1. Arrangements for signing letter
A letter of representation should be signed by persons whose level of authority is appropriate to the significance of the representations made - normally by one or more of the executive directors (for example by the chief executive and the financial director), on behalf of the whole board. The signatories of the letter should be fully conversant with the matters contained in it.
Auditors should request that consideration of the letter and its approval by the board for signature be minuted. Auditors may request that they be allowed to attend the meeting at which the board is due to approve the letter. Such attendance may also be desirable where the representations are to be formally minuted, rather than included in a letter.
2. Actions if management refuse to sign letter
Procedures regarding written representations should be agreed at an early stage in order to reduce the possibility of the auditor being faced with a refusal by management to co-operate in providing such representations. The representations can take the form of a letter from management, a letter from the auditors confirmed by directors, or minutes of a meeting of the board of directors.
If management disagrees with the auditor’s statement of representations, discussions should be held to clarify the matters in doubt and, if necessary, a revised statement prepared and agreed. Should management fail to reply, the auditor should follow the matter up to try to ensure that the understanding of the positions, as set out in auditor’s statement, is correct.
3. Qualification
There may, however, be circumstances where auditors are unable to obtain the written representations they need. This may be because of a refusal by management to cooperate, or because management properly declines to give the representations required on the grounds of their own uncertainty regarding the particular matter. In either case, if auditors are unable to satisfy themselves, they may have to conclude that they have not received all the information and explanations they need, and consequently may need to consider qualifying the audit report.
4. Dating of the letter
The formal record of representations by management should be dated on the same day that the financial statements are approved. It should never be dated after the audit report since it is part of the evidence on which the auditor’s opinion, expressed in the audit report, is based.