Hi all! For a quarterly control that was deficient, we need two effective quarters for the control to be remediated by year end right? Has anyone experienced a situation where the control was deficient in Q3 then remediated in Q4 and was closed for the year? (in the context of user access reviews)

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Good question.

Yes 2 are required. So we would call this “remediated, open at year end”. At least that’s how I’ve documented on summary of deficiencies at my internal/external audits.

Then in the next fiscal year, Q1 would be the next chance to call it remediated and closed

What was the nature of the failure?

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What are you confused about? You can’t go back and perform a previous quarter review

If the control was redesigned you can reassess the D&I. But you can’t conclude on effectiveness without minimum sample size.

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Depends on the risk and sampling methodology & varies across firms

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In theory if Q3 failed you need to test the Q4 sample. For TOC/TOE the control will conclude as not effective. That deviation or exception will carry over into the next audit. Whoever is the auditor for the next period needs to evaluate the deficiency, walkthrough the process again and test the D&I to remediate the prior FY deficiency. You still need 2 samples to pass for it to be effective.

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