that a material uncertainty exists that may cast significant doubt
on the Company’s ability to continue as a going concern. The financial statements do
not adequately disclose this fact.
ISA 705 (Revised) & ISA 570 (Revised)
51
Audit Finalisation Considerations
ISA 705 (Rev) Modifications to the Opinion in the Independent
Auditor’s Report
QUALIFIED:
Material Misstatement
QUALIFIED:
Material Inability to Obtain Audit
Evidence
ADVERSE:
Material & Pervasive Misstatement
DISCLAIMER:
Material & Pervasive Inability to
Obtain Audit Evidence
TYPES OF
MODIFICATIONS
52
New & Revised Auditor
Reporting Standards
Disclaimer of Opinion [Illustrative Extract as an Example]
We were engaged to audit the financial statements of ABC Fund…
We do not express an opinion on the accompanying financial statements of the Fund.
Because of the significance of the matter described in the Basis for Disclaimer of
Opinion section of our report, we have not been able to obtain sufficient appropriate
audit evidence to provide a basis for an audit opinion on these financial statements.
Basis for Disclaimer of Opinion…
Responsibilities of Management and TCWG for the FS…
Auditor’s Responsibilities for the Audit of the Financial Statements
Our responsibility is to conduct an audit of the Fund’s financial statements in
accordance with International Standards on Auditing and to issue an auditor’s report.
However, because of the matter described in the Basis for Disclaimer of Opinion section
of our report, we were not able to obtain sufficient appropriate audit evidence to provide
a basis for an audit opinion on these financial statements.
We are independent…
ISA 705 (Rev) Modifications to the Opinion in the Independent
Auditor’s Report
53
Audit Finalisation Considerations
ISA 705 (Rev) Modifications to the Opinion in the Independent
Auditor’s Report
QUALIFIED:
Material Misstatement
QUALIFIED:
Material Inability to Obtain Audit
Evidence
ADVERSE:
Material & Pervasive Misstatement
DISCLAIMER:
Material & Pervasive Inability to
Obtain Audit Evidence
TYPES OF
MODIFICATIONS
54
New & Revised Auditor
Reporting Standards
EoM can also be required by:
• ISA 210, Agreeing the Terms of Audit Engagements – paragraph 19(b)
• ISA 560, Subsequent Events – paragraph 12 (b) and 16
• ISA 800, Special Considerations – Audits of Financial Statements Prepared in
Accordance with Special Purpose Frameworks – paragraph 14
Other Matter paragraph can also be required by:
• ISA 560, Subsequent Events – paragraphs 12 (b) and 16
• ISA 710, Comparative Information – Corresponding Figures and Comparative
Financial Statements – paragraphs 13-14, 16-17 and 19
• ISA 720, The Auditor’s Responsibilities Related to Other Information in Documents
Containing Audited Financial Statements – paragraph 10 (a)
ISA 706 (Revised) Emphasis of Matter Paragraphs and Other Matter
Paragraphs in the Independent Auditor’s Report
55
New & Revised Auditor
Reporting Standards
• Updated to reflect IESBA’s Code of Ethics for Professional Accountants addressing
Non-Compliance with Laws and Regulations (NOCLAR)
• Effective for audit periods beginning on/after 15 December 2017
• Pathway for auditors/professional accountants to disclose potential non-compliance
situations to appropriate public authorities without constraints of the ethical duty of
confidentiality.
• Promoting compliance, preventing of non-compliance
ISA 250 (Revised) Consideration of Laws and Regulations in an Audit
of FS
56
4. Audit Completion, New & Revised
Auditor Reporting Standards
Questions?
