Opportunities and Challenges for an Enhanced Cooperation between Regulators and Auditors Pascal Frèrejacque, Senior Operations Officer, Centre for Financial Reporting Reform, The World Bank Vienna, 21 November 2013
Part I: International Guidance and Practices Financial Sector Exchange Forum, November 21, 2013
Audit Trust Public Oversight Law Ethics Standards Education & training Practice Quality Assurance Ultimate objective: Trust in financial reporting and audits Corporate governance 3
International Guidance affecting the Accounting Profession Liquidity shortage worldwide, inter bank lending slowing down Aug-07 Collapse of Lehman Brothers Sep-08 De Larosiere Report (EU) Feb-09 London G20 declaration on Strengthening the Financial System Apr-09 IMF on addressing procyclicality Feb-09 ECB: Financial Markets increasingly vulnerable Jun-07 ECB: Financial Markets potentially unstable Jan-07 Lowering of interest rates and facilitated access to refinancing by European Central Bank 4
International Guidance affecting the Accounting Profession EC Green Paper on audit policy Oct-10 PCAOB concept release on auditor independence & audit firm rotation Aug-11 EC audit reform proposal with Amendment of Directive 2006/43/EC Nov-11 FSB on enhancing the contribution of external audit to financial stability Mar-12 International Auditing Assurance Standard Board (IAASB) issued a proposal for a framework for audit quality Jan-13 BCBS issued a consultative document on External audits of banks Mar-13 UK CC summary of its provisional decision on the UK audit market competition -- Jul-13 Financial Stability Board (FSB) emphasized the importance of external audits in supplying Jan-12 IAASB issued an Invitation To Comment (ITC): Improving the Auditor s Report Jun-12 A key committee in the EC rejected proposals for audit-only firms and adopted prohibitions on non-audit services that generally align with the International Ethics Standards Board for Accountants code (IESBA) Apr-13 BOE issued a code of practice on the relationship between external auditor and the supervisor Apr-13 UK FRC issued a revised auditing standard intended to enhance the auditors report - Jun-13 RECENT INCREASED REGULATION AND AUTHORITATIVE GUIDANCE DEMONSTRATE BOTH THE IMPORTANCE AND RENEWED INTEREST IN 5 THE RELATIONSHIP BETWEEN REGULATORS AND EXTERNAL AUDITORS.
Interactions between Supervisors and Auditors 6
IAASB Proposal on New Sections in the Audit Report Key Audit Matters Going Concern Independence and other Ethical Requirements Disclosing the Engagement Partner Name 7
Interactions between Supervisors and Auditors 8
Interactions between Supervisors and Auditors 9
Principles Proposed by the Basel Committee P 1-3 Auditor s competence and independence P 4 Audit quality arrangements P 5-6 Specifics Duties of a Bank Auditor P 7-11 Role of the Audit Committee P 12-14 P 15-16 Communication with the audit firm and the accounting profession Communication with the audit oversight body 10
Part II: Results of the preliminary survey Financial Sector Exchange Forum, November 21, 2013
Results of the preliminary survey Expressed in % of countries per category The Central Bank of Armenia can object to the appointment of an auditor and engage a new auditor within 4 months Central Bank of Moldova may reject future appointment of external auditors by the bank if they do not comply with the provision of the Law on Financial Institutions and the Regulation With the participation of Albania, Armenia, Belarus, Federation of Bosnia and Herzegovina (incl. Republic Srpska), Croatia, Georgia, Kosovo, Macedonia, Moldova, Montenegro and Serbia 12
Results of the preliminary survey If the Central Bank of Montenegro finds that the audit has not been conducted in accordance with the current regulations, the Central Bank shall not accept such audit report and shall require that another auditor repeat the audit at the Central Bank expense A bank shall submit to the National Bank of Serbia a written notification on resignation or removal of the external auditor, including a statement of reasons for the resignation and/or removal at least within 15 days from the day of resignation and/or removal With the participation of Albania, Armenia, Belarus, Federation of Bosnia and Herzegovina (incl. Republic Srpska), Croatia, Georgia, Kosovo, Macedonia, Moldova, Montenegro and Serbia 13
Results of the preliminary survey With the participation of Albania, Armenia, Belarus, Federation of Bosnia and Herzegovina (incl. Republic Srpska), Croatia, Georgia, Kosovo, Macedonia, Moldova, Montenegro and Serbia 14
Results of the preliminary survey The National Bank of Bosnia and Herzegovina mentioned that they have short and long form audit report, AML audit report and IT audit report In Kosovo, there is a report on the compliance with the regulatory framework (which is different to IFRS) In Albania, auditors are required to review the local accounting standards (not IFRS) and prudential reporting system In Macedonia, external auditors are required to submit a long form report along with the audited financial statements of the banks. The long form report contains information regarding capital, impairment policy, description of the risk management process of the banks, compliance with regulations governing the supervisory function of the National Bank With the participation of Albania, Armenia, Belarus, Federation of Bosnia and Herzegovina (incl. Republic Srpska), Croatia, Georgia, Kosovo, Macedonia, Moldova, Montenegro and Serbia 15
Results of the preliminary survey 1. The supervisors intensively review audit opinion reports of annual financial statements and management letters 2. It is important with regards to the level of provisioning 3. Audit report and management letter are important 4. The audit opinion of the financial statements, the findings included in the management letter and the long form report submitted by the external auditor are taken into consideration when reviewing the overall risk profile of the bank Review of the whole extended report in Serbia 5. The external auditors findings will be only used as an orientation for examination 6. No With the participation of Albania, Armenia, Belarus, Federation of Bosnia and Herzegovina (incl. Republic Srpska), Croatia, Georgia, Kosovo, Macedonia, Moldova, Montenegro and Serbia 16
Results of the preliminary survey In order to follow up with external auditors, National Bank of Georgia (NBG) needs the consent from the commercial bank. NBG would actually ask both the bank and the auditor in a written form to arrange a follow-up discussion and would then sign a hold-harmless/confidentiality agreement With the participation of Albania, Armenia, Belarus, Federation of Bosnia and Herzegovina (incl. Republic Srpska), Croatia, Georgia, Kosovo, Macedonia, Moldova, Montenegro and Serbia 17