GAAP ALERT No.20/2009 To read on line please click here
By Colin Parker B.Bus FCA MAICD
Principal, GAAP Consulting, colin@gaap.com.au
Member of the Australian Accounting Standards Board (2006-2009)
INTRODUCTION
AASB ED on Amortised Cost and Impairment
ASIC Commences Civil Proceedings against Former Officers of MFS Group
ASIC Proceedings against Rich and Silbermann Fail
Passage of Executive Pay Termination Payments Legislation
MINCO Agrees Principles for Reform of Directors’ Liability
ASIC Proposed Guidance to Directors on their Duty to Prevent Insolvent Trading
Improving Protections for Corporate Whistleblowers
ASIC Releases New Proposals on Superannuation Forecasts
ATO Releases PSLA 2009/8 Asset is not an In-house Asset
SMSFs and In-house Assets
Related Party Disclosures – IASB Amendments
IAASB Alert Use of External Confirmations
GAAP Team in Action
‘Clarity Auditing Standards – An Introduction’ Publication Released
AASB ED on Amortised Cost and Impairment
The AASB is seeking comments on ED 189 ‘Financial Instruments: Amortised Cost and Impairment’, which proposes to clarify the amortised cost model and to rationalise and improve the approach to measuring and reporting impairments of financial assets. The proposals would result in one impairment method, replacing the multiple methods that have applied under AASB 139/IAS 39. Comments are sought by 17 May 2010. ED 189 is the Australian wrap around of ED 2009/12 on the same title issued by the IASB (see GAAP Alert 192009).
The key proposals include:
Objective of Amortised Cost Measurement: The objective is ‘to provide information about the effective return on a financial asset or financial liability by allocating interest revenue or interest expense over the expected life of the financial instrument’. Amortised cost is a measurement that combines current cash flow information at each measurement date with a valuation of those cash flows that reflects conditions on initial recognition of the financial instrument; and the types of amounts that are allocated over the expected life of the financial instrument (including for a financial asset the initial estimate of expected credit losses)
Measurement Principles: Amortised cost is calculated using the effective interest method. Amortised cost is the present value of the expected cash flows over the remaining life of the financial instrument discounted using the effective interest rate. The estimates of the cash flows are the expected values at each measurement date. Estimates of amounts and timing of cash flows are the probability-weighted possible outcomes. The effective interest method is the allocation mechanism for interest revenue and interest expense. The method reflects the nature of the financial instrument’s interest (type of interest formula), i.e., what part of the contractual interest rate (if any) is reset
Objective of Presentation and Disclosure: The objective to provide ‘information that enables users of the financial statements to evaluate the financial effect of interest revenue and expense, and the quality of financial assets including credit risk.’ The ED emphasises the importance of explaining to users of the financial statements the overall effect on the entity’s performance and financial position and the interaction between different aspects of the information provided (including a discussion of the causes of both that overall effect and any interaction between different aspects)
Presentation: The following line items are to be separately presented in the SOCI: gross interest revenue (calculated using the effective interest method before taking into account expected losses); the effect of allocating the initial expected credit losses, presented as a reduction of gross interest revenue; net interest revenue; gains and losses resulting from changes in estimates in relation to financial assets and liabilities that are measured at amortised cost; and interest expense (calculated using the effective interest method), and
Disclosure: The proposed disclosures include: mandatory use of an allowance account to record credit losses with disclosure of a reconciliation and the entity’s write-off policy; information about estimates and changes in estimates; stress testing information if an entity prepares such information for internal risk management purposes; the quality of financial assets that reconcile changes in an entity’s non-performing assets with supplementary qualitative information; and information about the origination and maturity of financial assets.
Commenting on the proposals, GAAP Consulting Network member David Sauer said “There will be parties who will find the revisions create a costly exercise to determine impairment. At face value the ‘expected loss’ model may suit entities such as financial institutions as it seems closer to the ‘specific plus general provision’ model they used before AIFRS. However, expected losses need to be established by considering expected cash flows and revising the effective interest rate. Without short-cuts, the calculations and documentation may be onerous compared to current or former methods for other entities.”
