Statement of Membership Obligations IFAC

Seminar IFAC Compliance Program

ICARM

Skopje, 23 April 2009Paul F.M. Hurks RA (Royal NIVRA)

About IFAC

• Foundation 1977, New York City• Increasing recognition of IFAC’s work by

international organizations• Expanding network of 160 member bodies in 120

countries, representing 2.5 million accountants• Membership: full, associate• Organization: Council, Board, Standard Setting

Boards, Committees, Staff (50) (IAASB, IESBA, IAESB, IPSASB, PAIB, DNC, SMPC, NC, CAP)

Mission IFAC

To serve the public interest, strengthen the worldwide accountancy profession and contribute to the development of strong international economies – Globilization & Public interest

– Enhancing economic growth & wealth

Strategy IFAC

• Establishing and promoting adherence to high quality comprehensive set of standards on auditing, ethics, education, and public sector financial reporting

(adoption & implementation)

• Furthering international convergence for transparent financial markets (harmonization is key issue for the profession)

• Speaking out on public policy issues

• Education provides foundation (life long learning)

Statement of Membership Obligations IFAC

IFAC Compliance Program:• SMO 1 Quality Assurance• SMO 2 Education Standards • SMO 3 Auditing & Assurance Standards• SMO 4 Standards of Ethics• SMO 5 Public Sector Accounting Standards• SMO 6 Investigation & Discipline• SMO 7 IFRS

SMOs Introduction

• Benchmark to current and potential IFAC members

• Support the development of high quality accountancy profession

• Covering IFAC & IASB pronouncements• Basis of IFAC Member Body Compliance

Program (CAP)• Ongoing self assessment for members and

associates• Bold & grey lettering (obligations & explanations)

Best Endeavours

• Ongoing self assessment towards compliance

(monitoring & evaluation)• Measurement at country level (member body,

government, regulators): encouragement• Relevance (sectors)• Departure with reason• Considering projects and initiatives underway:

action plans & progress• Sanctions: suspension or expulsion

SMO 1 Quality Assurance

• Implementation of a Quality Assurance Review Program (= QARP) for Audit Engagements (AE) of Financial Statements (FS)

• Obligations on 3 levels: – Member body (MB): review program: SMO1– Firm (including a sole practitioner): ISQC1 (license)– Engagement (audit professional, member): ISA 220

(qualification)

SMO 1 QARP

• Mandatory QARP for AE of FS of listed entities (minimum)

• Mandatory establishing and publishing criteria for all other AE of FS

• Mandatory including those other AE meeting the criteria in the QARP

• Best endeavours to encourage and assist other responsible authorities to follow SMO1, when applicable (government, regulators)

• When scope is narrower, member body should establish QARP for lacking aspects in existing QARPs

SMO 1 Control Standards

• Mandatory establishing and publishing quality control (QC) standards and guidance requiring firms to implement a system compliant with ISQC1 (for audit professionals: ISA 220)

• Firms are responsible for implementing policies and procedures

• MB is responsible for a QARP that monitors compliance with those policies and procedures

SMO 1 Quality Control Guidance

• Mandatory program tot assist members to:– Understand objectives– Implement and maintain an appropriate system

• Guidelines for– Continuous Professional Development (CPD)– Inspection Programs

SMO 1 Design a QARP

• Subject of a QARP can be chosen– a firm– a partner

• Criteria independent of the choice– adequate system on firm level– compliance at AE level– ref professional standards and regulatory and legal

requirements

• MB should publish scope, design, procedures of QARP and review teams

SMO 1 Review Cycle

• Selection– Cycle approach

– Risk based approach

• Cycle approach– Maximum of three years

– Consider quality and effectiveness of internal inspection program

• Risk based approach– Selection based on risk factors (listed entities, PIE, review results)

– Reasonable frequency, even if not selected on risk based approach

SMO 1 Review Team (RT)

• RT guidelines and procedures must be published

• RT Procedures– Assessment of the system of QC for listed entities

– Review of QC policies and procedures & working paper review and discussions with staff to evaluate• Compliance with the system

• Compliance with other regulatory and legal requirements

• Working paper review includes– Existence & Effectiveness QC system

– Compliance with regulatory and legal requirements

– Evidence documented

– Appropriateness of auditor’s report

SMO 1 RT Documentation

• Sufficient documentation– Evidence review report results

– Evidence that review is carried out in accordance with MB guidelines

• Procedures to retain documentation– Long enough to allow MB or Oversight Body do oversight of the

process

SMO 1 RT Members

• Skills and Competence– education, experience, QC-review training

• Size RT• RT Leader

– supervision, communication, reporting

• Ethical requirements– Code of Ethics + national, independence, no reciprocal peers

• Confidentiality– Exemption for firm members, Code of Ethics + national

SMO 1 Reporting

• Written review report to firm/partner of each assignment including:– Guidance utilized

– Comments on system and system compliance

– Comments on partner’s compliance to the system

– Reasons for negative conclusions and recommendations

• Timely written response to recommendations and conclusions

• MB annual report summarizing results and make available for authorities

SMO 1 Correction & Discipline

• MB requires correction to member’s system, policies and procedures if not compliant

