GUIDELINES: ANNUAL FINANCIAL REPORTING AND AUDITING FOR WORLD BANK-FINANCED ACTIVITIES

Transcription

1 GUIDELINES: ANNUAL FINANCIAL REPORTING AND AUDITING FOR WORLD BANK-FINANCED ACTIVITIES FINANCIAL MANAGEMENT SECTOR BOARD JUNE 30, 2003

2 ACRONYMS FMR IAS IASB IFAC-PSC IFRS INTOSAI IPSAS ISA MDB OECD-DAC SA SAI SOE TOR Financial Monitoring Report International Accounting Standard - issued by IASB International Accounting Standards Board International Federation of Accountants Public Sector Committee International Financial Reporting Standard issued by IASB International Organization of Supreme Audit Institutions International Public Sector Accounting Standard issued by IFAC-PSC International Standard on Auditing issued by IFAC International Auditing and Assurance Standards Board Multilateral Development Bank Organization for Economic Co-operation and Development Development Assistance Committee Special Account Supreme Audit Institution Statement of Expenditure Terms of Reference

3 GUIDELINES: ANNUAL FINANCIAL REPORTING AND AUDITING FOR WORLD BANK-FINANCED ACTIVITIES CONTENTS Page I. Introduction....1 II. Annual Financial Reporting...2 A. Accounting Standards...2 B. Format and Content...2 III. Auditing...4 A. Scope and Terms of Reference...4 B. Auditors...6 C. Auditing Standards...7 D. Periodicity... 7 E. Exemptions...8 F. Financing of Audit Costs...8 G. Timing of Auditor Appointment...9 IV. Audit Reports..9 Attachments 1. Entity Financial Statements Additional Disclosures: Bank only 2. Entity Financial Statements Additional Disclosures: Multiple Donors 3. Specimen Auditor s Opinion Standard 4. Specimen Auditor s Opinion Special

4 GUIDELINES: ANNUAL FINANCIAL REPORTING AND AUDITING FOR WORLD BANK-FINANCED ACTIVITIES I. INTRODUCTION 1. The World Bank 1 requires borrowers to provide it with audited annual financial statements of projects supported by the Bank. The financial statements should be prepared in accordance with acceptable accounting standards and audited in accordance with acceptable auditing standards by independent auditors acceptable to the Bank. 2 These Guidelines provide guidance to borrowers, auditors, and others whose work requires them to be familiar with the Bank s audit requirements. 3 They replace previous guidelines issued in this area. 4 The requirements are designed to provide assurance that the annual financial statements fairly present the financial transactions and balances associated with the implementation of the project and on the use of loan proceeds by reference to standards issued by the international standard-setting bodies 5, with provision to adapt audit scope to reflect assessed project risk. 2. Applicability. The audit requirement applies to all loans, credits, advances under the Project Preparation Facility, and grants financed from Bank resources including grants from the Institutional Development Fund and the Development Grant Facility. The requirement also applies to recipient-executed grants funded by donor Trust Funds, unless, exceptionally, the terms of the agreement with the donor makes provision for different requirements. 3. Harmonization. The Bank is committed to working with its development partners to reach agreement on common approaches to financial reporting and auditing in each country, and, when co-financing individual projects, on audited annual financial statements that meet the needs of borrowers and all co-financiers. Consistent with this, the Bank endorses the OECD-DAC Good Practice Paper on Financial Reporting and Auditing 6 and the MDB Framework for Collaboration on Financial Reporting and Auditing World Bank includes International Development Association, loan includes credit, and borrowers includes recipients of grants. World Bank Operational Policy Financial Management. Guidance on the Bank s requirements with respect to interim financial reporting can be found in Financial Monitoring Reports For World Bank-Financed Projects: Guidelines For Borrowers, November Previous guidance was provided in Financial Accounting, Reporting and Auditing Handbook (FARAH), Primarily the International Federation of Accountants, the International Accounting Standards Board and the International Organization of Supreme Audit Institutions. See Harmonizing Donor Practices for Effective Aid Delivery, OECD-DAC, available at See Framework for Collaboration Among Participating MDBs on Financial Reporting and Auditing, February 2003.

