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Structure of the Code. Don Thomson, Working Group Chair and IESBA Member IESBA Meeting September 16-18, 2013 Sydney. 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 Meeting September 16-18, 2013 Sydney
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
September CAG input • General support • Findings align with some stakeholder initiatives • Consider reading age, including impact on length • Consider a summary/overview; drill down to detail • Electronic Code interconnected with other options • Consider resources; balance this and new matters
Matters for IESBA CAG Consideration Comments or Questions ?