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ISSUE 191

JULY/AUGUST
2014
ICAEW.COM/AAF

WRITTEN IN STONE JOHN SELWOOD BUILD A PICTURE


HOW TO KEEP THE SHOULD YOU STILL AUDIT INSIGHTS:
BEST POSSIBLE GIVE MORTGAGE THE LATEST REPORT
DOCUMENTATION REFERENCES? ON CONSTRUCTION

Provocative
questions
Probing reliability at the
Audit Quality Forum

THE MAGAZINE FOR AUDIT & ASSURANCE FACULTY MEMBERS


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Dreams of audit WRITTEN IN STONE
HOW TO KEEP THE
BEST POSSIBLE
DOCUMENTATION
JOHN SELWOOD
SHOULD YOU STILL
GIVE MORTGAGE
REFERENCES?
BUILD A PICTURE
AUDIT INSIGHTS:
THE LATEST REPORT
ON CONSTRUCTION
ISSUE 191
JULY/AUGUST
2014
ICAEW.COM/AAF

Provocative
questions
Probing reliability at the
Audit Quality Forum

THE MAGAZINE FOR AUDIT & ASSURANCE FACULTY MEMBERS

Auditors tend to stand with both feet firmly 04 News and


events
planted on solid ground, their focus very much Audit and assurance

on the facts – which is exactly as it should be. news from the faculty

Yet the professional necessity to look backwards should not stop


the profession from moving forwards. Sometimes, even auditors 06 Keeping record
Whether its written
need to take a break from the cut-and-dried world of figures and communications or audit
let their imaginations run wild. Dare to dream. completion reviews,
Change is one of life’s inevitabilities – like birth, death and adequate documentation
taxes – and audit is not immune. The world is now far more is a must, says Michael Scott
complex than it was when the audit model was first conceived,
and audit must evolve if it is to be as valuable tomorrow as it is
today. So ICAEW and the Audit & Assurance Faculty are exploring 09 Building
on audit
the possibilities in a number of thought leadership initiatives. Louise Sharp looks at the
Audit Insights is demonstrating how auditors can work collectively to enhance the latest Audit Insights report
value of their statutory activities (see page 9); AuditFutures is inspiring innovation and into the construction
debate about the future of audit among stakeholders inside and outside the profession industry, and how it can
(auditfutures.org); and the Audit Quality Forum is asking difficult questions see (page benefit faculty members
10) about important matters such as trust and reliability and the assurance of the
financial and the non-financial metrics in the annual report.
These initiatives aim to stimulate auditors and other business stakeholders into 10 The evolution
of audit
thinking beyond where we are today. Research by Forbes Insights (see page 11) into Can auditors help make
how audit can evolve to meet the needs of an increasingly complex world indicates an annual reports more
appetite for auditors to look beyond the financial statements, and also conveys a reliable? The Audit
strong sense of urgency. Quality Forum tackled
Demands from investors and other stakeholders have already delivered mandated one of the profession’s
change from regulators and standard setters – with more on the horizon. However, toughest questions
Forbes’ research suggests that the wheels of regulatory change do not turn fast enough
for many stakeholders; they want auditors to provide more momentum. Perhaps the
time has come for individual firms and auditors to take the initiative, and do more to 12 Q&As
John Selwood answers
control the conversation and the direction in which audit evolves. Dare to dream. some questions from the
faculty’s recent webinar
on mortgage references

14 Technical
updates
Legal and regulatory
changes affecting the
profession
Henry Irving
Head of faculty
18 From the
faculties
A round up of features
from other faculty
magazines

© ICAEW 2014. All rights reserved. The views expressed in this publication are those of the contributors; ICAEW
does not necessarily share their views. ICAEW and the author(s) will not be liable for any reliance you place on
information in this publication. If you want to reproduce or redistribute any of the material in this publication, you
should first get ICAEW’s permission in writing. No responsibility for loss occasioned to any person acting or
refraining from action as a result of any material in this publication can be accepted by ICAEW, the publishers or the
author(s). Whilst every care is taken to ensure accuracy, ICAEW, the publishers and author(s) cannot accept liability
for errors or omissions. Details correct at time of going to press.

To comment on your magazine, please email publishing@icaew.com

AUDIT & BEYOND JULY/AUGUST 2014 3


News and events
FACULTY STAFF
Henry Irving
Head of Audit & Assurance
Faculty
+44 (0)20 7920 8450
henry.irving@icaew.com

Chris Cantwell
Technical manager,
NEW FACULTY CHAIRMAN
James Roberts, BDO audit partner, was recently elected as chairman of the Audit
Practice Regulation
+44 (0)20 7920 8742 & Assurance Faculty. He succeeds Charles Bowman, who has retired from the role.
chris.cantwell@icaew.com

Kate Bond
Services executive,
Sevices & Operations END OF ANNUAL ACCOUNTANTS
+44 (0)20 7920 8483
kate.bond@icaew.com
REPORT FOR SOLICITORS?
Louise Sharp Under the current SRA regulatory
Technical manager, regime, each and every firm holding
Audit Practice Issues client money is required to submit
+44 (0)20 7920 8552
an accountant’s report to the SRA on
louise.sharp@icaew.com
an annual basis. However, it is the
Ruth Ward view of the SRA that this approach is
Technical manager, Assurance
neither sufficiently targeted nor
+44 (0)20 7920 8639
ruth.ward@icaew.com proportionate, adding cost with only
limited benefits by way of consumer
Ameena Ahmad
protection and overall management
Technical manager
+44 (0)20 7920 8900 of the risk to client money.
ameena.ahmad@icaew.com If a recent discussion among
members of the Audit & Assurance
Angela Edwards
Faculty LinkedIn group is any
SME programme manager
+44 (0) 20 7920 8894 The Solicitors Regulation Authority indication, auditors are sceptical. To
angela.edwards@icaew.com (SRA) has published a consultation on learn more about their perspectives
Proportionate regulation: changes to or join the discussion visit the
Lesley Meall reporting accounting requirements LinkedIn page at linkd.in/1kEw4F5
Editor (bit.ly/1mjEpKY).
+44 (0)20 7920 8493
The two key proposals are:
tdaf@icaew.com
the removal of the mandatory Under the current
Contact details
Audit & Assurance Faculty
requirement that firms must provide an
annual accountant’s report to the SRA;
SRA regime, each
Chartered Accountants’ Hall
Moorgate Place, London EC2R 6EA
requiring the compliance officer firm holding client
+44 (0)20 7920 8493 for finance and administration to
sign a declaration they are satisfied
money is required to
+44 (0)20 7920 8754
tdaf@icaew.com that the firm is managing client send an accountant’s
icaew.com/aaf
Audit & Beyond is produced by
accounts in accordance with the SRA
Account Rules.
report annually
Progressive Customer Publishing
John Carpenter House
John Carpenter Street
London EC4Y OAN
Advertising enquiries to
FACULTY HIGHLIGHTS
advertising@progressivecp.com The faculty has published its latest Annual Review
(bit.ly/1oxcolR). “It has been leading the debate, leading
ISSN 1748-5789 TECPLM12632
innovation and leading change in audit,” said Charles
Printed in the UK by Bowman, chairman of the faculty during this period. “I
Sterling Solutions am pleased to see the faculty offering evolving to meet the
changing needs of members.”
Bowman praised the ever-popular roadshow, and the increasing number of
lectures, webinars and online resources available to members. He also noted
the success of faculty initiatives including Audit Insights (see page 9), AuditFutures,
CORBIS

