15.2 Other Information, Supplementary Information & Special Purpose Frameworks
Key Takeaways
- Under AU-C 720, the auditor must read other information in annual reports to identify material inconsistencies with audited financial statements or misstatements of the other information, but does not audit or express an opinion on it.
- Under AU-C 725, the auditor performs procedures on supplementary information and gives an 'in-relation-to' opinion; an adverse opinion or disclaimer on the statements precludes any opinion on it.
- Required Supplementary Information (RSI per AU-C 730), required by FASB or GASB, requires limited inquiries and procedures with an Other-Matter paragraph; omissions or departures are described in the report but do not modify the opinion on the basic statements.
- Special Purpose Frameworks (OCBOA per AU-C 800)—including cash, tax, regulatory, and contractual bases—require non-GAAP financial statement titles, an Emphasis-of-Matter paragraph referencing the note describing the basis, and restricted-use alerts for contractual and specific regulatory frameworks.
15.2 Other Information, Supplementary Information & Special Purpose Frameworks
Core Principle: An auditor's report often accompanies documents that extend beyond the core basic financial statements. The auditor's responsibilities vary dramatically depending on the authoritative nature of the accompanying data: from a "read and consider" responsibility for Other Information (AU-C 720), to an audit-level "in-relation-to" opinion for Supplementary Information (AU-C 725), to limited procedures for Required Supplementary Information (AU-C 730), and specific disclosure and restricted-use mandates for Special Purpose Frameworks (AU-C 800).
1. Other Information in Annual Reports (AU-C 720)
Entities frequently publish annual reports containing audited financial statements alongside non-audited narrative material, such as the Chairman's Letter, Management's Discussion & Analysis (for non-issuers), financial highlights, employment statistics, and operational goals.
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| OTHER INFORMATION RESPONSIBILITY SPECTRUM (AU-C 720) |
| |
| WHAT THE AUDITOR MUST DO: WHAT THE AUDITOR DOES NOT DO: |
| - READ the other information - Do NOT audit the other information |
| - Identify MATERIAL INCONSISTENCIES - Do NOT perform substantive verification |
| - Stay alert for misstated other info - Express NO OPINION or ASSURANCE on other information |
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Under SAS No. 137 (effective for periods ending on or after December 15, 2021), when the auditor obtains some or all of the annual report by the report date, the auditor's report includes a separate Other Information section. It identifies the other information, states that the auditor does not express an opinion on it, describes the auditor's responsibility to read it, and states whether an uncorrected material misstatement of the other information exists.
Material Inconsistencies vs. Misstatements of Other Information
- Material Inconsistency: A contradiction between information contained in the audited financial statements and information contained in the other narrative document (e.g., the income statement shows net income of $5 million, but the President's Letter claims net income was $12 million).
- Misstatement of Other Information: Other information unrelated to the financial statements that is incorrectly stated or otherwise misleading (e.g., claiming a factory opened in Paris when no such expansion occurred).
Resolution Workflow for Material Inconsistencies Prior to Report Release
When the auditor detects a material inconsistency between the financial statements and the other information:
MATERIAL INCONSISTENCY DETECTED
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FINANCIAL STATEMENTS WRONG OTHER INFORMATION WRONG
Request management revise statements; Request management revise other info;
If refused -> Express Qualified or If management refuses to revise:
Adverse Opinion on Financial Statements. 1. Communicate to Governance.
2. Action choices:
- Include Other Information Section
- Withhold Audit Report
- Withdraw from Engagement
Exam Trap: When other information in an annual report contains an uncorrected error (and the financial statements are completely accurate), the auditor never issues a qualified or adverse opinion on the financial statements! The financial statements themselves conform to GAAP; the error lies strictly in the non-audited narrative. The auditor responds through an Other Information paragraph/section, withholding the report, or withdrawing.
