Is SAB 99 Qualitative Materiality Triggered — Public Filer Facing

Situation

SAB 99 qualitative materiality sits with external counsel's accounting expert because a Big 4 inquiry on cutoff testing hit a public filer facing a whistleblower memo. Evidence is management-bonus accrual workbook; write the Forensic Accounting Revenue Integrity option that extract can carry.

Decision

External counsel's accounting expert in a public filer facing a whistleblower memo must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using management-bonus accrual workbook after a Big 4 inquiry on cutoff testing.

Hypotheses to test

• The population in management-bonus accrual workbook is the one a Big 4 inquiry on cutoff testing named, so Remove access or reverse the item follows for this Revenue Integrity file.
• The population in management-bonus accrual workbook is adjacent only to a Big 4 inquiry on cutoff testing; Temporary compensating control is the honest Forensic Accounting call.
• A public filer facing a whistleblower memo already contained a Big 4 inquiry on cutoff testing before management-bonus accrual workbook arrived; no new Revenue Integrity path.
• Provenance on management-bonus accrual workbook after a Big 4 inquiry on cutoff testing 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 public filer facing a whistleblower memo.
• Reconstruct vendor, journal, or inventory lines in management-bonus accrual workbook through the window opened by a Big 4 inquiry on cutoff testing.
• For this Forensic Accounting Revenue Integrity file, read management-bonus accrual workbook against a Big 4 inquiry on cutoff testing and write the one fact that would move SAB 99 qualitative materiality 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 / Revenue Integrity packet (management-bonus accrual workbook after a Big 4 inquiry on cutoff testing). The follow-on Revenue Integrity action is what external counsel's accounting expert does next: implement the option, assign an owner, and log the missing fact.