Auditing: A Journal of Practice & Theory Vol. 27, No. 2 November 2008 pp. 253–279 American Accounting Association DOI: 10.2308/aud.2008.27.2.253 A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness Paul Caster, Randal J. Elder, and Diane J. Janvrin SUMMARY: Confirmations are extensively used and are often perceived by practitioners to be one of the most persuasive forms of audit evidence. Yet academic research has found limitations that restrict confirmation effectiveness for many management assertions. In addition, a number of problems with false and forged confirmations are identified in Accounting and Auditing Enforcement Releases 共AAERs兲. The Public Company Accounting Oversight Board 共PCAOB兲 and the International Auditing and Assurance Standards Board 共IAASB兲 have put confirmation evidence on their respective agendas. Academic research indicates that receivable confirmations can be effective evidence for the existence assertion. Low response rates, as well as respondent errors and directional bias in detecting errors, are key barriers to confirmation effectiveness. Our review of AAERs identified failure to authenticate responses, collusion between auditee management and customers, and concealed side agreements and special terms as specific problem areas. We also identify a number of research questions for future research. Keywords: audit confirmations; audit evidence; confirmation reliability; AAER evidence. Data Availability: Please contact the authors. INTRODUCTION Confirmations are considered to be among the most persuasive forms of audit evidence, because they are received directly from a third party. Accounts receivable confirmations have been required in most circumstances since 1939, and because auditors perceive them to be persuasive evidence for many assertions, they also use them for other accounts, including cash, debt, marketable securities, and other account balances, even though their use is not required by auditing standards. However, academic studies have questioned the reliability of confirmations, Securities Paul Caster is an Associate Professor at Fairfield University, Randal J. Elder is a Professor at Syracuse University, and Diane J. Janvrin is an Assistant Professor at Iowa State University. We thank the editor, Dan Simunic, and two anonymous reviewers for their helpful comments. We also appreciate the comments of Doug Carmichael. We thank Dana Hermanson for providing data on AAERs, and Nicole Bogler, Andrew Crocco, Sarah Erdman, and Ahmed Abdel Meguid for research assistance. The views in this paper are those of the authors and do not represent an official position of the American Accounting Association. Submitted: January 2007 Accepted: May 2008 Published Online: March 2009 253 254 Caster, Elder, and Janvrin and Exchange Commission 共SEC兲 investigations have uncovered problems with confirmation evidence, including forgeries and other fraud, and new communication technologies allow auditors to obtain evidence directly from third parties without direct written communication. To address these and other issues, the PCAOB currently is engaged in a project on the use of confirmations in financial statement audits.1 In addition, the IAASB has put confirmation evidence on its agenda. In a Standing Advisory Group 共SAG兲 briefing paper, PCAOB staff identified 13 questions regarding the required use of confirmations, confirmation effectiveness and reliability, confirmation of special terms and agreements, confirmation of information other than accounts receivable, use of negative confirmations, and requests not to confirm 共PCAOB 2004b兲. This study provides a synthesis of academic and practitioner research on confirmation use and effectiveness. In addition, original research using AAER evidence was conducted to supplement the research synthesis. We conducted a search for academic literature relevant to each area of inquiry. A fairly extensive, although somewhat dated, literature exists on accounts receivable confirmation effectiveness and reliability. Limited academic research addresses many of the other research questions in the PCAOB SAG briefing paper. This lack of academic research is partially due to the narrow focus of some of the PCAOB questions, but also reflects a lack of available data on auditor confirmation decisions. As a result, we expanded our inquiry to include relevant practitioner literature 共for example, professional journals and AICPA guides兲. We also examined AAERs as they have been used in studies related to fraudulent financial reporting 共Dechow et al. 1996; Bonner et al. 1998兲, and many financial reporting frauds involve revenue recognition issues 共Beasley et al. 1999兲 that may be related to the use of accounts receivable confirmations. Our primary findings are: 共1兲 Currently, some auditors choose not to confirm accounts receivable without justifying how they met one or more of the criteria in Statement on Auditing Standards 共SAS兲 No. 67 共AICPA 1991兲 for not confirming the accounts. 共2兲 Generally, confirmations are relatively effective in testing the existence assertion for accounts receivable. However, low response rates have a negative impact on confirmation effectiveness. 共3兲 Anecdotal evidence and some research suggest confirmation response rates are declining. Research has identified several methods to improve response rates. 共4兲 Confirmations are also somewhat effective in examining the valuation assertion for accounts receivable. However, confirmees fail to detect many seeded errors in controlled experiments and are more likely to detect and report errors that are unfavorable to the confirmee rather than favorable errors. 共5兲 Collusion between auditee management and the confirmee was a problem area in receivables confirmations identified from AAERs. The relationship between management and the confirmee calls into question the perception by auditors of confirmees as “independent” third parties. 1 To facilitate the development of auditing standards and to inform regulators of insights from the academic auditing literature, the Auditing Section of the American Accounting Association 共AAA兲 is developing a series of literature syntheses for the PCAOB 共e.g., Allen et al. 2006兲. This paper is a literature synthesis prepared under this program. Additional information about the Research Synthesis Program is available on the Auditing Section website at: http:// aaahq.org/audit/index.htm. The views expressed in this paper are those of the authors and do not reflect an official position of the AAA or its Auditing Section. In addition, while discussions with the PCAOB staff helped us identify the issues that are most relevant to setting auditing standards, the author team was not selected or managed by the PCAOB, and the resulting paper expresses our views, which may or may not correspond to views held by the PCAOB and their staff. Auditing: A Journal of Practice & Theory American Accounting Association November 2008 A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness 255 共6兲 Fictitious responses provided by auditee management were a problem area identified from a review of AAERs for accounts receivable and cash balance confirmations. Current auditing standards do not require auditors to authenticate responses. 共7兲 Enforcement actions described in the AAERs indicated problems with bank confirmations.2 With the exception of accounts receivable, U.S. auditing standards related to confirmations do not provide explicit guidance for specific accounts, such as cash, marketable securities or other account balances, as well as confirmation of special terms or side agreements. 共8兲 Considerable evidence exists that electronic confirmations and other forms of electronic database queries 共i.e., defined views of supplier and/or customer databases兲 are becoming more prevalent. Technology offers alternatives to standard paper confirmations that may provide for authentication and improve confirmation effectiveness 共Aldhizer and Cashell 2006兲. Our study provides new insights into the confirmation process and the reliability of third party confirmations. Practitioners may be placing unwarranted reliance on confirmations because the evidence is provided by “independent” third parties, but collusion between auditee management and the confirmees, found in a number of AAERs, suggests that confirmees may not be “independent” third parties. After all, they do have a customer/supplier relationship with the auditee. Practitioners and regulators alike need to reassess the degree of persuasiveness afforded by third party confirmations in light of these findings. In addition, our review and synthesis of the academic literature found that most confirmation studies focused almost exclusively on accounts receivable confirmations and they were designed primarily to examine issues of reliability and response rates, where reliability is defined in terms of detection of errors. Our study highlights several avenues for future academic research, including research into confirmation evidence for account balances other than accounts receivable, as well as research into the effects of new technologies for electronic responses to confirmation requests. Further, academic research may also examine the issue of the degree of persuasiveness afforded by third party confirmations. The next section briefly describes our research method. The following section provides a summary of the findings from the review of research and enforcement releases. The final section presents our summary and conclusions. METHOD We conducted a review of the academic literature on confirmations. We found few current papers examining confirmations. Most prior research addressed the effectiveness of confirmation of accounts receivable. To provide additional evidence relevant to questions in the SAG briefing paper involving confirmation of other accounts, we reviewed AAERs and practitioner literature.3 We identified 113 confirmation-related AAERs involving 51 auditees. Interestingly, most AAERs dealt with accounts receivable confirmation problems. 