June 10, 2010 – Charleston June 24, 2010 – Seattle Ethics ...

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1 I"#$%"&#’("&) S#&",&%,- U/,&#$ 2010 Regional Meetings June 10, 2010 – Charleston June 24, 2010 – Seattle Ethics & Strategic Professional Issues Committee Gaylen R. Hansen, Chair

Transcript of June 10, 2010 – Charleston June 24, 2010 – Seattle Ethics ...

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2010 Regional Meetings June 10, 2010 – Charleston

June 24, 2010 – Seattle Ethics & Strategic Professional Issues Committee

Gaylen R. Hansen, Chair

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Since Last Time Oct 2008

In midst of financial crisis, IASB amends IAS 39 to allow reclass of certain investment assets, no due process, no coordination with FASB.

Jul 2009 IASB and FASB air divergent views on fair value measurements.

Oct 2009

Canada Finalizes Private Company Accounting Standards.

Nov 2009

FASB & IASB reaffirm goal of completing major projects by mid-2011.

Nov 2009

EU refuses to consider adopting IFRS fair value governing financial instruments.

Feb 2010

SEC issues statement affirming support of global standards.

Mar 2010

Japan allows use of IFRS / U.S. only major economy without IFRS.

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IFRS in the News Feb 24 No IFRS Requirement Until 2015 or Later Under New SEC

Timeline, Journal of Accountancy

Feb 25 SEC’s IFRS Work Plan is a Work in Progress, WebCPA

Feb 26 U.S. delay on global accounting leaves world waiting, Reuters

Feb 26 SEC on IFRS: Not So Fast, CFO.com

Mar 1 SEC Promises Again, Stalls Again on IFRS Adoption , Compliance Week

Mar 9 Half of US execs want to use IFRS early-survey, Reuters

Mar 11 The SEC's Wait-and-See Approach, Bank Investment Consultant

Mar 15 To the SEC: Forget the Timetable and Stop the Runaway Train, Accounting Today

Apr 11 U.S. moves toward global accounting, Rochester Democrat & Chronicle

May 18 Schapiro Defends SEC’s Approach to IFRS, WebCPA May 14 IFRS Risk: Not What You Think, CFO.com

May 25 Getting to IFRS With Wisdom, Not Expediency, Compliance Week

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!  Supports ◦  Convergence ◦  Single standard "  IFRS “appears” best suited to fill role

!  Roadmap replaced by “Work Plan” ◦  Final decision next year ◦  “Whether to Adopt” questioned ◦  “When” & “How” to adopt questions ◦  IFRS “no earlier than approximately 2015 or 2016” ◦  Progress reports to begin in October

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2008 2009 2010 2012 2014 2015 2016 2013 2007 31 December 2006

Evaluation period

Limited eligible entities

Accelerated filers

Non-accelerated filers

Large accelerated filers

SEC Final decision

2011

Transition date Reporting date

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!  Sufficient development & application of IFRS? ◦  Quality & comprehensiveness ◦  Successful convergence efforts ◦  Consistency of application ◦  Auditability ◦  Enforceability

!  Independence of IASB? ◦  Funding ◦  Governance ◦  Independence

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!  Investor understanding & education !  Impact on U.S. regulatory environment !  Impact on issuers, large & small ◦  Accounting systems ◦  Contractual arrangements ◦  Corporate governance ◦  Litigation contingencies

!  Human capital readiness ◦  Preparers, investors, auditors, regulators, educators ◦  Auditor capacity

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!  “High-level” convergence has occurred in some areas ◦  Income taxes ◦  Business combinations ◦  Share-based payments

!  Models very different in other areas ◦  Debt/equity classification ◦  Derecognition ◦  Consolidation ◦  Tangible assets

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!  Net Earnings ◦  2/3 of issuers: 12.9% higher under IFRS ◦  1/3 of issuers: 9.1% lower under IFRS ◦  Is 22% range of differences material?

