GAAP ALERT No.13/2008 To read on line please click here
31 July 2008
By Colin Parker B.Bus FCA MAICD
Principal, GAAP Consulting, colin@gaap.com.au
Member of the Australian Accounting Standards Board
Hot Spot: Consultations on Difficult or Contentious Matters
Senate Inquiry into Disclosure Regimes for Charities and NFP Entities
Agenda for Joint AASB/FRSB Meeting
AUASB July Meeting Highlights
AUASB Releases First Four Clarity Format Standard EDs
New Performance Reporting Standard
Enforceable Undertaking from Former HIH Auditor
APES Effective from 1 July 2008
IASB Hedging Amendments
Fair Value Advisory Panel Update
UK FRC Launches Complexity Project
IAASB Issues Four Revised Auditing Standards
International Auditing Directions for 2009-2011
IFAC’s Ethics Board Issues Proposals to Clarify Code of Ethics
IASB Constitution Review
Stephen LaGreca on Show
Presentation Feedback
Hot Spot: Consultations on Difficult or Contentious Matters
Justin Reid, CA, Associate, GAAP Consulting
Consultation: “the act of consulting; a conference for the exchange of information and advice.” As professional service providers, we (accountants and auditors) are constantly in consultation. We regularly consult with our colleagues, our clients, other professional advisors, professional bodies and with regulators.
APES 320 ‘Quality Control for Firms’ dictates the need for a firm to establish policies and procedures designed to provide reasonable assurance that appropriate consultations take place on difficult or contentious matters. The firm must also ensure that sufficient resources are available to enable the consultations to take place and that the consultations are documented.
Firms require staff to have appropriate knowledge, seniority and experience on significant technical and industry matters. It is particularly important for auditors to ensure that when consulting with experts, that those experts have the competency to provide the consultation required.
A major challenge for firms is to ensure that their professional staff not only has the necessary competencies and capabilities to perform their assigned engagements, but that staff is able to identify when a difficult or contentious matter requires consultation.
If the firm does not have the necessary skills internally to handle these difficult or contentious matters, then it will need to consult externally. External consultations must be sufficiently documented to enable an understanding of the matter and also the results of the consultation, including any decisions taken and the basis for those conclusions. It is important to note that the requirements within APES 320 are mandatory for all members in the firm, not just those in the assurance practice.
Senate Inquiry into Disclosure Regimes for Charities and NFP Entities
The Senate referred the disclosure regimes for charities and not-for-profit (NFP) entities to the Senate Standing Committee on Economics for report by the last sitting day of November 2008. The inquiry will examine:
The relevance and appropriateness of current disclosure regimes for charities and all other NFP entities Models of regulation and legal forms that would improve governance and management of charities and NFP entities and cater for emerging social enterprises, and Other measures that can be taken by government and the NFP sector to assist the sector to improve governance, standards, accountability and transparency in its use of public and government funds.
Written submissions which should be sent to: Committee Secretary, Senate Economics Committee, Department of the Senate, PO Box 6100, Parliament House, Canberra ACT 2600. The Committee requests that where possible, submissions should also be provided by email preferably as MS Word or RTF format documents. The closing date for submissions is 29 August 2008.
Agenda for Joint AASB/FRSB Meeting
The agenda for annual joint meeting of the AASB and NZ Financial Reporting Standards Boards held in Auckland on 30 and 31 July included the following agenda items:
Conceptual Framework Projects: Discussion of issues relating to IASB and IPSASB projects IPSASB Update: Presentation by IPSASB Chairman Policy for Modifying IFRSs: Discussion on identifying criteria Revenue Recognition – Exchange and Non-exchange Transactions: Discussion of IASB project and consider draft ED on non-exchange transactions Long-term Fiscal Sustainability: Education session IASB Update: Consider IASB work program Not-for-Profit Entities (Business Combination): Consider issues Emission Trading Schemes: Consider status report and issues Service Concession Arrangements: Consider submissions on ITC 16 and draft submission to IPSASB Financial Statement Presentation: Phase B Education session on IASB project Reporting Frameworks for SMEs: Discuss approaches and frameworks Interpretations: Consider proposed Interpretation and status of projects (AASB only meeting) Related Party Disclosures: Consider project plan for public sector project (AASB only meeting), and Concise Financial Reports: Consider proposed amendments to AASB 1039 (AASB only meeting).
