Document ID: chunk:federal_register_of_legislation:F2023C00330:reg:10:p4
Version: federal_register_of_legislation:F2023C00330
Segment Type: reg
Provision Reference: reg 10 (pt 4/14)
Character Range: 17808–20978

matters covered by such statements need not be included in the representation letter.  (Ref: Para. A19‑A21)

Doubt as to the Reliability of Written Representations and Requested Written Representations Not Provided

Doubt as to the Reliability of Written Representations

16.               If the auditor has concerns about the competence, integrity, ethical values or diligence of management, or about its commitment to or enforcement of these, the auditor shall determine the effect that such concerns may have on the reliability of representations (oral or written) and audit evidence in general.  (Ref: Para. A24‑A25)

17.               In particular, if written representations are inconsistent with other audit evidence, the auditor shall perform audit procedures to attempt to resolve the matter.  If the matter remains unresolved, the auditor shall reconsider the assessment of the competence, integrity, ethical values or diligence of management, or of its commitment to or enforcement of these, and shall determine the effect that this may have on the reliability of representations (oral or written) and audit evidence in general.  (Ref: Para. A23)

18.               If the auditor concludes that the written representations are not reliable, the auditor shall take appropriate actions, including determining the possible effect on the opinion in the auditor's report in accordance with ASA 705,[4] having regard to the requirement in paragraph 20 of this Auditing Standard.

Requested Written Representations Not Provided

19.               If management does not provide one or more of the requested written representations, the auditor shall:

(a)                Discuss the matter with management;

(b)                Re‑evaluate the integrity of management and evaluate the effect that this may have on the reliability of representations (oral or written) and audit evidence in general; and

(c)                Take appropriate actions, including determining the possible effect on the opinion in the auditor's report in accordance with ASA 705, having regard to the requirement in paragraph 20 of this Auditing Standard.

Written Representations about Management's Responsibilities

20.               The auditor shall disclaim an opinion on the financial report in accordance with ASA 705 if:

(a)                The auditor concludes that there is sufficient doubt about the integrity of management such that the written representations required by paragraphs 10 and 11 of this Auditing Standard are not reliable; or

(b)                Management does not provide the written representations required by paragraphs 10 and 11 of this Auditing Standard.  (Ref: Para. A26‑A27)

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Application and Other Explanatory Material

Written Representations as Audit Evidence (Ref: Para. 3)

A1.             Written representations are an important source of audit evidence.  If management modifies or does not provide the requested written representations, it may alert the auditor to the possibility that one or more significant issues may exist.  Further, a request for written, rather than oral, representations in many cases may prompt management to