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Structure of the Code

Structure of the Code. Don Thomson, Task Force Chair IESBA Meeting New York October 13-15, 2014. Recent developments. Several TF meetings and e-mail exchanges Drafting conventions refined and shared with TFs Additional material in process for January

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Structure of the Code

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  1. Structure of the Code Don Thomson, Task Force Chair IESBA Meeting New York October 13-15, 2014

  2. Recent developments • Several TF meetings and e-mail exchanges • Drafting conventions refined and shared with TFs • Additional material in process for January • Additional input received re Consultation Paper • September CAG and October Forum of Firms • Pre-meeting comments from Board members

  3. Input received • Supportive overall; specific issues re CP follow • Other issues • Safeguards and "other matters" are important (CAG) • Stakeholders also dealing with EU changes (CAG, FoF) • Prior to ED, consider translatability (FoF) • Facilitate thorough analysis, recognizing volume (FoF) • Work effort significant; timeline optimistic (FoF)

  4. Consultation Paper Introduction and Background • 2 : Change meaning only if agreement, process • Respondents may want changes outside scope (FoF) • 10 : Timing – reference to other projects (Board) • Safeguards outside scope; in SWP and not in CP

  5. Consultation Paper Restructuring the Code • 14, 17 : "Requirements" heading unchanged • Includes prohibitions (Board – TF considered) • 15, 17 : Clarified linkage to conceptual framework • Reference to framework repeated; more self-contained • More questions; presented in a more logical order • Throughout CP • Previous draft less clear, less detailed (Board)

  6. Consultation Paper Use of Language • 20, 21, 22 : Link to defined / described terms • Clarity of terms not previously resolved (Board)

  7. Consultation Paper Reorganization of the Code • 25 : Standards mentioned, question posed • Consider standards, particularly independence standards (CAG, Board) • Restructuring to date has reduced differences • Coverage of topics more self-contained • Also consider branding (WG) - deferred • Examples not set out as standards; not branded

  8. Consultation Paper Reorganization of the Code • 26, 27 : Renumbering proposal unchanged • Did not reduce 3 digits to 1 (Board – TF considered) • 27 : Proposals include • Sections 290 and 291 remain separate (Board) • Extant Part C relocated ahead of Part B (Board)

  9. Consultation Paper Responsibility • 32 : 300.201(c) to specifically mention breaches • Firm policies and procedures to require reporting of breaches to responsible individuals • Concern that Code may not be sufficiently specific, particularly regarding the identification of individual to whom report breaches – reporting should be outside the engagement team to firm / national level (CAG)

  10. Consultation Paper Electronic Code and Concordance • 37 : HTML version being developed • Enhanced navigation and hyperlinks • Concordance limited to paragraph references • Concern about amount of material to review (FoF) • Considering side-by-side (extant v proposed) wording for ED

  11. Consultation Paper Illustrative Examples • Foreword expanded (previously incomplete) • Explanation of terms; how to use Code • 200s : PAIBs ahead of PAIPPs / independence • Intent to enhance Code; avoid any weakening • Mindful of guidance v requirement • Revised draft will address other input • Intended focus of discussion and CP is on approach

  12. Forward timeline (tentative) • Sep'15– draft ED (CAG) • Oct'15– ED approved • Early'17– Finalize / issue restructured Code • Jan'18– Code effective • Oct'14– C P approved • Jan'15– review continues • Mar'15– responses (CAG) • Apr'15– responses • Jun-Jul'15– draft ED subject to responses to CP, timing of safeguards project

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