IN THIS ISSUE:

1. IESBA Revises 2012 Strategy
2. Responding to a Suspected Illegal Act
3. Breach of a Requirement of the Code
4. IESBA Proposes Changes to the Definition of “Engagement Team”
5. Upcoming Meetings
6. Share Ethics eNews with Your Colleagues

1. IESBA Revises 2012 Strategy

The IESBA has agreed on a revision to its strategy and activities for 2012. Its revised strategy calls for the board to undertake the following activities in 2012:

Rotation—The IESBA will consider firm rotation and also whether the position of the Code of Ethics for Professional Accountants (the Code) on partner rotation remains appropriate, including whether the requirement to rotate off the audit engagement after serving seven years as a key audit partner and observe a two-year time-out period continues to be appropriate.

Non-assurance services—The IESBA will consider whether the Code's position on non-assurance services remains appropriate, including the use of materiality, and, if so, whether guidance should be provided for applying the materiality test. If certain non-assurance services are permitted, the IESBA might also consider whether they should be subject to pre-approval by those charged with governance, restricted in size in relation to the audit fee, or publicly disclosed.

Structure of the Code—The IESBA will determine how to increase the visibility of the requirements and prohibitions in the Code and clarify who is responsible for meeting them.

Part C of the Code—The IESBA will determine whether recent corporate accounting irregularities reveal ethical implications for professional accountants in business (PAIBs) and whether part C of the Code should be strengthened to provide PAIBs with more guidance and support.

These matters will be discussed initially at the IESBA's June 2012 meeting. Depending upon the positions reached, the IESBA ultimately may propose revisions to the Code.

2. Responding to a Suspected Illegal Act

At its February 2012 meeting, the IESBA discussed its position on how a professional accountant should respond to a suspected illegal act. The IESBA agreed on the following:

• An auditor and a professional accountant in public practice providing non-assurance services to an audit client should be required to disclose to an appropriate authority suspected illegal acts that affect financial reporting or fall within the expertise of the professional accountant. This requirement would apply when the suspected illegal act is of such consequence that disclosure would be in the public interest and the client has not done so. 
• Accountants performing non-assurance services for non-assurance clients and accountants in business should be required to disclose the matter to the external auditor. If the response to the matter is not appropriate, the accountant would be expected to exercise his right to disclose the matter to an appropriate authority. 
• Exceptional circumstances may exist where a reasonable and informed third party would conclude that it is not in the public interest to make such disclosure because the probable consequences, such as the risk to the personal safety of the professional accountant or other individuals, would outweigh the benefits of disclosure.

The IESBA expects to approve an exposure draft on this subject at its next meeting in April.

3. Breach of a Requirement of the Code

At its February 2012 meeting, the IESBA began discussing responses to the Exposure Draft proposing a new framework for addressing a breach of a requirement of the Code. The IESBA noted:

• Respondents are supportive of the Code addressing breaches.
• Respondents expressed mixed views on whether all independence breaches should be reported as soon as possible to those charged with governance; a majority felt that all breaches should be reported while a minority felt that breaches that were not significant need not be reported.
• Many respondents commented on the timing of such reporting, including that insignificant breaches not be required to be reported as soon as possible.

The IESBA tentatively concluded that all breaches should be reported to those charged with governance, but it may be appropriate to have some flexibility on the timing of reporting less significant breaches. The IESBA will continue considering comment submissions at its June meeting. 

4. IESBA Proposes Changes to the Definition of “Engagement Team”

At its February 2012 meeting, the IESBA approved an exposure draft to revise the definition of “engagement team” to make it clear that internal auditors providing direct assistance to an external auditor are not considered to be part of the audit engagement team under the Code and eliminate the perception that the Code and ISA 610, Using the Work of Internal Auditors are in conflict. The comment deadline is May 30, 2012.

5. Upcoming Meetings

Meetings of the IESBA and the IESBA Consultative Advisory Group (CAG) are open to the public. The IESBA next meets by conference call on April 19, 2012, from 7:00–10:00 AM Eastern Daylight Time and, in person, June 18–20, 2012 in New York, USA. For more information and to register to attend an IESBA meeting as an observer, visit IESBA Meetings.

The next IESBA CAG meeting will be held on September 12, 2012 in New York, USA. For more information, visit IESBA CAG Meetings.

6. Share Ethics eNews with Your Colleagues

The IESBA issues regular eNews updates to help keep you informed of its activities and recent publications. Please forward this eNews to any interested colleagues and advise them that they can subscribe to receive IESBA eNews by following these simple steps:

• Register a new account or log in to your existing IFAC web account. 
• Go to My Subscriptions to manage your subscription preferences. 
• Select "Ethics eNews" from the check list, as well as any other newsletters or press releases that you would like to receive.

