Assess whether a referral to counsel is warranted (d8a47a)

Situation

External counsel's accounting expert in a pre-IPO SaaS company drafting an S-1 has one working extract — management-bonus accrual workbook — after an SEC comment letter on revenue. If management-bonus accrual workbook cannot support a referral to counsel is warranted, the honest Forensic Accounting output is hold.

Decision

External counsel's accounting expert 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 management-bonus accrual workbook after an SEC comment letter on revenue.

Hypotheses to test

• Management-bonus accrual workbook reads as Remove access or reverse the item once an SEC comment letter on revenue is lined up to the same Forensic Accounting population.
• Management-bonus accrual workbook is closer to Temporary compensating control after an SEC comment letter on revenue; Remove access or reverse the item would over-claim this Inventory and Cash Schemes extract.
• Approve a documented exception is still live in management-bonus accrual workbook for external counsel's accounting expert in a pre-IPO SaaS company drafting an S-1.
• Management-bonus accrual workbook is missing the fact external counsel's accounting expert needs after an SEC comment letter on revenue; stop this Forensic Accounting close.

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 pre-IPO SaaS company drafting an S-1.
• Reconstruct vendor, journal, or inventory lines in management-bonus accrual workbook through the window opened by an SEC comment letter on revenue.
• For this Forensic Accounting Inventory and Cash Schemes file, read management-bonus accrual workbook 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 / Inventory and Cash Schemes packet (management-bonus accrual workbook after an SEC comment letter on revenue). Lead with the Forensic Accounting option management-bonus accrual workbook can support after an SEC comment letter on revenue, then the two facts that force it, then the Monday action for external counsel's accounting expert in a pre-IPO SaaS company drafting an S-1.