the Audit Quality Forum (see page 10) and re:Assurance.

4 JULY/AUGUST 2014 AUDIT & BEYOND


FACULTY NEWS & EVENTS

EVENTS
UPDATE
PRIDE AND PREJUDICE ANIMATING AUDIT
The future of audit was the subject
Louise Sharp, technical manager, audit practice issues for discussion at a faculty debate on
‘Anticipating change’ (at Chartered
Am I the only one who has ever consider the year-end audit a bit Accountants’ Hall on 2 July) and at a British
felt a little apologetic when of a chore, the value of the input Accounting and Finance Association (BAFA)
responding to the question provided by auditors extends far auditing special interest group annual conference
‘What do you do for a living?’. beyond the audit report. (in Birmingham on 29 May).
The words ‘dull’, ‘boring’ or People only need to look at At ‘Anticipating change’, the discussion on the
‘techie’ spring to mind (and the six Audit Insights reports future of audit and assurance was stimulated by a
are often stereotyped in the (the latest one on the short animated film, and framed by perspectives
media as people sitting behind construction sector has just from the faculty’s recently retired chair Charles
desks surrounded by been published – see page 9) to Bowman, a PwC audit partner, the new faculty
spreadsheets, fingers poised recognise how much knowledge chair James Roberts, a BDO audit partner, and a
over calculators). Yet the reality, auditors have about the panel of experts.
as you know, is very far removed businesses they audit and the At BAFA, faculty representatives Henry Irving
from this. sectors they work in, and how and Ruth Ward gave a keynote speech on the long
There are few professions that valuable the assurance they term evolution of audit, building on the
gain such valuable insights into provide really is. Their skills and AuditFutures RSA report Enlightening Professions
how businesses are run and knowledge are not to be (AuditFutures.org). Other speakers included
require such a wide variety of underestimated – even if they Melanie McLaren from the FRC and Hilde Blomme
technical and interpersonal skills. are always in the firing line from the Federation of European Accountants.
While some businesses might when things go wrong.
RAISING AUDIT QUALITY
The next Audit Quality Forum (AQF) on 8 July will
STAY UP TO DATE WITH consider whether the professions have made the
step change in thinking necessary to respond to
FACULTY WEBINARS the financial crisis.
All members of the faculty have access to a growing library of
webinars. Subjects include: accounting estimates, documentation, AQF debates attract a wide range of stakeholders,
subsidiary company audit exemption, the audit of owner-managed including standard setters, regulators, company
groups across a number of countries, quality monitoring and the management, academics, audit committees and
challenges faced by accountants providing mortgage references. auditors. If you would like to attend the next
Visit icaew.com/aafwebinars armed with your faculty membership meeting or get involved email aqf@icaew.com
number and password. If you have forgotten this you can request a When the AQF last met, to discuss the provocation
new one at icaew.com/password ‘Auditors should do more to make annual reports
reliable’ it prompted an interesting Tweet story by
the Financial Reporting Council (@FRCnews). You
can read this at icaew.com/auditquality
DEMYSTIFYING WEB ADDRESSES
Not all web addresses are as short such as Bitly, to create and share AUTUMN ROADSHOW
and as snappy as icaew.com is. shortened versions. These links The adoption of FRS 102 The Financial Reporting
The more information there is are used in the same way as Standard applicable in the UK and Republic of Ireland
on a website, the more likely their longer equivalents: type and the transition to the new UK GAAP will create
you are to need a much longer the bit.ly code into the web challenges for many UK companies – and their auditors.
web address (aka URL) such as browser address bar, press enter, The Autumn Roadshow will focus on FRS 102
icaew.com/en/technical/audit- and you be automatically transition, addressing ethical considerations, threats
and-assurance/faculty to find it. redirected to the relevant website. to independence, the need to maintain the highest
ON THE
RECORD
From written communications with clients, to
recording substantive tests and conducting audit
completion reviews, the importance of adequate
documentation simply cannot be over emphasised,
as Michael Scott highlights