!  Where are major differences? ◦  Fair value, financial instruments, deferred taxes, PP&E,

pensions, minority interest, capitalization of interest, purchase accounting, asset impairment

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*

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FASB / IASB Completed Joint Project Description FASB – US GAAP IASB - IFRS

Share-based payments ASC 718 (FAS 123R) IFRS 2

Segment reporting ASC 280 (FAS 131) IFRS 8

Business combinations ASC 805 (FAS 141R) IFRS 3

Goodwill & other intangibles ASC 350 (FAS 142) IAS 36 & IAS 38

Long-lived assets held for sale & discontinued operations

ASC 360 (FAS 144) IFRS 5

Accounting changes & error corrections

ASC 250 (FAS 154) IAS 8

Fair value option & measurement

ASC 815 (FAS 155), ASC 820 (FAS 157) & ASC 820 (FAS

159) IAS 39

Even though joint projects, key differences persist

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Current Joint IASB / FASB Projects Project Q1 2010 Q2 2010 Q3 2010 Q4 2010 Q1 2011 Q2 2011

Financial instruments

Leases

Revenue recognition

Consolidation

F/S presentation

Discontinued ops

Comprehensive inc

Fair value measures

Debt v. equity criteria

Insurance contracts

Contingencies

Post-employment benefit

Emission trading

Exposure draft Discussion Final Standard 12

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! FASB’s future and U.S. GAPP foggy ◦  Blue Ribbon Panel may play key rolw

! Convergence vs. adoption decision unsettled ◦  Is SEC hedging its bets? ◦  EU may force the SEC decision

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!  International Ethics Standards Board for Accountants ◦  Operates under auspices of IFAC ◦  Sets “independent” standards under its own “authority” ◦  Subject to “Public Interest Oversight Board”

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!  Principles-based standards with “Conceptual Framework” for entire code (not just independence)

!  “Threats & safeguards” approach a key concept !  IFAC “member body” firms prohibited from issuing

IFAC attest reports if standards less stringent than IESBA’s ◦  Exception: if IESBA standards conflict with local

laws and regulations

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!  “Public Interest Entities,” ◦  Public companies AND others regulated by law ◦  Prohibitions similar to Sarbanes-Oxley (e.g. bookkeeping) ◦  Pre or post-issuance review if PIE audit client fees > 15% of

total firm fees for two consecutive years

!  Expanded non-attest service restrictions (~ET 101-3) !  Prohibit partner evaluation or compensation based

on selling non-audit services !  Moratorium on new standards – Jan 2011

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!  Conflicts of interest !  Responding to fraud or illegal acts !  Independence in audits of collective investments

(i.e. mutual funds)

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!  International Auditing & Assurance Standards Board ◦  Operates under auspices of IFAC ◦  Sets “independent” standards under its own “authority” ◦  Subject to a “Public Interest Oversight Board”

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!  Auditing Fair Value Estimates (Oct 2008) !  Going Concern (Jan 2009) !  Clarity Project – completed March 2009 ◦  Objectives clearly articulated ◦  Requirements prefaced by “the auditor shall” ◦  Improved readability and understandability ◦  Replace mechanical approach with a “Thinking Audit”

!  External Confirmations (Nov 2009) !  Moratorium on new ISAs – 2 years

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!  Concern about “disproportionality” ◦  Applicability of standards to smaller audits ◦  Documentation burden ◦  Inordinate inspection scrutiny

!  ISAs designed to be “proportionate” ◦  Size, level of complexity and nature of entity ◦  Proportionality ≠ modification of requirements ◦  Importance of professional judgment

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!  Using the Work of Internal Auditors !  Auditor’s Reports (Joint Project with AICPA’s ASB) !  Other Information in Documents Containing Audited F/S !  Assurance on Pro Forma Information !  Reviews & Compilations of F/S !  Assurance on Greenhouse Gas Statements !  Assurance Engagements Other Than Audits / Reviews of