AUASB July Meeting Highlights
Highlights of the 21-22 July meeting of the Auditing and Assurance Standards Board (AUASB) included:
Standard on Performance Engagements: Approved ASAE 3500 ‘Performance Engagements’ with an application date for reporting periods or engagements commencing on or after 1 January 2009 Standards on Review Engagements: Considered final versions of the following proposed standards on review engagements: ASRE 2400 ‘Review of Financial Reports Performed by an Assurance Practitioner who is Not the Auditor of the Entity’; ASRE 2405 ‘Review of Other Historical Financial Information Other Than a Financial Report’; ASA 2008-1 ‘Amendments to Australian Auditing Standards’ (Amendments to ASRE 2410 ‘Review of an Interim Financial Report Performed by the Independent Auditor of the Entity’). The Standards will be released in early August with an application date for engagements commencing on or after 1 October 2008. A compiled version of Auditing Standard ASRE 2410 Review of an Interim Financial Report Performed by the Independent Auditor of the Entity) will be prepared and released with these standards. This will comprise the original ASAE 2410 (28 April 2008) as amended by ASA 2007-1 and ASA 2008-1 ASA Redrafting (Clarity Format): Approved the issue of EDs in “Clarity” format of the following proposed revised Auditing Standards: ASA 240 ‘The Auditor’s Responsibilities relating to Fraud in an Audit of a Financial Report’; ASA 260 ‘Communicating with Those Charged with Governance’; ASA 315 ‘Identifying and Assessing the Risks of Material Misstatement Through Understanding the Entity and its Environment’; and ASA 330 ‘The Auditor’s Procedures in Response to Assessed Risk’. It is expected that the revised Auditing Standards will be finalised by October 2009, and be operative for reporting periods commencing on or after 1 January 2010 Proposed Guidance Statement – Self-Managed Superannuation Funds: Considered a further draft of the proposed Guidance Statement GS 009 ‘Financial and Compliance Audits of Self-Managed Superannuation Funds’ with its release anticipated in late August GAAP/GFS AASB 1049 Audit Issues: Issues concerning the form of the auditor’s report and the audit of budgets and budget variance explanations are currently being addressed by the AUASB and its Project Advisory Group, and ASIC Regulatory Guide 69 Debentures – Improving Disclosures for Retail Investors: Received an update on the form of the auditor’s report in the proposed revised ASIC Regulatory Guide 69.
AUASB Releases First Four Clarity Format Standard EDs
The Auditing and Assurance Standards Board (AUASB) released the first four exposure drafts of Australian Auditing Standards (ASAs) in Clarity format for comment by 31 August 2008. The exposure drafts are:
ED 5/08 ASA 240 ‘The Auditor’s Responsibilities Relating to Fraud in an Audit of a Financial Report’ ED 6/08 ASA 260 ‘Communication with Those Charged with Governance’ ED 7/08 ASA 315 ‘Identifying and Assessing the Risks of Material Misstatement through Understanding the Entity and its Environment’, and ED 8/08 ASA 330 ‘The Auditor’s Procedures in Response to Assessed Risk’
The International Auditing and Assurance Standards Board (IAASB) is in the process of revising its International Standards on Auditing (ISAs) in Clarity format, to ensure a clear and consistent application of its standards globally. To continue to conform with the ISAs, and in line with strategic direction from the Financial Reporting Council, the AUASB is also redrafting and reissuing the ASAs in a Clarity format.
Merran Kelsall, Chairman of the AUASB, said that there are some changes from the existing ASAs in the first four EDs, but they will not be significant. “With all of the exposure drafts, the AUASB is seeking comments on five specific questions relating to the application of the international standards in the Australian regulatory environment” Ms Kelsall said.
“It is critical that all audit firms take note of this next wave of proposed auditing standards. Processes will have to put in place to understand the changes, and a plan developed to incorporate them into the practice”, stated Justin Reid, Associate GAAP Consulting. “These four proposed Standards are the topics where ASIC has identified shortcomings in existing practice”, he added.