ocumentation. As an auditor, you International Standard on Quality Control that oral explanations alone are
D simply can’t get away from it – or
its importance. This starts
(UK and Ireland) ISQC 1 (bit.ly/S59r1Z) and
the UK Audit Regulations and Guidance
insufficient, but they may be used to
clarify or explain audit documentation.
before the firm can even accept an audit (at bit.ly/1pZqcGK). In practice, regulators may take the view
engagement. As well as complying with that the firm is using such oral
ISA 210 Agreeing the terms of audit All of this can be challenging, so ICAEW explanations as an excuse for their
engagements, engagement letters (and offers guidance. There are practice help inadequate documentation and, as a
disengagement letters) must be easy for sheets (bit.ly/LshUbU) covering consequence, they do not accept this.
clients to understand, while procedures engagement and disengagement letters, When challenged, firms can often
for acceptance, continuance and cessation decisions to accept appointments, audit provide regulators with additional
must be easy for staff to follow – and all firm compliance reviews, gathering new explanations to show how they have
related documentation kept up-to-date. client details and more. The faculty has obtained an appropriate audit. However,
The need for additions, deletions and produced two webinars on ISQC 1 if questions need to be asked this tends to
enhancements to written communications (icaew.com/aafwebinars) and practical indicate that the work simply has not
with clients can be driven by a myriad of guidance covering quality control in the been documented well enough. It could
internal and external factors. As well as audit environment for the UK & Ireland also be interpreted as a sign that the firm’s
regulatory developments (of which (bit.ly/1kcDqNM) and international review processes have not been as
there have been many over the past few (bit.ly/SHtBND). rigorous or effective as they should have
years) updates can be driven by changes been – especially the final engagement
to the terms of engagement of the AUDIT DOCUMENTATION partner review (which should also be
assignment, to remuneration, and to Of course, auditors also need to focus on thoroughly documented).
other matters such as the scope and the policies, procedures and Good audit documentation is essential,
context of the assignment. documentation needed to perform a as it provides both the evidence of the
Policies and procedures relating to high-quality audit. Anyone who conducts basis for the audit report and evidence
these processes and many others must audit file reviews on a regular basis will be that the audit work performed was
be regularly reviewed and the familiar with the response “We have done planned and performed in accordance
documentation for this updated as the work but not written it down”. with the ISAs. The audit file must
and when necessary. Some changes are Unfortunately, if work has been carried effectively stand on its own. Paragraph 8
almost inevitable if the office manual out but not documented, it is then very of ISA 230 (UK and Ireland) states that:
and other documentation is to: difficult to demonstrate to the regulator “The auditor shall prepare audit
cover everything that it should; that adequate audit evidence has actually documentation that is sufficient to enable
GALLERY STOCK

remain effective and fit for purpose; been obtained. an experienced auditor having no
be clearly understood by staff; and Paragraph A5 of ISA 230 (UK and previous connection with the audit to
demonstrate compliance with the Ireland) Audit Documentation indicates understand:

6 JULY/AUGUST 2014 AUDIT & BEYOND


DOCUMENTATION

Good audit documentation does not


comprise endless ticking of boxes and
checklists. It involves recording the key
judgements that the auditor has made

the nature, timing and extent of the


audit procedures performed to comply
with the ISAs (UK and Ireland) and
applicable legal and regulatory
requirements;
the results of the audit procedures and
the audit evidence obtained; and
significant matters arising during the
audit, the conclusions reached thereon
and significant professional judgments
made in reaching those conclusions”.

It is important to appreciate who this


“experienced auditor having no previous
connection with the audit” might be. In
reality, for most ICAEW practices it is
their external file reviewer or ICAEW’s
Quality Assurance Department. This
should be borne in mind when audit work
is being documented.
It is also important to appreciate what
the potential fallout could be, should
something go awry. If a serious problem is
encountered and the quality of the firm’s

AUDIT & BEYOND JULY/AUGUST 2014 7


DOCUMENTATION

audit work is examined in court, for


example, then the documentation of that
work will be of paramount importance.
Poor documentation will undoubtedly
give rise to serious problems.
Good audit documentation does not
comprise endless ticking of boxes and
In most audit files, the vast majority, if
checklists in the firm’s standard audit not all of the audit documentation
programme: it involves recording the key
judgements that the auditor has made. All
should be present when the audit report is
of the guidance notes to ISA 230 (UK and signed off. In larger group files with audit
Ireland) point to the view that auditors
should not merely tick such checklists;
subsidiaries, this may be difficult
instead, they need to think and document
the key decisions and considerations
made during the audit in a concise and
logical fashion (practice note 26 may be
particularly helpful).

CONSISTENCY COUNTS
From a practical point of view, a good
way of ensuring consistency of audit
documentation across the firm and to
help ensure that the requirements of
paragraph 8 of the ISA are met, is to use
a standard format for the audit working
papers when conducting a substantive
test. One such format is to use the making processes is particularly be present when the audit report is signed
headings ‘objective’, ‘work performed’, important during a regulatory visit. off. In a larger group file with a number of
‘results’, ‘evaluation’ and ‘conclusion’ on Conclusion: Confirming whether or not audit subsidiaries this may be more
all such working papers. the audit assertion has been satisfied. The difficult and the 60-day requirement may
Objective: Showing the purpose of the working paper must also document who have to be utilised. From a practical point
test, specifically linking to one of the audit performed the audit work and the date of view, the sooner, the better. If
assertions defined in ISA 315 (UK and that the audit work was completed. It amendments are made to the file after the
Ireland) Identifying the risk of material should also indicate who reviewed the 60 days, then there must be a record of
misstatement through understanding the audit work and the date of review. when the changes were made, by whom
entity and its environment, namely they were made and why they were made.
existence, completeness, ownership Audit documentation may be recorded on It should not be removed or deleted.
(rights and obligations), valuation and paper or electronically – whichever the
accuracy, valuation and allocation, cut off, auditor prefers. An electronic format BALANCING NEEDS
classification, understandability and might aid efficiency as some working Good documentation is essential in
occurrence. papers can be rolled forward to future quality audits, and insufficient or
Work performed: Recording details of the years. It is easier to add additional inadequate documentation may result
specific audit test performed, the information and to make amendments in serious regulatory problems. On the
direction in which the test has been following any review of the file. other hand too much documentation
carried out, the size of the sample and can be inefficient and impact on audit
method of selection. COMPLETION profitability and recoverability for the
Results: Recording specific details of the ISA 230 specifies that auditors must auditor. It might also indicate an inability
items tested. It is not enough to say that assemble the file and complete the to focus the audit on the most important
you tested 10 items and they were all fine; documentation on a timely basis. This is matters. So for most firms, the biggest
you need to make clear which 10 items understood as being not more than 60 documentation challenge could be
you looked at and include an audit tick days after the date of the audit report. finding the right balance.
showing exactly what audit work was This does not mean that you can sign off
performed on them. the audit report and you then have 60
Evaluation: Recording details on the days in which to start and complete the
impact of any errors found. When audit work. Rather it means that you
Michael Scott is joint owner and
appropriate, it should also be used to have 60 days to finish the assembly of
director of Proactive Consulting
justify why the audit evidence obtained is the file and ensure that all relevant for Professionals, a specialist in
sufficient: for example, explaining why documentation is present. audit compliance reviews and
the sample size does not need to be In most audit files, the vast majority, if practice management
increased. Information on your decision- not all of the audit documentation should

