WEBVTT

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ESG and GenAI are everywhere, and the firm

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has been adapting quickly to seize opportunities.

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Let’s check in with Paloma, the audit partner for SEC audit

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client, Estatewood and Kai, a Tech Assurance managing

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director, as they talk through two opportunities for Estatewood.

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PALOMA: The planning workshop for Estatewood’s audit went 

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really well! They were impressed with the new AI technology

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that we’ll be using on the audit this year.

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KAI: Yeah, they were!  I agree! Actually - Estatewood’s CFO

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just reached out to me about helping with their GenAI transformation.

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I was thinking about an Ignition Experience at Lakehouse. We

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can share benchmarking and insights about their performance

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compared to their competitors, and brainstorm GenAI use cases.

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PALOMA: That’s a great idea! But let’s make sure we’ve

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considered any independence implications.

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If we plan to provide a benchmarking deliverable, we need to

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ensure that during that session, we aren’t providing

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services beyond the audit that haven’t been pre-approved.

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KAI: I see what you mean…

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PALOMA: The Independence Guidance on Ignition Experiences

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and AI services are helpful resources. The Ignition

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Experience you’ve described may be permissible, provided we

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don’t delve into developing their AI solutions. But it would

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be considered a separate non-audit service, regardless of

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whether we charge a fee.

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Kai is now more aware of the ways in which activities we

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plan to offer to our audit clients can expand into providing

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non-audit services. Although these non-audit services may be

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permissible, they still require evaluation in Sentinel and

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Audit Committee pre-approval.

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Paloma and Kai talk through what Estatewood would like to

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achieve with GenAI.  They come up with an appropriate agenda

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to address the client’s needs that would also be permissible

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from an independence perspective.

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Because they also have an ongoing ESG reporting assessment

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engagement with Estatewood, Kai continues the discussion

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with Paloma, talking through the draft deliverable they

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would like to share with the client.

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KAI: Oh, I’ve been meaning to ask…Have you had a chance to

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review the draft deliverable for the ESG reporting

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assessment service?  We had some valuable IT insights, and

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wanted to provide them as soon as possible!

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PALOMA: I have reviewed it. The team did a great job.

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KAI: Thanks, Paloma.

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PALOMA: And it’s great you used the standard deliverable

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template, but in certain places we do need to adjust our

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level of recommendations to avoid going beyond the scope of

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work in the approved ESG engagement letter.

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KAI: OK. Where were your concerns?

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PALOMA: There were a few places where we made assurance type

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statements like “the report is complete and accurate” or

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“the control is designed effectively”.

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We aren’t auditing here, so, our work can’t go beyond

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high-level observations and recommendations.

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KAI: Ok, I see what you mean.  We can’t conclude or provide

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inadvertent assurance, since this is a non-audit service

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done under consulting standards.

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So - for our observations and recommendations, if we frame

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them as high-level feedback for the client’s consideration

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and categorize the feedback as high, medium, and low – would

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that be permissible?

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PALOMA: Yes, that’s permissible.

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We should avoid making recommendations that are too specific

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and extensive, as it could in substance be seen as designing

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or concluding on the client’s controls, or developing their

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action plan, which would be impermissible.

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KAI: That makes sense.

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I’ll make those changes to the ESG deliverable.

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Paloma emphasized the importance of staying within the

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approved scope and that teams need to take off their “audit”

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hat when drafting deliverables for non-audit services.

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She also reinforced the importance of providing objective

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recommendations and observations without conclusions,

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avoiding scope creep and maintaining independence.

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As Audit and Tech Assurance offer more non-audit services to

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audit clients, it is important to keep these considerations in mind.

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