Section 1 Report Overview Section 2 Meeting Updates and Operation Matters Section 3 Significant Project Status/Updates
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IAESB Consultative Advisory Group Agenda Item 6-6 February 2008 – San Diego DATE: SEPTEMBER 4, 2007 TO: COUNCIL FROM: BOB MEDNICK CHAIR, COMPLIANCE ADVISORY PANEL RUSSELL GUTHRIE DIRECTOR, QUALITY ASSURANCE AND MEMBER BODY RELATIONS SUBJECT: REPORT FROM THE COMPLIANCE ADVISORY PANEL __________________________________________________________________________________ Section 1 Report Overview 1.1 This annual report outlines the activities of the IFAC Compliance Advisory Panel (CAP) and Compliance staff over the period of November 2006 and October 2007. Section 2 Meeting Updates and Operation Matters 2.1 During 2007, the CAP has met 3 times with a final meeting planned for late September: • January 2007 in Hanoi, Vietnam; • April 2007 in Bucharest, Romania; • July 2007 in Vancouver, Canada; • September 2007 in Buenos, Argentina. The CAP also held a conference call in August 2007. 2.2 In July 2007, IFAC welcomed Mr. Thomas Zimmermann, a new staff member focusing on the Compliance Program and membership activities and assisting with Developing Nations Committee projects. Section 3 Significant Project Status/Updates Reporting to PIOB 3.1 The CAP, as a Public Interest Activity Committee, is subject to oversight by the Public Interest Oversight Board (PIOB) and has regularly reported to it on the progress of the Compliance Program, proposed amendments to the Statements of Membership Obligations (SMOs), the IFAC membership application process, and the status of specific membership applications and expressions of interest. 3.2 During the past 12 months, the CAP Chair and Director, Quality Assurance and Member Body Relations (Director, QA-MBR) have met twice with the PIOB during its meetings in Washington, D.C. and Amsterdam. The CAP also submits the minutes of its meetings to the PIOB as part of its ongoing reporting to the Board and has had a PIOB representative in attendance at its last 3 meetings. November 2007 IAESB Consultative Advisory Group Agenda Item 6-6 February 2008 – San Diego Part 2, SMO Self-Assessment Questionnaire 3.3 The staff began its Part 2 review process in June 2006 and, as of the date of this report, 148 members’ and associates’ responses have been published on IFAC’s website. 2 more responses are with members for their final review and agreement to publish. Unfortunately 2 members suspended in June 2007 for their failure to finalize their Part 2 response still have not agreed their Part 2 (see Suspensions and Possible Expulsions of Members below). The Iraqi member has been excused from participation in the Program. Part 3, Action Plans 3.4 The primary emphasis of the Compliance Program is on continuous improvement by members and associates in the convergence to and implementation of the international standards and practices covered in the seven SMOs. This emphasis will be particularly significant in Part 3 of the Program where the focus will be on areas requiring improvement based on matters identified through Part 2 self-assessments. More specifically, unlike Part 1 and Part 2 where the Program focused on collecting information about existing frameworks, activities and programs, Part 3 will require members and associates to initiate the preparation of detailed Action Plans describing how they plan to address and implement required actions to come into full compliance with the SMOs over time. Process 3.5 Part 3 will comprise 3 phases: (1) Compliance staff development of Policy Recommendations proposing areas requiring action based on matters identified through the Part 2 self-assessments, (2) members’ and associates’ development of detailed Action Plans based on the Policy Recommendations, and (3) periodic reporting of progress to ensure required actions are being addressed. For Part 3 to be most effective, there’s a need for: • An iterative approach both within the organization and with Compliance staff, marked by a continuous and open exchange of information, so that the matters to be addressed and proposed solutions are fully agreed by all key players. • Members and associates to take full ownership and responsibility for their Action Plans by making sure all relevant governance bodies, management, technical staff, and key volunteers are involved in the development process. • A continued focus on transparency by publishing agreed Action Plans on the IFAC website as well as information about the progress being made as required actions are implemented. 