SAS No. 99 changed the prior guidance, SAS No. 82, in several ways, but perhaps the most notable is the brainstorming required in the planning stage. Auditors are required to brainstorm the specific fraud schemes that might be perpetrated and the level of risk for each. Accordingly, the high risks that can lead to a material misstatement must be addressed in the audit procedures themselves. Second, the auditor basically assumes that a revenue recognition (financial statement) fraud is going on. The AICPA argues that the risk assessment process used in SAS No. 99 is very different, including many more elements than previously required, and follows a top-down, risk-based approach that is more effective in detecting material fraud.