F/S !  Examination of Prospective Financial Information !  Auditing Derivative Financial Information

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1.  Consider need to recognize international standards in state rules

2.  Will FASB/AICPA successfully complete 11 major projects by June?

3.  Don’t believe everything you hear about internationalization

4.  IFAC ethics and auditing standards are substantive and address some areas we don’t

5.  Consider impact of “threats and safeguards” approach on enforcement

6.  Closely monitor audit “proportionality” and SME/SMP* concepts

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• IASB’s SME – “Small & Medium-Sized Entities;” • IFAC’s SMP – “Small & Medium-Sized Practices”

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Gaylen R. Hansen Email: [email protected]

Phone: 303.670.4648

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U.S. History of International Accounting & Reporting

Standards 1973 International Accounting Standards Committee (IASC) formed

1998 Basic standards completed

2000 SEC reviews basic standards and issues concept release IASC approves new constitution International Organization of Securities Commissions (IOSCO review finalized European Commission proposes IFRS for public companies by 2005

2001 IASB assumes accounting standard-setting responsibilities from IASC

2002 EU adopts IFRS effective January 2005

2005 First widespread use of IFRS

2007 SEC permits foreign private issuers to use IFRS with reconciliation to U.S. GAAP

2008 SEC proposes roadmap for potential use of IFRS by U.S. public companies

2010 SEC announces work plan to consider adoption of IFRS for U.S. public companies

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!  With regard to topics covered ◦  This “overview” is at a very high level ◦  Not all differences between the two frameworks identified

!  Just some “flavour” on major differences

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!  Stock !  Inventory !  Equity !  Investee !  Accrual !  Presents fairly

!  Shares !  Stock !  Reserves !  Associate !  Provision !  True and fair

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Good

Bad

Ugly

!  You know more about IFRS than you may think ◦  Many areas are similar to GAAP

!  There are significant areas of difference ◦  New way of thinking about standards

!  Historically there have been some lax practices in applying IFRS (jurisdictional differences – i.e. IFRS “Lite”)

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Accounting policies

Estimates

Errors

Materiality

•  Specific principles, bases, conventions, rules and practices

•  Adjustments in carrying amount of assets/liabilities •  Result from new information or developments

•  Material omissions or misstatements ◦  Include clerical errors, mistakes in application, oversight or

misinterpretation of facts, fraud

•  Omissions or misstatements that individually or collectively influence the economic decisions of users

•  Consider the size and nature of the item

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!  Financial statement presentation !  Fair value !  Goodwill !  Revenue recognition !  Intangible and tangible assets !  Leases !  Inventories

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* US GAAP as described in the following high-level discussion is for private reporting and does not include additional requirements of SEC Reg. S-X for public issuers of financial statements

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GAAP IFRS

Format Format not prescribed but usually in decreasing order of liquidity

No prescribed format but minimum lines presented

Current / Non-current distinction

May choose Required except when a liquidity presentation used

Netting assets & liabilities

• OK if there is: ! Intent of offset ! Offset enforceable by law

• Limited to two parties

• Derivatives based on “master netting arrangement” allowed

• OK only if allowed by specific Standards/ Interpretations.

• May involve different parties

• Derivatives based on “master netting arrangement” not allowed

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GAAP IFRS

Format

No prescribed format Same, but minimum lines to be presented

“Functional” and “natural” classifications allowed

Same

Extraordinary items

Virtually disallowed Expressly prohibited

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GAAP IFRS

Format Direct & indirect methods allowed but indirect method more common

Similar to GAAP

Cash equivalents

• Highly liquid investments with maturity of 3 months or less

• Overdrafts always excluded

• Qualification similar to GAAP

• Overdrafts that fluctuate from positive to negative included

Specific item presentation

•  Interest paid/received and dividends received are operating

• Dividends paid are financing

• Interest paid/received and dividends paid/received can be both financing or operating

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GAAP IFRS Comparative presentation

No requirement One year of comparatives for all numerical information reported

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GAAP IFRS

Guidance

SFAS 157 •  Dispersed widely throughout IFRS •  Inconsistencies: ! Business combinations (tax assets/liabilities, pension

plans) ! PPE: revaluation model – use FV if it can be measured

reliably ! Leases: require FV measurement but there is no guidance ! FV not defined in Conceptual Framework

Note: IASB has an active fair value measurement project with plans to issue guidance in 2010.