New Performance Reporting Standard
The AUASB released ASAE 3500 ‘Performance Engagements’ that establishes mandatory requirements and provides explanatory guidance for conducting and reporting on performance engagements. Such requirements include: relationship with other ASAEs, ASAs and ASREs; ethics; quality control; initiation or acceptance; terms of the engagement; understanding the activity; assessing the appropriateness of the activity as the subject matter; assessing the suitability of the criteria; and reporting findings, recommendations and responsible party comments.
The essential elements of performance engagements are:
A three party relationship involving an assurance practitioner, a responsible party or a number of responsible parties, and intended users, where either the responsible party or the intended user may also be the engaging party An appropriate activity Suitable criteria Sufficient appropriate evidence; and A written assurance report in a form appropriate to a performance audit engagement, or a performance review engagement, or a report addressing both levels of assurance.
Following the issuance of the ‘Framework for Assurance Engagements’ (Framework) and ASAE 3000 ‘Assurance Engagements Other than Audits or Reviews of Historical Financial Information’, the AUASB reviewed existing assurance standards issued including AUS 806 ‘Performance Auditing’ (July 2002) and AUS 808 ‘Planning Performance Audit’s (October 1995), and identified the need to update these standards. ASAE 3500 reflects the outcome of this process. This ASAE is operative for performance engagements commencing on or after 1 January 2009.
“Recently, there have been some fundamental changes in auditing requirements for assurance engagements that do not involve the audit of financial statements; ASAE 3500 ‘Performance Engagements’ is a further example” stated Justin Reid, Associate GAAP Consulting. “Audit practices need to understand the Framework and these new and revised assurance standards. There is much to be done in a short time frame; engagements letters reissued; staff trained and clients educated; audit program updated; and audit reporting precedents revised”, Justin concluded.
Enforceable Undertaking from Former HIH Auditor
ASIC accepted an enforceable undertaking from the former partner of Arthur Anderson and auditor of HIH Insurance Ltd (HIH), Mr. John Buttle. Mr. Buttle was the engagement partner for the audit of HIH’s financial report for the year ended 30 June 2000, and signed an unqualified audit report with an emphasis of matter in relation to reinsurance.
While the HIH Royal Commission found deficiencies in Arthur Anderson ‘s audit work in relation to the HIH 2000 financial year report, it acknowledged Mr. Buttle’s emphasis of matter in the HIH 2000 audit financial statements and his insistence that the HIH Board report the Pacific Eagle transaction to ASIC.
As a result of investigations and the findings of the HIH Royal Commission, ASIC formed a view that the audit of HIH for 2000 was inadequate in that: Arthur Anderson failed to properly manage the risk associated with the HIH audit contrary to auditing standards and its own audit procedures manual; and Arthur Anderson’s audit working papers did not contain sufficient appropriate audit evidence regarding future income tax benefits, income tax balances, the assessment of the recoverable amount of deferred acquisition cost, or to resolve the doubt and uncertainty as to the appropriateness of the going concern assumption.
The enforceable undertaking was offered after ASIC expressed concerns that Mr. Buttle may have failed to carry out or perform adequately and properly the duties of an auditor in relation to the 2000 audit of HIH. The enforceable undertaking provides for Mr. Buttle’s registration as an auditor to be cancelled and for him not to apply for re-registration until after 1 March 2010. In agreeing to this enforceable undertaking, ASIC has taken into account that Mr. Buttle has not signed any audit reports since 2004, is currently not practising as a registered company auditor, and provided ASIC with statements relevant to criminal proceedings following its investigations into the collapse of HIH.
APES Effective from 1 July 2008
Public Practitioners are reminder that the following professional standards came into effect from 1 July 2008, and are applicable to relevant engagements commenced on or after this date:
APES 205 ‘Conformity with Accounting Standards’ (replaces APS 1) APES 220 ‘Taxation Services’ (replaces APS 6), and APES 305 ‘Terms of Engagement’ (replaces APS 2).
In addition, APS 8 Statement of management consulting standards is to be withdrawn, with effect from 30 June 2008 and will not be replaced.