5 2 4. Country Audit Strategies. The Bank increasingly develops country-specific approaches to financial reporting and auditing, and, where capacity permits, relies on country reporting and auditing processes to meet its requirements. It therefore seeks to apply these Guidelines in the context of overall country audit strategies agreed with borrowers and, where appropriate, other donors. 8 In countries where national auditing standards are expected to be applied in the conduct of audits, country audit strategies document and analyze the impact of significant departures from international standards. This approach is intended to contribute to the development of sustainable audit capacity, while providing the Bank with the assurance that it needs on the use of loan proceeds. A. Accounting Standards II. ANNUAL FINANCIAL REPORTING 5. Annual financial statements are required to be prepared in accordance with accounting standards acceptable to the Bank. Acceptable accounting standards are International Financial Reporting Standards and International Accounting Standards (IFRS/IAS) issued by the International Accounting Standards Board (IASB) or International Public Sector Accounting Standards (IPSAS) issued by the Public Sector Committee of the International Federation of Accountants (IFAC-PSC). In addition, the Bank may accept national accounting standards where they do not significantly depart from international standards and the effect of any such departures are adequately disclosed and explained in the financial statements. 6. Choice of Accounting Standard. IFRSs/IASs are designed to apply to the financial statements of profit-oriented entities, while IPSASs are designed to apply to the financial statements of public sector entities, other than those that are profit-oriented. In the context of Bank-financed operations it is likely that a significant proportion of financial statements will be prepared in accordance with IPSASs (cash or accruals basis) or equivalent national standards. The standards adopted should be specified in the annual audited financial statements. B. Format and Content 7. The Bank does not mandate a format of annual financial statements. However, where borrowers prepare financial statements on a cash basis, the Bank encourages the adoption of formats laid out in Cash Basis IPSAS, Financial Reporting Under The Cash 8 A country audit strategy typically includes (a) the normal scope and terms of reference for audits of Bank-financed projects; (b) applicable accounting and auditing standards; (c) the process for determining auditors acceptable to conduct audits on Bank-financed projects; (d) those institutions and implementing entities on whose normal audit processes the Bank may rely; (e) strategies to advance harmonization, by setting out the approach to common audits with other donors active in the country; and (f) areas where the Bank, working as appropriate with other donors, may support additional capacity.

6 3 Basis of Accounting. Further guidance may also be obtained from IFAC-PSCs International Public Sector Guidelines and International Public Sector Studies Contents of Financial Statements. A broad outline of the expected contents of annual financial statements will be agreed during project preparation and be confirmed during loan negotiations. Consistent with Financial Reporting Under the Cash Basis of Accounting, typical contents are expected to include, as a minimum: A Statement of Cash Receipts and Payments which recognizes all cash receipts, cash payments and cash balances controlled by the entity; and separately identifies payments by third parties on behalf of the entity. The Accounting Policies Adopted and Explanatory Notes. The explanatory notes should be presented in a systematic manner with items on the Statement of Cash Receipts and Payments being cross referenced to any related information in the notes. Examples of this information include a summary of fixed assets by category of assets, and a summary of accounts receivable and accounts payable. A Management Assertion that Bank funds have been expended in accordance with the intended purposes as specified in the relevant World Bank legal agreement. 9. Reporting Entity. Identification of the specific financial statements to be prepared and submitted will depend on the nature of the project implementing entity. In general, Bank projects are implemented by either special purpose or continuing entities. 10 Where a special purpose entity implements a Bank-financed operation, the annual financial statements should reflect all project activities, including those financed by other donors. 11 Where a Bank-financed operation is being implemented by a continuing entity, the annual financial statements of that entity should be prepared in accordance with accounting standards acceptable to the Bank. They should disclose, for example by way of note or supporting schedule or statement, sufficient information on sources and uses of funds associated with the Bank-financed activity. Attachments 1 and 2 provide illustrations of project related disclosures which may be appropriate in these See IFAC-PSC website at A special purpose entity, sometimes known as a project implementing unit (PIU), is one that is specially created for the purposes of implementing a Bank-Financed project. A continuing entity is one that has an existence independent of the implementation of the operation financed by the Bank loan. It will normally have been in existence before, or will continue to exist after, the life of a Bank-supported operation. A continuing entity may or may not be revenue-earning. Some donors funds are not disbursed within the borrower s country, and relevant information is not communicated to borrower implementing entities to allow them to be recorded. Where such information is not available, the financial statements should disclose the non-availability and include as far as possible estimates of the amounts so provided, or a statement that it has not been possible to arrive at such an estimate. Where information is available, but the donor concerned objects to an external audit of its funds, this should be noted, as appropriate, in the financial statements and audit reports. The IFAC-PSC, at the request of MDBs and the OECD-DAC, is working on an accounting standard for development assistance which, when issued (expected late 2004), will provide further guidance in this area.