57
5. Auditing Crypto Funds
58
Auditing Crypto Funds
BACKGROUND
500 crypto funds are already known to exist
Decentralized Autonomous Organizations (DAO)
Blockchain – distributed ledger technology; immutable log of data/transactions
Smart Contract – self-executing coded agreements existing across a distributed
ledger technology. Could be used to offer investment and insurance products
Cryptocurrencies – digital assets that function as currency “coins”
Asset-Backed Tokens – define their value from a claim on an asset
Utility Tokens – tokens for specific use applications
Security Tokens – passive investment opportunities
ICOs / token generation / token distribution events – like crowd financing
Cloud Mining Contracts – an interest in the output of crypto mining power from
remote datacentres mining in the cloud
59
Auditing Crypto Funds
CRYPTOCURRENCY / DIGITAL CURRENCY
Disintermediation
Anonymous transactions are possible
Fraud could be concealed more easily, like cash transactions
Not legal tender (not backed by state)
Not widely accepted in any single jurisdiction (not yet)
Processing times are not instant, but much faster than wires
Scalability limited (currently)
Volatile (mainly)
Intrinsic value (depends)
Known quantity of coins/tokens limits risks of inflation/deflation
Smart contracts (evolving)
60
Auditing Crypto Funds
ACCOUNTING FOR CRYPTOCURRENCIES
Varying approaches, no crypto guidance offered by IFRS
• Not a Cash Equivalent if significant risk of fluctuations in value
• Not a Financial Asset (no contract, except Bitcoin derivatives)
• Accounting for Intangible Assets
• At FVTPL for Investment Entities, if there is an Active Market
• Otherwise Changes in FV go through OCI
• Clear disclosure of the accounting policies & nature of transactions is
key
61
Auditing Crypto Funds
Additional audit procedures to consider:
• Is the fund issuing Tokens or Redeemable Shares? Review the offering.
• What are the KYC/AML checks for investor transactions (and in-kind
transactions) and who performs and reviews this?
• Consider source of funds for transactions outside of regulated exchange
• Review and consider testing controls and systems plus any substantive
procedures over digital wallet, cold storage, broker/custodian
• Test ownership and access controls over any corporate digital wallets
• Audit confirmations from (independent?) custodians
• Review pricing methodology, consider using the most active market price,
and look at the timing/cut-off of pricing on 24/7 markets
• Detailed review investment transactions during the year include a
comprehensive analytical review of trading performance in each
cryptocurrency
62
Auditing Crypto Funds
Background information:
• bitcoin.org/en
• blockchain.com/explorer
• bitnodes.earn.com
• coindesk.com
• coinmarketcap.com
• cointelegraph.com
• onlinemd5.com
• bitbonkers.com
• CPA Canada: Audit Considerations Related to Cryptocurrency Assets and
Transactions
63
5. Auditing Crypto Funds
64
Questions?
Thank you!
65

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Auditing Funds and Crypto Funds (2018 08 22)

  • 1. International Standards on Auditing with a focus on Cayman Funds David Walker Candice Czeremuszkin Etienne Jensen-Fontaine 22 August 2018 Helping you grow PRECISE. PROVEN. PERFORMANCE. 1
  • 2. DisclaimerStandards on Auditing CIIPA and the presenters disclaim any responsibility or liability resulting from the use and application of this presentation. 2
  • 3. 1. Audit Planning Considerations 2. Internal Controls & Risk Assessment Considerations 3. Auditing Specific Accounting Cycles 4. Audit Completion, New & Revised Auditor Reporting Standards 5. Auditing Crypto Funds Agenda 3
  • 4. 1. Audit Planning Considerations 4
  • 5. Audit Planning Considerations Engagement (Re-) Acceptance Requirements & Deliverables Audit Planning & Documentation 5
  • 6. • Fraud/Non-Compliance Risk Assessments • Accounting Cycles Risk Assessments • Materiality • Expected Modification of the Audit Opinion 6 Audit Planning Considerations
  • 7. Audit Planning Considerations • Prior year audit issues • Changes in the Fund’s operations • Estimated values and assumptions • Errors and restatements • Going concern assessment • Communication with Those Charged with Governance 7
  • 8. Audit Planning Considerations Laws & Regulations (ISA 250) RiskResponse ReportingRiskAssessment • Is material non-compliance disclosed/reported if required? • Report to Those Charged with Governance • Obtain management representations • Identify any non-compliance • Discuss with management, if appropriate • Evaluate impact • Legal & regulatory framework for funds • How entity is complying? • Inquire about compliance • Review regulatory correspondence 8
  • 9. Audit Planning Considerations Laws & Regulations • IAASB Handbook of International Quality Control… • Companies Law • Mutual Funds Law & Annual Returns Regulations • Proceeds of Crime Law • Anti-Money Laundering Regulations • Confidential Information Disclosure Law • www.cima.ky/investment-funds-regulatory-measures • https://www.ciipa.ky/page-18225 9
  • 10. Audit Planning Considerations Related Parties RiskResponse ReportingRiskAssessment • Has sufficient appropriate evidence been obtained? • Does a material misstatement exist? • Is financial statement disclosure adequate? • Obtain management representations. Report on any findings • Any indication of undisclosed related parties? • Obtain support for management’s assertions about the nature, extent, and purpose of transactions • If consider significance, measurement and recognition of transactions, as well as any fraud risk • Identify related parties, including and any changes • Understand nature, extent, & purpose of transactions • Consider potential for fraud • Remain alert for undisclosed related- party transactions 10
