Annual Audit and Reporting Requirements Internal Control Attestation Standards for Independent Auditors
FIL-5-2008 February 1, 2008
The FDIC is providing the attached guidance on the internal control attestation standards that auditors of insured institutions with $1 billion or more in total assets should follow to comply with the FDIC's audit and reporting requirements in Part 363 of the FDIC's regulations.
Part 363 of the FDIC's regulations requires assessments of internal control over financial reporting by both management and independent auditors for insured institutions with $1 billion or more in total assets.
Section 404 of the Sarbanes-Oxley Act imposes similar internal control requirements on public companies. On May 24, 2007, the Public Company Accounting Oversight Board (PCAOB) adopted Auditing Standard No. 5 (AS 5).
Generally, auditors of public institutions that are accelerated filers will follow AS 5 for Section 404 purposes for fiscal years ending on or after November 15, 2007.
Generally, auditors of public institutions that are non- accelerated filers will follow AS 5 for Section 404 purposes for fiscal years ending on or after December 15, 2008.
In response to questions it has received, the FDIC has determined that auditors' internal control reports issued under AS 5 satisfy the requirements of Part 363.
For non-public institutions, auditors may follow the American Institute of Certified Public Accountants' (AICPA) attestation standards, known as "AT 501," when reporting on internal controls.
Auditors of public institutions that are non-accelerated filers need only follow AT 501 to satisfy Part 363 until AS 5 takes effect for non-accelerated filers in 2008.
For Part 363 purposes, the scope of financial reporting includes financial statements prepared for regulatory reporting.
FDIC-Insured Institutions With $500 Million or More