IASB Hedging Amendments
The International Accounting Standards Board (IASB) issued an amendment to IAS 39 Financial Instruments: Recognition and Measurement regarding eligible hedged items. The amendment clarifies how the existing principles underlying hedge accounting should be applied in two particular situations. The IFRIC requested the IASB to provide additional guidance on what can be designated as a hedged item. The responses to an exposure draft of proposed guidance (September 2007) indicated that diversity in practice existed, or was likely to exist, in the designation of a one-sided risk in a hedged item, and inflation in a financial hedged item. The IASB has focused on developing application guidance to illustrate how the principles underlying hedge accounting should be applied in those situations. Entities are required to apply the amendment retrospectively for annual periods beginning on or after 1 July 2009, with earlier application permitted.
Fair Value Advisory Panel Update
On 17 July 2008 the sub-group of the panel met to discuss specific examples to illustrate the measurement issues identified, these included: measuring fair value when there are no longer observable market prices; using transaction prices when the number of actual transactions has decreased; using data from pricing services, brokers or other sources; selecting inputs to models and adjusting those inputs; dealing with forced transactions (forced liquidation or distressed sales; measuring changes in non-performance risk (own credit). The examples related to the following instruments and structures: commercial paper and auction rate securities; asset backed securities; loans in syndication; real estate loans; and structured derivatives. The panel members discussed the approaches to these issues and transactions that have been developed over the past several months. These examples will form the basis of a draft document that was presented to the full panel at its meeting on 31 July 2008.
UK FRC Launches Complexity Project
The UK Financial Reporting Council has launched a project to review the complexity and relevance of current company reporting requirements. The increasing size and complexity of company reports has become a subject of growing concern among investors, accountants, auditors and others with an interest in clear and relevant corporate reporting. Ian Wright, the FRC’s Director of Corporate Reporting, and head of the project, says: “We need to offer a vision of less complexity that stakeholders support so we can begin to move in the right direction.” The FRC, the UK’s independent regulator responsible for promoting confidence in corporate reporting and governance, has identified the complexity issue as one of the more serious threats to confidence.
The FRC has established this project “to address the risk that corporate reporting requirements, and related influential guidance, are contributing to the increasing complexity of reports without making them more useful or understandable.” The scope of the project includes requirements relating to financial statements, accompanying management commentary and other reports. Ian Wright says: “As a first goal, we would like to understand the causes of complexity in corporate reporting and engage the community in a debate about how to stop complexity increasing further. To achieve this we need to understand the different perspectives of finance teams, directors, investors and analysts – what is it they find complex in what they do?”
The project team is initially seeking input from interested parties who has suggestions about how to address the problem. The team has an extensive consultation program with key groups and individuals, who prepare, present and read corporate reports. The project team aims to publish a Discussion Paper later this year.
Commenting on the project, Jim Dixon, Associate, GAAP Consulting stated “The ever present challenge of reducing the level of complexity in financial reporting will not be resolved until there is greater certainty as to the needs, skills, knowledge and experience expected of the users of financial reports. As potential users represent such a wide spectrum of needs, it is very problematic to contemplate a single or final resolution of this issue. A possible way forward would be for reporting entities to provide a comprehensive data base from which users can select the data necessary to meet their individual requirements which range from the simple to the most complex. In this respect, the development of XBRL has an important role to play in the future of financial reporting. For example XBRL requires only one entry for each bit data which then permits multiple reporting opportunities both within and external to the reporting entity”.
Jim concluded that “the level of complexity should be the choice of the user, and not the provider of the data”.
IAASB Issues Four Revised Auditing Standards
The IAASB released International Standard on Auditing (ISAs) 550 (Revised and Redrafted) ‘Related Parties’, and three clarity redrafted ISAs.
The revised Related Parties standard clarifies the meaning of ‘related party’ for purposes of an audit. It also makes clear the auditor’s responsibility to obtain sufficient evidence about the required accounting and disclosure of related party relationships and transactions, and to understand how such relationships and transactions affect the view given by the financial statements.
The standard will strengthen current auditing practice by emphasising the need for the auditor to understand related party relationships and transactions to identify the risks of material misstatement to which these may give rise, and directing the auditor to focus work effort on the assessed risks of material misstatement, including those due to fraud.
