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The audited balance sheet of a non-issuer general partner that is included in a transactional filing or registration statement of a limited partnership issuer is not required to be audited by a PCAOB registered firm.
Registrants should consult with CF-OCA prior to filing any S-X 3-10(g) financial statements that are not audited by a PCAOB- registered firm.
For example, in the context of a CAM related to goodwill impairment, the PCAOB provides the following questions to be addressed in the auditor’s description of the principal considerations: The description of audit procedures should “be specific to the CAM and to the audit,” not general statements that might apply in any audit or “to most significant areas of the audit, such as ‘testing the operating effectiveness of the company’s controls’ in the case of an integrated audit.” Most useful would be descriptions of procedures that are tied to the considerations that led to the matter being identified as a CAM.
For example: Although the auditor may choose to include findings as an indication of the outcome of audit procedures or as key observations about a matter, the auditor should not use language that implies “that the auditor is providing a separate opinion on the CAM or on the accounts or disclosures to which it relates.
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While the FAQs are intended for auditors, they can provide some insight Under the new auditing standard for the auditor’s report (AS 3101), CAMs are defined as “matters communicated or required to be communicated to the audit committee and that: (1) relate to accounts or disclosures that are material to the financial statements; and (2) involved especially challenging, subjective, or complex auditor judgment.” Essentially, the concept is intended to capture the matters that kept the auditor up at night, so long as they meet the standard’s criteria.