HM Medical Clinic

 

Letter

KPMG IFRG Limited
Tel +44 (0) 20 7694 8089 Fax +44 (0) 20 7694 8429 8 Salisbury Square DX 38050 Blackfriars London EC4Y 8BB [email protected] Technical Director International Auditing and Assurance International Federation of Accountants 545 Fifth Avenue, 14th Floor New York, New York 10017 Contact Sylvia Smith IAASB Exposure Draft, Proposed International Standard on Review Engagements: ISRE
2400 (Revised), Engagements to Review Historical Financial Statements
We are pleased to have the opportunity to comment on the International Auditing and Assurance Standards Board's ("IAASB" or "the Board") proposed International Standard ISRE 2400 (Revised), Engagements to Review Historical Financial Statements ("the ED" or "the proposed standard"). This letter represents the views of KPMG International and its member firms. We agree that the requirements and guidance in extant ISRE 2400 need to be strengthened. However, we are concerned that the approach taken to achieve this objective blurs the distinction between an audit and a review and may cause confusion to practitioners and users as to the scope and nature of a review engagement. The areas that have given rise to our concern are elaborated in our overarching comments. Overarching comments
1. Co-mingling of audit and review concepts
The ED introduces concepts and terminology used in the ISAs to describe the nature and extent of procedures to be performed in a review engagement on the basis that a review, like an audit, is an assurance engagement, except that in a review, the objective is to achieve limited assurance whereas in an audit, the objective is to achieve reasonable assurance. We recognize that this approach is consistent with that taken in the extant Framework, International Framework for Assurance Engagements, however, we are concerned that a co-mingling of audit and review concepts in a standard meant only for review engagements blurs the distinction between an audit and a review, making the extent of procedures a practitioner needs to perform in a review less clear. Registered in England No 5253019 KPMG IFRG Limited, a UK company limited by guarantee, is a member of Registered office: Tricor Suite, 7th Floor, 52-54 Gracechurch Street, KPMG International Cooperative, a Swiss entity. London, EC3V 0EH KPMG IFRG Limited
Proposed International Standard on Review Engagements: ISRE 2400 (Revised), Engagements to Review Historical Financial Statements 3 June 2011 Given that one of the stated aims of the Board is to improve consistency, we are concerned that the ED does not establish a clear benchmark for work effort and that it may lead to a significant lack of consistency in practice. We therefore believe it is important that the proposed standard explain the procedures that ordinarily would be performed in a review and how such procedures differ from those performed in an audit. The specific areas that have given rise to our concerns are: a. Emphasizing throughout the ED the need to "evaluate the sufficiency and appropriateness of evidence obtained" as the basis for concluding on the financial statements as a whole without clear guidance as to what constitutes sufficient and appropriate evidence for limited assurance on financial information; b. Requiring the identification of areas in the financial statements where material misstatements are likely to arise without being clear on how practitioners would design review procedures to reduce these risks to a level that is appropriate to provide limited assurance as compared to reasonable assurance; and c. Omitting guidance, at the procedural level, on the differences between a review engagement and an audit and not providing review procedures that typically would be conducted in a review engagement. 2. Additional procedures
There are two specific situations in the proposed standard that require additional procedures to be performed: • When the results from inquiry and analytical procedures performed do not adequately address areas in the financial statements where material misstatements are likely to arise (paragraph 48 of the ED); and • When the practitioner becomes aware of a matter(s) that causes the practitioner to believe that financial statements may be materially misstated (paragraph 57 of the ED). Our concern is not with the requirement to perform additional procedures, but with the apparent open-ended nature of the requirement in terms of the nature and extent of those additional procedures. The stated purpose of the additional procedures in paragraph 57 is to design and perform additional procedures sufficient to enable the practitioner to conclude whether or not the statements are materially misstated. In our view, this goes beyond what is necessary to provide limited assurance and is more consistent with what is necessary when providing reasonable assurance. KPMG IFRG Limited