ASIC Commences Civil Proceedings against Former Officers of MFS Group
ASIC commenced civil proceedings in the Supreme Court of Queensland against three subsidiary companies of the formerly listed MFS Ltd (now known as Octaviar Ltd (in Liquidation)) and four former officers and one manager of MFS Investment Management Ltd. The proceedings relate to the use of $147.5 million in funds of the Premium Income Fund (PIF), for which MFS Investment Management Ltd (‘MFSIM’, now known as Managed Investments Ltd) was the responsible entity at the relevant time. In taking this action, ASIC is addressing the core obligations of a responsible entity and its directors and officers to operate the fund with care and diligence, and in the best interest of the fund’s members.
ASIC alleges that in November 2007, officers of MFSIM caused PIF to transfer $130 million to MFS Administration Pty Ltd so that MFS Administration could use those funds to pay financial obligations of other MFS Ltd subsidiaries, including $103 million owed to Fortress Credit Corporation (Australia) Pty Ltd by MFS Castle Pty Ltd. ASIC also alleges that in December 2007, officers of MFSIM caused PIF to transfer $17.5 million to MFS Pacific Finance Ltd, a New Zealand registered company (now known as OPI Pacific Finance Ltd (Receivers and Managers Appointed)). ASIC further alleges that in about January 2008, officers and the fund manager of MFSIM created and used false documents, relating to the use of the $147.5 million. As a result of the funds being transferred, ASIC alleges that the PIF suffered a loss of $147.5 million. ASIC is seeking orders for declarations of contraventions, pecuniary penalties, compensation and disqualifications from managing corporations.
MFS Ltd was a publicly listed company with interests in financial services, travel and leisure and child care businesses. MFSIM was an unlisted public company and wholly owned subsidiary of MFS Ltd (now in Liquidation). MFSIM was the responsible entity for six unlisted managed investment schemes, including the PIF and the Maximum Yield Fund (‘MYF’). MYF is also relevant to the current civil penalty proceedings. The PIF was an unlisted managed investment scheme which offered investments to retail and wholesale investors through a Product Disclosure Statement. Wellington Capital Ltd took over as responsible entity of the PIF in late 2008. PIF units have since been listed on the National Stock Exchange.
The defendants in the matter are: Michael Christodoulou King, former CEO and Director of MFS Ltd; Craig Robert White, former Deputy CEO (and for a short period, CEO) and director of MFS Ltd and MFSIM; Guy Hutchings, former CEO and director of MFSIM; David Mark Anderson, former CFO and Company Secretary of MFS Ltd; Marilyn Anne Watts, NSW, former fund manager of MFSIM; Managed Investments Ltd (formerly known as MFSIM and Octaviar Investment Management Ltd); Octaviar Administration Pty Ltd (formerly MFS Administration Pty Ltd) (In Liquidation); and Octaviar Castle Pty Ltd (formerly MFS Castle Pty Ltd and MFS Investment Holdings No 17 Pty Ltd).
ASIC Proceedings against Rich and Silbermann Fail
The NSW Supreme Court dismissed ASIC’s civil proceedings against One.Tel’s former joint Managing Director, Mr Jodee Rich and the company’s Finance Director, Mr Mark Silbermann. ASIC commenced civil proceedings in 2001 against three executive directors and the non-executive chairman of One.Tel in relation the company’s collapse in 2001. ASIC sought rulings from the court on the duties and obligations of officers to disclose a company’s financial position to the board and the market.
ASIC Chairman, Mr Tony D’Aloisio said the case should provide important guidance to executives and directors on the exchange of information between the board and management. Additionally, the case has shed light on several important legal issues, notably the additional responsibilities of the chairman of a public company, particularly one with a finance/accounting background and considerable experience on public boards. It also identified the right of defendants in civil penalty proceedings not to give discovery or file witness statements until the conclusion of evidence by ASIC’s witnesses.
Former One.Tel board members and directors, Mr Brad Keeling (One.Tel’s joint managing director) and Mr John Greaves (the company’s chairman) were also part of ASIC’s original proceedings. However, both agreed to settlements with ASIC in 2003. Mr Keeling agreed to a ten-year disqualification from acting as a director and liability to pay compensation of $92 million. Mr Greaves settlement involved a disqualification from being a director for four years and liability to pay compensation of $20 million.
