Based on SAS No. 99, as well as prior accounting and psychology research, we develop a model of auditors’ use of brainstorming in the consideration of fraud. SAS No. 99 provides guidance to improve the likelihood that auditors will detect fraud using a multi-phase approach AICPA 2002, 2003. First, auditors collect information related to the risk of material misstatement due to fraud e.g., data on equity-based compensation. Using such information, auditors brainstorm to identify fraud risk factors e.g., incentives, synthesize this information to develop a fraud risk assessment, and develop a response to the risk assessments such as altering the staffing of the engagement, or modifying the nature, timing, and extent of audit procedures. Brainstorming sessions are intended to aid auditors in linking fraud risk factors to risk assessments and, in turn, foster the development of appropriate audit responses. As such, the model depicted in Figure 1indicates that brainstorming should influence both phases of the fraud decision-making process such that the relations among fraud risk factors, risk assessments, and responses are positively moderated by the quality of the brainstorming session.