The revised standard also clarifies the auditor’s responsibilities in those cases where the financial reporting framework establishes minimal or no related party requirements. In addition, it provides enhanced guidance to assist the auditor in understanding and responding to the risks of material misstatement that may arise in relation to related parties with dominant influence.
In addition to ISA 550 (Revised and Redrafted), the IAASB has also released the following clarity redrafted ISAs: ISA 250 (Redrafted) ‘Consideration of Laws and Regulations in an Audit of Financial Statements’; ISA 510 (Redrafted) ‘Initial Audit Engagements – Opening Balances’; and ISA 570 (Redrafted) ‘Going Concern’.
To date, the IAASB has released 15 final clarity redrafted ISAs. The IAASB is on track to finalise its complete set of clarified ISAs by the end of this year. The complete set of clarified ISAs, including newly revised standards such as ISA 550 (Revised and Redrafted), will be effective for audits of financial statements for periods beginning on or after 15 December 2009.
International Auditing Directions for 2009-2011
The IAASB has released its Strategy and Work Program, 2009-2011. The three-year strategy includes an emphasis on the development of standards that contribute to the effective operation of the world's capital markets and that address the needs of small-and medium-sized entities and small and medium practices.
The Strategy and Work Program responds to significant developments in the environment in which audit and other assurance services are performed, and in which standards for such services are set. It also highlights the IAASB role in working toward global acceptance of and convergence with its standards and in establishing and maintaining relevant partnerships. It is underpinned by the IAASB's communications initiatives to keep stakeholders informed of its activities and to promote adoption and implementation of its standards.
The Strategy and Work Program, 2009-2011 can be downloaded free-of-charge from the IFAC online bookstore. To access the related Basis for Conclusions and other information on the IAASB's work, visit its home page.
IFAC’s Ethics Board Issues Proposals to Clarify Code of Ethics
To further promote and facilitate accountants' adherence to high ethical and independence standards, the International Ethics Standards Board for Accountants (IESBA), an independent standard-setting board within the International Federation of Accountants (IFAC), has proposed changes to the IFAC Code of Ethics for Professional Accountants. The changes focus on enhancing the clarity of the Code. The proposed changes make clear the specific requirements that are contained in the Code and refine the application of the Code's conceptual framework. “The proposals significantly enhance the clarity and understandability of the provisions in the Code,” states Richard George, IESBA Chair. Comments on the exposure draft are requested by 15 October 2008.
IASB Constitution Review
The Trustees of the International Accounting Standards Committee (IASC) Foundation published a discussion document Review of the Constitution: Public Accountability and the Composition of the IASB - Proposals for Change. The document contains proposals that are dealt with in the first phase of the organisation’s five-yearly Constitution Review. The deadline for public comment on the document is 20 September 2008.
The proposals would establish a formal link between the organisation and a Monitoring Group (comprising representatives of public authorities and international organisations that have requirements for accountability to public authorities); and expand the membership of the IASB to 16 members, and add new guidelines regarding the geographical diversity of the members of the IASB.
The establishment of the link to a Monitoring Group, a group established by public authorities outside the IASC Foundation’s organisational framework, is aimed at enhancing the transparency and public accountability of the IASC Foundation, while not impairing the independence of the standard-setting process.
The initial membership of the Monitoring Group would comprise the responsible member of the European Commission, the managing director of the International Monetary Fund, the chair of the IOSCO Emerging Markets Committee, the chair of the IOSCO Technical Committee, the commissioner of the Japan Financial Services Agency, the chairman of the US Securities and Exchange Commission, and the president of the World Bank. The Monitoring Group would have the responsibility of approving the selection of Trustees. The Trustees would also report to the Monitoring Group regularly to enable it to address whether and how the Trustees are fulfilling their role set out in the Constitution.
The expansion of the IASB would enable it to engage more efficiently and effectively with interested parties throughout the world and bring new perspectives to its deliberations. The addition of a geographical component would strengthen the legitimacy of the IASB in the view of the countries choosing to adopt IFRSs.
The Trustees expect to complete the first part of the Constitution Review at their October meeting, with the changes taking effect from 1 January 2009. A review of other elements of the IASC Foundation’s Constitution will begin after the meeting in Beijing. The Trustees will publish a further discussion document inviting respondents to suggest topics for consideration by the Trustees. It is expected that consultations will be held during the course of 2009, with changes taking effect from 1 January 2010.