Passage of Executive Pay Termination Payments Legislation
The Government has welcomed the passage of the Corporations Amendment (Improving Accountability on Termination Payments) Bill 2009 through the Senate. The legislation and accompanying regulations will take effect the day after Royal Assent is granted. Key features of the legislative package include:
New regulatory framework will ensure that termination benefits for company directors and executives exceeding one year’s average base salary are subject to shareholder approval Scope of the requirements relating to termination benefits is expanded to include senior executives or key management personnel of a disclosing entity Definition of what constitutes a “benefit” is broadened, including a requirement for a broad interpretation of the term “benefit” and a requirement that the substance should prevail over its legal form New regulation-making powers to specify what types of payments are, or are not, a termination benefit, and to define “base salary” Immediate repayment of unauthorised termination benefits with an increase in the penalty provisions (including the possibility of a six month’s jail sentence), and Retention of the existing requirement for the giving of the benefit to be approved by a resolution passed at a general meeting.
“These reforms will empower shareholders to reject excessive termination payments and promote responsible remuneration practices,” Mr Bowen said.
MINCO Agrees Principles for Reform of Directors’ Liability
The Minister for Financial Services, Superannuation and Corporate Law, Chris Bowen MP welcomed the agreement reached at the Ministerial Council for Corporations (MINCO) meeting on the next step in reform of directors’ liability provisions. MINCO agreed on a set of principles by which all jurisdictions will audit their legislative provisions that deal with personal liability on company directors.
Ministers recommend the following principles for adoption on a national basis in relation to corporate liability and the circumstances in which directors may also be liable for corporate fault:
Where a corporation contravenes a statutory requirement, the corporation should be held liable in the first instance. Directors should not be liable for corporate fault as a matter of course or by blanket imposition of liability across an entire Act The imposition of personal criminal liability on a director for the misconduct of a corporation should be confined to situations where: there are compelling public policy reasons for doing so; liability of the corporation is not likely on its own to sufficiently promote compliance; and it is reasonable in all the circumstances for the director to be liable having regard to factors including: the obligation on the corporation, and in turn the director, is clear; the director has the capacity to influence the conduct of the corporation in relation to the offending; and there are steps that a reasonable director might take to ensure a corporation's compliance with the legislative obligation, and Where above the principle is satisfied and directors’ liability is appropriate, directors could be liable where they: have encouraged or assisted in the commission of the offence; or have been negligent or reckless in relation to the corporation's offending. In addition, in some instances, it may be appropriate to put directors to proof that they have taken reasonable steps to prevent the corporation's offending if they are not to be personally liable.
Ministers recommend the following action with a view ensuring that legislation imposing liability on directors for corporate fault operates fairly and can be clearly justified:
A legislative review by each jurisdiction to identify those existing offences for which directors’ liability, or removal of that liability, is appropriate in accordance with above principles Harmonisation following cross-jurisdictional comparison in key policy areas A harmonised legislative approach to provisions imposing directors’ liability around key concepts and definitions, and Greater clarity about the offences for which directors may be liable through a specific listing or schedule approach.
This is the next step towards achieving consistency across Australia on the laws that impose personal liability on directors. “It is pleasing that MINCO has reached a sensible agreement on the next step of reform on directors’ liability,” Minister Bowen said. “Today’s agreement will see the Commonwealth, States and Territories begin to audit their legislative provisions on directors' liability against these agreed principles.” Upon completion of the audit, the next step for all jurisdictions will be a move to amend any laws that do not adhere to the agreed principles.
ASIC Proposed Guidance to Directors on their Duty to Prevent Insolvent Trading
ASIC has released a Consultation Paper outlining proposed guidance to directors on their duty to prevent insolvent trading. The Corporations Act imposes a positive duty on directors to prevent insolvent trading. ASIC wishes to ensure that directors, particularly those in small-to-medium enterprises in financial difficulty, fully understand this duty.
The proposed guidance, contained in Consultation Paper 124 ‘Duty to prevent insolvent trading: Guide for directors’ (CP 124), sets out the relevant legal background to the duty to prevent insolvent trading and the key principles that ASIC considers directors need to take into account in performing their duty to prevent insolvent trading. Those principles are that a director:
Must keep him or herself informed about the financial affairs of the company and regularly assess the company’s solvency Immediately on identifying concerns about the company’s viability, should take positive steps to confirm the company’s financial position and realistically assess the options available to deal with the company’s financial difficulties Should obtain appropriate advice from a suitably qualified person, and Should consider and act appropriately on the advice received in a timely manner.