8 JULY/AUGUST 2014 AUDIT & BEYOND


AUDIT INSIGHTS

Beneath
the top line
The latest Audit Insights report adds construction to the list of sectors to
benefit from the profession’s expertise and experience – and now
members of the faculty can benefit too, as Louise Sharp explains
lthough auditors have unique construction sector. “The risk of “These are fundamental issues and
A access to companies and their
financial reports,
overtrading needs to be managed. A slow
and steady approach to growth is better
more key than ever,” comments Emily
Biddulph, equity research analyst at
confidentiality makes it difficult for than just looking at the top line,” he says. JP Morgan Cazenove. The report also
them to share insights and observations To take advantage of emerging highlights some of the biggest risks
that could benefit investors, non-execs, opportunities, the sector needs to learn facing those in the sector, such as the
senior managers, politicians, from past experiences and do more to cost challenges of delivering on contract
policymakers and other stakeholders, address the important issues this diverse bids during the recession on very low
including their fellow professionals. But and fragmented UK industry faces. So margins, the shortage of skilled labour,
since 2013, when the faculty launched the report directs the attention of and a lack of transparency in profit
its Audit Insights programme, it has government, the sector and investors recognition policies and order book
successfully done this for a number of reporting. Westerman says: “To secure
sectors and issues (see box).
“The Audit Insights programme was
“ Confidence in the economic stability, future growth and
long-term confidence in the sector,
set up to recognise that audit and the construction industry businesses must plan for the longer term.”
profession is about more than providing
audit reports and opinions,” says
is at a high, but there Audit Insights: Construction can also
be useful to auditors. “Meeting your
Charles Bowman, who was chairman of is no room for peers helps you to realise that some of
the Audit & Assurance Faculty at the
time. By getting auditors to share their
complacency ” the concerns you have are the same as
theirs,” says Jonathan Hook, PWC
sector-specific knowledge of business partner and member of the working
processes and best practices and to the most interesting, relevant and group behind the report.
highlight trends, challenges and urgent issues with the help of the And the flags do seem to resonate
opportunities in the wider market, following flags (and suggestions on how with other auditors. Peter Upton,
ICAEW believes Audit Insights reports to address them): whose firm does some small entity
are adding more value to what is Flag 1: work collaboratively to help plan audits in the construction sector, says:
already a public interest activity. for the future; “After I’ve read it, I’ll take it to some
“Confidence in the construction Flag 2: procure and bid responsibly and audit planning meetings we are going
industry is at a high and there are deliver consistently; to have soon.”
opportunities ahead, but there is no Flag 3: address the shortage of skilled
room for complacency,” says Phil labour; Louise Sharp is a
technical manager
Westerman, spokesperson for Audit Flag 4: be more transparent in reporting; in the Audit &
Insights: Construction and Grant and Assurance Faculty
Thornton audit partner. Periods after Flag 5: invest in information systems.
a downturn are risky for the

FURTHER READING
Audit Insights reports are available on the
CHRIS KEEGAN/IKON

construction, retail, manufacturing and


banking sectors and cyber security –
download them at bit.ly/1dfEIBT

AUDIT & BEYOND JULY/AUGUST 2014 9


EVOLUTION OR
REVOLUTION?
Panellists at the last Audit Quality Forum
debated the role of auditors in making
annual reports more reliable. Lesley Meall
shares their perspectives

uditors should do more to make conducted by Forbes Insights on behalf of


A annual reports reliable: that was
the provocation put to a panel of
the global public policy committee of the
six largest audit networks. She explained:
experts at the most recent meeting of the “We wanted to find out how audit might
Audit Quality Forum (AQF). It’s an evolve and what the audit of the future
assertion that could prompt some should look like, because it was very
auditors to throw their metaphorical toys apparent, that as a profession, we needed
out of their metaphorical prams, so it to do more to be able to continue to serve
merits clarification. “We are not talking the public interest and help to create
about doing existing audits better,” said
Louise Sharp, a technical manager in the
confidence between investors and
companies.” The suggestion that audit
“Now we are beginning
Audit & Assurance Faculty, although she must evolve seemed to be met with to see more
isn’t discouraging this. “We mean
encouraging the development of new and
approval by others on the panel and in the
audience, though opinions differed on
transparency, this gives
innovative ways of making other how to achieve this, and how fast. investors a hook to
information in annual reports more
reliable, as this could then provide a
Stakeholders in the Forbes survey urged
the profession to move quickly and
challenge management
launch pad for looking at the reliability of suggested three ways for audit to move judgements and
other forms of corporate reporting,” she
explained (see box, opposite).
forward (see box); some of which are
easier to achieve than others. Panellist
assertions in accounts”
This goes beyond financial statements and PwC partner, Andrew Ratcliffe,
and auditors’ reports on them. It’s about observed: “On transparency, the UK has
the bigger picture; working towards a jumped ahead with the new audit report Audit professionals gathered
world with more joined up reporting. As and what the FRC has done,” and auditors to hear a panel discussion at
ICAEW highlights in The Journey: Assuring can already offer perspectives on key the recent AQF event, which
was hosted by Stephanie
All of the Annual Report? (bit.ly/1c97sk9), management information within the McGovern, the business
auditors can, in principle, report on current assurance framework. “The reporter for BBC Breakfast
anything. “They have the tools and the difficult one is providing insights,” he said.
knowledge to report on information If the auditor is to give new and original
beyond the existing statutory audit information on what management is
requirements and some auditors are doing, this will probably require a change
already demonstrating this by performing in the reporting model.
similar engagements in different Liz Murrell, director of corporate
contexts,” says Sharp. The faculty is governance and reporting at the
supporting this with technical guidance, Investment Management Association,
case studies and other material (see noted that the reporting framework had
bit.ly/1hPWb7h) including articles in changed with IFRS, and that the auditing
Audit & Beyond (bit.ly/1foBFiB). model dragged behind this – until very
But what do regulators, investors, recently. “Investors appreciate the
auditors and other business stakeholders risk-based approach adopted by the FRC,”
have to say? Felice Friedman, deputy she said, before suggesting that all
global public policy leader at EY, began standard setters could have gone further.
the AQF discussion by sharing the results “Nobody has actually asked the auditors
of a survey of global audit stakeholders, ‘What did you actually find? How good or