7 4 circumstances. Where a Bank-financed operation is being implemented by a continuing entity, but it is more cost-effective to prepare separate project financial statements, the Bank may also require copies of the continuing entity s audited annual financial statements Use of Continuing Entities. Continuing entity financial statements may be appropriate where, for example, the implementing agency is a state-owned enterprise, a nongovernmental organization, or a social fund. In these cases it is likely that the entity has a history of preparing financial statements on a regular and timely basis and operates an accounting system readily adaptable to the requirement to disclose project-specific information. Continuing entity financial statements may also be appropriate where a single entity is responsible for implementing several Bank-financed operations. The Bank may also accept the financial statements of government ministries and departments where these disclose information acceptable to the Bank on the activities supported by the loan. 11. Adjustment Operations. In the case of adjustment operations, Bank loan proceeds do not normally finance specific expenditures. Accordingly, the Bank does not require the preparation of financial statements. Where the Bank exercises its right to require an audit of the account into which the loan proceeds are deposited a summary of the transactions in this account would be prepared. III. AUDITING 12. The Bank requires that the audit scope and terms of reference, the auditor, and the audit standards applied be acceptable to it. A. Scope and Terms of Reference 13. Scope. The scope of the audit is determined by the borrower in agreement with the Bank, based on project-specific circumstances, and adapted as appropriate to identified project risks. The auditor then determines the audit procedures to be undertaken in order to achieve the objectives of the audit. In determining the audit procedures to be undertaken, the auditor should take into consideration findings of the assessment of financial management capacity during project preparation, internal audit findings, audit findings from other operations in the same sector, or the results of previous reviews of Statements of Expenditures (SOE) or Financial Monitoring Reports (FMR). The audits of all projects should include an opinion on the annual financial statements. In response to identified project risks, the scope may be expanded to include a report or the expression of an opinion on specific aspects of the operation such as internal controls, eligibility of expenditures, compliance with Bank procurement policies, or efficiency and effectiveness in the use of loan proceeds. 12 This is only the case if either (i) the financial viability of the continuing entity is vital to the success of the Bank-financed operation or (ii) one of the operation s objectives is to improve the entity s institutional capacity.

8 5 14. Materiality. Special considerations exist where continuing entity financial statements are being audited and balances and amounts that are Bank-financed are low in the context of the entity s overall operations. In these situations, the auditor s professional judgment of what is material, and therefore subject to particular scrutiny and/or disclosure in the financial statements, is critical and should include non-monetary considerations. Financial Reporting Under The Cash Basis of Accounting, states that information is material if its omission or misstatement could influence the decisions or assessments of users made on the basis of the financial statements. ISA 320 Audit Materiality, 13 goes on to state that in assessing materiality, the public sector auditor must consider any legislation or regulation which may impact that assessment. In the public sector, materiality is also based on the context and nature of an item and includes, for example, sensitivity as well as value. Sensitivity encompasses a variety of matters such as compliance with authorities, legislative concern or public interest. In the context of a Bank-financed operation, compliance with the terms of the legal agreement, in particular the requirement that Bank loan proceeds may only be used for the purposes stated therein, should be taken into consideration in defining materiality. 15. Adjustment Operations. As noted in paragraph 11, financial statements are not required to be prepared in connection with adjustment operations. Accordingly, the normal audit scope is not applicable. Although it does not routinely do so, the Bank may require an audit of the account into which the Bank loan proceeds are deposited. 16. Terms of Reference. The Bank requires the auditor s opinion and any other reports to be of such scope and in such detail as it may reasonably request. The agreed scope of the audit should be reflected in terms of reference prepared by the borrower and be acceptable to the Bank. When it is expected that the auditor will need to place reliance on the work of a specialist, for example where an efficiency and effectiveness audit is required, separate terms of reference for the specialist should be agreed at the same time as the terms of reference for the main audit. The terms of reference should normally include the following: Background: a detailed description of the project including information on project sources of funding; the purposes for which the funds are intended; and a general description of implementation arrangements, including the organizational structure of all implementing entities. Standards: a statement of the accounting standards to be adopted in preparing the accounts and the auditing standards to be applied in performing the audit. Scope: this should be sufficiently clear as to properly define the scope of the audit, but should not in any way restrict the audit procedures or the techniques that the auditor may wish to use in forming an opinion on the required reports. It should (a) explain that the auditor will carry out tests of transactions as are necessary, and will obtain an understanding of the entity accounting system, 13 Issued by IFAC International Auditing and Assurance Standards Board. See