2 3 The Auditing Standards Board developed a standard bank confirmation form and suggestions for its use; however, SAS No. 67 does not require bank confirmations 共AICPA 1991兲. AAERs are available at the SEC’s Enforcement Division website and on Commerce Clearing House’s Accounting Research Manager database and cover the period 1982 through 2006. Auditing: A Journal of Practice & Theory November 2008 American Accounting Association 256 Caster, Elder, and Janvrin RELEVANT FINDINGS FROM RESEARCH AND ENFORCEMENT RELEASES Use of Confirmations In response to the large-scale fraud at the McKesson-Robbins Corporation, the accounting profession issued Statement on Auditing Procedures 共SAP兲 Number 1, Extensions of Auditing Procedure, in 1939. Before SAP No. 1, confirmation of receivables was not widely used except in the brokerage and banking industries 共Peloubet 1939兲. McKesson-Robbins created a fictitious subsidiary with fictitious customers and inventory; thus, SAP No. 1 recommended confirmation of accounts receivable “wherever practicable and reasonable” 共American Institute of Accountants 1939兲.4 The first discussion question addresses the effectiveness of confirmations in addressing management assertions. DQ1: Are confirmations an effective source of evidence for auditors in substantiating management’s assertions in the financial statements? If yes, to what extent should confirmations be used during an audit? SAS No. 67 notes that confirmations, if properly designed, may address any one or more of management’s assertions.5 The standard also notes that confirmations do not address all assertions equally well. For example, SAS No. 67 notes that accounts receivable confirmations are likely to be more effective at addressing the existence assertion than the completeness and valuation assertions. Evidence from Accounts Receivable Confirmation Studies Existence Assertion. The McKesson-Robbins case highlights the perceived importance of accounts receivable confirmations as evidence in support of the existence assertion. The subsequent requirements for the use of accounts receivable confirmations were issued based on the belief that if the McKesson-Robbins auditors had sent confirmation requests, they likely would have discovered the fictitious accounts receivable. Ashton and Hylas 共1980兲 indirectly examined the reliability of accounts receivable evidence in support of the existence assertion. They sent 600 confirmation requests, of which 200 requests were sent to fictitious companies at fictitious addresses. The United States Post Office returned all 200 letters as “undeliverable.” Thus, in similar fraud situations, accounts receivable confirmation requests may detect fictitious accounts, assuming no change has occurred in the effectiveness of postal services. However, if management provides valid mailing addresses that are controlled by management, mailing of confirmations will not detect the fictitious customers unless the auditor performs extended procedures to validate the existence of the customer. For the existence assertion, accounts receivable confirmations are probably the best source of evidence, because the evidence is obtained from sources outside of the auditee. Alternative types of evidence, such as sales invoices or bills of lading, are not as persuasive because they are internal documents produced by auditee management. Even with confirmation requirements, accounts receivable frauds continue to occur similar to McKesson-Robbins, such as Equity Funding, or more recent examples such as Royal Ahold 共AAER No. 2124, 2004兲.6 It is an open question as to the extent confirmation requirements inhibit such fraud. 4 5 6 The accounting profession subsequently revised the confirmation standards. The standard currently in effect is SAS No. 67 共AICPA 1991兲. SAS No. 67 specifically refers to the five management assertions in SAS No. 31 共AICPA 1980兲 —existence or occurrence, completeness, rights and obligations, valuation or allocation, and presentation and disclosure. SAS No. 106 共AICPA 2006a兲 replaced SAS No. 31 and is applicable for audits of nonpublic entities. Many cases cited involve multiple AAERs. In these cases, we cite the most relevant AAER. Auditing: A Journal of Practice & Theory American Accounting Association November 2008 A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness 257 Valuation and Other Assertions. Prior academic literature on accounts receivable confirmations has focused on the reliability of the evidence in support of the valuation assertion, although anecdotal evidence supports the use of confirmations as a secondary source of evidence for the completeness assertion. Studies by Davis et al. 共1967兲, Sauls 共1970, 1972兲, Warren 共1974兲, Sorkin 共1978兲, Armitage 共1990兲, Caster 共1990兲, and Engle and Hunton 共2001兲 addressed the ability of confirmees to detect and report errors seeded into accounts receivable. In general, these studies found that confirmees fail to report a large percentage of seeded errors, and the evidence tends to be biased such that confirmees are more likely to report errors that are unfavorable to the confirmee. Confirmation Effectiveness The effectiveness of the confirmation process must also be considered. Several studies examined one aspect of effectiveness, confirmation response rates. In a field experiment conducted at a large retailer, Ashton and Hylas 共1981b兲 examined seven different techniques designed to increase confirmation response rates. They found that attention-getting techniques used in survey research, such as the type of postage used and pre-notification by postcard, enhanced confirmation response rates. Also, stamping the envelope with “confirmation enclosed” increased response rates. Other techniques were less successful, although personally signed requests and requests that included balance details increased response rates slightly. Bailey and Ballard 共1986兲 tested four techniques to increase response rates. They found that three techniques—using a first class stamp on the reply envelope, enclosing a token gift 共a pen兲, and sending a follow-up reminder letter—enhanced response rates. The fourth technique, a rubber stamp reading “important—please respond” was not effective. File and Ward 共1995兲 found that response rates to second confirmation requests can be increased by printing the requests on the auditor’s letterhead instead of on the auditee’s letterhead. Engle 共1991兲 and Engle and Hunton 共2001兲 found that small monetary incentives helped increase response rates. However, Engle and Hunton 共2001兲 also found that detection rates of seeded errors were lower for groups given small monetary incentives. Krogstad and Romney 共1980兲 conducted a field experiment to test the effectiveness of confirming individual invoices included in year-end accounts receivable rather than the entire yearend account balance. They found that invoice confirmations improved confirmation reliability and effectiveness. Response rates were significantly higher and fewer exceptions were noted as compared to traditional account balance confirmation requests. However, Ashton and Hylas 共1981a兲 also conducted an experiment on invoice and balance confirmation requests, and their results favored balance confirmations. In addition, Allen and Elder 共2001兲 did not report any increase in response rates for invoice confirmation requests over balance confirmation requests when examining workpapers for audits of 53 medium-sized companies; the sample included three large accounting firms. They also found that fewer errors were detected by invoice confirmations. Swearingen et al. 共1991兲 used a field study to examine confirmation effectiveness based on the type of confirmation respondent. Accounts payable clerks 共presumably with some accounting training兲 reported a greater number of errors with greater magnitude than individual consumer respondents 共presumably with little to no accounting training兲. However, individual consumers were better than accountants at detecting certain types of errors, such as unrecorded collections and unrecorded returns and allowances. Evidence from SEC AAERs Our review of AAERs revealed several instances of collusion between auditee management and their customers that limited the effectiveness of confirmations. For example, in the Digital Lava case 共AAER-1807, 2003兲, management persuaded their customers to sign and return false Auditing: A Journal of Practice & Theory November 2008 American Accounting Association 258 Caster, Elder, and Janvrin confirmations. In Suprema 共AAER-1938, 2004兲, auditee management even paid the customer for the false confirmations. Collusion between auditee personnel and their customers was the most prevalent pitfall found in our review of AAERs. In other cases such as Quintus 共AAER-1560, 2002兲, auditee personnel were able to forge signatures or otherwise provide auditors with false receivable confirmations. These cases call into question the reliability of confirmation evidence and the perception that confirmation evidence is more persuasive because it comes from “independent” third parties. Some cases highlighted that confirmation evidence can be effective in determining existence and supporting valuation when collusion is not involved. For example, AAER-1295 共2000兲, involving Boston Scientific, specifically noted that the accounts receivable fraud was detected by the accounts receivable confirmations. In other cases such as California Micro Devices 共AAER-1823, 2003兲, the confirmation process worked; however, the auditors failed to follow up on confirmation exceptions. Summary of Question 1 Confirmation effectiveness varies depending upon which management assertion is involved. Academic research suggests that confirmations provide effective evidence to support the accounts receivable existence assertion. However, the effectiveness of confirmations is limited by nonresponses, and anecdotal evidence suggests that response rates may have declined over time.7 Further, a review of AAERs found a significant number of cases involving collusion and also forged and false confirmations, suggesting that confirmation evidence may not be as persuasive as it is generally perceived.8 Findings from academic research indicate confirmations are somewhat less effective in supporting the valuation assertion. Although many errors are reported to auditors on confirmation forms, confirmees fail to detect and report a significant percentage of seeded errors. Moreover, the procedure produces biased results in that confirmees are more likely to report errors that overstate accounts receivable rather than understate the balance. Table 1 provides a summary of response and detection rates for selected receivable confirmation studies. Early studies in Panel A indicate very high response rates, while later studies indicate significantly lower response rates. This could reflect a decreased willingness of confirmees to respond, or it may represent a lack of auditor effort in obtaining responses through second and third requests. These studies pre-date the Sarbanes-Oxley Act. Public companies may be less willing to respond to confirmation requests to avoid any potential legal responsibility under the Act for failure to detect misstatements 共Aldhizer and Cashell 2006兲. Further, Panel B does not indicate that invoice confirmations result in higher responses. Invoice and balance confirmations are significantly different, but little evidence exists on the extent of use of invoice confirmations and their relative effectiveness. Confirmation Pitfalls DQ2: Are there any pitfalls the auditors should be aware of in using confirmations? Pitfalls Identified in Practitioner Literature. The pitfalls Carmichael 共1991兲 identified when the AICPA Auditing Standards Board was considering SAS No. 67 are still relevant today. 