Stephen LaGreca on Show
Stephen is a member of the GAAP Consulting Network. His recent consulting engagements have included:
Project director of an AIFRS implementation, APRA regulatory considerations, for a major Australian Bank over a two and half year period Review the AGAAP, AIFRS and APRA regulatory requirements of complex structured transactions Project management services on Basel II capital requirements, particularly, in relation to economic capital, including the development of financial evaluation models and business case evaluation processes Writing technical material in diverse areas, including financial material and assurance services, and Assistance to newly listed companies in preparing discourse for the annual financial reports, including remuneration reports and corporate governance statements.
Stephen specialises in providing an implementation resource to companies on new and revised accounting standards. He was previously Chairman of the Accounting and Audit Committee of BDO, the Australian representative to its international technical committee, and an audit partner. Stephen undertakes long-term consulting engagements on implementing GAAP and related accounting assignments for the listed entities.
Presentation Feedback
Our team leader, Colin Parker, was a key note presenter at the NIA Tasmanian Conference held at Port Arthur where he spoke on contemporary financial issues. The feedback included:
Presented with in-depth knowledge and understanding of the standards Informative and well presented Understandable High quality Important topic and appropriately presented Lively, and Made a dry subject interesting.
Following completion of a series of litigation support and consulting engagements on contemporary financial reporting issues, you can catch Colin presenting the following seminar topics ‘Impairment in the 2008 Context’ (CPA Australia), ‘Financial Reporting for SMEs – the New Regime’ (ICAA), and ‘CFO Heads Up on New Standards’ (Strategy Group). Members of the GAAP Consulting team are also available for in-house training sessions, partner and audit committee briefings, as well as internal conferences.
Outstanding Exposure Drafts
Accounting
1 August Discussion Paper ‘Financial Instruments with Characteristics of Equity’ – AASB 1 August Consultation Paper ‘Accounting and Financial Reporting for Service Concession Arrangements’ – PSASB 22 August Discussion Paper ‘Reducing Complexity in Reporting Financial Instruments’ – AASB 25 August ED 164 ‘An Improved Conceptual Framework for Financial Reporting: The Objective of Financial Reporting and Qualitative Characteristics and Constraints of Decision-useful Financial Reporting Information’ – AASB 25 August ITC 17 ‘Request for Comment on IASB Discussion Paper Preliminary Views on an improved Conceptual Framework for Financial Reporting: The Reporting Entity’ – AASB 5 September Discussion Paper ‘Financial Instruments with Characteristics of Equity’ – IASB 19 September Discussion Paper ‘Reducing Complexity in Reporting Financial Instruments’ – IASB 19 September Discussion paper ‘Preliminary Views on Amendments to IAS 19 Employee Benefits’ – IASB 20 September 2008 ‘Review of the Constitution: Public Accountability and the Composition of the IASB – Proposals for Change’ – IASB 29 September ‘An Improved Conceptual Framework for Financial Reporting: Chapter 1: The Objective of Financial Reporting and Chapter 2: Qualitative Characteristics and Constraints of Decision-useful Financial Reporting Information)’ – IASB and FASB 29 September ‘Preliminary Views on an Improved Conceptual Framework for Financial Reporting: The Reporting Entity’ – IASB and FASB
Auditing
31 August ED 5/08 ASA 240 ‘The Auditor’s Responsibilities Relating to Fraud in an Audit of a Financial Report’ 31 August ED 6/08 ASA 260 ‘Communication with Those Charged with Governance’ 31 August ED 7/08 ASA 315 ‘Identifying and Assessing the Risks of Material Misstatement through Understanding the Entity and its Environment’ 31 August ED 8/08 ASA 330 ‘The Auditor’s Procedures in Response to Assessed Risk’
Ethics
Other
1 August Consultation Paper ‘Thin Capitalisation: Amendments to the Application of Accounting Standards’ – Federal Treasury 5 August Consultation Paper 99 ‘Mortgage Schemes – Improving Disclosure for Retail Investors’ and Consultation Paper 100 ‘Unlisted Property Schemes – Improving Disclosure for Retail Investors’ and draft regulatory guides – ASIC
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