  • 11. Audit Planning Considerations • Involves different Audit Practitioners at different locations:  Cayman “Principal Auditor” signs audit report, where the Fund is domiciled;  “Other Auditor” in different jurisdiction where management or records based. • Cayman Practitioner:  Sign the Engagement Letter  Supervises Other Auditor  Review Other Auditor’s work • Cayman auditor involvement in audit planning, risk assessment and review:  Which auditor is responsible for communication to the Directors?  Can the auditors effectively collaborate to meet the client deadline?  Does the “Other auditor” have adequate funds audit experience? Working with other Auditors 11
  • 12. 1. Audit Planning Considerations Questions? 12
  • 13. 2. Internal Controls & Risk Assessment Considerations 13
  • 14. Internal Control & Risk Assessment If placing reliance on an internal controls assurance report: • What is the nature of the report? • Consider the report’s findings • Are the critical controls being relied upon by the auditor sufficiently tested and are these free from findings? • Document the audit risk assessment and resultant audit approach AND/OR: Perform controls reliance testing. REMEMBER: Consider prior year audit adjustments and any other significant deficiencies. 14
  • 15. Internal Control & Risk Assessment Only rely on documented controls that are evidenced to work • May we rely on controls? • Service organisation controls report? • Risks of fraud? • Risks of errors? • Walkthroughs • Tests of control • Substantive procedures • Confirmations • Proof-in-total roll- forward calculations • Substantive analytical review procedures • Substantive tests of detail 15
  • 16. Internal Control & Risk Assessment Management Override Procedures to Address Management Override Risk Examine: Journal Entries Estimates Significant Transactions Revenue Recognition Management override and fraudulent revenue recognition are presumed to be significant risks and as a result, there are certain audit procedures that would be performed in every audit. 16
  • 17. 2. Internal Controls & Risk Assessment Considerations Questions? 17
  • 18. 3. Auditing Specific Accounting Cycles 18
  • 19. Auditing Specific Accounting Cycles Investments 19 Valuation techniques Market approach Cost approach Income approach
  • 20. Auditing Specific Accounting Cycles Investments 20 Valuation techniques Market approach Cost approach Income approach Uses prices and other relevant information generated by market transactions involving an identical or comparable (similar) asset or liability
  • 21. Auditing Specific Accounting Cycles Investments 21 Valuation techniques Market approach Cost approach Income approach Reflects the amount that would be required currently to replace the service capacity of an asset (current replacement cost)
  • 22. Auditing Specific Accounting Cycles Investments 22 Valuation techniques Market approach Cost approach Income approach Converts future amounts (cash flows or income and expenses) to a single current (discounted) amount
  • 23. Auditing Specific Accounting Cycles Investments Level 1 – unadjusted quoted prices in active markets for identical assets or liabilities 23
  • 24. Auditing Specific Accounting Cycles Investments 24
  • 25. Auditing Specific Accounting Cycles Investments 25 Level 2 – inputs other than quoted prices include within Level 1 that are observable for the asset or liability, either directly or indirectly
  • 26. Auditing Specific Accounting Cycles Investments 26 Level 3 – inputs for the assets or liability that are not based on observable market data, including assumptions in determining the fair value of investments
  • 27. Auditing Specific Accounting Cycles Investments Audit the valuation, classification, levelling and risk disclosures • ? Obtain sufficient and appropriate audit evidence for Level 3 investments especially • ? Consider additional procedures for significant related party transactions • ? DOCUMENT WHETHER ADDITIONAL WORK IS REQUIRED Review post-year end portfolio • ? Confirm observable prices independently Audit any valuation techniques • ? Confirm quantities with custodian • ? Review any breaches of restrictions/policy/strategy Query any unusual investments or investment transactions • ? Assess any Management Estimates for reasonableness and related FS disclosures • ? Perform analytical review Investment roll forward calculation • ? 27
  • 28. Auditing Specific Accounting Cycles Investments Auditing the Statement of comprehensive income • Interest & dividend income • Other net changes in FV on financial assets and liabilities at FVTPL • Qualitative & quantitative risk disclosures • Management’s methods to monitor & mitigate risk 28 • Offsetting disclosure requirements
  • 29. Auditing Specific Accounting Cycles Investments • Side pockets or other designated investments 29 • Document, justify any reliance on controls • Reconcile balances to lead schedules, FS and audit confirmations • Investigate reconciling or unusual items and FX rates
  • 30. Auditing Specific Accounting Cycles Agree Review Evaluate Opening Balances 30
  • 31. Auditing Specific Accounting Cycles Cash and Cash Equivalents Due from/ to Brokers Recalculate cash flow statement workings • ? Review post year end statements • ? Review any offsetting disclosures for validity and transparency • ? DOCUMENT WHETHER ADDITIONAL WORK IS REQUIRED Justify any reliance on controls • ? Reconcile balances to Lead schedules, Audit Confirmations and Financial Statements • ? Investigate reconciling or unusual items • ? Verify credit facility limits Are there any breaches Look at renewal dates • ? Verify FX rates • ? Document an understanding of controls • ? 31 Evidence any charges over assets, restricted balances, collateral & related Financial Statement Disclosures • ?