9 6 to assess its adequacy as a basis for the preparation of the project financial statements and to establish whether adequate records have been maintained; and (b) confirm that although responsibility for preventing irregularity, fraud, or the use of loan proceeds for purposes other than as defined in the legal agreement remains with the borrower, the audit will be planned so as to have a reasonable expectation of detecting material misstatements in the entity financial statements. When additional opinions/reports on issues such as compliance with Bank procurement policies, accuracy of documentation submitted in support of loan withdrawals, efficiency and effectiveness are required from the auditor, these should also be detailed. Reports: this section should confirm the specific reports, for example management letters, that the auditor will be required to produce. Available Information: this should include, but not be limited to, copies of the Bank s Project Appraisal Document, the relevant Legal Agreements, a copy of these Guidelines, and a copy of the Bank s Financial Management Assessment of the project entity. This section should also confirm that the auditor has a right of access to any information relevant for the purposes of conducting the audit. Timing: confirmation of when the audited financial statements, management letter and any other reports are required to be submitted to the borrower. B. Auditors 17. Bank-financed operations are required to be audited by an auditor who is technically competent and independent. 18. Technical Competence. A technically competent auditor is one who is well established and reputable; experienced in auditing entities receiving development assistance; uses procedures and methods that conform with generally accepted auditing practices; has effective quality assurance arrangements in place; and employs adequate staff with appropriate professional qualifications and experience. 19. Independence. Auditors of Bank-financed projects should be independent of the entity being audited. A supreme audit institution (SAI) established under constitutional or legal provisions designed to assure independence (for example, by enshrining the SAIs right to report directly to the legislature) is normally considered to be independent. There may however be circumstances in which the Bank will wish to agree with a borrower either that an independent private sector auditor should assist the SAI, or that the Bank will be provided with opinions and reports prepared by an independent private sector auditor in addition to the report of the SAI. Such an agreement might be sought by the Bank when an SAI is directly involved in the accounting or internal control processes of the entity and its independence may consequently be compromised. In the context of a private sector auditor, tests of independence include confirming that the auditor has no relationship with the entity to be audited (in particular, the auditor should not be

10 7 employed by, serve as director for, or have any financial or close business relationship with the entity during the period(s) covered by the audit). The Bank normally does not accept auditors who also provide consulting services to the implementing entity. 20. Determining Acceptability. The Bank, in conjunction with co-financing partners where appropriate, adopts a structured approach for determining a list of acceptable auditors in each country. For private firms, assessments involve a review of issues such as independence, experience, quality assurance arrangements, and personnel and training policies. This approach is consistent with that set out in the OECD-DAC Good Practice Paper on Financial Reporting and Auditing. The Bank obtains information on SAI capacity and performance from Country Financial Accountability Assessments, peer reviews by SAIs with recognized capacity, experience with audits of projects under implementation, and dialogue with SAIs. C. Auditing Standards 21. Annual financial statements are required to be audited in accordance with auditing standards acceptable to the Bank. Acceptable auditing standards are International Standards on Auditing (ISA) issued by the International Auditing and Assurance Standards Board of the International Federation of Accountants and the Auditing Standards issued by the International Organization of Supreme Audit Institutions (INTOSAI). In addition, the Bank may accept national auditing standards if these do not significantly depart from international standards. The Bank reviews such national auditing standards as part of it country diagnostic work. 22. Choice of Auditing Standard. ISAs have been developed for the private sector but provide the basic principles, practices and procedures that are relevant to all financial audits. INTOSAI standards have been developed for the public sector. They adopt a holistic approach to the issue of public sector accountability that is broader than reporting on financial statements and regularity. Pending convergence between the two sets of standards, the decision on which set to apply may be made by the auditor. 14 The standards adopted in auditing the financial statements should be specified in the auditor s opinion. D. Periodicity 23. Audited financial statements, together with any additional reports required in accordance with the audit terms of reference, are required to be prepared with respect to each borrower fiscal year, and are normally required to be submitted to the Bank no later than six months following the end of the fiscal year. The Bank normally accepts the borrower s fiscal reporting period. 14 Discussions are underway between IFAC and INTOSAI towards the adoption of a single set of auditing standards for financial reporting by private and public sector entities based on those presently issued by the IAASB.