3.6 The CAP’s review of this process has included a detailed review of the first 16 draft Policy Recommendations, focusing on their tone, level of detail and consistency from member to member, as well as the results of the staff’s field test of 3 Policy Recommendations. In addition, any additional Policy Recommendations that are particularly complex or entail sensitive matters will be submitted to the CAP for its consideration before being issued to the member or associate. November 2007 IAESB Consultative Advisory Group Agenda Item 6-6 February 2008 – San Diego Implementation and Communication About Part 3 3.7 Part 3 was implemented in April 2007 after the CAP approved the process to be used by the staff in the preparation and issuance of Policy Recommendations. Policy Recommendations are the means to reach agreement between members / associates and Compliance staff on what needs to be done and will lead to the development of more detailed Action Plans, including timelines and accountabilities, by members and associates. To date, the Compliance staff has issued 24 Policy Recommendations (see below). 3.8 Unlike the Part 1 and Part 2 process, the staff is not taking a strict “first in, first out” approach to selecting the member bodies and associates for review. Because responsibility for IFAC members and associates has been allocated among the 4 key staff responsible for preparing Policy Recommendations, priority countries can be more easily identified on a more regular basis. In addition, the staff is attempting to cover a cross section of the membership (e.g., by region, stage of economic development, stage of the member’s or associate’s development as a professional organization, etc.) as it performs its reviews. Priorities may also be adjusted to take advantage of other developments in progress (e.g., a World Bank ROSC or an application for membership by an associate). 3.9 The implementation process has included regular communication about Part 3 in IFAC newsletters, reports to the Board, and outreach activities initiated by the Member Relations staff. A detailed explanatory memorandum about the Part 3 process available in English, Spanish, French and Russian, has also been provided to members and associates when they receive their Policy Recommendations. A copy of this memorandum is included in an Appendix to this Report. 3.10 Policy Recommendations issued to date: COUNTRY MEMBER / ASSOCIATE Federación Argentina de Consejos Profesionales de 1 ARGENTINA Ciencias Económicas 2 BOTSWANA Botswana Institute of Accountants 3 BULGARIA Institute of Certified Public Accountants in Bulgaria The Chinese Institute of Certified Public Accountants 4 CHINA (CICPA) CZECH 5 REPUBLIC Chamber of Auditors of the Czech Republic 6 EGYPT The Egyptian Society of Accountants & Auditors 7 ESTONIA Estonian Auditing Board 8 FIJI Fiji Institute of Accountants 9 HAITI Ordre des Comptables Professionels Agrees d'Haiti November 2007 IAESB Consultative Advisory Group Agenda Item 6-6 February 2008 – San Diego COUNTRY MEMBER / ASSOCIATE 10 INDONESIA Indonesian Institute of Accountants 11 ISRAEL Institute of Certified Public Accountants in Israel Ordre des Experts Comptables et Comptables Agréés de 12 IVORY COAST Côte d'Ivoire 13 JAMAICA The Institute of Chartered Accountants of Jamaica 14 LESOTHO Lesotho Institute of Accountants Ordre des Experts Comptables et Financiers de 15 MADAGASCAR Madagascar 16 MOROCCO OEC Morocco (Certified Public Accountants Association) 17 NEPAL The Institute of Chartered Accountants of Nepal 18 NICARAGUA Colegio de Contadores Públicos de Nicaragua 19 PANAMA Colegio de Contadores Públicos Autorizados de Panamá 20 ROMANIA The Chamber of Financial Auditors 21 RUSSIA The Institute of Professional Accountants of Russia SAUDI 22 ARABIA Saudi Organization for Certified Public Accountants 23 TUNISIA Ordre des Experts Comptables de Tunisie 24 ZIMBABWE The Institute of Chartered Accountants of Zimbabwe 3.11 Members and associates are given 3 months to review, clarify and agree the proposed Policy Recommendations with Compliance staff. To date, preliminary responses have been received from Botswana, Egypt, Estonia, Nepal, Panama and Romania. The Part 3 process emphasizes the importance of continuous two-way communication; that is, requesting members and associates to maintain open communication with Compliance staff as Compliance staff is reaching out to them. Nevertheless, as the 3-month response date approaches for the issued Policy Recommendations, staff anticipates it will still be necessary to follow up with some non-responsive members and associates. Recommendations for New IFAC Associates and an IFAC Affiliate 3.12 Based on the CAP’s recommendation, the Board is recommending that Council approve 3 organizations as new associates and 1 organization as an affiliate. The detailed assessments for the following organizations are included in the Council papers: November 2007 IAESB Consultative Advisory Group Agenda Item 6-6 February 2008 – San Diego Associate Recommendations • Cayman Islands Society of Professional Accountants (CISPA); • Mauritius Institute of Professional