Proposed International Standard on Review Engagements: ISRE 2400 (Revised), Engagements to Review Historical Financial Statements 3 June 2011 Paragraph 48 requires the practitioner to consider performing additional procedures when the results from inquiry and analytical procedures do not adequately address areas in the financial statements where material misstatements are likely to arise. The proposed standard does not explain what is meant by the results of procedures "not adequately" addressing areas in the financial statements where material misstatements are likely to arise. Therefore, it is not clear why this situation is not encompassed by paragraph 57, particularly since paragraphs 48 and 57 are both cross-referenced to the same application paragraphs suggesting that the practitioner's response to both situations would be similar. It would be helpful if the proposed standard could clarify this. We also believe it is important that the proposed standard provide guidance at engagement acceptance so that practitioners actually avoid placing themselves in the situation contemplated by paragraph 48. This could be achieved by expanding the discussion of the circumstances as to when it may not be appropriate to accept a review engagement in paragraph 29(c) to include the circumstance where the practitioner believes that procedures normally performed in a review may not be appropriate to address the areas where material misstatements are likely to arise. We would also suggest that paragraph A41 which supports paragraph 29(c) also be expanded to include an example of such circumstance. We discuss this recommendation further in our response to question 4 in the Appendix to this letter. 3. Inconsistency with ISRE 2410
We also would like to highlight the apparent inconsistency between the ED and extant ISRE 2410, Review of Interim Financial Information Performed by the Independent Auditor of the Entity. The ED is proposing to move the level of assurance for a review engagement from "moderate" to "limited" on the basis that moderate assurance as set out in extant ISRE 2400 may lack meaning for users. We recommend that IAASB revise ISRE 2410 in the same manner to avoid the confusion of having two kinds of review engagements in the market place. Our responses to specific questions posed by IAASB in the Explanatory Memorandum to the ED are set out in the Appendix. KPMG IFRG Limited
Proposed International Standard on Review Engagements: ISRE 2400 (Revised), Engagements to Review Historical Financial Statements 3 June 2011 Please contact Sylvia Smith at +44 (0)20 7694 8089 if you wish to discuss any of the issues raised in this letter. Yours faithfully KPMG IFRG Limited cc: Jean Blascos, KPMG KPMG IFRG Limited
Proposed International Standard on Review Engagements: ISRE 2400 (Revised), Engagements to Review Historical Financial Statements 3 June 2011 Appendix - Our responses to specific questions posed by IAASB
Our responses to the questions posed in the Exposure Draft are set out below: 1. Do respondents who are users or preparers of financial statements believe the proposed
ISRE will result in an assurance engagement that is meaningful?
In our capacity as practitioners who perform review engagements, we support the IAASB's objective to strengthen extant ISRE 2400. However, as discussed in our response to question 2 below, we are concerned that the approach taken to achieve this objective blurs the distinction between an audit and a review. In addition to making the extent of procedures a practitioner needs to perform in a review less clear, we also are concerned that blurring the distinction between an audit and a review may cause confusion as to the level of assurance that may be derived by users from a review report. We therefore believe it would be helpful for the proposed standard to describe how a review differs from an audit. 2. Do respondents who are practitioners believe that proposed ISRE 2400 will result in
engagements that can be understood and performed by practitioners in a cost-effective
manner in a way that clearly distinguishes the engagement from an audit?
We do not believe that proposed ISRE 2400 will result in engagements that can be clearly distinguished from an audit and performed by practitioners consistently and in a cost-effective manner. The ED introduces concepts and terminology used in the ISAs to describe the nature and extent of procedures to be performed in a review engagement on the basis that a review, like an audit, is an assurance engagement, except that in a review, the objective is to achieve limited assurance whereas in an audit, the objective is to achieve reasonable assurance. While we agree that this approach is appropriate for assurance engagements that deal with a wide range of subject matters, we do not believe that it is necessarily helpful when dealing with historical financial information. In our view, it only serves to blur the distinction between a review of historical financial information and an audit of such information, making the extent of procedures a practitioner needs to perform in a review much less clear. The areas that have given rise to our concerns are: a. Emphasizing throughout the ED the need to "evaluate the sufficiency and appropriateness of evidence obtained" as the basis for concluding on the financial statements as a whole without clear guidance as to what constitutes sufficient and appropriate evidence for limited assurance on financial information; b. Requiring the identification of areas in the financial statements where material misstatements are likely to arise without being clear on how practitioners would design review procedures to reduce these risks to a level that is appropriate to provide limited assurance as compared to reasonable assurance under an audit; and KPMG IFRG Limited
