The accused has a Sixth Amendment right of self-representation if he or she knowingly, intelligently, and voluntarily waives his or her Sixth Amendment right to the assistance of counsel. (Faretta v. California (1975) 422 U.S. 806 at pp. 812-835; People v. Barnum (2003) 29 Cal.4th 1210, 1214.) In Faretta, the trial court warned the accused, a "literate, competent, and understanding" (Faretta, at p. 835) high school graduate who had defended himself once before in a criminal prosecution, that if he were to represent himself he would have to follow "all the 'ground rules' of trial procedure" (id. at p. 836), that only someone who had tried "'a lot of cases'" (id. at p. 808, fn. 2) would know, that he "would receive no special favors," (id. at p. 808) and that he would be "'making a mistake'" (ibid.). After the trial court forced a public defender on him, the high court reversed, holding that even though the accused "should be made aware of the dangers and disadvantages of self-representation, so that the record will establish that 'he or she knows what he or she is doing and his choice is made with eyes open,'" (id. at p. 835) the court must honor the choice of self-representation "out of 'that respect for the individual which is the lifeblood of the law.'" (Id. at p. 834; see Barnum, at p. 1226.) The test of "whether there has been an intelligent waiver of the right to counsel must depend, in each case, upon the particular facts and circumstances surrounding that case, including the background, experience, and conduct of the accused." (Johnson v. Zerbst (1938) 304 U.S. 458, 464.) Although the accused can challenge the grant of a motion for self-representation by arguing that the record fails to show he or she was made aware of the risks of self-representation, no particular form of words of admonishment is required. (People v. Koontz (2002) 27 Cal.4th 1041, 1070; People v. Bloom (1989) 48 Cal.3d 1194, 1225.) To the contrary, the test is simply "whether the record as a whole demonstrates that the defendant understood the disadvantages of self-representation, including the risks and complexities of the particular case." (Koontz, at p. 1070; Bloom, at p. 1225.) Congruently, the prevailing test in the federal circuit courts for a valid waiver of the right to counsel is a "similar nonformalistic approach to determining sufficiency of the waiver from the record as a whole rather than requiring a deliberate and searching inquiry." (U.S. v. McDowell (6th Cir. 1987) 814 F.2d 245, 249, disapproved on another ground in Godinez v. Moran (1993) 509 U.S. 389, 395, fn. 5.) "We prefer trial courts to simplify our review by explaining the risks of self-representation to the accused," the Ninth Circuit notes. (United States v. Kimmel (9th Cir. 1982) 672 F.2d 720, 722.) "However, because the test concerns what the accused understood rather than what the court said or understood, explanations are not required." (Ibid.) "The ultimate test is not the trial court's express advice, but rather the defendant's understanding." (Fitzpatrick v. Wainwright (11th Cir. 1986) 800 F.2d 1057, 1065.)