  • 32. Auditing Specific Accounting Cycles Sample: • Subs, Reds & Transfers • Signed investor instructions • Transaction authorisation • Recalculate using NAV/share at transaction date • Agree bank receipt/payment/in-kind transfer • Verification of investors? DOCUMENT WHETHER ADDITIONAL WORK IS REQUIRED Share capital roll-forward recalculation: • Agree opening to prior year • Agree movement and closing amounts to an audit confirmation • Agree FS disclosures Recalculate where applicable: • NAV/share at Y/E • Analytical review of NAV/share per class • Financial Highlights Document & test allocation of income/expenses between share classes. Only rely on documented controls that are evidenced to work. Review any gates, suspensions, or investor lock-in agreements. Share Capital 32
  • 33. Auditing Specific Accounting Cycles NAV-Based Fees • Recalculate a sample or total based on the service-agreement or prospectus • Fees payable at year-end might be verified to after date settlement • Review breakdown of payments during the year and consider analytical techniques Other Expenses • Review any significant legal fee invoices • Directors’ fees to be compared with FS disclosures, OM, directors’ service agreements • Consider whether any expenses are contrary to the offering document Other Payables/Receivables For significant balances, obtain adequate support, e.g.: • Any post year end settlement • Outstanding invoices • Settlement terms and consider documenting reasons for any undue delay Disclosure of Related Party Transactions Expenses & Other Receivables/Payables 33
  • 34. Auditing Specific Accounting Cycles Going concern basis of accounting The auditor report’s now includes: • Description of management’s responsibility and whether the use of the going concern basis of accounting is appropriate • The auditor’s responsibilities are to conclude on the appropriateness of management’s use of the going concern basis of accounting, based on the audit evidence obtained, whether a material uncertainty exists related to events or conditions that may cast significant doubt on the entity’s ability to continue as a going concern. Going Concern – ISA 570 (Revised) 34
  • 35. Auditing Specific Accounting Cycles Going Concern RiskResponse ReportingRiskAssessment Determine: • Does a material uncertainty exists in relation to the identified issue? • Is the going concern basis of accounting appropriate? • Are the FS disclosures sufficient? Obtain management representations For any issues identified: • Review management’s assessment • Remain alert for possible conditions or events Consider management’s assessment of issues that may cast doubt on the going concern basis of accounting: • Review management’s assessment • Remain alert for possible conditions or events 35
  • 36. Auditing Specific Accounting Cycles Going Concern Any events that may cast significant doubt on entity's ability to continue as a going concern? Ask management for a preliminary assessment of the entity’s ability to continue as a going concern Conclude if a material uncertainty exists or if the going concern basis of accounting is inappropriate Remain alert throughout audit for evidence of events/conditions that may cast significant doubt on entity's ability to continue as a going concern. Discuss any issues with management and obtain their response Evaluate management’s plan of action and supporting documentation Identify any events/ conditions and obtain management’s action plans in response NO 36
  • 37. Auditing Specific Accounting Cycles Use of Going Concern Basis of Accounting Inappropriate Express a qualified or adverse opinion, and state material uncertainty exists Do financial statements fully describe events/ conditions and disclose existence of material uncertainty? • ? Determine the impact of identified events/conditions on the audit report and communicate the decision to management and those charged with governance, where applicable: Going Concern Use of Going Concern Basis of Accounting Appropriate but a Material Uncertainty Exists • ? Unmodified opinion plus “Material Uncertainty Related to Going Concern” • ? Express an adverse opinion 37
  • 38. Auditing Specific Accounting Cycles Risks: • Erroneous disclosure or missing financial statement disclosures • Incorrect valuations at year-end Procedures to include: • Document the date to which we have identified all material subsequent events • Review post year end activities • Obtain Management confirmation of no undisclosed subsequent events Subsequent Events - Overview 38