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GAAP IFRS

Negative goodwill Residual excess recognized as profit or loss (no extraordinary gain)

Same

Provisional accounting

Adjustments of provisional fair value to goodwill within 12 months from acquisition date. After that, adjusted thru income statement

Same

Amortization No amortization Same

Impairment Impairment tested at least annually

Same

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GAAP IFRS

Definition (RU – GAAP)

(CGU – IFRS)

• Operating segment or one level below the segment (referred to as “component”)

• A component is a business with discrete financial information and a segment where management regularly reviews operating results

• Components of an operating segment are aggregated and deemed a single RU if they have similar economic characteristics

• Smallest identifiable group of assets generating cash inflows that are largely independent of cash inflows from other assets or groups of assets

•  If active market exists for output produced by CGU, it is identified as a CGU, even if some or all of output used internally

•  Considers various factors; i.e. how management monitors the entity’s operations or makes decisions about continuing or disposing of the entity’s assets and operations

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GAAP IFRS

Calculation methodology

Two-step approach: 1) If carrying amount of

reporting unit including goodwill less than fair value, then go to step 2

2) Determine implied fair value of goodwill and compare with carrying amount. Implied fair value of goodwill determined in same manner as goodwill in a business combination.

One-step approach: • Difference between carrying amount and higher of asset’s value in use and fair value less cost to sell

• Value in use: reasonable estimate performed by individual enterprise (not market specific); includes requirements to prevent using unjustified assumptions different from the market

Indication of impairment

Assess at each reporting date and at least annually

Test on an annual basis and between annual tests in certain circumstances

Reversal Prohibited Prohibited

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GAAP IFRS

Preliminary views on recognition

•  IASB and FASB Joint project •  A contract-based revenue recognition model •  Revenue recognized when performance obligations satisfied

Revenue recognition framework

•  Not a single dedicated standard

•  Extensive detailed guidance, including industry-specific guidance

Principle-based approach: • Goods: “Risk & rewards” approach

where seller retains neither management involvement nor control of goods

• Services: percentage of completion • Interests: effective interest method • Dividends: right to receive payment • Royalties: accrual basis

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GAAP IFRS

Multiple-element arrangements

Revenue arrangements separated into units of accounting and accounted for separately if conditions of EITF 00-21 met

• Some principle-based guidance available in IAS 18

• Little specific guidance

Software

Detailed specific guidance • Almost non-existent specific guidance; only general principles

• US GAAP “may” be used for interpretive purposes

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GAAP IFRS

Development costs

• Strict criteria results in very rare development costs capitalized

• Computer software for sale must be capitalized if certain criteria met

• Capitalize if certain criteria met; if expensed cannot subsequently be capitalized

• No specific guidance for software

Revaluation Prohibited Permitted only if active market exists

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GAAP IFRS

Change in depreciation method

Treated as a change in accounting estimate and reflected entirely in current period income statement

Same as GAAP but effect reflected in current and prospective periods

Subsequent measurement

Revaluation prohibited • Revaluation allowed • Revaluation model: Changes in FV recognized in OCI; depreciation and impairment charged to the income statement

Investment property

No specific definition of but depreciated cost model must be applied

• May choose FV or depreciated cost models

• Fair value model: all changes in FV recognized in income statement

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GAAP

IFRS

Similar approaches – capitalize when substantially all risks & rewards associated with an asset transfer to a lessee. GAAP more form-driven and more quantitative-test oriented