10 JULY/AUGUST 2014 AUDIT & BEYOND


AUDIT QUALITY FORUM

bad were management’s estimates?’,” she balanced and understandable, and for the
WHAT STAKEHOLDERS WANT
explained, praising one audit firm for auditor to speak out if they do not agree.
FROM AUDIT
going a step further in its audits of However, she also cited FRC research on The Forbes Insights report Future role of
Rolls-Royce and New World Resources by stakeholder views (see box right and page audit – a more insightful audit for a more
describing some management judgements 14): “There are some investors who would complex world confirmed demand from
as “mildly optimistic” and “mildly cautious”. like to have more confidence in audit, but stakeholders for audit to evolve.
Panellist John Lelliott, finance director they don’t yet see it as justifiable
Stakeholders suggested audit could
at the Crown Estate, talked about another confidence,” she said, adding: “Current
move forward by providing:
pioneering approach to making the audit quality does need attention.” 1. more transparency into what has
annual report more insightful. “We have Murrell confirmed investors’ “concerns been learned during the course of
myriad stakeholders who don’t about audit quality”, attributing some of the audit;
understand what we do and we felt that these to the limitations of the pass/fail 2. perspectives on key information
integrated reporting was a good way of opinion. “Now we are beginning to see generated by management; and
explaining and putting across a consistent more transparency, this gives investors a 3. deeper insights on company
message,” he said. So in the spirit of the hook to challenge management judgements performance, operations and risks.
recently released draft framework of the and assertions in the accounts. We can
The report is at onforb.es/1rBC8Tx.
International Integrated Reporting have a better dialogue with audit
FRC research into perceptions of the
Council (iirc.org), the Crown Estate has committees and that can help build
value of audit are at bit.ly/1oZRv3R
produced an integrated report that pulls confidence between investors and
together financial, social, economic and companies,” she said. An IMA benchmark
environmental information, and shows in 2013 (bit.ly/1oWD5ST) found that many WHY RELIABILITY MATTERS
how all of these interlink to impact on the institutional investors have increased the These themes have been explored in
business – to make its reporting “material, headcount among those ‘responsible for recent ICAEW publications including:
Reliability Matters: Reliability and the
responsive to stakeholder concerns, and engagement’. With so many initiatives in
Central Role of the Auditor.
as complete as possible”. play, it is understandable that the panel
icaew.com/auditquality
Bringing the debate down to earth, seemed to agree on the need for evolution The Journey: Assuring All of the
Melanie McLaren, FRC executive director rather than revolution. “We have put our Annual Report? and Milestone 1:
of governance, codes and standards, best efforts into landing the changes we’ve Assurance Over Key Performance
focused less on where the annual report already agreed,” said McLaren. “We need Indicators. bit.ly/1c97sk9
is heading and more on where it is. “As a to be patient and see whether some of the
regulator, we have tried to unshackle the things we are suggesting actually work.” Related articles in Audit & Beyond:
GUILHEM ALLANDRY

reporting regime and make it more fit for Reframing audit quality: bit.ly/1khFhUH)
purpose,” she said. Measures include long A two-part video recording of the AQF Future prospects: bit.ly/1hPWW0b
form audit reports, the requirement for event is available at bit.ly/1n3fVsF and Great leap forward: bit.ly/1wSwoVB
directors to state that accounts are fair, bit.ly/RWJikG

AUDIT & BEYOND JULY/AUGUST 2014 11


John Selwood’s Q&As
The recent faculty webinar on the trouble with
mortgage references sparked an avalanche of
questions – and it was impossible to answer all of
them on the day. This month, John tackles some
of the most asked – and the most interesting

Q What is the legal basis for your


suggestion that accountants
should not charge the client for
Technical Release Audit 2/01 Requests
for references on client’s financial status
and their ability to service loans provides
The question of whether or not to
charge for mortgage references was also
covered in the November 2011 issue of
providing a mortgage reference? guidance to accountants that seek to Audit & Beyond (which is archived at
manage their risks effectively, when they bit.ly/1rchskY) and more recently in
As accountants often receive receive these requests. Accountants need economia (bit.ly/1kjTT4W). Although
A requests from banks, building
societies and other lenders on the
to use their professional judgement when
applying Audit 2/01. It does not provide
neither of these articles provides legal
advice, they do explore some of the
financial status of their clients when they legal advice, but it does say that it is associated risks, so they may both have
intend to obtain a loan or enter into some appropriate to provide this type of something to add to the decision-making
other obligation, this is a very common reference only when “there is no need for process.
question – and it has generated a certain the accountants to perform any work, When making your decision on whether
amount of heat. However, the question is research or investigation to produce the or not to provide a mortgage reference
not whether an accountant can charge for reference.” and whether or not to charge for this
a mortgage reference, but whether it is Where this is not the case, Audit 2/01 service, you will also need to consider
advisable to charge. suggests that accountants agree a specific the fact that all client work needs to be
I am an accountant, not a lawyer, but it formal engagement, following ICAEW covered by professional indemnity
is my understanding that if an accountant guidance on Reporting to Third Parties insurance, and the implications of this.
provides a mortgage reference and takes (currently TECH 10/12 AAF). Audit 2/01 Where there is potential that the
payment for it, this could constitute an also reminds accountants of the need to practitioner has accepted risk, the
implied contract. As a result, the be aware of the duty of care implications practitioner needs to ensure that their
accountant could be seen to owe a duty of of entering into such engagements. insurer is aware of, and comfortable
care to the lender or the client, which with, the nature of the work that is
could lead to potential legal risks. You being undertaken.
might be exposed to a claim, for example, Ultimately, the decision will be a
if a lender makes a loan as a result of
relying on your reference and something
Where there is potential commercial one. Some accountants
may chose to provide mortgage
goes awry, or you provide information that the practitioner has references as a specific formal
which results in a client loan application
being declined.
accepted risk, the engagement, charging for them and
appropriately managing and mitigating
However, this is a complex area where practitioner needs to the associated risks. Accountants who
the legal issues are not clear cut. It is not
simply the case that charging for the
ensure that their insurer charge for references without taking
these steps are not doing anything
reference makes you liable and not is comfortable with the technically wrong. But they are taking a
charging means that you have no liability
to the lender or client; this is merely one
nature of the work risk, and it is one that ICAEW suggests can
and should be avoided – as I mentioned
of a number of contributing factors. during the webinar.

