Assess whether SAB 99 qualitative materiality is triggered after an SEC

Situation

SAB 99 qualitative materiality sits with litigation-support partner because an SEC comment letter on revenue hit a pre-IPO SaaS company drafting an S-1. Evidence is ghost-employee payroll extract; write the Forensic Accounting Occupational Fraud option that extract can carry.

Decision

Litigation-support partner 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 ghost-employee payroll extract after an SEC comment letter on revenue.

Hypotheses to test

• Litigation-support partner can defend Remove access or reverse the item from ghost-employee payroll extract after an SEC comment letter on revenue in a Forensic Accounting challenge.
• Litigation-support partner cannot defend Remove access or reverse the item from ghost-employee payroll extract; Temporary compensating control is what the extract actually supports after an SEC comment letter on revenue.
• An SEC comment letter on revenue never reached the population in ghost-employee payroll extract — reopen intake, do not close SAB 99 qualitative materiality.
• Two facts in ghost-employee payroll extract after an SEC comment letter on revenue conflict for litigation-support partner; hold this Occupational Fraud file.

Analysis required

• Reconstruct vendor, journal, or inventory lines in ghost-employee payroll extract through the window opened by an SEC comment letter on revenue.
• Trace approval, SoD, and related-party links that ghost-employee payroll extract actually shows.
• Test cutoff, reversals, and system-of-record ties for materiality on SAB 99 qualitative materiality.
• For this Forensic Accounting Occupational Fraud file, read ghost-employee payroll extract against an SEC comment letter on revenue and write the one fact that would move SAB 99 qualitative materiality for litigation-support partner.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Occupational Fraud packet (ghost-employee payroll extract after an SEC comment letter on revenue). The follow-on Occupational Fraud action is what litigation-support partner does next: implement the option, assign an owner, and log the missing fact.