The guidance includes information about ASIC’s approach to insolvent trading and describes some of the factors ASIC will take into account, and the evidentiary material it will look at, in assessing whether there has been a breach of the insolvent trading provisions. By providing guidance, ASIC seeks to assist directors to both understand their duty to prevent insolvent trading and also, what they can do to minimise the risk that they will breach their duty. ASIC is seeking feedback on these proposals by 22 January 2010.
Improving Protections for Corporate Whistleblowers
The Minister for Financial Services, Superannuation and Corporate Law, the Hon Chris Bowen MP, released an options paper exploring strategies for improving protections for corporate whistleblowers. Currently, corporate whistleblowers are protected under Part 9.4AAA of the Corporations Act 2001. Copies of the paper can be obtained from the Treasury website. The closing date for submissions is 21 December.
However, these protections have been in place since 2004 and only four whistleblowers have felt safe enough using them to provide information to ASIC. “I am concerned that the existing protections for corporate whistleblowers contain fundamental shortcomings,” Mr Bowen said. “The options considered in this paper are important steps towards ensuring corporate whistleblowers are adequately protected,” he concluded.
Issues include:
Who is allowed to qualify for protection as a whistleblower – former employees, for example, currently do not qualify What types of issues can be disclosed under the protections – some matters which ASIC can investigate cannot currently be the subject of a protected disclosure Whether motive should affect protection – currently an individual with malicious motives cannot be protected even if the information they disclose is genuine Whether anonymity should affect protection – many whistleblowers may wish to be anonymous, but if they do not disclose their name from the start then, should they later need to come forward, such as to give evidence, they cannot be protected When can a Court order the production of documents which reveal a whistleblower's identity – there is concern that whistleblowers will be discouraged from coming forward unless there is further guidance on this issue What confidentiality restrictions should apply to those receiving disclosures second-hand – there may be a loophole in post-disclosure confidentiality protections, and Whether prospective whistleblowers should be protected for seeking legal advice – this may encourage more whistleblowers to come forward by providing greater certainty in relation to how the law operates.
Several of the potential reforms also relate to the whistleblower protections provided by the banking and insurance prudential legislation. However, as these provisions are relatively recent, broad changes to the protections offered by these Acts are not anticipated.
ASIC Releases New Proposals on Superannuation Forecasts
ASIC released proposals to grant relief to superannuation funds to enable them to provide superannuation forecasts to their members. Consultation Paper 122 ‘Superannuation forecasts: ASIC relief and guidance for super funds’ (CP 122), and the accompanying draft regulatory guide, describe the situations in which ASIC proposes to grant relief from licensing, advice, conduct and disclosure requirements under the Corporations Act for the provision of such forecasts. This will allow super funds to provide their members with an estimate of the likely balance of their superannuation funds on retirement (retirement projection) with their periodic superannuation statements.
Superannuation forecasts are likely to contain personal advice within the meaning of s766B(1) of the Corporations Act 2001, as they take into account a consumer’s objectives, financial situation or needs (e.g., by using information about their current balance, salary, and age, etc). Without relief, providers of superannuation forecasts would need to comply with the personal advice requirements of the financial services licensing regime.
ASIC currently gives licensing relief for providers of calculators, including superannuation calculators, where the calculator does not advertise or promote one or more specific financial product (Class Order (CO 05/1122) ‘Relief for providers of generic calculators’). While providers do not need to be licensed, CO 05/1122 also gives providers who are AFS licensees relief from the advice, conduct and disclosure requirements of Part 7.7 of the Corporations Act. ASIC does not currently provide any relief for providers of projections.
ASIC believes consumers will benefit strongly from receiving a regular personalised retirement projection and that clear and effective information about their likely benefits will give them a sound basis for making choices that best suit their needs. ASIC’s proposals are set out in Section B of the Consultation Paper. The relief will be conditional on trustees meeting certain requirements in relation to the content, presentation and calculation of projections, and the timing and manner in which they are given.
ASIC is also aiming to create greater clarity for super funds that take advantage of the current relief for providers of financial calculators. The draft regulatory guide gives guidance as to how providers of superannuation calculators can best comply with the requirement in ASIC Class Order (CO 05/1122) ‘Relief for providers of generic calculators’ that all assumptions applied by the calculator be ‘reasonable’.
