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Microlesson · 5-min read

Content of Written Representations – Management Responsibilities, Other WRs & Specific Assertions

## SA 580: Content of Written Representations

### A. WR on Management's Responsibilities

#### 1. Preparation of Financial Statements

Management confirms it has fulfilled its responsibility for preparing the FS in accordance with the applicable financial reporting framework (including fair presentation where relevant).

Who may management consult before signing?

  • Actuary – actuarially determined accounting measurements
  • Staff engineers – environmental liability measurements
  • Internal counsel – provisions for legal claims

Qualifying language: Management may state representations are made "to the best of its knowledge and belief"acceptable if those signing have appropriate responsibilities and knowledge.

Informed representations: The auditor may ask management to confirm it made appropriate internal inquiries before signing the WR.

#### 2. Information Provided & Completeness of Transactions

Management must confirm:

  • It provided the auditor all relevant information and access as agreed in the audit engagement terms
  • All transactions have been recorded and are reflected in the financial statements

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### B. Other Written Representations

Required by other SAs, or obtained at the auditor's discretion. These supplement (but are NOT part of) the management responsibilities WR. Cover:

AreaExamples
Accounting policiesSelection and application are appropriate
Assets & liabilitiesPlans/intentions affecting carrying value or classification
LiabilitiesBoth actual and contingent
AssetsTitle to/control over assets; liens, encumbrances, collateral
Legal/regulatoryLaws, regulations, contractual agreements including non-compliance

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### C. Additional WR on Internal Control Deficiencies

The auditor may request a WR that management has communicated all deficiencies in internal control of which it is aware.

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### D. WR on Specific Assertions (Management Intent)

When evaluating management judgments/intentions, the auditor considers:

1. Entity's past history in carrying out stated intentions

2. Entity's reasons for choosing a particular course of action

3. Entity's ability to pursue a specific course of action

4. Other information that may be inconsistent with management's judgment or intent

> Example: Where management's intent is material to valuation of investments, a WR about intent may be necessary – but it still does NOT constitute SAAE on its own.

Worked example

### Example 1

During the audit of Sharma Industries, classification of investments as held-to-maturity depends entirely on management's intent. The auditor obtains a WR from management confirming the intention to hold to maturity. Is this sufficient? No – the WR is necessary but not SAAE alone. The auditor must also examine past patterns of investment behavior, the entity's financial position, and any contradictory evidence.

### Example 2

The auditor discovers Kapoor Ltd has potential environmental liabilities assessed by staff engineers. When requesting the WR on environmental liability measurements, the auditor asks management to confirm it consulted staff engineers with specialized knowledge and that the WR reflects their findings – ensuring the representation is an informed one.

⚠️ Common exam mistakes

  • Assuming 'to the best of my knowledge and belief' language makes a WR unacceptable – this qualifying language is permitted when signatories have appropriate responsibilities and knowledge.
  • Treating 'other written representations' (covering accounting policies, liabilities, etc.) as part of the management responsibilities WR – they are separate and supplementary.
  • Forgetting that even WR about specific assertions (e.g., management intent on investments) require corroborative evidence.
  • Not requesting a WR about internal control deficiencies when circumstances (e.g., prior year weaknesses) make it appropriate to do so.
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