The SMP Committee submitted this letter to the IFAC Board's Exposure Draft, Statements of Membership Obligations. The comments focus on the aspects of most relevance to SMPs, including the scope of quality assurance review systems, IFRS for SMEs, and translation requirement.

Many entities establish internal audit functions as part of their internal control, risk management, and governance structures; effective coordination and communication between the external and internal auditors can contribute positively to the external audit. Recognizing this, the International Auditing and Assurance Standards Board (IAASB) today released International Standard on Auditing (ISA) 610 (Revised), Using the Work of Internal Auditors, which addresses the external auditor’s responsibilities if using the work of an internal audit function in obtaining audit evidence.

“Internal auditing standards and practices have continued to develop, as has the relationship between external and internal auditors. Equally, the expectations on the external auditor continue to evolve, particularly with recent heightened emphasis on audit quality and accountability,” stated Prof. Arnold Schilder, IAASB chairman. “Our standards must also evolve to take account of these changes. Our revision of this standard involved extensive input from, and liaison with, the regulatory community, which we believe has helped enhance the quality of the final standard.”

The revised standard is aimed at enhancing the external auditor’s performance by providing a more robust framework for evaluating and using the work of an entity’s internal audit function. Related changes have also been made to ISA 315 (Revised), Identifying and Assessing the Risks of Material Misstatement through Understanding the Entity and Its Environment, to explain how the internal audit function and its findings can usefully inform the external auditor’s risk assessments.

“The external auditor may be able to use the work of a robust internal audit function. Nevertheless, the external auditor has sole responsibility for the audit opinion expressed, and that responsibility is not reduced by the external auditor’s use of the work of the internal audit function,” notes James Gunn, IAASB technical director. “This revised ISA defines the conditions that are necessary for the external auditor to be able to use the work of internal auditors, including ensuring that the internal audit function’s work is adequate for the audit, and preventing overuse or undue use of such work.”

Both ISA 610 (Revised) and ISA 315 (Revised) are effective for audits of financial statements for periods ending on or after December 15, 2013.

Using Internal Auditors to Provide Direct Assistance
In revising ISA 610, the IAASB also agreed on requirements and guidance that specify the conditions and establish responsibilities of the external auditor if the external auditor intends to use internal auditors to provide direct assistance during the audit.

The IAASB has engaged closely with the International Ethics Standards Board for Accountants (IESBA) in relation to this matter. While the IAASB has concluded its deliberations on the requirements addressing direct assistance, it intends to incorporate such material in ISA 610 (Revised) only after the IESBA concludes its deliberations on its February 2012 exposure draft of proposed changes to the definition of “engagement team” in the Code of Ethics for Professional Accountants (IESBA Code). The IESBA exposure draft proposes to resolve a perceived inconsistency between the ISAs and the IESBA Code regarding the ability of external auditors to use internal auditors to provide direct assistance.

About the IAASB
The IAASB develops auditing and assurance standards and guidance for use by all professional accountants under a shared standard-setting process involving the Public Interest Oversight Board, which oversees the activities of the IAASB, and the IAASB Consultative Advisory Group, which provides public interest input into the development of the standards and guidance. The structures and processes that support the operations of the IAASB are facilitated by IFAC.

About IFAC
IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

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The Professional Accountants in Business Committee was invited to participate in the Institute of Cost Accountants of India's National Cost Convention in New Delhi, India, in March 2012.

Article IFAC's paper calling for enhanced financial management transparency and accountability in the public sector, especially in the midst of the sovereign debt crisis.

Presentation given at the United Nations Conference on Trade and Development (UNCTAD)'s Climate Change Workshop

The International Federation of Accountants (IFAC) seminar, The Sovereign Debt Crisis, a Matter of Urgency―From Lessons to Reform, convened key decision makers, politicians, public finance management leaders, and others over two days in Vienna. The presentations, debates, and discussions sought a comprehensive understanding of the causes contributing to the international sovereign debt crisis and conveyed a clear and consistent message that the fiscal stress and instability associated with the crisis need to be addressed urgently, through a radical reform of public financial management systems and institutions in many countries.