7 8 Although it is widely believed that response rates have declined, this has not been examined in any controlled longitudinal study. Elder and Allen 共2005兲 reported a decline in response rates of approximately 6 percent between 1994 and 1999 based on a field study of 53 companies in 1994 and 41 companies in 1999. An IAASB issues paper 共IFAC 2006兲 also notes that the presumption that confirmations may provide reliable evidence may be overstated, and that auditors may not be well suited to identify when a response is not reliable. Auditing: A Journal of Practice & Theory American Accounting Association November 2008 A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness 259 TABLE 1 Confirmation Response and Detection Rates for Selected Studies Panel A: Response Ratesa Study Davis et al. 共1967兲 Hubbard and Bullington 共1972兲 Sauls 共1970兲 Armitage 共1990兲 Caster 共1990兲 Engle 共1991兲 Engle and Hunton 共2001兲 Allen and Elder 共2001兲 Elder and Allen 共2005兲 Type of Entity Bank—demand deposit accounts Heating oil distributor Credit union—time deposits: Standard Blank form Midwestern manufacturer Steel distribution company Bank—installment and commercial loans 4 newspaper organizations 53 manufacturers or distributors 41 manufacturers or distributors Sample Size Positive First Request Positive Second Request Positive Total Response 150 68% 21% 89% 34 44% 35% 79% 100 100 50 80% 62% 52% 16% 16% 28% 96% 78% 80% 331 NA NA 68% 40 43% 40% 83% 800 47% NA 47% 1149 NA NA 49%b 683 NA NA 43%b Panel B: Response Rates for Balance versus Invoice Confirmations Type of Balance Invoice Study Entity Confirmations Confirmations Krogstad and Romney 共1980兲 Ashton and Hylas 共1981a兲 Allen and Elder 共2001兲 Elder and Allen 共2005兲 Manufacturing conglomerate 47% 60% Large chemical manufacturer— commercial customers 53 manufacturers or distributors 41 manufacturers or distributors 72% 64% 59% 43% 55% 37% (continued on next page) Auditing: A Journal of Practice & Theory November 2008 American Accounting Association 260 Caster, Elder, and Janvrin TABLE 1 (continued) Panel C: Confirmation Detection Rates for Selected Studies Positive Confirmationsc Study Davis et al. 共1967兲 Hubbard and Bullington 共1972兲 Sauls 共1970兲 Sauls 共1972兲 Warren 共1974兲 Sorkin 共1978兲 Armitage 共1990兲 Caster 共1990兲 Type of Entity Bank—demand deposit accounts Heating oil distributor Credit union— time deposits Bank—personal and automobile loan accounts Credit union— loan balances Bank—loan balances Midwestern manufacturer Steel distribution company Gross Detection Negative Net Detection Confirmations 59% 64% 44% 48% 54% 40% 76% 83% NAd 43% 100% NAd 21% 32% 18% 35% 45% 18% 38% 49% 16% 47% 76% NAd a Only studies or portions of studies that did not involve seeded errors or incentives are reported since seeded errors and incentives may impact response rates. b Study involves field data and is a blend of invoice and balance confirmations. While it is illustrative of response rates actually achieved, these response rates may not represent achievable rates since extent of use of second requests is unknown. c The gross detection rate is the number of errors detected divided by the number of confirmations sent. The net detection rate is the number of errors detected divided by the number of confirmations received. d Negative confirmations were not used. NA = not available. Carmichael raised concerns about the auditor’s responsibility to verify the identity of the confirmation respondent. In many confirmation frauds, such as the Equity Funding case, auditee personnel simply signed confirmation requests themselves. Carmichael 共1991兲 also raised the issue of confirmation responses received by telephone or fax. He cautioned that with nontraditional 共i.e., nonpaper-based兲 confirmation responses, individuals with intent to commit fraud can fairly easily deceive auditors through intercepting and altering the confirmation request. Today, electronic mail can be added to this list of nontraditional confirmation responses. Thus, confirmation respondent authentication is an important issue with both traditional and nontraditional forms of confirmation response. Another pitfall Carmichael 共1991兲 discussed occurs when the confirmee is not independent of the auditee. This will occur in related party transactions and may require auditors to go beyond the confirmation process to seek satisfactory evidence. Auditing: A Journal of Practice & Theory American Accounting Association November 2008 A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness 261 McConnell and Banks 共1998兲 highlighted additional pitfalls in the confirmation process, based on problems identified in the AICPA’s peer review program.9 Pitfalls identified generally involved auditors’ apparent lack of understanding of the guidance contained in SAS No. 67, such as when confirmations do not need to be sent, when it is appropriate to send positive or negative confirmation requests, how to properly project errors from a sample of accounts to the population, and when to apply or not apply alternative procedures. In addition, they also raised the issue of nontraditional forms of confirmation responses. Pitfalls Identified in Academic Literature. As noted earlier, the primary pitfalls identified in academic literature include the overall problem with declining response rates, the inability of respondents to identify seeded errors, and the tendency for respondents to accounts receivable confirmations to identify more errors that overstate rather than understate the accounts receivable balance.10 Pitfalls Identified from a Review of SEC AAERs. We identified several pitfalls from reviewing SEC AAERs as summarized in Table 2. Twenty-five of the cases, representing over 40 percent of the auditees, involve collusion between management and/or employees and their customers. Auditee management persuaded one or more of its customers to provide the auditors with false information, such as failing to admit to side agreements that permitted the right of return or represented sales on consignment, or simply agreeing to sign and confirm a balance that was clearly incorrect. Ten of these cases included concealed side agreements, and another 15 involved false confirmations without side agreements. These cases are most problematic for auditors, because direct correspondence with third parties is considered to have a high degree of persuasiveness. However, when third parties collude with auditees, detection of the fraud is much more difficult. In ten cases, auditee management provided confirmations with forged signatures to the auditors. For example, a Quintus officer 共AAER-1560, 2003兲 provided auditors with contracts and purchase orders with forged signatures in addition to the false confirmations. Ten other cases involved auditors failing to send confirmations or gather sufficient evidence. For example, in the Powerball International, Inc. case 共AAER-1985, 2004兲, the auditors relied on a faxed copy of a bank statement. Another seven cases involved inadequate follow-up on confirmation exceptions, and four cases involved auditors’ failure to adequately control the confirmation process. Special Terms and Side Agreements DQ3: Should an auditing standard on confirmations require auditors to confirm the terms of revenue transactions? If yes, in what circumstances? DQ4: Should an auditing standard on confirmations require auditors to confirm the absence of side agreements and oral modifications of side agreements? If yes, in what circumstances? Revenue recognition is a high-risk area, as evidenced by the number of financial statement restatements involving revenue transactions 共Beasley et al. 1999兲. Academic research has not directly addressed the existence of special terms or side agreements, or whether confirmations 9 10 Peer review is the review of a CPA firm’s quality control system for its accounting and auditing practice performed by another CPA firm, and is required for membership in the AICPA. The Sarbanes-Oxley Act requires the PCAOB to perform inspections of auditors of public companies to assess compliance with the Act, the rules of the Board and the Securities and Exchange Commission, and professional standards. The PCAOB inspections replace peer review for audit firms’ public company audit practice. Details were discussed earlier under the caption “Valuation and Other Assertions.” Auditing: A Journal of Practice & Theory November 2008 American Accounting Association 262 Caster, Elder, and Janvrin TABLE 2 Summary of Confirmation Pitfalls Identified from Accounting and Auditing Enforcement Releases (AAERs) Confirmation Pitfall Number of Occurrences Auditee personnel colluded with customer and customer provided a signed false confirmation—transactions included concealed side agreements. 10 Auditee personnel colluded with customer and customer provided signed false confirmation—cases did not involve or mention side agreements. Auditee personnel provided forged or false confirmations to auditors. 15 Auditors did not send confirmations or gather sufficient evidence. 10 10 Auditor performed no or minimal follow-up on confirmation exceptions. 7 Auditors did not process confirmation requests properly. 