GAAP capitalizes if any one of the following criteria is met: • Transfers ownership at

lease end • Bargain purchase option • PV of minimum lease

payments greater than 90% of fair value

• Lease term longer than 75% of estimated economic life

IFRS indicators similar to GAAP indicators + others; however these are “genuine” indicators and not triggering events

Qualitative

Quantitative

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•  Joint FASB – IASB project

•  Nearly all leases “financing” & therefore capitalized

• Will eliminate “operating leases”

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GAAP IFRS

Measurement

•  Lower of cost or market

•  Market means current replacement cost (purchase or reproduction), but:

" Not exceeding NRV (estimated selling price less completion and disposal cost)

" Not less than NRV reduced by allowance for normal profit margin

•  Lower of cost or net realizable value

•  NRV is estimated selling price in the ordinary course of business less estimated costs of completion and estimated costs necessary to make sale (this is not the same as fair value)

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GAAP IFRS

LIFO Permitted Prohibited

FIFO Allowed Allowed

Average cost method Allowed Allowed

Retail method Allowed in some situations if both practical and appropriate

May be used for convenience if the results approximate cost

Biological assets Not specified. Normally historical cost is used

Measured at fair value less estimated point-of-sale costs

Write-downs reversals Prohibited Required if certain criteria met

* The use of LIFO will be banned in IFRS for SMEs as well

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•  For tax purposes U.S. companies must continue to follow rules of the IRC, Regulations and case law

•  Accounting changes may require permission from IRS ◦  LIFO, IFRS prohibits this inventory method ◦  Intangible asset capitalization ◦  Change in depreciation method ◦  No revaluation allowed on assets for tax purposes ◦  Revenue recognition ◦  Lease recognition (capital leases) ◦  Any other change in method that does not conform to tax

law or that changes the method used for currently recognizing income or deductions

!  IFRS may have a major impact on implementation of FIN 48

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!  Part A – Conceptual framework (applies to all) !  Part B – Professional accountants in public practice !  Part C – Professional accountants in business

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!  Integrity ◦  Straight forward & honest in all professional and business

relationships !  Objectivity ◦  No bias, conflict of interest or undue influence of others

to override professional or business judgments !  Professional Competence & Due Care ◦  Maintain professional knowledge and skill at level

required to ensure competent professional services based on current developments in practice, legislation and techniques

◦  Act diligently in accordance with applicable technical and professional standards

IESBA - Fundamental Principles

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!  Confidentiality ◦  Refrain from disclosing confidential information

acquired as a result of professional and business relationships without proper and specific authority to disclose unless there is a legal or professional right or duty to disclose

◦  To refrain from using confidential information acquired as a result of professional and business relationships for personal advantage or the advantage of third parties

!  Professional behavior ◦  Obligation to comply with relevant laws and

regulations and avoid any action that discredits the profession

IESBA - Fundamental Principles

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!  Professional behavior – Applies to ALL ◦  Obligation to comply with relevant laws and

regulations and avoid any action that discredits the profession

Part A - Fundamental Principles

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!  Requires active consideration of all issues !  Establishes basic principles !  Can be applied to differing circumstances !  Responsive to rapid change !  Requires judgment rather than literal

interpretations encouraged by a pure rules approach

Conceptual Framework

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Threats !  Self-interest !  Self-review !  Advocacy !  Familiarity !  Intimidation

Safeguards (2 categories) !  Created by the

profession, legislation or regulation

!  The work environment

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When safeguards are not adequate

Prohibitions

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!  Professional Appointment* !  Conflicts of Interest !  Second Opinions* !  Fees and Other Types of Remuneration !  Marketing Professional Services !  Gifts and Hospitality !  Custody of Client Assets !  Objectivity – All Services !  Independence – Audit and Review Engagements !  Independence – Other Assurance Engagements