Proposed International Standard on Review Engagements: ISRE 2400 (Revised), Engagements to Review Historical Financial Statements 3 June 2011 c. Omitting guidance, at the procedural level, on the differences between a review engagement and an audit and not providing review procedures that typically would be conducted in a review engagement. The concept relating to "sufficient and appropriate evidence" permeates the whole ED. It is specifically stated as one of the practitioner's objectives in paragraph 14(a): to "conclude" and "evaluate the sufficiency and appropriateness of evidence obtained". The same idea is emphasized in the requirements. Paragraph 48, for example, states that the practitioner shall "evaluate the sufficiency and appropriateness of the evidence obtained from the inquiry and analytical procedures performed, and determine whether it is necessary to perform additional procedures". Paragraph 57 also requires the practitioner to perform additional procedures when the practitioner becomes aware of a matter(s) that causes the practitioner to believe that financial statements may be materially misstated. Our concern is not with the requirement to perform additional procedures, but with the apparent open-ended nature of the requirement in terms of the nature and extent of those additional procedures. The stated purpose of the additional procedures in paragraph 57, for example, is to design and perform sufficient procedures to enable the practitioner to conclude whether or not the statements are materially misstated. In our view, this goes beyond what is necessary to provide limited assurance and is more consistent with what is necessary when providing reasonable assurance. This also is not consistent with extant ISRE 2410.29, which links the extent of follow-up procedures to the nature of the conclusion expressed: "29. When a matter comes to the auditor's attention that leads the auditor to question
whether a material adjustment should be made for the interim financial information to
be prepared, in all material respects, in accordance with the applicable financial
reporting framework, the auditor should make additional inquiries or perform other
procedures to enable the auditor to express a conclusion in the review report. For
example, if the auditor's review procedures lead the auditor to question whether a
significant sales transaction is recorded in accordance with the applicable financial
reporting framework, the auditor performs additional procedures sufficient to resolve the
auditor's questions, such as discussing the terms of the transaction with senior marketing
and accounting personnel, or reading the sales contract."
With regard to the requirement in paragraph 57, we believe that it would be helpful to emphasize that in the first instance, the practitioner follow up on matters identified with management and those charged with governance before designing further procedures. In the case of an audit engagement, the approach to identifying risks of material misstatement and evaluating the sufficiency and appropriateness of audit evidence is well understood because the level of assurance is clearly articulated, the conclusion is expressed in a positive form and there are established procedures and practices backed by audit literature and specific standards to support the practitioner's assessment of what would be considered sufficient and appropriate audit evidence. This may be less well understood for review engagements, especially in jurisdictions that have historically performed statutory audits and may be now moving to review engagements. We therefore believe it would be helpful to emphasize in the proposed standard KPMG IFRG Limited
Proposed International Standard on Review Engagements: ISRE 2400 (Revised), Engagements to Review Historical Financial Statements 3 June 2011 the procedures that ordinarily would be performed in a review and how such procedures differ from those performed in an audit. Otherwise, we are concerned that the blurring of review and audit may lead to inconsistent work effort, with some practitioners doing too much work. This obviously will affect the cost effectiveness of review engagements. However, there also is a risk that the lack of clarity with respect to work effort will result in having some practitioners not doing enough work. This will obviously have an effect on the quality of review engagements. To help address this issue, we recommend that IAASB consider including wording/guidance that currently is included in extant ISRE 2400.20 and 2410.21, about the procedures that "ordinarily" are performed in a review and that if Appendix 2 in extant ISRE 2400 were updated and included in the proposed standard. Also, it would be helpful if the proposed standard included a statement similar to the following included in extant ISRE 2410.20: "20. A review ordinarily does not require tests of the accounting records through inspection, observation or confirmation. Procedures for performing a review of interim financial information are ordinarily limited to making inquiries, primarily of persons responsible for financial and accounting matters, and applying analytical and other review procedures, rather than corroborating information obtained concerning significant accounting matters relating to the interim financial information. The auditor's understanding of the entity and its environment, including its internal control, the results of the risk assessments relating to the preceding audit and the auditor's consideration of materiality as it relates to the interim financial information, affects the nature and extent of the inquiries made, and analytical and other review procedures applied." 3. Do respondents believe that the objectives stated in the proposed ISRE appropriately
describe the expected outcome of the practitioner's work in a review engagement and the
means by which the objectives are to be achieved? Is there any wording in the objectives
that might have unintended consequences, or that may blur understanding of the
difference between a review and an audit?