4 Total occurrences Implication Auditors might include inquiries about side agreements in confirmation requests and may need to consider the possibility of collusion and gather other corroborating evidence. Auditors may need to consider the possibility of collusion and gather other corroborating evidence. Auditors may need to consider procedures to authenticate confirmation responses, especially for material items. Additional guidance regarding when cash and accounts receivable confirmations are required or recommended may be needed. Auditors may need to demonstrate further professional skepticism and diligently perform alternative procedures. Auditors may need to ensure that confirmations are sent directly to third parties and authenticate responses not received directly by mail. 56 Pitfalls were identified from examination of 113 AAERs involving confirmation requests. Some AAERs involved more than one confirmation pitfall. would be effective in detecting the existence of these items. As indicated in Table 2, ten cases involving collusion included side agreements. We identified an additional 52 AAERs involving 16 companies with concealed side agreements that do not mention confirmations and are not included in Table 2. Carmichael 共1991兲 identified several circumstances that may dictate confirmation of transaction terms in addition to account balances. For example, he suggested that confirming transaction terms may be appropriate for auditees where a moderate-to-high degree of risk of improper revenue recognition is present. Auditors may note that red flags exist regarding potential management misrepresentations, or that the auditee may have entered into side agreements with certain customers. For example, several AAERs included revenue recognition issues involving side agreements with resellers in the software industry. Carmichael also suggested that confirming transaction terms may be appropriate when the auditee has “bill-and-hold” transactions or other unusual revenue recognition policies. Further, Carmichael pointed out that although an auditee’s customer may not volunteer information on side agreements, they often will report them if auditors ask specific questions regarding the existence of such agreements. Auditing: A Journal of Practice & Theory American Accounting Association November 2008 A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness 263 In some cases, the possibility of special terms and side agreements is indicated by the auditee’s industry, nature of sales agreements, or general economic conditions. It may be relatively easy to add confirmation of special terms and side agreements to a positive confirmation request; however, the additional information may decrease already low response rates. In addition, the individual responsible for confirming account balances may not be knowledgeable about special terms or side agreements. In the Digital Lava case 共AAER-1807, 2003兲, auditee top management was unaware of a side agreement made by a salesperson. Research has not assessed the ability of confirmations to detect side agreements and other special terms, and whether requesting such information would impact confirmation response rates. Confirming the existence of transactions and the existence of special terms instead of, rather than in addition to, account balance information may be one technique to mitigate the potential adverse effect on response rates. SAS No. 99 requires auditors to identify revenue recognition as a specific fraud risk in most circumstances. Confirming specific revenue transactions or the existence of any side agreements may be one technique to address revenue recognition fraud risks such as bill-and-hold sales, channel stuffing, side agreements for return of goods, and other techniques to accelerate revenue. Confirmation could be limited to individually significant accounts or to situations where, as a result of auditee inquiry or other procedures, the auditor believes that special terms of a material nature may exist. Exceptions to the Use of Confirmations DQ5: Confirmation of the terms of significant revenue transactions can provide the auditor with evidence about the existence and amount of any receivable related to the transaction. If a new auditing standard on audit confirmations requires auditors to confirm the existence and terms of certain revenue transactions, should the current SAS No. 67 requirement to confirm accounts receivable be eliminated? A few studies have examined the reliability of invoice confirmations as compared to balance confirmations. We discuss this work since invoice confirmations may share some characteristics with significant revenue transactions; for example, a significant revenue transaction may involve a single invoice. Krogstad and Romney 共1980兲 were the first to suggest that confirming an individual sales invoice amount might improve response rates and confirmation accuracy as compared to confirming an ending account balance, as is usually done. Subsequent studies by Ashton and Hylas 共1981a兲 and Allen and Elder 共2001兲 did not find any improvements in response rates when individual sales invoice amounts were confirmed as compared to account balances. No other academic studies examine the issue of confirming specific details of revenue transactions, such as side agreements involving the right of return or sales that are essentially consignment sales. Evidence from several AAERs found that when side agreements are involved between an auditee and its customers, the customers sometimes cooperate with the auditee by signing false audit confirmation requests. In the Digital Lava case 共AAER-1807, 2003兲, the auditors specifically asked about the existence of side agreements, and the auditee’s customer lied to the auditors and failed to report the side agreement. Research findings indicated that confirmations are most effective in testing for existence and suggest alternative procedures may be more effective when testing for valuation. Confirmation of the existence of a customer relationship and the presence of special terms may provide greater assurance than traditional balance confirmations. Confirmation of the balance would not be necessary as valuation can be tested using alternative procedures. DQ6: If the requirement to confirm accounts receivable is retained, should the exceptions to confirm accounts receivable be retained? If so, should they be clarified? Auditing: A Journal of Practice & Theory November 2008 American Accounting Association 264 Caster, Elder, and Janvrin Under SAS No. 67, a presumption exists that receivable confirmations will be sent unless 共1兲 accounts receivable are immaterial to the financial statements; 共2兲 the auditor’s combined assessed level of inherent risk and control risk is low, and this assessed level, combined with evidence provided by analytical procedures or other substantive tests of details, reduces audit risk to an acceptably low level; or 共3兲 the use of confirmations would be ineffective. The academic and practitioner literature has not addressed the issue of when it may be appropriate not to send confirmation requests. Elder and Allen 共2005兲 provided some evidence that reliance on the exceptions in SAS No. 67 to justify the decision to not send confirmations is increasing, but not widespread. They also noted that auditors do not always justify the decision to not send confirmations. McConnell and Banks 共1998兲 reported that failure to send confirmations was a problem commonly found in peer reviews. Auditors also often failed to appropriately document the justification when receivables confirmations were not sent. AAERs also provide some evidence of a lack of clarity in existing confirmation standards, although the AAERs do not provide enough details to understand why the auditors chose not to send confirmation requests. In the Vista 2000, Inc. case 共AAER-1413, 2001兲, 82 percent of recorded sales were fictitious. The auditor failed to examine purchase orders, invoices, shipping documents, or subsequent cash receipts, and presumably no confirmation requests were sent. In the case of e-Safetyworld 共AAER-2354, 2005兲, the auditee improperly recorded consulting revenue and receivables by arbitrarily valuing stock it received from start-up companies in lieu of cash. Presumably, if confirmations had been sent, the improper valuation would have been detected. In the case of First American Health Concepts 共AAER-2291, 2005兲, the auditee overstated its accounts receivable by 59 percent. The accounts receivable subsidiary ledger did not reconcile to the general ledger, and yet, the audit firm failed to send any confirmation requests. Confirmation of Other Information DQ7: Should an auditing standard on audit confirmations require auditors to confirm cash balances? If yes, under what circumstances? Academic research has not examined the use and effectiveness of cash confirmations. However, a survey of national standards setters by the IAASB found that the quality of responses to bank confirmations was high in 15 out of 24 countries. Poor quality bank confirmations were not complete or accurate or were not returned on a timely basis 共IFAC 2006兲. Confirmation of bank balances is not required under existing auditing standards, but discussions with auditors suggest that confirmation of cash balances is used extensively, even for immaterial amounts. Auditors indicate that the response rate for cash confirmations is high, and these confirmations may also identify other information such as restrictions on cash and indebtedness. Further, the AAER involving Powerball International, Inc. 