Assess whether a referral to counsel is warranted from related-party customer

Situation

A referral to counsel is warranted sits with FCPA investigation lead because an SEC comment letter on revenue hit a pre-IPO SaaS company drafting an S-1. Evidence is related-party customer map; write the Forensic Accounting Revenue Integrity option that extract can carry.

Decision

FCPA investigation lead in a pre-IPO SaaS company drafting an S-1 must choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold using related-party customer map after an SEC comment letter on revenue.

Hypotheses to test

• An SEC comment letter on revenue is noise around an already-controlled Revenue Integrity process in a pre-IPO SaaS company drafting an S-1, given related-party customer map.
• An SEC comment letter on revenue is the event in related-party customer map that forces Remove access or reverse the item for FCPA investigation lead under Forensic Accounting.
• Related-party customer map shows a one-file miss after an SEC comment letter on revenue, not a Revenue Integrity program failure.
• Related-party customer map cannot decide a referral to counsel is warranted yet after an SEC comment letter on revenue; hold is the only Forensic Accounting close a pre-IPO SaaS company drafting an S-1 can defend.

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 pre-IPO SaaS company drafting an S-1.
• Reconstruct vendor, journal, or inventory lines in related-party customer map through the window opened by an SEC comment letter on revenue.
• For this Forensic Accounting Revenue Integrity file, read related-party customer map against an SEC comment letter on revenue and write the one fact that would move a referral to counsel is warranted for FCPA investigation lead.

Recommendation

Choose Remove access or reverse the item / Temporary compensating control / Approve a documented exception / Hold on this Forensic Accounting / Revenue Integrity packet (related-party customer map after an SEC comment letter on revenue). If related-party customer map cannot force a Forensic Accounting label under Revenue Integrity, stop. Do not invent pages a pre-IPO SaaS company drafting an S-1 does not have.