11 8 24. Periods other than 12 months. In the following circumstances, the Bank may agree to accept reporting periods other than 12 months: If the period from the date of effectiveness of the loan to the end of the borrower s fiscal year is no more than six months, the first audit report may cover financial statements for the period from effectiveness to the end of the second fiscal year (that is, a period of up to 18 months). If the last disbursement date 15 is no more than six months from the beginning of the final fiscal year of the project, the final audit report may cover the period from the beginning of the penultimate fiscal year through the last disbursement date (that is, a period of up to 18 months). If the life of the project is expected to be relatively short (for this purpose, less than 24 months in duration) and thus is expected to cover only one full borrower fiscal year, a single audit report covering the life of the project may be agreed. In the case of Project Preparation Facilities, separate audits will not be required when the amounts disbursed are expected to be accounted for in the first reporting period of the project supported by the Project Preparation Facility advance and the follow-up project becomes effective within two years of the date of the first disbursement under the Project Preparation Facility. E. Exemptions 25. In limited circumstances, and in response to the assessed risk of individual projects, the Bank may permit exemptions from the normal audit requirement. Specifically, where alternative, more cost-effective mechanisms that provide equivalent assurance that the funds have been used appropriately exist, the Bank may seek in the first instance to place reliance on these, while still retaining the right to request an audit. The application of this exemption is expected to occur more frequently in the context of operations not exceeding $500,000 equivalent at the time of the signing of the legal agreement. F. Financing of Audit Costs 26. At the request of the borrower, Bank loan proceeds may be used to finance the reasonable costs of all audits required by the Bank. The audit of financial statements covering the project s final reporting period is usually completed after the project closing date, typically rendering the related costs ineligible for Bank financing. Given the importance that the Bank attaches to the final audit, it may agree to finance these costs through an escrow account, opened by the borrower, on terms and conditions acceptable to the Bank. 15 The last disbursement date means the latter of the closing date or the application deadline date.

12 9 G. Timing of Auditor Appointment 27. The auditor should be appointed, or re-appointed, as early as possible in each fiscal year. This enables the auditor to commence reviews sufficiently early in the fiscal year and facilitates the timely completion of the audit. IV. AUDIT REPORTS 28. Copies of the audited financial statements (including the auditor s opinion) together with other reports specified in the TOR should be forwarded to the Bank by the borrower. The Bank reserves the right to refer back to the borrower the work of any auditor that it considers unsatisfactory, and to request additional information or audit work. Attachment 3 provides a specimen audit opinion. 29. Additional Reports. The Bank may require additional reports or opinions to be submitted, based on project-specific circumstances. The scope of this work will be detailed in the audit terms of reference. It may include, as illustrated in Attachment 4, a special opinion on SOEs or FMRs. Additional reports may also address the operation of the entity s control framework during the reporting period, or the entity s compliance with Bank procurement procedures. 30. Management Letter. When significant weaknesses come to the attention of the auditor during the course of the audit that are not reflected in the audit opinion, they should be reported in a management letter addressed to the borrower: Weaknesses in the internal control systems. Inappropriate accounting policies and practices. Issues regarding general compliance with broad covenants such as implementing the project with economy and efficiency. Any other matters that the auditor considers should be brought to the attention of the borrower. 31. Disclosure. The Bank supports the public availability of information on public finances. It routinely reviews, as part of its diagnostic work, the levels of transparency in connection with public finances. As part of this approach, it encourages borrowers to make publicly available all audit reports associated with the activities it finances.