Part B – Public Practice

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Topics

* Topics not covered by AICPA Code of Conduct

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•  “Firm” includes “network firm,” except when stated otherwise

•  Documentation: conclusions regarding compliance with independence requirements, and substance of any relevant discussions that support those conclusions

•  Long association of senior personnel with an audit client •  Reports that include a restriction on use or distribution

Independence – Audit & Reviews

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•  Potential conflicts •  Preparation and reporting of information •  Acting with sufficient expertise •  Financial interests •  Inducements (gifts)

Part C – Accountants in Business

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SEC / AICPA * IESBA * !  Defined: ◦  SEC reporting entities ◦  ERISA reporting entities ◦  Government retirement plans ◦  Single audit reporting entities ◦  Financial institutions, credit

unions and insurance companies

* See ET §100.01.20, fn 5

!  Defined: ◦  Listed entities ◦  Defined by regulation / law ◦  Entities subject to audit by

regulation / law with same provisions as a listed entity

* See §290.25

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These comparisons, and those that follow, are not intended to be all-inclusive or definitive, but rather solely to demonstrate significant differences between U.S. and international independence standards for audits and review engagements.

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SEC / AICPA * IESBA * !  Management functions not

allowed for attest clients !  May provide ◦  Advice ◦  Recommendations ◦  Research materials

!  Allowed non-attest services requires documentation

* See ET §101.05.20, fn 5

!  Management functions not allowed for audit clients

!  May provide ◦  Advice

◦  Recommendations

!  Allowed non-attest services doesn’t require documentation

* See §290.164

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SEC / AICPA * IESBA * !  Public interest entities: ◦  Prohibited by law

!  Non-public interest entities: ◦  Allowed subject to general

requirements & activities specified in ET 101-3

* See ET §101.05

!  Public interest entities: ◦  Prohibited, with “emergency”

exception

!  Non-public interest entities: ◦  Allowed if services are of a

routine or mechanical nature

* See §290.167 – §290.171

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SEC / AICPA * IESBA * !  Public interest entities: ◦  Prohibited by law

!  Non-public interest entities: ◦  Not allowed if material &

involve significant subjectivity

* See ET §101.05

!  Public interest entities: ◦  Prohibited, if it would involve a

material effect on F/S

!  Non-public interest entities: ◦  Not allowed if material &

involve significant subjectivity

* See §290.175 – §290.178

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SEC / AICPA * IESBA * !  Allowed, if: ◦  Client reviews, approves and

(generally) signs tax return

* See ET §101.05

!  Allowed, if: ◦  Client takes responsibility &

makes significant judgments ◦  Services typically based on

facts in existence or historical transactions ◦  Return subject to review or

approval process by tax authority

* See §290.183

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SEC / AICPA * IESBA * !  Public interest entities: ◦  Prohibited by law

!  Non-public interest entities: ◦  Allowed subject to general

requirements & activities specified in ET 101-3

* See ET §101.05

!  Public interest entities: ◦  Prohibited, with “emergency”

exception

!  Non-public interest entities – allowed depending on: ◦  Degree of subjectivity of

calculations

◦  Materiality

* See §290.167 – §290.184 67

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SEC / AICPA * IESBA * !  Allowed, subject to general

requirements & activities specified in ET 101-3

* See ET §101.05; 191.015-.016, .144-.145

!  Self-review threat factors: ◦  Degree of subjectivity/

materiality ◦  Level of tax expertise of client ◦  Advice supported by law /

regulation

!  Prohibit if no safeguards and: ◦  Reasonable doubt as to

outcome ◦  Outcome materially impacts F/S

* See §290.187-191

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SEC / AICPA * IESBA * !  Allowed, subject to general

requirements & activities specified in ET 101-3, however: ◦  Representing client in court

impairs independence

* See ET §101.05

!  Self-review threat factors: ◦  Firm provided advice on

matter ◦  Materiality ◦  Extent matter supported by

law/ regulation ◦  Management’s role in resolving

!  Prohibit if services involve advocating in court and: ◦  Amounts are material to F/S