共AAER-1985, 2004兲 highlights the risk that an auditee may misstate cash when auditors do not confirm cash balances. The president of Powerball stole cash and hid this from the auditors by altering the bank statements and sending the statements to the auditors by fax. The auditor accepted the fax copies of the bank statements as audit evidence and did not send any bank confirmations, even though cash was over two-thirds of the total assets. Accordingly, it may be appropriate to require confirmation of all material cash balances. DQ8: Should an auditing standard on audit confirmations require auditors to confirm balances or transaction terms related to AP, such as purchase commitments? If yes, under what circumstances? Auditing: A Journal of Practice & Theory American Accounting Association November 2008 A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness 265 Use of payables confirmations is generally believed to be limited to situations where internal controls are weak, but their use has not been addressed in academic research. We identified three AAERs involving confirmation of accounts payable. In the case of Hermitite 共AAER-2, 1982兲 the auditors sent accounts payable confirmations because of poor internal controls, but failed to follow up on confirmation exceptions. The poor controls allowed the bookkeeper to embezzle funds, which was detected by the auditors. Another payables case involved Just for Feet 共AAER-1955, 2004兲 in which the auditee convinced vendors to confirm fictitious amounts. Auditors are generally more concerned with completeness than existence for accounts payable. As a result, testing for completeness would require sampling from a population that addresses the possibility of omitted amounts, such as the population of vendors. Confirmation of payables has generally not been considered necessary since external documentation is usually available. However, similar to receivables, the auditor may wish to confirm where evidence of material special terms or commitments exists, such as vendor allowances in the retail industry. DQ9: Should an auditing standard on audit confirmations require auditors to confirm other accounts such as investments and marketable securities? Little academic research exists that examines the effectiveness of confirming other accounts such as investments, marketable securities and inventories stored in public warehouses. Similar to confirming cash balances, confirming investments and marketable securities addresses the existence assertion. In addition to the existence assertion, confirmation of investments and marketable securities may provide evidence in support of the rights 共ownership兲 and valuation assertions. However, Interpretation 1 of SAS No. 92 共AICPA 2005兲 provides guidance on the use of confirmation evidence for securities and cautions that the mere receipt of a confirmation may not provide support for the existence or valuation assertions for certain securities. In AAER-2470 共2006兲, a Big 5 audit partner allowed Lipper Holdings to overvalue investments despite evidence collected from three independent sources indicating investments were overvalued. Technology currently exists to securely trade investments and marketable securities electronically 共Jones 1993; Kopeikin 1996兲. Similarly, with technology, an intermediary online link can be established between the auditor and a client’s third party to share data quickly and at a lower cost. This technology could be adapted to confirm investments and marketable securities holdings. Negative Confirmations Existing guidance in SAS No. 67 indicates that negative confirmations may be used when: 共1兲 the combined assessed level of inherent and control risk is low, 共2兲 a large number of small balances are involved, and 共3兲 the auditor has no reason to believe that the recipients of the requests are unlikely to give them adequate consideration. International Standard on Auditing 共ISA兲 505 共IFAC 2001兲, paragraph 23, gives similar guidance as follows: Negative confirmation requests may be used to reduce the risk of material misstatement to an acceptable level when: 共1兲 共2兲 共3兲 共4兲 the assessed risk of material misstatement is lower, a large number of small balances is involved, a substantial number of errors is not expected, and the auditor has no reason to believe that the respondents will disregard these requests. The two definitions are substantively equivalent. The first requirement in SAS No. 67 is that Auditing: A Journal of Practice & Theory November 2008 American Accounting Association 266 Caster, Elder, and Janvrin the combined risk assessment is low. In contrast, the ISA requirement is that the assessed risk of material misstatement is lower, and a substantial number of errors is not expected. The term “assessed risk of material misstatement is lower” leaves open the question as to how much lower the assessed risk should be. Research by Elder and Allen 共2003兲 found that assessed combined inherent and control risk is low on many U.S. audit engagements. It appears that the intent in each standard is to restrict the use of negative confirmations to areas of very low risk. If that is the case, more precise terminology or supporting guidance may be necessary to identify when risk is sufficiently low to justify use of negative confirmations, as well as the definition of a small balance. This assumes that greater use of negative confirmations is not desirable. The second issue relates to whether confirmees will give confirmation requests adequate consideration. This may be an increased concern given anecdotal evidence of declining response rates to positive confirmation requests. Updated AICPA Practice Alert 2003-01 共AICPA 2007b兲 indicates that auditors may consider the results of positive confirmations in prior years or on similar engagements when determining whether recipients will give the confirmation request adequate consideration. Very little evidence exists on the extent of usage of negative confirmations. However, their use appears restricted to certain industries, such as banks and other financial services, where the requirements of SAS No. 67 are likely to be met. In a study involving three audit firms and a sample of manufacturing and distribution companies, Elder and Allen 共2005兲 found that positive confirmations were used almost exclusively. Use of Negative Confirmations DQ10: Since negative confirmations rarely provide evidence about the assertions related to AR, should an auditing standard on audit confirmations preclude auditors from using negative confirmations and require them to use only positive confirmations? As noted previously, the 200 positive confirmation requests sent to fictitious companies at fictitious addresses by Ashton and Hylas 共1980兲 were all returned as undeliverable. Assuming no changes in the effectiveness of the post office and no differences in mail delivery effectiveness for positive and negative confirmations, auditors may assume that negative confirmations were delivered to the recipient. Little recent evidence exists on the effectiveness of negative confirmations. A review of AAERs did not reveal the existence of enforcement releases related to the use of negative confirmations. Table 1, Panel C summarizes detection rates for positive and negative confirmations from selected studies. The gross detection rate is the number of errors detected divided by the number of confirmations sent. The net detection rate is the number of errors detected divided by the number of confirmations received. Only a gross detection rate can be calculated for negative confirmations. Davis et al. 共1967兲 sent a sample of 350 positive and 497 negative confirmations to bank customers with balances under $10,000. They did not manipulate the balances to be confirmed. Instead, the error condition involved a code included on the customer’s statement. The customers were requested to verify both the balance and the code. The gross 共net兲 detection rate was 59 共64兲 percent for the positive confirmations and 44 percent for the negative confirmations. However, most of the difference in detection rates was attributable to the use of second requests with positive confirmations. Hubbard and Bullington 共1972兲 sent a sample of 100 positive and 100 negative confirmations to customers of a heating oil distributor. The customers were primarily consumers. Within each sample, approximately one-third of the accounts were intentionally shown as overstated and another one-third were understated. Both the average account size and error size were quite small. Auditing: A Journal of Practice & Theory American Accounting Association November 2008 A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness 267 For the misstated accounts, the response rate to positive confirmation requests was higher. However, the error detection rates were not significantly different. Approximately 40 percent of the errors were detected by the negative confirmations and approximately 48 percent by the positive confirmations. Warren 共1974兲 tested the effectiveness of positive and negative confirmations for loan balances for a credit union. The gross 共net兲 detection rate for positive confirmations was 21 共32兲 percent, and the detection rate for negative confirmations was 18 percent. Sorkin 共1978兲 tested confirmations of loan balances for a large bank. The gross 共net兲 detection rate for positive confirmations was 35 共45兲 percent, and the detection rate for negative confirmations was 18 percent. Armitage 共1990兲 tested the effectiveness of positive and negative confirmations in an internal audit setting for a Midwest manufacturing firm. He sent 250 positive and 250 negative confirmations; 200 confirmations in each group were misstated. He manipulated both the direction and size of the error; the errors were larger than in previous studies. He found that negative confirmations detected only 16.5 percent of the errors. The detection rates for overstated and understated accounts were 26 percent and 7 percent, respectively. In comparison, positive confirmations discovered 38 percent of the errors, and 27.5 percent of the errors on the first request. Table 1, Panel C, summarizes evidence from selected studies on error detection rates for positive and negative confirmations. The evidence indicates that detection rates for negative confirmations are generally statistically significantly lower than those for positive confirmations. The detection rate for positive confirmations is also quite low. Warren 共1974兲 noted that negative confirmations are the least informative, but they are also the least costly. We note that both ISA 505 共IFAC 2001兲 and AICPA Practice Alert 2003-01 共AICPA 2007b兲 indicate that a combination of positive and negative confirmations may be used. ISA 505, paragraph 24, indicates where accounts receivable are made up of a small number of large balances and a large number of small balances, auditors may decide to use positive confirmations for all or a sample of the large balances and negative confirmations for a sample of the small balances. Response rates are higher for smaller account balances 共e.g., Ashton and Hylas 1981b; Bailey and Ballard 1986兲 suggesting customers would give them adequate consideration. The positive confirmations would provide some substantive evidence on the existence and valuation of receivables. The evidence in Elder and Allen 共2005兲 suggests that such mixed testing strategies are rarely used in practice. Rouse and Lathan 共1986兲 suggested that the use of negative confirmations for small balances may be more applicable than indicated in the standards. If the auditee sends regular monthly statements, including a negative confirmation request by use of gummed labels or a sentence added to the statement can be a low-cost form of evidence to supplement the use of positive confirmations for larger balances.11 One interesting technique is the use of positive-out, negative-in 共PONI兲 confirmations 共Williams and Ziegler 1987兲. The PONI confirmations are primarily used in place of negative confirmations. Under this approach, auditors increase the sample size for positive confirmations to account for the expected nonresponse rate. For example, if the sample size is 60 and the expected response rate is 50 percent, the revised sample size is 120 共60 ÷ 50 percent兲. If the expected response rate of 50 percent is realized, auditors will receive 60 positive confirmations, eliminating the need to send second confirmation requests and perform alternative procedures. 