Well, it has come to pass. The new guidance from the SEC and PCAOB will almost certainly be officially stamped in time for the guidance to apply to 2007 audits. So good luck. The new rules will mean different things to different companies. My guess is that the internal process may not change dramatically this year, though everyone should breath easier. The new guidance does not require an opinion on the effectiveness of managements' risks review process--that sort of sets the tone for compliance under AS5. Even though the document is a lot shorter than AS2, it contains an awful lot. There aren't any huge surprises. My short list of notable items: The guidance aims to ease the transition for small-companies, which have been exempt until now, including lots of notes on how rules apply. The text is a lot easier to understand. It does not, unfortunately, provide a very specific definition of materiality. Still, Sarbanes-Oxley is here to stay, and this clears the air some.
As for the larger effects, they are being debated. The early take is that the new rules are great for large companies [1]--one analysts says corporate earnings will rise by 2 percent--while vendors, staffing firms and maybe the Big Four suffer. Others aren't so sure [2].
For more:
- here's an overview [3]
- here's the quick take [4] on the new standard
- here's the whole enchilada [5] with some added sauce
- even more guidance coming from COSO [6] via grant Thornton