12 JULY/AUGUST 2014 AUDIT & BEYOND


Q&A

Q You said in your webinar that


an accountant should not sign a
reference that uses a standard form
Refusing to provide a
future income or future solvency”.
Accountants can legitimately decline to
provide a reference if they judge the risks
from a lender if the accountant is reference can be very to be too high. An accountant’s income
unhappy about what they are being
asked to sign. How realistic is it to
damaging to the client/ reference is not a right, it is a privilege –
and accountants have the right to give
refuse, if the lender will not accept accountant relationship. references on their own terms, which
any alternative form of wording?
The accountant is, quite does not seem unreasonable to me.

rightly, following
A This is another hot topic. Since the
credit crunch, lenders have sought
to place as much reliance as possible on
guidance from ICAEW Q You referred to ICAEW
guidance in the webinar.
Where can I find this?
income references from accountants. In
their enthusiasm, lenders have made The current ICAEW guidance is
their standard forms more robust and
have asked for information such as
she should refuse to provide a reference.
Both lenders and clients have been
A Audit 2/01 Requests for references on
client’s financial status and their ability to
“confirmation of income” or “future known to complain about this. service loans. This is going to be updated
income projections”. I have spoken to Unhelpfully, lenders often say, “you are in the near future. Meanwhile, it can be
delegates on courses who report that the only accountant who has complained found at bit.ly/1rchVUd.
the word “guarantee” sometimes about our standard reference form”.
appears. Would your insurer be happy Given how often I hear this from A recording of the faculty webinar The
with this wording? accountants, it simply cannot be true. trouble with mortgage references is
available at icaew.com/aafwebinars
Hopefully, it goes without saying that Some clients may also view the
accountants should not sign anything that accountant as being unreasonable. I
they are unhappy with. Instead, the recognise that refusing to provide a
lender’s wording could be tailored by the reference can be very damaging to the
accountant to produce something they client/accountant relationship, which is
would be willing to sign, or the example unfortunate. However, there is no way
wording from the faculty technical release around this, as the accountant is, quite
Audit 2/01 Requests for references on rightly, acting prudently and following
client’s financial status and their ability to guidance from ICAEW.
service loans could be used or adapted. It is not the accountant’s responsibility
Sometimes the lender will not accept to assess affordability on a lender’s
either of these options. If after behalf. As Audit 2/01 highlights, future
discussions with the lender to see if a income and expenditure is “inherently John Selwood is a member
solution could be found, the accountant uncertain” and this prevents accountants of the faculty’s Practitioner
finds themselves at an impasse, he or from reporting “in positive terms on Services Committee

AUDIT & BEYOND JULY/AUGUST 2014 13


Technical
updates
Our round-up of legal
and regulatory changes

AUDITING AND ASSURANCE:


UK & IRELAND
CONFIDENCE IN THE QUALITY enhancing the quality of bank audits. scope of audit is necessary to meet
OF AUDIT (APRIL 2014) It also plans to: investor expectations.
The Financial Reporting Council develop best practice guidance The FRC commissioned a survey in
(FRC) has set out its programme of for audit committees on assessing 2013 which benchmarked the views
work to give justifiable confidence in audit quality; of stakeholders on confidence in the
the quality of audit. This expands on assess whether the ethical quality of audit. This has been
the outline of projects and activity standards for audit remain fit for developed partly in response. The
that was recently announced in the purpose; and stakeholder survey will be repeated
FRC’s current three-year strategic review audit firm governance, in future to test the effectiveness of
programme. including whether the declining the FRC’s programme in meeting
In the near- to medium-term, the proportion of audit in the total legitimate expectations.
FRC will focus on the expansion of its business of the major audit firms bit.ly/1gOFjCY
audit inspection work (in line with poses unacceptable risk to audit
recommendations from the quality and capacity. GUIDANCE ON RECEIPT OF
Competition Commission), the INFORMATION IN CONFIDENCE
implementation of the new EU Over the longer term, the FRC will The faculty has updated its guidance
Directive on statutory audit, and assess whether any change to the for auditors when they receive

AUDIT AND ASSURANCE:


INTERNATIONAL
PROPOSED ENHANCEMENTS TO This work has been informed by IAASB RE-PROPOSES STANDARD
AUDITING STANDARDS IN RELATION feedback to the IAASB’s January ADDRESSING INFORMATION IN
TO FINANCIAL STATEMENT 2011 discussion paper, The evolving ANNUAL REPORTS (APRIL 2014)
DISCLOSURES (MAY 2014) nature of financial reporting: The IAASB has released for re-exposure
The International Auditing and disclosure and its audit implications. an enhanced International Standard on
Assurance Standards Board (IAASB) is The board has also undertaken Auditing (ISA) 720 (Revised), The
proposing changes to the liaison and outreach with auditor’s responsibilities relating to other
International Standards on Auditing stakeholders, including accounting information. The proposed standard
to clarify expectations of auditors standard setters, which are actively clarifies and strengthens the scope and
when auditing financial statement exploring initiatives relating to focus of auditor efforts on information
disclosures. disclosures. The IAASB recognises (other than the audited financial
The proposals include new that many of the issues around statements) included in entities’ annual
guidance on considerations relevant disclosures cannot be solved by the reports, and introduces new auditor
to disclosures at the stage when the IAASB alone and that collaboration reporting responsibilities.
auditor plans the audit and assesses and cooperation between many Under the proposed ISA, the auditor
the risks of material misstatement, interested stakeholders is necessary would now be required to perform
through to when the auditor to further enhance the public’s limited procedures to evaluate the
evaluates misstatements and forms confidence in financial statement consistency of the other information
an opinion on the financial disclosures. with the audited financial statements.
statements. bit.ly/1gOFMFd In addition, while reading the other