Unlike the future projections provided on annual members’ statements in the past, the current ASIC proposal will require providers which elect to give investors projections, to provide:
Mandatory content including warnings and disclosures Projections prepared using required variables and default assumptions, and Projections with the member statement.
The purpose of the projections is to give superannuation members information about potential future savings however the limitations imposed by standardisation of assumptions may limit the effectiveness of the projections to members decision making. Advisors to funds who may be impacted by this proposal should consider making representations to ASIC by 11 December 2009.
SMSFs and In-house Assets
In a declining investment market there is an increased risk that due to the decline in value of listed investments an SMSF has in-house assets in excess of 5% of the market value of total assets. The SIS Act requires the trustee to develop a plan to dispose of assets to bring the in-house asset value under the 5% limit. The trustee has one year to develop the plan and the plan should set out the assets which are in-house assets and a timeline for their disposal. The timeline will take into consideration the time required for an orderly disposal of the asset e.g., for residential property this may be a period of 4 -6 months to allow for reasonable marketing and settlement.
While technically the failure to dispose of assets is required regardless of the subsequent movement in investment markets, the Commissioner has indicated that where other investments improve and the in-house assets are less than 5% prior to the implementation of the plan this is to be treated as a resolution of the in-house asset breach.
While the auditor is not required to report in-house assets arising due to movements in investment markets for the 30 June 2009 year end, as the breach relates to the failure to implement the plan and is likely to arise in the year ended 30 June 2010. There is an uncertainty for auditors about future reporting obligations as the Act requires the asset to be disposed of rather than the fund receiving additional contributions or improvements in the value of other assets.
This issue was raised as a matter for clarification at a recent ATO auditor meeting attended by Susan Orchard, GAAP Consulting Network member.
ATO Releases PSLA 2009/8 Asset is not an In-house Asset
The PSLA sets out the circumstances where the Commissioner will make a determination that a particular asset is not, or will not be, an in-house asset of the fund. Where the Commissioner makes a determination it may be retrospective and may be revoked. Where the Commissioner refuses to make a decision or revokes an earlier decision this is reviewable and can be referred to the AAT. The guidance states that the Commissioner will consider it appropriate to make a determination if: the facts of the case indicate circumstances that are unusual or out of the ordinary and by making the determination it will not undermine the purpose of the in-house asset rules in Part 8.
The Commissioner will consider circumstances to be unusual or out of the ordinary where: a trustee of an SMSF has complied with the SISA requirements in investing the fund's assets; certain events occur, which are unforeseeable and beyond the trustee's control, and these events when they relate to the fund result in the in-house assets of the fund exceeding the 5% in-house asset limit.
The Commissioner would not normally consider the circumstances as unusual or out of the ordinary where the in-house assets of the fund exceed the 5% in-house asset limit as a result of the following events:
Fluctuations in economic conditions The trustee is not aware of the requirements of the in-house asset rules The trustee relies on the exercise of due care and diligence by a professional and necessary advice is not provided There is a significant benefit to the fund from the investment The trustee does not want to incur any difficulties or costs in keeping the in-house assets under the 5% limit There is a failure to satisfy the exclusions to the in-house asset definition specified by regulation under paragraph 71(1)(j), or The transitional provisions allowing additional investments in particular related party assets expired at 30 June 2009 and further additional investments in assets of that kind are made after that date.
“This PSLA provides a limited but important opportunity to seek an exemption to the in-house assets rules” says Susan Orchard GAAP Network member.
Related Party Disclosures – IASB Amendments
The IASB released a revised version of IAS 24 ‘Related Party Disclosures’ that simplifies the disclosure requirements for government-related entities and clarifies the definition of a related party. There is no change to the fundamental approach to related party disclosures contained in previous version of IAS 24, which requires entities to disclose information about related party relationships and transactions. The revised IAS 24 is effective for annual periods beginning on or after 1 January 2011, with earlier application permitted.
IAS 24 requires entities to disclose in their financial statements information about transactions with related parties. Broadly, two parties are related to each other if one party controls, or significantly influences, the other party. The IASB has revised IAS 24 in response to concerns that the previous disclosure requirements and the definition of a ‘related party’ were too complex and difficult to apply in practice, especially in environments where government control is pervasive. The revised IAS 24 addresses these concerns by: providing a partial exemption for government-related entities and simplified the definition and removed inconsistencies in the definition of a related party.