2. Supplementary Information in Relation to the Financial Statements (AU-C 725)
Under AU-C 725, an auditor may be engaged to report on whether accompanying Supplementary Information (SI)—such as combining balance sheets, supporting departmental schedules, or detailed statistical exhibits—is fairly stated, in all material respects, in relation to the financial statements as a whole.
Conditions for Reporting Under AU-C 725
To issue an "in-relation-to" opinion on supplementary information, all of the following conditions must be satisfied:
- The supplementary information was derived from, or relates directly to, the underlying accounting records used to prepare the financial statements.
- The supplementary information relates to the same period as the basic financial statements.
- The financial statements were audited, and the auditor served as the principal (group) auditor.
- Neither an adverse opinion nor a disclaimer of opinion was issued on the financial statements.
- The supplementary information will accompany the audited financial statements, or those statements will be made readily available.
Required Audit Procedures for Supplementary Information
Unlike "other information" (which is merely read), the auditor must perform substantive audit procedures on supplementary information:
- Inquire of management regarding the purpose and criteria used to prepare the SI.
- Determine whether the SI complies with applicable regulatory or client criteria.
- Obtain an understanding of the internal controls over the preparation of the SI.
- Reconcile and compare the SI directly to the underlying accounting records and the basic financial statements.
- Obtain written representations from management specifically affirming management's responsibility for the SI.
Interaction with the Opinion on Basic Financial Statements
| Audit Opinion on Basic Statements | Permitted Opinion on Supplementary Information (AU-C 725) |
|---|---|
| Unmodified Opinion | Unmodified "in-relation-to" opinion (Fairly stated in all material respects in relation to the financial statements as a whole). |
| Qualified Opinion | Qualified "in-relation-to" opinion (Explain the effects of the qualified matter on the supplementary information). |
| Adverse Opinion | No opinion on the SI. The auditor withdraws from reporting on the SI (when permitted) or states that, because of the matter, it does not express an opinion on the SI. |
| Disclaimer of Opinion | No opinion on the SI, for the same reason. |
3. Required Supplementary Information (AU-C 730)
Required Supplementary Information (RSI) is information that an authoritative body—specifically the FASB, the GASB, or the FASAB—requires to accompany an entity's basic financial statements (e.g., Management's Discussion & Analysis for state/local governments, 10-year pension and OPEB funding schedules, oil and gas reserve disclosures).
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| RSI AUDIT REQUIREMENTS (AU-C 730) |
| |
| LEVEL OF WORK: LIMITED PROCEDURES ONLY |
| 1. Inquire of management about measurement, presentation methods, and whether assumptions changed. |
| 2. Compare RSI for consistency with audited statements and knowledge obtained during audit. |
| 3. Obtain specific written representations from management concerning RSI. |
| |
| REPORTING REQUIREMENTS: |
| - Always include an OTHER-MATTER PARAGRAPH detailing RSI. |
| - Explicitly state that the auditor EXPRESSES NO OPINION AND PROVIDES NO ASSURANCE on RSI. |
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Handling Deficiencies in Required Supplementary Information
An auditor must include an explanatory Other-Matter paragraph when any of the following occur:
- RSI is omitted by the client.
- RSI departs materially from the prescribed standard-setter guidelines.
- The auditor is unable to complete the required limited procedures.
Key Takeaway: Deficiencies in RSI—even complete omission of required schedules—never modify the audit opinion on the basic financial statements! Because RSI is outside the basic financial statements, the basic statements remain unmodified (clean), provided they conform to GAAP. The auditor simply explains the omission or departure in the Other-Matter paragraph.