14 JULY/AUGUST 2014 AUDIT & BEYOND


UPDATES

FINANCIAL REPORTING:
UK & IRELAND
information in confidence. TECH FINANCIAL REPORTING LAB well as the new financial reporting
10/14AAF Receipt of information in STAKEHOLDER SURVEY standards (FRS 101 and FRS 102) for
confidence supersedes AUDIT 2/99/ (MAY 2014) the UK and Ireland.
TECH 16/99 (Dec 99), which is now Working with companies and The consultation deadline is 8 July
withdrawn. investors, the FRC’s Financial 2014 and the taxonomies will then be
TECH 10/14AAF covers the Reporting Lab (the Lab) has finalised. HMRC and Companies
requirements that apply in situations published seven reports that have House are expected to adopt the
where the information might be covered a range of governance and taxonomies in due course for filings
relevant to the audit and the duty financial reporting topics. The Lab of accounts under the relevant
auditors have to those providing the was launched to facilitate standards. The Irish Revenue
information. It is at bit.ly/1kBMptX improvements in the effectiveness of Commissioners also expect to
The technical release can be corporate reporting in the UK and the adopt these taxonomies once the
downloaded and printed off, but FRC wants to ensure that its work appropriate Irish extensions are
it is worth noting that the online remains focused on issues important available.
version helpfully includes hot links to the reporting community. bit.ly/1sTSgLw
to the other documents it Via a short survey, feedback has
references. See bit.ly/1ojfF6I been requested from all those CORPORATE REPORTING IN A
involved in reporting, including DIGITAL WORLD (APRIL 2014)
companies, their advisers, auditors, The FRC has announced a project to
representative/professional bodies investigate how companies currently,
and investors (institutional and and might in the future, use digital
individual) and analysts. The survey media in their corporate reporting
focuses on subject areas that should to improve investors’ access to
be a priority for the Lab in future. information.
information, the auditor would be bit.ly/1vFkH4a The project will be undertaken
responsible for considering whether by the Financial Reporting Lab (the
there is a material inconsistency FRC CONSULTS ON CONVENTIONS Lab). The Lab will initially review
between the other information and the FOR ELECTRONIC TAGGING OF how companies use a wide range
auditor’s knowledge obtained during ACCOUNTS (MAY 2014) of digital media, including
the course of the audit, and remaining Following transfer of responsibility websites, videos, apps, social
alert for other indications that the to the FRC, the eXtensible Business media platforms and blogs in their
other information appears to be Reporting Language accounts tagging external communications to
materially misstated. The terms ‘other conventions (“taxonomies”) have investors, and how investors use
information’ and ‘annual report’ are been updated and the FRC has what is produced.
defined and explained in the standard published a consultation on three of This project is the first part of a
with the intention of making the scope the taxonomies to enhance the series of three projects on Corporate
of the standard as clear as possible, quality of financial reporting in the Reporting in a Digital World. Over
while enabling its appropriate UK and Ireland. the next 18 months, the Lab plans to
application in light of differing These are the first taxonomies investigate:
corporate reporting regimes and resulting from the project which was Digital Present: the current state
practices in a wide variety of announced in September 2013 to of corporate reporting through
jurisdictions and circumstances. improve the quality of electronic digital media;
bit.ly/1kG9cRp tagging of accounts and reflect UK Digital Challenges: barriers to the
reporting using EU adopted IFRS, as use of digital media in reporting; and

AUDIT & BEYOND JULY/AUGUST 2014 15


Digital Future: how companies CONSULTATION ON THE UK financial statements whether they
might make the most of technological CORPORATE GOVERNANCE consider it appropriate to adopt the
opportunities. CODE PUBLISHED going concern basis of accounting
(APRIL 2014) and identify any material
The Lab has invited listed companies, The FRC is consulting on its two- uncertainties to their ability to
investors and analysts to take part in yearly review of changes to the continue to do so;
the project. UK Corporate Governance Code companies should robustly assess
bit.ly/1o5vdQe following earlier consultations on their principal risks and explain
directors’ remuneration (October how they are being managed and
FRC SIMPLIFIES ACCOUNTING 2013) and risk management, mitigated;
FOR MICRO-ENTITIES internal control and the going companies should state whether
(APRIL 2014) concern basis of accounting they believe they will be able to
The FRC has published an amended (November 2013). continue in operation and meet their
version of the Financial Reporting The proposed changes to the UK liabilities taking account of their
Standard for Smaller Entities Corporate Governance Code are that: current position and principal risks,
(FRSSE) for use by micro-entities greater emphasis be placed on and specify the period covered by
that want to take advantage of new ensuring that remuneration policies this statement and why they consider
regulations allowing them to prepare are designed with the long-term it appropriate. It is expected that the
simplified financial statements. success of the company in mind and period assessed will be significantly
Following new EU legislation, the lead responsibility for doing so rests longer than 12 months; and
micro-entities regime was introduced with the remuneration committee; companies should monitor their
in UK company law in November companies should put in place risk management and internal control
2013. Micro-entities can now use the arrangements that will enable them systems and, at least annually, carry
FRSSE when choosing to apply the to recover or withhold variable pay out a review of their effectiveness,
new micro-entities regime and when appropriate to do so and and report on that review in the
prepare simplified financial should consider appropriate vesting annual report.
statements with fewer disclosure and holding periods for deferred
notes than previously required by remuneration; Comments were invited by Friday 27
the FRSSE. companies should explain when June 2014 and, subject to comments
The amendments to the FRSSE are publishing AGM results how they received, any proposed changes will
effective for financial years ending intend to engage with shareholders apply to financial years beginning on
on or after 30 September 2013 for when a significant percentage of or after 1 October 2014.
companies filing their accounts on them have voted against any bit.ly/1lbMJiG
or after 1 December 2013. resolution;
bit.ly/R8vKSU companies should state in their