11 The gummed label is an adhesive form that includes the auditor’s negative confirmation request and contact information and is attached to the customers’ monthly statements sent by the client, eliminating the need to send separate confirmations. Of course, if the auditor attaches labels to the client’s monthly statements, the auditor must control the mailing of the statements. Auditing: A Journal of Practice & Theory November 2008 American Accounting Association 268 Caster, Elder, and Janvrin These studies suggest that negative confirmations may be underutilized as an approach. Additional guidance could clarify that the requirements for sending negative confirmation requests apply when negative confirmations are the only or primary source of evidence regarding accounts receivable. Additional Procedures with Use of Negative Confirmations DQ11: If an auditing standard on audit confirmations continues to permit the use of negative confirmations in certain circumstances, should the standard require auditors to apply other substantive procedures to supplement the use of negative confirmations? We were unable to identify academic research or other relevant literature to address this normative question. Although tests of controls are not a substantive procedure, the use of negative confirmations currently requires a low combined assessed level of inherent and control risk. To justify a low assessment for control risk, auditors must document and test controls. Required substantive procedures in addition to the use of negative confirmations could add unnecessary cost if the requirements for sending negative confirmations have been clearly met. It may be appropriate for auditors to use substantive analytical procedures of the account balance tested by the negative confirmation procedures, and extended procedures where responses to negative confirmations suggest that errors exist in the account balance. Management Requests Not to Confirm DQ12: Should an auditing standard on audit confirmations address the auditor’s responsibility when clients request that the auditors refrain from confirming account balances or other information? If yes, how? We are unaware of evidence that addressed this issue. A search of recent AAERs did not identify circumstances involving management requests not to confirm accounts. In an older case involving J.B. Hanauer 共AAER-13, 1983兲, the auditee requested that multiple accounts involving fraud not be confirmed. Both Practice Alert 2003-01 共AICPA 2007b兲 and ISA 505 共IFAC 2001兲 indicate that the auditor should consider the reasonableness of the request and perform alternative procedures. The Practice Alert further indicates that the existence of a dispute is insufficient reason for not confirming the account and auditors should seek corroborating evidence supporting the decision not to confirm. ISA 505 indicates that auditors should consider whether the request has implications regarding management’s integrity or indicates possible fraud or error. Practice Alert 2003-01 recommends that auditors document in the client representation letter requests not to confirm, including the reasons for the request. The Practice Alert notes that if the request not to confirm is considered reasonable, it is not a scope limitation. The magnitude of the request is not directly discussed in the Practice Alert. However, if the amounts requested not to be confirmed exceed planning materiality, this could be considered a specific fraud risk that requires auditors to apply additional procedures beyond standard alternative procedures to establish the existence of the receivables. Additional Issues DQ13: Are there other practice issues that should be addressed in an auditing standard on audit confirmations? Our review of AAERs and the literature on pitfalls in the confirmation process suggests that the issues of authentication and automation should be considered. Authentication involves verifying both the identity of the respondent and the absence of intruders during the transmittal process. Auditing: A Journal of Practice & Theory American Accounting Association November 2008 A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness 269 For example, Parmalat 共AAER-1936, 2003兲 involved a forged cash balance confirmation for $4.9 billion held by a Grand Cayman subsidiary of the company at a New York branch of a major bank. The confirmation was on a nonstandard confirmation form, but the auditors did not question the response, despite the amounts involved. The account did not exist, indicating the need to authenticate cash balance confirmation responses and perform additional procedures to validate material bank balances. Traditionally, the transmittal process involved auditors mailing paper confirmations to third parties who signed and returned via postal mail the original paper confirmations. To obtain assurance that no one tampered with the transmittal process, auditors examined each response looking for any unexplained changes to information. However, auditors need to go further to establish the validity of responses for material balances. With automation, auditors can use nontraditional forms of communication such as fax, phone, and/or email to obtain confirmation information from third parties. For example, auditors may email their information request to a third party and ask for an electronic response. Furthermore, in response to confirmation requests, some third parties may provide auditors access to their databases. Several other industries now communicate with customers and vendors electronically 共e.g., brokerage firms 共Kopeikin 1996兲, banking 共Zimmermann 1989兲, and healthcare 共Bingham 2001兲兲 and these nontraditional communication forms may increase response rates. One concern is that these nontraditional communication forms reduce control over the confirmation process and increase the likelihood of fraud. For example, an auditee could intercept a confirmation request emailed to a vendor, falsely “verify” the information, and return it to the unknowing auditor. However, technological advances such as authentication protocols and “security paper” are available to verify 共1兲 the identity of the third parties providing electronic responses, and/or 共2兲 the absence of intruders during the transmittal process 共Marcial 2006兲. Current auditing standards do not address how auditors should authenticate confirmations sent and/or received via these newer communication forms, although an interpretation of SAS No. 67 共AICPA 2007a兲 indicates if electronic confirmations are secure and properly controlled they may be considered sufficient, valid confirmation responses. Practice Alert 2003-01 共AICPA 2007b兲 indicates that direct inquiry of a third-party database is not a confirmation but an alternative procedure. Auditing standards should address whether such inquiries constitute sufficient appropriate evidence. Other issues arising from our review of AAERs include 共1兲 the prevalence of collusion by auditee management or other auditee personnel and confirmation respondents, and 共2兲 failure of auditors to follow confirmation procedures properly. For example, auditors may not follow up on exceptions or nonresponses, a problem that has been noted in PCAOB inspection reports of smaller audit firms 共AICPA 2006b兲. Also, they may not consider the effectiveness of confirmations when selecting sample sizes and evaluating sample results. Although Krogstad and Romney 共1980兲 indicated larger sample sizes should be used for invoice confirmation, Elder and Allen 共2005兲 found that type of confirmation does not impact the confirmation sample size decision in practice. Although recent auditing guidance encourages auditors to use computer-assisted audit techniques 共CAATs兲 when selecting confirmation samples 共AICPA 2001; PCAOB 2004a兲, recent research indicates that many auditors are not using CAATs for this purpose 共Janvrin et al. 2009兲. Use of audit software such as ACL or IDEA offers efficient methods to select and generate confirmations. The effectiveness of these types of audit software would be further enhanced if they were integrated with electronic techniques to authenticate responses. Auditing: A Journal of Practice & Theory November 2008 American Accounting Association 270 Caster, Elder, and Janvrin SUMMARY AND CONCLUSIONS We reviewed academic and practitioner research on the use of confirmations, as well as AAERs. This evidence generally supports the effectiveness of receivables confirmations in testing for the existence and valuation of accounts receivable, although this effectiveness is hindered by low response rates. Further, enforcement releases found several confirmation pitfalls, especially a significant number of cases of collusion between auditees and customers, many involving concealed side agreements. As a result, practitioners may be placing undue reliance on confirmations, assuming that they are derived from independent sources. These findings have several implications for standard setters, practitioners, and academic researchers. First is a need to improve response rates, as well as authenticate responses. Technology, perhaps involving third-party intermediaries, can help address these issues. Second, depending on the circumstances and identified risks, auditors may need to confirm the existence of side agreements and special terms. Auditors may also need to consider the possibility of collusion in their testing strategies. In addition, confirmation requirements may need to be extended to other accounts, at least in some circumstances. Many questions raised in the SAG report and in our current study have not been addressed by existing research. We encourage further research in the following areas: 共1兲 Client collusion with confirmees was a significant problem identified in AAERs. What client and confirmee factors are associated with collusion? 