4. Special Purpose Frameworks / OCBOA (AU-C 800)
Under AU-C 800, financial statements may be prepared in accordance with a special purpose framework (historically called an Other Comprehensive Basis of Accounting or OCBOA). Recognized frameworks include:
SPECIAL PURPOSE FRAMEWORKS (AU-C 800)
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CASH BASIS TAX BASIS REGULATORY BASIS CONTRACTUAL BASIS
Cash & modified Prepared per IRS Prepared to comply Prepared to comply
cash flows. rules and tax code. with state/federal with specific contract
regulator (e.g., DOI) (e.g., loan agreement)
Financial Statement Titles Under Special Purpose Frameworks
Financial statements prepared under a special purpose framework must be suitably titled so that users do not confuse them with GAAP statements. GAAP titles are strictly prohibited!
| Prohibited GAAP Title | Acceptable Cash Basis Title | Acceptable Tax Basis Title |
|---|---|---|
| Balance Sheet | Statement of Assets and Liabilities Arising from Cash Transactions | Statement of Assets, Liabilities, and Equity - Tax Basis |
| Income Statement | Statement of Revenues Collected and Expenses Paid | Statement of Revenue and Expenses - Tax Basis |
| Statement of Cash Flows | Omitted (not required under cash basis) | Statement of Cash Flows - Tax Basis (if prepared) |
Required Reporting Elements Under AU-C 800
- Description of Framework: The notes to the financial statements must disclose the special purpose framework and summarize how it differs from GAAP.
- Emphasis-of-Matter Paragraph: The auditor's report must include an Emphasis-of-Matter paragraph that:
- Notes that the financial statements are prepared in accordance with the applicable special purpose framework.
- References the footnote disclosure describing the basis.
- Explicitly states that the basis is a framework other than U.S. GAAP.
- Alert Restricting the Use of the Auditor's Report:
- Contractual Basis: Use of the report must ALWAYS be restricted to the contracting parties.
- Regulatory Basis: Restricted to the regulatory agency if prepared solely for regulatory filing. If prepared for general use, the auditor must express a dual opinion: an Adverse opinion on GAAP conformity and an Unmodified opinion on regulatory basis conformity!
- Cash & Tax Bases: Generally unrestricted, as these frameworks are accepted for general-purpose distribution.
5. Master Comparison Table: Accompanying Information & Frameworks
| Dimension | Other Information (AU-C 720) | Supplementary Information (AU-C 725) | Required Supplementary Info (AU-C 730) | Special Purpose Frameworks (AU-C 800) |
|---|---|---|---|---|
| Governing Authority | Entity's Annual Report | Client / Management | FASB, GASB, FASAB | Non-GAAP Standard Setters |
| Level of Work | Read and consider | Substantive audit procedures | Limited inquiries & comparisons | Full GAAS audit applied to framework |
| Assurance Expressed | No assurance / No opinion | Audit-level opinion ("in relation to") | No assurance / No opinion | Audit opinion on framework fairness |
| Report Paragraph | Other Information Section | Other-Matter (or separate report) | Other-Matter paragraph | Emphasis-of-Matter (and Restrict Use) |
| Effect of Error on FS Opinion | None (FS are clean) | None (SI opinion modified) | None (FS opinion unmodified) | Material non-compliance leads to Qual/Adv |
| Restricted Use Alert? | No | No | No | Yes for Contractual & Regulatory |
While reading the annual report of a non-issuer client under AU-C 720, the auditor notes that the President's Letter reports net sales of $85 million, whereas the audited income statement reports net sales of $58 million. The auditor confirms that the audited financial statements are correct. Management refuses to revise the President's Letter prior to report release. What is the auditor's appropriate initial course of action?
An auditor is engaged to audit an entity's financial statements and also report on accompanying supplementary information in relation to the financial statements as a whole under AU-C 725. Due to an unresolved material GAAP departure regarding depreciation, the auditor expresses an adverse opinion on the basic financial statements. What opinion may the auditor express on the accompanying supplementary information?
A local government entity presents its basic financial statements accompanied by Required Supplementary Information (RSI) mandated by GASB, including a budgetary comparison schedule and pension trend data. The auditor performs required inquiries and limited procedures, but management refuses to present the required pension trend schedule. How should this omission affect the auditor's report?
An auditor is engaged to report on financial statements prepared in accordance with a contractual basis of accounting under AU-C 800 (a special purpose framework). Which reporting requirement is mandatory for this engagement?