  • 39. Auditing Specific Accounting Cycles Subsequent Events - Timeline Date of Financial Statements Timeline Obtain evidence about subsequent events Respond to new facts that become known Date of Management Approval of Financial Statements Date of Auditor’s Report on Financial Statements Date Financial Statements Are Issued 39
  • 40. Auditing Specific Accounting Cycles Document a review of the FS Test material journal entries, including “top-side” journals (ISA 330.20) Perform a final analytical review (ISA 520.6) Address any additional risks identified Discuss findings Financial Statements Review Process 40
  • 41. 3. Auditing Specific Accounting Cycles Questions? 41
  • 42. 4. Audit Completion, New & Revised Auditor Reporting Standards 42
  • 43. Audit Finalisation Considerations The Directors Should Review and When Satisfied, Approve the Audited Financial Statements (SoG 6.16) & Representation Letter • Responsibilities • Appropriate books & records, minutes & resolutions made available • Material transactions properly recorded • Responsibility for establishing and maintaining adequate internal controls • Responsibility for assessing fraud risk Seek General Representations of: • FS presented fairly • Reflect ownership • Investments, other assets & liabilities, valued per prospectus, FS disclosures and accounting policies complete and correct • Subsequent events are disclosed / adjusted for • All related party transactions disclosed Seek FS Representations that: • Breaches of law, regulation, investment restriction or prospectus • Investor complaints • Contingent events and or assets / liabilities • Significant deficiencies identified • Internal control weaknesses • Adjusted & unadjusted audit differences • “Other Information” to be appended to the FS Seek Management Representations of any: 43
  • 44. New & Revised Auditor Reporting Standards • ISA 260 (Revised) Communication with Those Charged with Governance • ISA 570 (Revised) Going Concern • ISA 700 (Revised) Forming an Opinion and Reporting on Financial Statements • ISA 701 Communicating Key Audit Matters in the Independent Auditor’s Report • ISA 705 (Revised) Modifications to the Opinion in the Independent Auditor’s Report • ISA 706 (Revised) Emphasis of Matter Paragraphs and Other Matter Paragraphs in the Independent Auditor’s Report • ISA 720 (Revised) The Auditor’s Responsibilities Relating to Other Information • ISA 810 (Revised) Engagements to Report on Summary FS • Conforming amendments to other ISA ISA effective for periods ending on/after 15 December 2016 44
  • 45. New & Revised Auditor Reporting Standards • The Auditor’s Responsibilities • Overview of the planned scope, timing and significant risks identified • Qualitative Aspects of Accounting Practices • Significant Difficulties Encountered • Significant Matters Arising Relevant to Financial Reporting • Written Representations • Circumstances Affecting the Audit Report • Key Audit Matters, if any • Auditor Independence ISA 260 (Revised) Communication with Those Charged With Governance 45
  • 46. New & Revised Auditor Reporting Standards • Audit opinion is at the start of the report. • More explicit statement on independence, other ethical responsibilities, and which standards or code were followed by the auditor. • New section in the audit report when a material uncertainty over going concern exists which refers to adequate disclosure in the FS. • New section to cover the auditor’s work in relation to other information in the annual report (ISA 720 (Revised)) • Going concern explanation wording clarified, referencing the going concern “basis of accounting” concept (as separate from a “solvency” definition). • Enhanced description of the responsibilities of management and the auditor, (with an option to move text on certain responsibilities to an appendix or website). ISA 700 (Revised) Forming an Opinion and Reporting on Financial Statements 46
  • 47. New & Revised Auditor Reporting Standards Applies to Listed Entities or Voluntary Adopters • A section in the audit report to explain key audit matters (KAM). • A succinct description of the matter being included as a KAM, and a meaningful summary of the audit procedures undertaken to address the matter. • KAM are those of most significance in the audit, which are a subset of matters communicated to TCWG:  With a higher risk of material misstatement  Requiring significant judgement, including accounting estimates  Where there was a significant event or transaction in the year  Required for any reason to have modified the Opinion  Replaces any Emphasis of Matter / Other Matter paragraph except the new “Material Uncertainty Related to Going Concern” paragraph, if applicable • Wording must not imply discrete opinions on separate elements of the FS. ISA 701 Communicating Key Audit Matters in the Independent Auditor’s Report 47