We do not believe that the objective appropriately describe the means by which the practitioner is to achieve the outcome of the review. We are of the view that there is an inconsistency between the basis of conclusion part of the objective, i.e. "evaluating the sufficiency and appropriateness of evidence obtained", and the actual conclusion in the report. The objective refers to an active (i.e., positive) evaluation of the sufficiency and appropriates of evidence obtained yet the actual conclusion is expressed negatively as "nothing has come to the practitioner's attention that causes the practitioner to believe the financial statements are not prepared, in all material respects, in accordance with…". 4. Do respondents believe that the factors affecting engagement acceptance and
continuance, and the preconditions for performing a review under the proposed ISRE,
are appropriate and clearly communicated in the proposed ISRE?
We believe that the guidance regarding preconditions for performing a review under the proposed standard is appropriate and clear except for paragraph 29(c), which appears to have a narrow focus on accounting systems and information with reference to the meaning of KPMG IFRG Limited
Proposed International Standard on Review Engagements: ISRE 2400 (Revised), Engagements to Review Historical Financial Statements 3 June 2011 "engagement circumstances". This is narrower than the application guidance in A41 which refers to the practitioner's preliminary understanding of the engagement circumstances indicating when a review engagement is not appropriate. We believe that reference to engagement circumstances is more suitable for the requirement since it would enable consideration of additional circumstances that may lead one to conclude that a review is not appropriate. For example, as we noted in our overarching comments, it would be helpful if the proposed standard could clarify that it is not appropriate for a practitioner to agree to perform a review engagement when he/she determines that procedures normally performed in a review engagement may not be appropriate to address the areas where material misstatements are likely to arise. An example of such a circumstance may be when an entity's business includes significant treasury operations involving complex derivatives. We therefore recommend that 29(c) be expanded to refer to the practitioner's understanding of the engagement circumstances indicating that a review engagement is not appropriate and that A41 be amended to include examples of such engagement circumstances. 5. The approach to performing a review set out in the proposed ISRE (paragraphs 43 and
44) requires the practitioner to identify areas in the financial statements where material
misstatements are likely to arise, based on the practitioner's understanding of the entity
and its environment, and the applicable financial reporting framework, and then to focus
the design and performance of inquiry and analytical procedures in those areas.
a) Do respondents believe this approach is appropriate for a review?
With regard to the approach to the review engagement, the relevant paragraphs in the ED are drafted in a manner that does not include the words "risk assessment". However, the practitioner is required to obtain sufficient understanding of the entity and its environment and the applicable financial reporting framework, including its application in the industry in which the entity operates, to enable him or her to identify areas in the financial statements where material misstatements are likely to arise and to be able to design procedures to address those areas. It is unclear how the practitioner would be able to identify such areas if he or she does not perform a risk assessment. It would be helpful if the ED clarified this by providing some additional guidance in this area. b) Do respondents believe that the requirement and guidance in the proposed ISRE
adequately convey this intended approach?
Generally, as mentioned in our response to part (a) above, we believe that the proposed standard needs to provide more guidance on the scope, nature and extent of review procedures. We believe that the introduction of audit concepts and terminology into the standard will drive audit-like behaviour. Without detailed guidance on what procedures would ordinarily be considered sufficient and appropriate evidence, or examples of procedures that would ordinarily be performed, the practitioners performing the review and the users of reviewed financial statements may not necessarily have a common understanding of what constitutes "sufficient and appropriate evidence" for a review of historical financial information. KPMG IFRG Limited
Proposed International Standard on Review Engagements: ISRE 2400 (Revised), Engagements to Review Historical Financial Statements 3 June 2011 c) Do respondents believe that the requirements and guidance relating to the
practitioner's understanding (explained in paragraph 44), are sufficient to promote
performance of reviews on a reasonably consistent basis with the application of the
practitioner's professional judgment and understanding, taking account of the
circumstances in individual review engagements?
We are not confident that the requirements and guidance relating to the practitioner's understanding are sufficient to promote performance of reviews on a reasonably consistent basis. Paragraph 43 requires the practitioner to obtain an understanding of the entity sufficient to identify areas in the financial statements where material misstatements are likely to arise. Paragraph 44 then requires the practitioner to perform procedures to address those areas in the financial statements where material misstatements are likely to arise. However, the application guidance in paragraph A83 that supports paragraph 44 appears to suggest that the procedures performed to address areas where material misstatements will arise are the same procedures that will help identify these areas. This appears to be circular. It would be helpful if the proposed standard was able to make a distinction between the procedures performed to identify the areas where misstatements will arise and the procedures performed to respond to such areas. 6. Do respondents agree with the requirements and guidance in the proposed ISRE
(paragraphs 57 and 58) describing the trigger point at which additional procedures are
required? Do respondents agree with the related requirements concerning the
practitioner's response when there are matters that cause the practitioner to believe the
financial statements may be materially misstated?