• MB should take disciplinary actions with failing members

• MB must be clear about linkage between conclusions and corrections– CPD, system, engagements, persons, number of peers

– reprimands, fines, suspension, expulsion, publication

SMO 2 Education Standards (IESs)

• IAESB provides consistent global framework of education• Promotes convergence in accountancy education processes and in

application of technical and practice standards• Supports greater mobility of accountants by portability of

qualifications• Contributes to co-operation among member bodies

• Develops guidance for education and development of professional accountants and accounting technicians

• IAESB members include practicing accountants, academics, representatives from business and the public

• Transparency in standard-setting process (observers from international accounting academic community and UNCTAD)

• Different approaches around the world

SMO 2 Education Standards (IESs)

SMO 2 – comply with and promote IFAC IES• IES 1 – entry requirements

• IES 2 – content of professional education

• IES 3 – professional skills

• IES 4 – values, ethics and attitudes

• IES 5 – practical experience

• IES 6 – assessment of professional competence

• IES 7 – continuous professional development (CPD)

• IES 8 – competences for audit professionals

SMO 2 Framework IESs

• Framework – objectives and operating procedures– new ED

• Introduction– purpose, scope and development of IES– discussion about way standards may be adopted and

applied

SMO 2 IES 1

• Requirements for entry to a program of professional accounting education and practical experience

• Aim to ensure students have background to have reasonable chance of achieving success

SMO 2 IES 2

• Prescribes knowledge and competences candidates require to function as a professional accountant– Accounting, finance and related knowledge

– Organizational and business knowledge

– IT knowledge and competences

• Degree or professional qualification • At least two years full time study

SMO 2 IES 3

• Prescribes the mix of professional skills required– Intellectual skills– Technical and functional skills– Personal skills– Interpersonal and communication skills– Organizational and business management skills

• General education helps to develop these skills

SMO 2 IES 4

• Prescribes the professional values, ethics and attitudes required

• Prescribes minimum subject areas

• Acknowledge different approaches will reflect national and cultural environment

SMO 2 IES 5

• Aims to ensure candidates have the necessary practical experience to become a professional accountant

• Minimum of 3 years’ practical experience

• Guidance of experienced professional accountant

• Record of experience and review

SMO 2 IES 6

• Final assessment before qualification as a professional accountant

• Test of theoretical knowledge and practical application of knowledge

• Reliable and valid

SMO 2 IES 7

• Mandatory CPD for all professional accountants• Foster commitment to lifelong learning• Facilitate access to CPD opportunities • Establish benchmarks for development and competence of

professional accountants• Monitor and enforce CPD• 120 hours, three year rolling period• Three approaches:

– Input approach– Output approach– Combination approach

SMO 2 IES 8

• Audit of historic financial information

• All IES1-7 and additional advanced knowledge

• Graduate level

• Audit specific skills

• Application of ethics in an audit context

• Specific work experience

SMO 3 IAASB Standards

• Assurance Framework• Standards & Practice Statements• Timely and accurate translation and

dissemination• Responsibility for adoption and implementation– Adoption in national standards or convergence between

national standards and IAASB Standards (encouragement, persuasion)

– Assistance with implementation (promotion, guidelines)

SMO 4 Ethics Standards

• IESBA Standards: Code of Ethics• MB should avoid less stringent standards, unless it

is prohibited by law or regulation• Timely and accurate translation and

dissemination• Responsibility for adoption and implementation– Adoption in national standards or convergence between

national standards and IESBA Standards (encouragement, persuasion)

– Assistance with implementation (promotion, guidelines)

SMO 5 IPSASB-Standards

• MB should notify members of all IPSASs: International Public Sector Accounting Standards– guidelines, studies, papers)

• Timely and accurate translation and dissemination

• Responsibility for adoption and implementation– Adoption in national standards or convergence between

national standards and IPSASB Standards (encouragement, persuasion)

– Assistance with implementation (promotion, guidelines)

SMO 6 Investigation & Discipline

• MB should provide rules for I&D against breaches of professional standards and rules

• Both for members & firms

• Misconduct– criminal activity, disrepute profession, breaches of standards and

ethics, professional negligence (cumulative), unsatisfactory work

SMO 6 Investigation & Discipline

• Sanctions based on a just and effective investigative and disciplinary regime (by MB, law, regulator):– Reprimand

– Loss or restriction of practice rights

– Fine / payment of costs

– Loss of professional title (designation)

– Exclusion from membership

SMO 6 Investigation & Discipline

• Provision of information and guidance for members

• Liaison with outside bodies• Investigative powers & processes• Disciplinary process• Rights of representation & appeal• Administrative processes

SMO 7 IFRS

• MB support the work of IASB by notifying members of every IFRS

• Timely and accurate translation and dissemination

• Responsibility for adoption and implementation– Adoption in national standards or convergence between

national standards and IAASB Standards (encouragement, persuasion)

– Assistance with implementation (promotion, guidelines)

ICARM Policy

Compliance program:

• Questionnaires Part I & II

• Action Plan (7 SMOs)

• Policy Directives (IFAC CAP)

• Membership application (associate)

To be achieved before 31 May 2010