  • 48. Audit Finalisation Considerations ISA 705 (Rev) Modifications to the Opinion in the Independent Auditor’s Report QUALIFIED: Material Misstatement QUALIFIED: Material Inability to Obtain Audit Evidence ADVERSE: Material & Pervasive Misstatement DISCLAIMER: Material & Pervasive Inability to Obtain Audit Evidence TYPES OF MODIFICATIONS 48
  • 49. New & Revised Auditor Reporting Standards Qualified Opinion [Illustrative Extract as an Example] We have audited the financial statements… In our opinion, except for the incomplete disclosure of the information referred to in the Basis for Qualified Opinion section of our report, the accompanying financial statements present fairly (or do give a true and fair view of), the financial position of the Company as at December 31, 2018, and of its financial performance and its cash flows for the year then ended in accordance with International Financial Reporting Standards (IFRSs). Basis for Qualified Opinion As discussed in Note YY, the Company’s financing arrangements expire and the amounts outstanding are payable on December 31, 2018. The Company has been unable to conclude re-negotiations or obtain replacement financing. This situation indicates that a material uncertainty exists that may cast significant doubt on the Company’s ability to continue as a going concern. The financial statements do not adequately disclose this matter. ISA 705 (Revised) & ISA 570 (Revised) 49
  • 50. Audit Finalisation Considerations ISA 705 (Rev) Modifications to the Opinion in the Independent Auditor’s Report QUALIFIED: Material Misstatement QUALIFIED: Material Inability to Obtain Audit Evidence ADVERSE: Material & Pervasive Misstatement DISCLAIMER: Material & Pervasive Inability to Obtain Audit Evidence TYPES OF MODIFICATIONS 50
  • 51. New & Revised Auditor Reporting Standards Adverse Opinion [Illustrative Extract as an Example] We have audited the financial statements… In our opinion, because of the omission of the information mentioned in the Basis for Adverse Opinion section of our report, the accompanying financial statements do not present fairly (or do not give a true and fair view of), the financial position of the Company as at December 31, 2018, and of its financial performance and its cash flows for the year then ended in accordance with International Financial Reporting Standards (IFRSs). Basis for Adverse Opinion The Company’s financing arrangements expired and the amount outstanding was payable on December 31, 2018. The Company has been unable to conclude re- negotiations or obtain replacement financing and is considering filing for bankruptcy. This situation indicates that a material uncertainty exists that may cast significant doubt on the Company’s ability to continue as a going concern. The financial statements do not adequately disclose this fact. ISA 705 (Revised) & ISA 570 (Revised) 51
  • 52. Audit Finalisation Considerations ISA 705 (Rev) Modifications to the Opinion in the Independent Auditor’s Report QUALIFIED: Material Misstatement QUALIFIED: Material Inability to Obtain Audit Evidence ADVERSE: Material & Pervasive Misstatement DISCLAIMER: Material & Pervasive Inability to Obtain Audit Evidence TYPES OF MODIFICATIONS 52
  • 53. New & Revised Auditor Reporting Standards Disclaimer of Opinion [Illustrative Extract as an Example] We were engaged to audit the financial statements of ABC Fund… We do not express an opinion on the accompanying financial statements of the Fund. Because of the significance of the matter described in the Basis for Disclaimer of Opinion section of our report, we have not been able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on these financial statements. Basis for Disclaimer of Opinion… Responsibilities of Management and TCWG for the FS… Auditor’s Responsibilities for the Audit of the Financial Statements Our responsibility is to conduct an audit of the Fund’s financial statements in accordance with International Standards on Auditing and to issue an auditor’s report. However, because of the matter described in the Basis for Disclaimer of Opinion section of our report, we were not able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on these financial statements. We are independent… ISA 705 (Rev) Modifications to the Opinion in the Independent Auditor’s Report 53
  • 54. Audit Finalisation Considerations ISA 705 (Rev) Modifications to the Opinion in the Independent Auditor’s Report QUALIFIED: Material Misstatement QUALIFIED: Material Inability to Obtain Audit Evidence ADVERSE: Material & Pervasive Misstatement DISCLAIMER: Material & Pervasive Inability to Obtain Audit Evidence TYPES OF MODIFICATIONS 54
