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Structure of the Code. Don Thomson, Working Group Chair and IESBA Member IESBA CAG Meeting September 11, 2013 New York. Background. Input from certain regulators Raise visibility of requirements and prohibitions Clarify who is responsible for meeting them
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Structure of the Code Don Thomson, Working Group Chair and IESBA Member IESBA CAG Meeting September 11, 2013 New York
Background • Input from certain regulators • Raise visibility of requirements and prohibitions • Clarify who is responsible for meeting them • SME/SMP input – enhance understandability • April 2013 – CAG input received • June 2013 – terms of reference approved
Research Overview • Questions - usability, understandability, navigability • Research being performed May to October 2013 • 34 participants to date; 5 continents • NSS, IFAC member bodies, regulators • Large firm, SMP Committee • Preliminary analysis; still finalizing conclusions
Options that Would Change Code • Support for change • Visibility • Understandability, enforceability, convergence • Plain English, drafting conventions • Long & complex sentences, quasi-legal style • Understandability, translation • Repackaging – pros and cons more balanced
Options that Would Change Code • Responsibility • 290 does not generally prescribe responsibility • 290.12 refers to compliance with ISQC 1 • No specific reference to responsibility • 154 “shall” statements in Section 290 • Some regulators, not all, expressed concern • Enforcement and consistency
Options that Would not Change Code • Off-Code Guidance/Complementary Materials • Additional guidance for trainers and users • Particularly SMPs and PAs in business • Summaries, flow charts, FAQs, case studies • Reinforce and not detract from Code • Need impacted by structural improvements • Electronic Code helpful but not urgent need
Matters for IESBA CAG Consideration Comments or Questions ?