共2兲 Similarly, research could be conducted to determine auditors’ awareness of the prevalence of collusion, forgeries, and false confirmations in detected frauds. How persuasive do auditors view confirmation evidence, and is this reliance overstated because of the perception that it is derived from “independent” third parties? 共3兲 Do accounts receivable confirmations inhibit fraud? If confirmations were no longer required, would creation of fictitious accounts receivable increase? 共4兲 Issues with special terms and side agreements were identified in AAERs, and anecdotally seem to be associated with certain industries. What factors are associated with the existence of such agreements? When is confirmation of special terms and side agreements appropriate? 共5兲 Would confirmation of special terms and side agreements in addition to receivable balances adversely impact confirmation response rates? 共6兲 Studies suggest declining response rates to confirmations. Have response rates declined further, especially after the Sarbanes-Oxley Act? What factors are associated with nonresponses to help guide auditors’ confirmation decisions? 共7兲 Can alternative forms of confirmation requests provide greater assurance? Existing receivable confirmations focus on the valuation of the balance, but the balance is readily tested using alternative procedures. Research on the effectiveness of confirmations that focus on any special terms in addition to confirming the account balance would be useful. 共8兲 How effective are alternative procedures in detecting errors? Although an extensive amount of research has tested the effectiveness of confirmations in detecting seeded errors, little research has addressed the effectiveness of alternative procedures that may replace or supplement them. 共9兲 Can mixed testing strategies provide greater levels of assurance? Auditors currently apply the same techniques to all receivables tested. A mix of positive and negative confirmations, as well as confirmation of special terms for larger or high-risk accounts, may provide greater assurance. Auditing: A Journal of Practice & Theory American Accounting Association November 2008 A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness 271 共10兲 How familiar are auditors with existing confirmation standards? Do they understand the exceptions for when confirmations do not have to be sent? Do these exceptions need clarification? 共11兲 How prevalent are management requests not to confirm receivables, and how have auditors responded to those requests? 共12兲 What are the costs and benefits of using electronic communication technologies to send and receive confirmations, as well as authenticate responses? How do these compare to authentication techniques for paper confirmations? There is limited current research on confirmations. Early studies addressed confirmation effectiveness using data from an individual client, while other studies used controlled experiments based on a single client to assess the effectiveness of various techniques in improving response rates. It is likely that the lack of current research is at least partially attributable to a lack of data on accounting firms’ use of confirmations. Many of the research questions we have identified could be addressed using controlled experiments or archival data from audit firms. We encourage audit researchers to pursue these questions and audit firms to provide data access to support such research. Auditing: A Journal of Practice & Theory November 2008 American Accounting Association 272 Auditing: A Journal of Practice & Theory American Accounting Association TABLE 3 APPENDIX Citation Summary Citation Allen and Elder 共2001兲 Ashton and Hylas 共1980兲 Purpose Investigate response rates and error detection rates for balance and invoice confirmations. Determine whether U.S. Postal Service will return confirmations that cannot be delivered. Research Methods Reviewed workpapers for 53 audits of medium-sized companies audited by three large audit firms. Mailed 600 confirmations to nonexistent names and/or addresses in 25 cities. Variables manipulated were: • Recipient 共individual or business兲 Determine whether differences in response rates exist for balance and invoice confirmations. • Average response rate was under 50%. • Response rate was higher for balance than invoice confirmations. • Balance confirmations tested greater percentage of receivables dollars and identified more errors. • 100% of non-existent names for non-existent addresses were returned as undeliverable. • Some confirmations were delivered if an existing name 共address兲 was used with a nonexistent address 共name兲. November 2008 • Response rates were significantly higher for balance than invoice confirmations. Response rate was 60.8% 共54.4%兲 for balance 共invoice兲 confirmations for first requests, and 72.1% 共64.4%兲 for first and second requests. • Smaller customers were more likely to respond. (continued on next page) Caster, Elder, and Janvrin Ashton and Hylas 共1981a兲 • Size of city • Type of postage • Error 共non-existent addressee and/or address兲 Mailed 1,344 confirmation requests to domestic customers of one large chemical company. Findings Citation Purpose Ashton and Hylas 共1981b兲 Determine whether various techniques were effective in improving confirmation response rates. Bailey and Bullard 共1986兲 Determine whether various techniques were effective in improving confirmation response rates. Assess reliability of positive confirmation requests. Mailed 480 confirmations for customers of large retail firm; manipulated seven research variables: • Type of postage • Postcard prenotification • Signature • Use of letterhead • Alternative wording • Statement detail • Size of account balance Tested following four techniques using sample of 593 sales contracts for real estate company while controlling for size of account: • Stamp Findings • Prenotification postcards and special postage 共individual stamp, indication of “confirmation enclosed” or special delivery兲 improved response rates. • Stamp, gift pen, and thank you were effective at improving initial responses. • Gift pen • Effects were not additive. One technique was as effective as two or more. • After second requests, only gift pen was associated with significant improvement in response rates, and only for smaller accounts. • Attention stamp • Thank you letter Mailed confirmations with seeded errors to 331 steel company customers. Manipulated variables were: • Error direction • 47% of errors were detected and reported to auditors. • Confirmees were somewhat more likely to detect large unfavorable errors. (continued on next page) 273 November 2008 American Accounting Association Caster 共1990兲 Research Methods A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness Auditing: A Journal of Practice & Theory TABLE 3 (continued) 274 Auditing: A Journal of Practice & Theory American Accounting Association TABLE 3 (continued) Citation Purpose Research Methods • Error size Davis et al. 共1967兲 Elder and Allen 共2005兲 Assess effectiveness of various types of confirmations for personal demand deposit accounts. Assess whether firms decreased use of confirmations and changed type of confirmations used. • Account balance size • Account transaction volume • Account age Mailed 874 confirmations with seeded error in account code 共not account balance兲. Types of confirmations were: • Positive confirmations • Negative confirmation—letter • Negative confirmation—request for phone call if discrepancy Reviewed workpapers for 53 audits in 1994 and 46 audits in 2000; 28 audits were common to both periods. Data collected included: • Whether confirmations were used • Account balance size, transaction volume, and age were not significantly associated with error detection. • Response rate for positive confirmations was 91%. • Detection rate was 59% for positive confirmations; 44% for negative confirmations. • Audit firms were less likely to send confirmations in latter period, but were still likely to use confirmations on almost all audits. November 2008 • Two Big 4 firms extensively used invoice confirmations and increased their use in later period. • Overall response rate was below 50% in both periods; response rate was higher for balance confirmations. • Response rates (continued on next page) Caster, Elder, and Janvrin • Type of confirmation 共balance or invoice兲 Findings Citation Engle 共1991兲 Engle and Hunton 共2001兲 Purpose Assess whether prenotifications and small monetary incentives increased response rates for confirmations. Assess whether small monetary incentives improved response rates and quality. Research Methods Mailed confirmations to 240 customers with loan balances at west central Florida bank. Variables were: • Prenotifications encouraged timely responses but did not improve response rates. • Incentive 共none, $.25, $1.00兲 • Small monetary incentives increased response rates for installment loans, but only in absence of prenotification. • Prenotification 共letter or none兲 • Account 共installment or commercial兲 Mailed 7,200 confirmations to customers of four large independent newspaper organizations. Experimental variables: • Misstatement 共none, understatement, overstatement兲 • Incentive 共none, $.25, $1.00兲 File and Ward 共1995兲 Assess reliability of positive confirmations compared to negative confirmations. Examined data from nine audits of commercial businesses by midwestern offices of three international audit firms. Mailed 102 positive confirmations and 102 negative confirmations with small seeded errors to customers of heating oil company. Errors were all transposition errors. • Monetary incentives improved response rates across all conditions. • Overstatement errors were more likely to be detected; incentives did not narrow difference in detection rates. • Incentives were associated with decrease in detection rates. • CPA letterhead response rate of 36.0% was lower than response for auditee letterhead 共38.6%兲. • Responses for auditee letter were six times more likely to indicate exception. • Overall detection rate was 48.5% for positive confirmations; 39.7% for negative confirmations. (continued on next page) 275 November 2008 American Accounting Association Hubbard and Bullington 共1972兲 Determine whether use of audit letterhead improves response to second requests. Findings A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness