Assess whether a referral to counsel is warranted (a0d872)

Situation

An SEC comment letter on revenue put bill-and-hold side-letter folder in front of external counsel's accounting expert in a county government payroll environment. This Forensic Accounting / Related-Party and Corruption Risk close is a referral to counsel is warranted from bill-and-hold side-letter folder, and the live options are Remove access or reverse the item, Temporary compensating control, Approve a documented exception.

Decision

External counsel's accounting expert in a county government payroll environment must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using bill-and-hold side-letter folder after an SEC comment letter on revenue.

Hypotheses to test

• The population in bill-and-hold side-letter folder is the one an SEC comment letter on revenue named, so Remove access or reverse the item follows for this Related-Party and Corruption Risk file.
• The population in bill-and-hold side-letter folder is adjacent only to an SEC comment letter on revenue; Temporary compensating control is the honest Forensic Accounting call.
• A county government payroll environment already contained an SEC comment letter on revenue before bill-and-hold side-letter folder arrived; no new Related-Party and Corruption Risk path.
• Provenance on bill-and-hold side-letter folder after an SEC comment letter on revenue is broken; do not pick Remove access or reverse the item or Temporary compensating control yet.

Analysis required

• Quantify the entry if external counsel's accounting expert has to reverse it.
• Separate a close-process miss from a qualitative SAB 99 issue in a county government payroll environment.
• Reconstruct vendor, journal, or inventory lines in bill-and-hold side-letter folder through the window opened by an SEC comment letter on revenue.
• For this Forensic Accounting Related-Party and Corruption Risk file, read bill-and-hold side-letter folder against an SEC comment letter on revenue and write the one fact that would move a referral to counsel is warranted for external counsel's accounting expert.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Related-Party and Corruption Risk packet (bill-and-hold side-letter folder after an SEC comment letter on revenue). The follow-on Related-Party and Corruption Risk action is what external counsel's accounting expert does next: implement the option, assign an owner, and log the missing fact.