13 Attachment 1 CONTINUING ENTITY FINANCIAL STATEMENTS ADDITIONAL DISCLOSURES BANK ONLY Appropriate for use when the World Bank is the single donor Note X. World Bank Financing (a) The State Power Generating Company received financial support from the World Bank IBRD Loan No MY dated mmmm/dd/yy to support implementation of [describe]. Summary information on transactions taking place during the year is as follows: Preceding Current year year $ $ Balance at the beginning of the year X X Amounts received during the year X X Expenditures during the year (X) (X) Balance at the end of the year X X (b) The opening and closing balances shown above are included in Cash and Cash Equivalents and represent balances outstanding on the World Bank Funded Special Account No held at the National Bank of Included in long term liabilities is also an amount of $x (preceding year: $x) in respect of the amounts disbursed under the loan to date. (c) The proceeds of the World Bank loan have been expended in accordance with the intended purposes as specified in the Loan Agreement.

14 Attachment 2 CONTINUING ENTITY FINANCIAL STATEMENTS ADDITIONAL DISCLOSURES MULTIPLE DONORS Appropriate for use when funds are received from multiple donors Note X. Amounts received in Development Assistance: (a) Summary information on transactions taking place during the year is as follows: Current Year Preceding Year Donor 1 World Bank Donor 3 Total Donor 1 World Bank Donor 3 Total $ $ $ $ $ $ $ $ Balance at the beginning of the year X X X X X X X X Amounts received during the year X X X X X X X X Expenditures during the year (X) (X) (X) (X) (X) (X) (X) (X) Balance at the end of the year X X X X X X X X (b) The opening and closing balances shown above are included in Cash and Cash Equivalents and represent, in respect of the World Bank, Special Account No held at the National Bank of Included in long term liabilities is also an amount of $x (preceding year: $x) in respect of the amounts disbursed under the World Bank loan to date. (c) The proceeds of all Development Assistance have been expended in accordance with the intended purposes as specified in the relevant legal agreement.

15 Attachment 3 SPECIMEN AUDITOR S OPINION STANDARD We have audited the accompanying Financial Statements comprising [statement of receipts and payments/balance sheet/additional disclosure notes] of the [project name] for the year ended mmmm/dd/yy. These statements are the responsibility of the [project name]. Our responsibility is to express an opinion thereon based on our audit. We conducted our audit in accordance with [International Standards on Auditing issued by the International Auditing and Assurance Standards Board of the International Federation of Accountants/Auditing Standards issued by the International Organization of Supreme Audit Institutions/National Auditing Standards issued by..]. These standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement. An audit includes examining, on a test basis, evidence supporting the amounts and disclosures in the financial statements. An audit also includes assessing the accounting principles used and significant estimates made by management as well as evaluating the overall statement presentation. We believe our audit provides a reasonable basis for our opinion. The [project name] management's policy is to prepare the accompanying statements on the cash receipts and payments basis in conformity with [International Public Sector Accounting Standards issued by the Public Sector Committee of the International Federation of Accountants/International Accounting Standards issued by the International Accounting Standards Board/National Accounting Standards issued by.]. On this basis, cash receipts are recognized when received and cash expenditures are recognized when paid rather than when incurred. [In our opinion, the financial statements present fairly the cash receipts and payments of the project during the year ended mmmm/dd/yy in accordance with [International Public Sector Accounting Standards issued by the Public Sector Committee of the International Federation of Accountants/International Accounting Standards issued by the International Accounting Standards Board/National Accounting Standards issued by.described in note x]]. OR [In our opinion, the financial statements have been prepared in accordance with [International Public Sector Accounting Standards issued by the Public Sector Committee of the International Federation of Accountants/International Accounting Standards issued by the International Accounting Standards Board/National Accounting Standards issued by.described in note x], present fairly the cash receipts and payments of the project during the year ended mmmm/dd/yy and, in all material respects, expenditures have been applied to the purposes intended in Loan Agreement No ]

16 Attachment 4 SPECIMEN AUDITOR S OPINION SPECIAL We have audited the accompanying [Statements of Expenditures/Financial Monitoring Reports] submitted to the Bank during the year ended mmm/dd/yy in support of loan withdrawals under Loan Agreement No MY. We conducted our audit in accordance with generally accepted auditing standards that accordingly included examination, on a test basis, of evidence supporting the amounts and disclosures in the [Statements of Expenditures/Financial Monitoring Reports]. An audit also includes assessing the accounting principles used and significant estimates made by management as well as evaluating the overall statement presentation. We believe our audit provides a reasonable basis for our opinion. In our opinion, the [Statements of Expenditures/Financial Monitoring Reports] submitted together with the internal controls and procedures involved in their preparation can be relied upon to support the applications for loan withdrawals.