* See §290.192-194

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SEC / AICPA * IESBA * !  Public interest entities: ◦  Prohibited by law

!  Non-public interest entities: ◦  Allowed subject to general

requirements & activities specified in ET 101-3

* See ET §101.05

!  Public interest entities – prohibited if related to: ◦  Significant part of ICFR

◦  Generating material F/S info

◦  Material F/S amounts/disclosures

!  Non-public interest entities – allowed depending on: ◦  Management takes responsibility

◦  Firm not assuming responsibility

* See §290.195 – §290.199

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SEC / AICPA * IESBA * !  Public interest entities: ◦  Prohibited by law

!  Non-public interest entities: ◦  Allowed subject to ET 101-3 ◦  Design/implementation

prohibited

◦  Off-the-shelf installs allowed

* See ET §101.05

!  Public interest entities: ◦  Design/implementation

prohibited ◦  Off-the-shelf program installs

allowed

!  Non-public interest entities:

◦  Design/implementation, allowed if adequate safeguards ◦  Off-the-shelf installs allowed

* See §290.201 – §290.202

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SEC / AICPA * IESBA * !  Public interest entities: ◦  Prohibited by law

!  Non-public interest entities: ◦  Testifying as an advocate is

generally prohibited

* See ET §101.05

!  Public interest entities: ◦  Prohibited

!  Non-public interest entities: ◦  Prohibited if services involving

estimates of damages are material

* See §290.201 – §290.202

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SEC / AICPA * IESBA * !  Public interest entities: ◦  Prohibited by law

!  Non-public interest entities: ◦  Generally prohibited, although

advisory services allowed subject to compliance with ET 101-3

* See ET §101.05

!  Prohibited when: ◦  Effectiveness of advice depends

on accounting treatment

◦  Advice is material

◦  Reasonable doubt as to appropriateness of accounting treatment

* See §290.216 – §290.219

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SEC / AICPA * IESBA * !  Public interest entities: ◦  Prohibited by law

!  Non-public interest entities: ◦  Generally allowed subject to

compliance with ET 101-3

◦  May not make compensation decisions, hire or terminate

* See ET §101.05

!  Public interest entities prohibit: ◦  Search for or seek candidates ◦  Reference checks

!  Non-public interest entities: ◦  Allowed subject to safeguards ◦  May not assume management

role, negotiate or make hiring decisions

* See §290.214 – §290.215

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SEC / AICPA * IESBA * !  Public interest entities: ◦  Relative size of fees not

addressed ◦  Pre-issuance reviews required

on engagements

!  Non-public interest entities: ◦  Relative size of fees not

addressed

!  Public interest entities, if total fees represent > 15% of total firm fees for 2 years, then: ◦  Pre- or post-issuance review

◦  Reviews performed by someone outside firm

!  Non-public interest entities: ◦  Allowed subject to safeguards

* See §290.220 – §290.222

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SEC / AICPA * IESBA * !  Public interest entities: ◦  Compensation & evaluation

practices not specifically addressed in independence rules (although considered in PCAOB inspections)

!  Non-public interest entities: ◦  Compensation & evaluation

practices not addressed

!  Key audit partners shall not be evaluated on or compensated based on success in selling non-attest services

!  Compensating or evaluating other members of audit team for selling non-attest services may create a threat

* See §290.228 – §290.229

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http://web.ifac.org/publication •  Code of Ethics for Professional Accountants •  Overview of the Code (PowerPoint) •  Independence Overview of Section 290

(PowerPoint) •  Independence of Public Interest Entities

(PowerPoint) •  Strategic & Operational Plan •  Newsletters

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http://www.ifac.org/IAASB/Resources.php#Publications

•  Annual Reports •  Strategic & Operational Plan •  Newsletters

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