A Securities and Exchange Commission order issued in the wake of recent high-profile bankruptcy filings may cause some federal contractors to amend their financial statements.  Recent guidance from DCAA asks its auditors to carefully examine any resulting changes to assure prior audit results remain “appropriate.”  The guidance further states the new SEC rules require CEO and CFOs to “attest” to the accuracy of the financial statements or file a statement, referred to as “Other”, describing the facts and circumstances preventing the attestation.

Auditors are to determine if contractors are included in the SEC’s list of 945 companies subject to the order (found at www.sec. gov/rules/extra/ceocfo.htm ).  They are to examine any adjustments to financial statements and reexamine any audit effort that relied on those statements e.g. financial condition risk assessment, financial capability audits.  Also, if a contractor is required to file the sworn affidavits and has not done so, auditors are to use the SEC website to determine when the contractor will submit and then revisit it after that date.

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