We support the key principle that as a matter of public interest in undertaking a review whenever matters come to the practitioner's attention that cause the practitioner to believe the financial statements may be materially misstated the practitioner must pursue those matters. However, as noted above in our response to question 2, we disagree with the stated purpose of the additional procedures in paragraph 57, i.e., to design and perform sufficient procedures to enable the practitioner to conclude whether or not the statements are materially misstated. In our view, this goes beyond what is necessary to provide limited assurance and is more consistent with what is necessary when providing reasonable assurance. Lastly, it also is important for the standard to acknowledge that in rare circumstances the practitioner may not be able to conclude after performing additional procedures. We therefore believe it would be useful for the requirement in paragraph 57 to acknowledge this and provide a link to paragraph 69 that deals with scope limitations. 7. With respect to the practitioner's review report (as illustrated in Appendix 2 of the
proposed ISRE):
a) Do respondents believe the report adequately communicates to users the work
undertaken by the practitioner for the review?
KPMG IFRG Limited
Proposed International Standard on Review Engagements: ISRE 2400 (Revised), Engagements to Review Historical Financial Statements 3 June 2011 We do not believe the wording in the practitioner's responsibility section of the report is clear with reference to the following three parts: • "A review of financial statements in accordance with ISRE 2400 consists … and evaluating the sufficiency and appropriateness of evidence obtained"; • "We believe that the evidence we have obtained in our review is sufficient and appropriate to provide a basis for our conclusion."; and • "A review also requires performance of additional procedures when the practitioner becomes aware of matters that cause the practitioner to believe the financial statements as a whole may be materially misstated". As mentioned above, we do not believe that the reference to "evaluating sufficiency and appropriateness of evidence obtained" is clear in the context of a report that is worded as to whether anything has come to the attention of the practitioner. With regard to the performance of additional procedures to address any issues identified, our concern is the apparent open-ended nature of the requirements from a practical standpoint in terms of the extent of work to be performed by the practitioner. The risk is that users may place a higher level of reliance on the limited assurance that a review engagement provides than that which is intended by the proposed standard. b) Do respondents believe that the form of the practitioner's conclusion (that is,
"nothing has come to the practitioner's attention that causes the practitioner to
believe . . ") communicates adequately the assurance obtained by the practitioner?
Is this form of wording of the practitioner's conclusion preferable to other forms
that have been explored by the IAASB as discussed above, including those that use
wording perceived as being more positive? If not, please explain and provide
alternative wording that could be used to express the practitioner's conclusion.
We agree with the form of the practitioner's conclusion proposed in the ED on the basis that this form of conclusion helps in differentiating the conclusion reported in a review from the opinion expressed in an audit. However, we are of the view that there is an inconsistency between the basis of conclusion part of the objective, which suggests that the practitioner is able to actively evaluate the sufficiency and appropriateness of evidence, and the actual conclusion in the report, i.e. "nothing has come to the practitioner's attention that causes the practitioner to believe the financial statements are not prepared, in all material respects, in accordance with .". c) Is the practitioner's conclusion expressed in this form likely to be understandable
and meaningful to users of the financial statements? Does this form of conclusion
achieve the intended purpose of properly differentiating the conclusion reported in a
review from the opinion expressed in an audit of financial statements?
We believe that practitioners and users understand a report stating that "nothing has come to the practitioner's attention that causes the practitioner to believe the financial statements are not prepared, in all material respects, in accordance with ." in the KPMG IFRG Limited
Proposed International Standard on Review Engagements: ISRE 2400 (Revised), Engagements to Review Historical Financial Statements 3 June 2011 context of the procedures that have been performed to arrive at the conclusion. If the nature of those procedures is unclear to practitioners and users, the conclusion expressed in this form could be misinterpreted. The factors that we mentioned in our response to question 7(a) are relevant considerations. We would also add that whilst the form of the conclusion helps in differentiating the conclusion reported in a review from the opinion expressed in an audit, we do not believe that the form of the conclusion alone makes up for the potential for blurring the distinction between the review engagement and the audit engagement if the issues identified elsewhere in our letter are not resolved.

Source: https://www.ifac.org/system/files/publications/exposure-drafts/comments/5079-comment-letter-isre-2400.pdf