Until now, if a government controlled, or significantly influenced, an entity, the entity was required to disclose information about all transactions with other entities controlled, or significantly influenced by the same government. The revised standard still requires disclosures that are important to users of financial statements but eliminates requirements to disclose information that is costly to gather and of less value to users. It achieves this balance by requiring disclosure about these transactions only if they are individually or collectively significant.
IAASB Alert Use of External Confirmations
External confirmation procedures can be a compelling tool in obtaining relevant and reliable evidence for audits of financial statements. Recent experience, however, highlights the need for auditors to pay particular attention to circumstances that may affect the planned use of confirmations, including the risk of fraud and the adequacy of evidence. To raise awareness of potential issues and to help auditors use external confirmation procedures more effectively, the staff of the International Auditing and Assurance Standards Board (IAASB) released a new audit practice alert.
Titled ‘Emerging Practice Issues Regarding the Use of External Audit Confirmations in an Audit of Financial Statements’, the alert highlights areas within the International Standards on Auditing (ISAs) that are particularly relevant when deciding to request external confirmations, designing and carrying out confirmation procedures, and evaluating responses received. The alert also raises awareness of potential issues that may surface from the increasing use of technology in the confirmation process and the use of restrictive language by respondents.
James Gunn, IAASB Technical Director, explains “Requesting external confirmations is a commonly used audit procedure in an audit of financial statements. Today’s environment, however, reinforces the need for professional scepticism and professional judgment in all aspects of an audit, including the use of confirmations. The alert reminds auditors of the need to maintain control over the confirmation process, and to remain alert to circumstances that may undermine its effectiveness.”
GAAP Team in Action
“Implications of the James Hardie decision for Directors’ Risk” was the topic discussed by David Sauer, GAAP Network member, as one of the speakers at a forum for practitioners held by AusBrokers Countrywide in November. David discussed why the 2009 judgement should be studied by directors and officers of large and small entities. Key issues include the personal liability of individuals in management as well as the Board, the importance of minutes, the responsibilities of individuals with particular expertise, such as the Chief Financial officer and company secretary, and the questions of recording approval of decision by vote or by consensus. The duties of officers and the links to financial reporting is a topic being discussed in current GAAP training.
Television Education Network has released a DVD of an interview with Colin Parker, Principal, GAAP Consulting on the topic of ‘Forensic Accounting – Updated Requirements. Forensic Accounting Services in connections with legal proceeding and investigations are now subject to updated requirements under a revised professional standard APES 215 ‘Forensic Accounting Services’ which replaces APS 11 and supporting guidance note 12. The program examined:
Scope and timing of application – for the first time, APES 215 applies to accountants working in the corporate and government sectors (previously only to members in public practice) The most significant changes for the previous regime How the various requirements of forensic accounting services are now defined and categorised
The mandatory requirements of APES 215 Specific requirements regarding the ‘public interest’ obligations, and Specific requirements for Expert Witness Services, particularly regarding the reports issued.
‘Clarity Auditing Standards – An Introduction’ Publication Released
Our booklet ‘Clarity Auditing Standards – An Introduction’, authored by Justin Reid, provides an overview of the ‘Clarity’ Auditing Standards to partners and senior managers of accounting firms so that the audit practice can:
Understanding the principles underlying ‘Clarity’ rewrite of Auditing Standards Identify the key changes to individual Auditing Standards that warrant attention Start to assess the implications of ‘Clarity’ Auditing Standards on the audit practice (e.g., timing, methodology management, training, resource requirements) Assist with an orderly implementation of the ‘Clarity’ Auditing Standards through a structured process Begin the client communication process, and Use a reference and training tool.
‘Clarity Auditing Standards – An Introduction’ is an important first step in this process; and retails for $99.00 (inc. GST). Act now and place your orders by email or visit www.gaap.com.au.
Accounting
Other
11 December Consultation Paper 122 ‘Superannuation forecasts: ASIC relief and guidance for super funds’ – ASIC 21 December ‘Improving Protections for Corporate Whistleblowers: Options Paper’ – The Treasury 22 January Consultation Paper 124 ‘Duty to prevent insolvent trading: Guide for directors’ – ASIC
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