Whether cash ever economically changed hands from intercompany elimination

Situation

In a pre-IPO SaaS company drafting an S-1, intercompany elimination mismatch report is the evidence after a new counterparty formed 19 days before quarter-end. FCPA investigation lead has to pick Remove access or reverse the item or Temporary compensating control for this Forensic Accounting Revenue Integrity close using intercompany elimination mismatch report.

Decision

FCPA investigation lead in a pre-IPO SaaS company drafting an S-1 must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using intercompany elimination mismatch report after a new counterparty formed 19 days before quarter-end.

Hypotheses to test

• Intercompany elimination mismatch report reads as Remove access or reverse the item once a new counterparty formed 19 days before quarter-end is lined up to the same Forensic Accounting population.
• Intercompany elimination mismatch report is closer to Temporary compensating control after a new counterparty formed 19 days before quarter-end; Remove access or reverse the item would over-claim this Revenue Integrity extract.
• Approve a documented exception is still live in intercompany elimination mismatch report for FCPA investigation lead in a pre-IPO SaaS company drafting an S-1.
• Intercompany elimination mismatch report is missing the fact FCPA investigation lead needs after a new counterparty formed 19 days before quarter-end; stop this Forensic Accounting close.

Analysis required

• Separate a close-process miss from a qualitative SAB 99 issue in a pre-IPO SaaS company drafting an S-1.
• Reconstruct vendor, journal, or inventory lines in intercompany elimination mismatch report through the window opened by a new counterparty formed 19 days before quarter-end.
• Trace approval, SoD, and related-party links that intercompany elimination mismatch report actually shows.
• For this Forensic Accounting Revenue Integrity file, read intercompany elimination mismatch report against a new counterparty formed 19 days before quarter-end and write the one fact that would move cash ever economically changed for FCPA investigation lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Revenue Integrity packet (intercompany elimination mismatch report after a new counterparty formed 19 days before quarter-end). If intercompany elimination mismatch report cannot force a Forensic Accounting label under Revenue Integrity, stop. Do not invent pages a pre-IPO SaaS company drafting an S-1 does not have.