“We heard over these two days that the problems with financial management and reporting are not confined to a small handful of European countries, but are widespread. There is a real danger of the current sovereign debt crisis, coupled with the fiscal challenges of aging populations, deepening into a global fiscal crisis—and it is therefore more urgent than ever that we act to bring about a radical transformation in public financial management,” said Ian Ball, CEO of IFAC. “Our goal is enhanced transparency and accountability on the part of public sector entities around the world. This would achieve long-term fiscal sustainability, more effective and efficient governments, and reduced risk of new fiscal crises.”

Speakers included influential financial and accounting leaders, such as Vincenzo La Via, Chief Financial Officer of the World Bank Group; Göran Persson, former Prime Minister of Sweden; Hon. Ruth Richardson, former New Zealand Minister of Finance; and Hon. David Walker, Founder and CEO of the Comeback America Initiative and former United States Comptroller General (complete list attached).

Key findings of the seminar included:

• The sovereign debt crisis has identified a compelling and urgent need for governments to address seriously the quality of their public financial management systems and institutions.
• The fiscal risks associated with the aging population in many countries amplify the risks associated with poor fiscal measurement and management that have been exposed by the sovereign debt crisis.
• The current crisis has emphasized the deficiencies associated with cash-based accounting and budgeting.
• Governments need to adopt accrual accounting and budgeting to better measure and manage fiscal position.
• The adoption of International Public Sector Accounting Standards (IPSASs) is necessary to provide global consistency and comparability in public sector financial reporting.
• Accrual accounting and IPSASs are being successfully implemented in many countries, including Australia, Austria, New Zealand, Spain, Switzerland, and Sweden; these countries now have the tools for better resource allocation and fiscal decision-making.
• The accountancy profession has a key role to play in this transformation, and should be leaders and catalysts for change.
• Politicians, governments, and ministers of finance need to recognize the political advantages of high-quality financial management systems in absorbing and managing economic shocks.
• Conversely, politicians, governments, and ministers of finance need to recognize that the cost of failure in financial management can be a loss of sovereignty.
• Many stakeholders have a role to play: International organizations (like the Financial Stability Board) should consider the institutional changes necessary; citizens, investors, credit rating agencies, and auditors general need to be educated, communicated with, and engaged.
• The International Public Sector Accounting Standards Board must have strong governance and legitimacy, as well as financial and operational stability.

The Sovereign Debt Crisis, a Matter of Urgency—From Lessons to Reform took place March 19-20, 2012, at the Hilton Vienna. Event sponsors included CECCAR, Ernst & Young, PwC, and the World Bank.

For more information about the conference, visit http://sovereigndebt.ifac.org.

About IFAC
IFAC is the global organization for the accountancy profession dedicated to serving the public interest by strengthening the profession and contributing to the development of strong international economies. IFAC is comprised of 167 members and associates in 127 countries and jurisdictions, representing approximately 2.5 million accountants in public practice, education, government service, industry, and commerce.

Speakers for The Sovereign Debt Crisis, a Matter of Urgency—From Lessons to Reform included:

• Ian Ball, Chief Executive Officer, International Federation of Accountants
• Andreas Bergmann, Chair, International Public Sector Accounting Standards Board
• Jón Blöndal, Head of Budgeting and Public Expenditures, Organisation for Economic Co-operation and Development (OECD)
• Robert Dacey, Chief Accountant, the United States Government Accountability Office
• Prof. Dr. Roger J.M. Dassen RA, Global Managing Director Clients, Services and Talent, Deloitte Touche Tohmatsu Limited
• John M. Herhalt, Global Chair, Government and Infrastructure, KPMG LLP
• Ms. Belén Hernández, Public Accounting Directorate, Spain
• Vincenzo La Via, Chief Financial Officer, World Bank Group
• Bo Lundgren, Director General, Swedish National Debt Office
• Professor the Hon. Stephen Martin, Chief Executive, Committee for Economic Development of Australia
• The Hon. Ruth Richardson, Former New Zealand Finance Minister
• Göran Persson, Former Prime Minister of Sweden
• Gerhard Steger, Director General Budget and Public Finance Ministry of Finance, Austria
• Jan Sturesson, Leader Global Government and Public Services, PWC
• Göran Tidström, President, International Federation of Accountants
• James S. Turley, Chairman and Chief Executive Officer, Ernst & Young
• Nicolas Véron, Senior Fellow, Bruegel–Brussels, Visiting Fellow, Peterson Institute for International Economics–Washington, D.C.
• Hon. David M. Walker, Founder, President and CEO, Comeback America Initiative and Former Comptroller General of the U.S.
• Fritz Zurbrügg, Director, Swiss Federal Finance Administration

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See all presentations at www.ifac.org/2012SMPForum.