Auditing: A Journal of Practice & Theory TABLE 3 (continued) 276 Auditing: A Journal of Practice & Theory American Accounting Association TABLE 3 (continued) Citation Krogstad and Romney 共1980兲 Sauls 共1970兲 Sauls 共1972兲 Purpose Assess whether invoice confirmations increased response rates and were less time-consuming than balance confirmations. Assess effects of nonresponse and improper response on evaluation of accounts receivable balances. Comparison of use of balance and invoice confirmations for one auditee of large audit firm involving 187 balance confirmations in 1975 and 300 invoice confirmations in 1976. Mailed 160 confirmations out of a population of 456 Michigan State University Credit Union accounts. Variables manipulated were: • Seeded error—10% negative and positive adjustments to account balance. • Type 共standard versus blank form兲 Mailed 230 confirmations to personal loan and automobile loan accounts for customers of Continental Illinois National Bank. Sample consisted of: Findings • Response rate for positive confirmations was 86% after sending second requests. • Response rate was 60% for invoice confirmations compared to 46.5% for balance confirmations. • Audit hours decreased from 187 hours with balance confirmations to 143 hours with invoice confirmations. • Overall response rate was 83%. • Response rate to standard confirmation without errors was 96%; response rate to blank forms was 78%. • Improper responses were received for 17% of confirmations with seeded errors; no improper responses were received using blank forms. • Blank forms appear to reduce improper responses, but also lower response rates. • Nonresponse rate for blank forms was almost double nonresponse rate for standard confirmations. (continued on next page) Caster, Elder, and Janvrin November 2008 Determine extent of nonsampling errors in confirmation of accounts receivable from nonresponses and incorrect responses. Research Methods Citation Purpose Research Methods • 100 standard confirmations without adjustment Swearingen et al. 共1991兲 Warren 共1974兲 Assess quality of confirmation responses by businesses, clerks, and consumers. • Error type • Error amount • Confirmee type Mailed confirmations to 361 loan and 363 share accounts at Michigan State University Credit Union. Variables used: • Confirmation type 共positive, negative, blank兲 • Account size 共above or below median兲 • Account type 共loan or share兲 • No improper responses were received to any confirmations, including confirmations with seeded errors. • Accountants reported more than twice the errors consumers did 共4.86% of confirmations compared to 1.68%兲. • However, there was no difference in average size of error detected by accountants compared to consumers. • Blank and positive confirmations are about equally informative. • Negative confirmations are least informative. 277 November 2008 American Accounting Association Determine informativeness of positive, negative, and blank form confirmations • 30 standard confirmations with seeded overstatement errors of approximately 10% of account balance • 100 blank form confirmations Examined confirmation responses from workpapers of two regional and seven international CPA firms. Data collected: • Error rate Findings A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness Auditing: A Journal of Practice & Theory TABLE 3 (continued) 278 Caster, Elder, and Janvrin REFERENCES Aldhizer, G., and J. Cashell. 2006. Automating the confirmation process. The CPA Journal 共April兲: 6–10. Allen, R., and R. Elder. 2001. An empirical investigation of the effectiveness of balance and invoice confirmations. Journal of Forensic Accounting 2: 3–16. ——–, D. Hermanson, T. Kozloski, and R. Ramsay. 2006. Auditor risk assessment: Insights from the academic literature. Accounting Horizons 22 共June兲: 157–178. American Institute of Accountants 共AIA兲. 1939 Extensions of Auditing Procedure. Committee on Auditing Procedure. Statement on Auditing Procedure No. 1. New York, NY: AIA. ——–. 1980. Evidential Matter. Statement on Auditing Standards No. 31. New York, NY: AICPA. ——–. 1991. The Confirmation Process. Statement on Auditing Standards No. 67. New York, NY: AICPA. ——–. 2001. The Effect of Information Technology on the Auditor’s Consideration of Internal Control in a Financial Statement Audit. Statement on Auditing Standards No. 94. New York, NY: AICPA. ——–. 2005. Auditing Derivative Instruments, Hedging Activities, and Investments in Securities: Auditing Interpretations of Section 332. Interpretation 1 of Statement on Auditing Standards No. 92. New York, NY: AICPA. ——–. 2006a. Audit Evidence. Statement on Auditing Standards No. 106. New York, NY: AICPA. ——–, Center for Public Company Audit Firms. 2006b. Smaller Firm PCAOB Inspection Deficiency Analysis. New York, NY: AICPA. ——–. 2007a. The Confirmation Process: Auditing Interpretations of Section 330. Interpretation 1 of Statement on Auditing Standards No. 67. New York, NY: AICPA. ——–, Professional Issues Task Force. 2007b. Practice Alert 2003-01, Audit Confirmations. New York, NY: AICPA. Armitage, J. 1990. Accounts receivable confirmation effectiveness. Internal Auditing 共Summer兲: 15–24. Ashton, R., and R. Hylas. 1980. The return of problem confirmation requests by the U.S. Postal Service. The Accounting Review 55 共October兲: 649–657. ——–, and R. Hylas. 1981a. A study of the response to balance and invoice confirmation requests. Journal of Accounting, Auditing and Finance 4: 325–332. ——–, and ——–. 1981b. Increasing confirmation response rates. Auditing: A Journal of Practice & Theory 1 共Summer兲: 12–22. Bailey, C., and G. Ballard. 1986. Improving response rates to accounts receivable confirmations: An experiment using four techniques. Auditing: A Journal of Practice & Theory 5 共Spring兲: 77–85. Beasley, M., J. Carcello, and D. Hermanson. 1999. Fraudulent Financial Reporting: 1987–1997: An Analysis of Public Companies. Committee of Sponsoring Organizations of the Treadway Commission. Jersey City, NJ: AICPA. Bingham, A. 2001. Internet-based eligibility verification lowers costs, improves payment timeliness. Healthcare Financial Management 55 共February兲: 47–49. Bonner, S., Z-V. Palmrose, and S. Young. 1998. Fraud type and auditor litigation: An analysis of SEC accounting and auditing enforcement releases. The Accounting Review 73 共October兲: 503–532. Carmichael, D. 1991. Pitfalls in the confirmation process. The CPA Journal 共June兲: 54–56. Caster, P. 1990. An empirical study of accounts receivable confirmations as audit evidence. Auditing: A Journal of Practice & Theory 9 共Fall兲: 75–91. Davis, G., B. Neter, and R. Palmer. 1967. An experimental study of audit confirmations. Journal of Accountancy 共June兲: 36–44. Dechow, P., R. Sloan, and A. Sweeney. 1996. Causes and consequences of earnings manipulation: An analysis of firms subject to enforcement action by the SEC. Contemporary Accounting Research 13 共Spring兲: 1–36. Elder, R., and R. Allen. 2003. A longitudinal field investigation of auditor risk assessments and sample size decisions. The Accounting Review 78: 983–1002. ——–, and ——–. 2005. An empirical investigation of changes in confirmation procedures. Working paper, Syracuse University. Engle, T. 1991. Increasing confirmation response rates: Prenotifications, monetary incentives and address differences. Journal of Accounting, Auditing and Finance 6 共1兲: 109–127. Auditing: A Journal of Practice & Theory American Accounting Association November 2008 A Summary of Research and Enforcement Release Evidence on Confirmation Use and Effectiveness 279 ——–, and J. Hunton 2001. The effect of small monetary incentives on response quality and rates in the confirmation of accounts receivable balances. Auditing: A Journal of Practice & Theory 20 共March兲: 157–168. File, R., and B. Ward. 1995. Improving the results of second request confirmation procedures. Auditing: A Journal of Practice & Theory 14 共Spring兲: 87–93. Hubbard, T., and R. Bullington. 1972. Positive and negative confirmations—A test. Journal of Accountancy 共March兲: 48–56. International Federation of Accountants 共IFAC兲. 2001. External Confirmations. International Standard on Auditing 505. New York, NY: IFAC. ——–. 2006. External Confirmations—Issues Paper. New York, NY: IFAC. Janvrin, D., J. Bierstaker, and J. Lowe. 2009. An investigation of factors influencing the use of computerrelated audit procedures. Journal of Information Systems 共forthcoming兲. Jones, D. 1993. First tests of electronic confirmation links. Financial Technology International Bulletin 11 共November兲: 6–7. Kopeikin, R. 1996. Secure trading on the net. Telecommunications 共October兲: 89–94. Krogstad, J., and M. Romney. 1980. Accounts receivable confirmation: An alternative approach. Journal of Accountancy 149 共February兲: 68–74. Marcial, G. 2006. Watch it counterfeiters. BusinessWeek 共February 13兲: 92. McConnell, D., and G. Banks. 1998. A common peer review problem. Journal of Accountancy 185 共June兲: 39–44. Peloubet, M. 1939. The McKesson and Robbins case. The Chartered Accountant in Australia 共May兲: 722– 733. Public Company Accounting Oversight Board 共PCAOB兲. 2004a. An Audit of Internal Control Over Financial Reporting Performed in Conjunction with an Audit of Financial Statements. Release No. 2004-001 共March 9兲. Washington, D.C.: PCAOB. ——–. 2004b. Standing Advisory Group Meeting: Audit Confirmations. September 8–9. Washington, D.C.: PCAOB. Rouse, R., and M. Lathan. 1986. Improving the confirmation process. The CPA Journal 共December兲: 58–61. Sauls, E. 1970. An experiment on nonsampling errors. Journal of Accounting Research 共Supplement兲: 157– 171. ——–. 1972. Nonsampling errors in accounts receivable confirmation. The Accounting Review 47 共January兲: 109–115. Sorkin, H. 1978. The Expanded Field Confirmation. IIA Research Report No. 21. Altamonte Springs, FL: The Institute of Internal Auditors 共IIA兲. Swearingen, J., F. Wilkes, and S. Swearingen. 1991. Confirmation response differences between businesses, clerks and consumers. The CPA Journal 共May兲: 58–60. Warren, C. 1974. Confirmation informativeness. Journal of Accounting Research 12 共1兲: 158–177. Williams, D., and T. Ziegler. 1987. Positive-out negative-in confirmations–An innovative confirmation approach. The CPA Journal 共July兲: 78–81. Zimmermann, K. 1989. Reg. CC, marketing perks, spark interest in signature verification. Bank Systems & Equipment 26 共April兲: 64–67. Auditing: A Journal of Practice & Theory November 2008 American Accounting Association