Assess whether books should be restated or merely adjusted (46e070)

Situation

A public filer facing a whistleblower memo cannot treat a tax-authority information document request as color commentary on ghost-employee payroll extract. FCPA investigation lead must close books should be restated from that extract under Forensic Accounting / Occupational Fraud.

Decision

FCPA investigation lead in a public filer facing a whistleblower memo must choose Books should be restated / Merely adjusted using ghost-employee payroll extract after a tax-authority information document request.

Hypotheses to test

• Ghost-employee payroll extract reads as Books should be restated once a tax-authority information document request is lined up to the same Forensic Accounting population.
• Ghost-employee payroll extract is closer to Merely adjusted after a tax-authority information document request; Books should be restated would over-claim this Occupational Fraud extract.
• A dual reading is still live in ghost-employee payroll extract for FCPA investigation lead in a public filer facing a whistleblower memo.
• Ghost-employee payroll extract is missing the fact FCPA investigation lead needs after a tax-authority information document request; stop this Forensic Accounting close.

Analysis required

• Quantify the entry if FCPA investigation lead has to reverse it.
• Separate a close-process miss from a qualitative SAB 99 issue in a public filer facing a whistleblower memo.
• Reconstruct vendor, journal, or inventory lines in ghost-employee payroll extract through the window opened by a tax-authority information document request.
• For this Forensic Accounting Occupational Fraud file, read ghost-employee payroll extract against a tax-authority information document request and write the one fact that would move books should be restated for FCPA investigation lead.

Recommendation

Choose Books should be restated / Merely adjusted on this Forensic Accounting / Occupational Fraud packet (ghost-employee payroll extract after a tax-authority information document request). The follow-on Occupational Fraud action is what FCPA investigation lead does next: implement the option, assign an owner, and log the missing fact.