16 JULY/AUGUST 2014 AUDIT & BEYOND


UPDATES

FINANCIAL
REPORTING:
INTERNATIONAL
AMENDMENTS TO IAS 16 PROPERTY, IASB PUBLISHES AMENDMENTS TO accounting requirements of IAS 39
PLANT AND EQUIPMENT AND IAS 38 IFRS 11 JOINT ARRANGEMENTS Financial instruments are generally
INTANGIBLE ASSETS (MAY 2014) (MAY 2014) considered to be difficult to apply
The International Accounting International Financial Reporting when accounting for such
Standards Board (IASB) has published Standard IFRS 11 addresses the transactions.
amendments to International accounting for interests in joint The IASB is replacing IAS 39 with a
Accounting Standard (IAS) 16 ventures and joint operations. The new standard, IFRS 9 Financial
Property, plant and equipment and amendments published by the IASB instruments. That project is in the
IAS 38 Intangible assets. add new guidance on how to account final stages of completion. However,
IAS 16 and IAS 38 both establish the for the acquisition of an interest in a the IASB decided to treat as a
principle for the basis of depreciation joint operation that constitutes a separate project the macro hedging
and amortisation as being the business. The amendments specify component of these reforms in order
expected pattern of consumption of the appropriate accounting treatment to seek views from a broader range of
the future economic benefits of an for such acquisitions. constituents.
asset. The IASB has clarified that the bit.ly/1j688EX Comments on the discussion
use of revenue-based methods to paper Accounting for dynamic risk
calculate the depreciation of an asset IASB DISCUSSION PAPER ON management: a portfolio revaluation
is not appropriate because revenue ACCOUNTING FOR MACRO HEDGING approach to macro hedging are invited
generated by an activity that includes (APRIL 2014) by 17 October 2014.
the use of an asset generally reflects The IASB has issued a discussion bit.ly/1ro4UDN
factors other than the consumption paper which explores an approach to
of the economic benefits embodied in better reflect entities’ dynamic risk
the asset. management activities in their
The IASB has also clarified that financial statements, otherwise
revenue is generally presumed to be known as macro hedging.
an inappropriate basis for measuring Many financial institutions and
the consumption of the economic other entities manage risks, such as
benefits embodied in an intangible interest rate risk, dynamically on a
asset. This presumption, however, portfolio basis rather than on an
may be rebutted in certain limited individual contract basis. Dynamic
Louise Sharp
circumstances. risk management is a continuous
produces Technical
bit.ly/1iS9yD3 process because the risks that such Updates. She is a
entities face evolve over time, as does technical manager
their approach to managing those at the Audit &
risks. However, the existing Assurance Faculty

AUDIT & BEYOND JULY/AUGUST 2014 17


PORTFOLIO

From the faculties


Keep in touch with
our selection from
ICAEW’s other
faculty magazines

WE’RE SHOPPING A CONSISTENT AND SEND IN THE ACTUARIES


CORPORATE FINANCIER COHERENT STORY FS FOCUS
BY ALL ACCOUNTS
The past six months have seen plenty of Solvency II has altered the roles of many
retailers floating on the London Stock The Financial Reporting Faculty has professionals. Under the new regime,
Exchange: Boohoo.com and Poundland profiled Russ Houlden, CFO of United actuaries may need to play a role in risk
made their stock market debut; in May, Utilities, in his role as chairman of The 100 management that goes beyond their usual
Card Factory and Shoe Zone floated, with Group’s financial reporting committee. He numerical analysis.
market caps of £766m and £80m discussed the issues keeping finance Solvency II now requires closer co-
respectively. Others are in the pipeline. directors of the UK’s biggest companies operation between the actuary and the risk
But why? EY partner and retail specialist awake at night. functions. Under article 44 in the directive,
Jessica Clayton says: “There have been As chairman of the the body that these areas include reserves issues, asset
pretty unfavourable conditions in the past represents UK FTSE 100 FDs, Houlden liability management, liquidity and
few years. There’s a pent-up backlog of recognises that financial reporting is in the concentration risk, a review of underwriting,
exits that have been waiting to happen.” firing line. Critics say financial statements operational risk, and reinsurance, together
While growth has slowly edged up – EY are overly complex and that key messages with other risk mitigation techniques.
expects the UK economy to increase 2.9% are increasingly lost among lengthy However, not all areas require the urgent
this year and 2.3% next – consumer disclosures and jargon. But Houlden also attention of actuaries. The reserves area,
confidence has increased. has firm ideas on what needs to be done to where amounts can include uncertainty, is
David McCorquodale, head of retail at change perceptions. particularly prominent. Technical provisions
KPMG, says: “While we’re not back into Going back to basics wouldn’t be a bad such as calculating the risk appetite are
huge growth, the public markets are putting start, he says. “Financial statements where the actuary really starts to get
higher valuations on retailer businesses.” should be focused on the needs of debt involved. The actuary’s assessment will not
For a while, it seemed difficult to get and equity investors. They should not only help to provide robust and reasonable
through a month without a retailer hitting become some sort of general purpose projections, but will also give an
the buffers. HMV, Jessops, Comet and document that acts as a repository for independent and justified view.
Republic entered administration; some, information of interest to all and sundry.” Risk mitigation is equally important. Here,
such as Blockbuster, couldn’t be saved. Statements now include disclosures on actuarial input is needed for an own risk and
It is far too simplistic to put the upturn topics such as employee diversity and solvency assessment, which can identify the
down to economic conditions. One trend human rights. But Houlden feels that most effective risk mitigation for the insurer,
has been innovation in clearly defined investors are interested in something more and can allow for various scenarios to be
markets – value, luxury and online. fundamental: “They should clearly set out assessed more accurately.
Change in retail means there are the company’s strategy, and this should be Firms should be aware of the
opportunities for those who respond and supported by financial and non-financial contribution actuaries can make.
challenges for those who are slower. These performance measures. Companies can achieve optimum results
forces will continue to shape the sector, “They must tell a consistent and if the actuarial function works well with
leading to activity in the coming months. coherent story.” the risk management system.

For more from the Corporate Finance Faculty, For more from the Financial Reporting For more from the Financial Services Faculty,
visit icaew.com/cff Faculty, visit icaew.com/frf visit icaew.com/fsf

18 JULY/AUGUST 2014 AUDIT & BEYOND


WHEN YOU GET CERTIFIED,
YOU GET RECOGNIZED.
THAT MAKES CLIENTS
RESPECT YOUR OPINIONS.”
— ROSEMARY AMATO, CISA
DIRECTOR, DELOITTE
AMSTERDAM, THE NETHERLANDS
ISACA MEMBER SINCE 1998

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connected. It announces that you have the expertise and insight to
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