  • 55. New & Revised Auditor Reporting Standards EoM can also be required by: • ISA 210, Agreeing the Terms of Audit Engagements – paragraph 19(b) • ISA 560, Subsequent Events – paragraph 12 (b) and 16 • ISA 800, Special Considerations – Audits of Financial Statements Prepared in Accordance with Special Purpose Frameworks – paragraph 14 Other Matter paragraph can also be required by: • ISA 560, Subsequent Events – paragraphs 12 (b) and 16 • ISA 710, Comparative Information – Corresponding Figures and Comparative Financial Statements – paragraphs 13-14, 16-17 and 19 • ISA 720, The Auditor’s Responsibilities Related to Other Information in Documents Containing Audited Financial Statements – paragraph 10 (a) ISA 706 (Revised) Emphasis of Matter Paragraphs and Other Matter Paragraphs in the Independent Auditor’s Report 55
  • 56. New & Revised Auditor Reporting Standards • Updated to reflect IESBA’s Code of Ethics for Professional Accountants addressing Non-Compliance with Laws and Regulations (NOCLAR) • Effective for audit periods beginning on/after 15 December 2017 • Pathway for auditors/professional accountants to disclose potential non-compliance situations to appropriate public authorities without constraints of the ethical duty of confidentiality. • Promoting compliance, preventing of non-compliance ISA 250 (Revised) Consideration of Laws and Regulations in an Audit of FS 56
  • 57. 4. Audit Completion, New & Revised Auditor Reporting Standards Questions? 57
  • 58. 5. Auditing Crypto Funds 58
  • 59. Auditing Crypto Funds BACKGROUND 500 crypto funds are already known to exist Decentralized Autonomous Organizations (DAO) Blockchain – distributed ledger technology; immutable log of data/transactions Smart Contract – self-executing coded agreements existing across a distributed ledger technology. Could be used to offer investment and insurance products Cryptocurrencies – digital assets that function as currency “coins” Asset-Backed Tokens – define their value from a claim on an asset Utility Tokens – tokens for specific use applications Security Tokens – passive investment opportunities ICOs / token generation / token distribution events – like crowd financing Cloud Mining Contracts – an interest in the output of crypto mining power from remote datacentres mining in the cloud 59
  • 60. Auditing Crypto Funds CRYPTOCURRENCY / DIGITAL CURRENCY Disintermediation Anonymous transactions are possible Fraud could be concealed more easily, like cash transactions Not legal tender (not backed by state) Not widely accepted in any single jurisdiction (not yet) Processing times are not instant, but much faster than wires Scalability limited (currently) Volatile (mainly) Intrinsic value (depends) Known quantity of coins/tokens limits risks of inflation/deflation Smart contracts (evolving) 60
  • 61. Auditing Crypto Funds ACCOUNTING FOR CRYPTOCURRENCIES Varying approaches, no crypto guidance offered by IFRS • Not a Cash Equivalent if significant risk of fluctuations in value • Not a Financial Asset (no contract, except Bitcoin derivatives) • Accounting for Intangible Assets • At FVTPL for Investment Entities, if there is an Active Market • Otherwise Changes in FV go through OCI • Clear disclosure of the accounting policies & nature of transactions is key 61
  • 62. Auditing Crypto Funds Additional audit procedures to consider: • Is the fund issuing Tokens or Redeemable Shares? Review the offering. • What are the KYC/AML checks for investor transactions (and in-kind transactions) and who performs and reviews this? • Consider source of funds for transactions outside of regulated exchange • Review and consider testing controls and systems plus any substantive procedures over digital wallet, cold storage, broker/custodian • Test ownership and access controls over any corporate digital wallets • Audit confirmations from (independent?) custodians • Review pricing methodology, consider using the most active market price, and look at the timing/cut-off of pricing on 24/7 markets • Detailed review investment transactions during the year include a comprehensive analytical review of trading performance in each cryptocurrency 62
  • 63. Auditing Crypto Funds Background information: • bitcoin.org/en • blockchain.com/explorer • bitnodes.earn.com • coindesk.com • coinmarketcap.com • cointelegraph.com • onlinemd5.com • bitbonkers.com • CPA Canada: Audit Considerations Related to Cryptocurrency Assets and Transactions 63
  • 64. 5. Auditing Crypto Funds 64 Questions?