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TECHNICAL RELEASE Interim Guidance
TECHNICAL RELEASE Interim Guidance GUIDANCE FOR AUDITING FINANCIAL STATEMENT DISCLOSURES MADE UNDER IFRS 7 (FRS 29), FINANCIAL INSTRUMENTS: DISCLOSURES FSF 03/07 GUIDANCE FOR AUDITING FINANCIAL STATEMENT DISCLOSURES MADE UNDER IFRS 7 (FRS 29), FINANCIAL INSTRUMENTS: DISCLOSURES Status of Guidance FSF 3/07 is issued as interim guidance to assist auditors of entities applying IFRS 7 for the first time. The Institute of Chartered Accountants in England and Wales (ICAEW) is not responsible for setting Financial Reporting Standards, which are set in the UK by the Accounting Standards Board (ASB), or for the International Financial Reporting Standards set by the International Accounting Standards Board (IASB). Nor is it responsible for International Standards on Auditing (ISAs) which are set by the International Auditing and Assurance Standards Board (IAASB) or for ISAs (UK and Ireland), which are set by the Auditing Practices Board (APB). Our role includes providing guidance to our members where we consider such guidance is necessary and is not provided elsewhere, in order to enhance the consistency and quality of auditing. The content of this Technical Release has no formal or mandatory status beyond that of guidance to our members. Final guidance will only be issued if further issues arise or significant comments are received in respect of this interim guidance. Invitation to comment Comments on the interim guidance are welcome and should be provided to Iain Coke at the address below by 1 February 2008. [email protected] Iain Coke, Head of the Financial Services Faculty Chartered Accountants’ Hall PO Box 433 Moorgate Place London EC2P 2BJ No responsibility for loss occasioned to any person acting or refraining from action as a result of any material in this Technical Release can be accepted by the ICAEW. © The Institute of Chartered Accountants in England and Wales, 2007 TECHNICAL RELEASE FSF 03/07: Guidance for Auditing Financial Statement Disclosures made under IFRS 7 (FRS 29), Financial Instruments: Disclosures Page 1 Contents Paragraph Numbers Introduction 1 Background 2–4 Summary of the changes introduced by IFRS 7 5–6 Auditing issues Assessing the risk of material misstatement The auditor’s procedures in response to assessed risks 7 8–12 13–15 The relationship between information reported internally and externally 16 Matters specific to group audits 17 Qualitative disclosures relating to the risk management process 18–20 Assessing the quality of disclosures overall 21–23 Appendix Page 2 TECHNICAL RELEASE FSF 03/07: Guidance for Auditing Financial Statement Disclosures made under IFRS 7 (FRS 29), Financial Instruments: Disclosures INTRODUCTION 1 The purpose of this Technical Release is to provide guidance to auditors on the audit of disclosures made in financial statements under International Financial Reporting Standard (IFRS) 7, Financial Instruments: Disclosures. BACKGROUND 2 The IASB issued IFRS 7 in 2005, to promote the quality and consistency of disclosures in financial statements relating to financial instruments. IFRS 7 supersedes International Accounting Standard (IAS) 30, Disclosures in the Financial Statements of Banks and Similar Financial Institutions and the disclosure requirements in IAS 32, Financial Instruments: Presentation and Disclosure. 3 IFRS 7 (‘the Standard’) is effective for periods commencing on or after 1 January 2007, with earlier application encouraged. The Standard subsequently adopted by the European Union is identical to that issued by the IASB and has the same effective date. 4 The Standard is also being implemented by the ASB for UK GAAP preparers as Financial Reporting Standard (FRS) 29, which has the same effective date as its international equivalent. FRS 29 differs in a few significant particulars from IFRS 7 but the following guidance for auditing IFRS 7 applies to FRS 29 except where indicated. Paragraph references are to IFRS 7. SUMMARY OF THE CHANGES INTRODUCED BY IFRS 7 5 IFRS 7 requires more extensive disclosures about an entity’s exposure to risk and how those risks are managed than IAS 32, and specifies that both qualitative and quantitative disclosures should be given. Qualitative disclosures include an explanation, for each type of risk arising from financial instruments, of an entity’s ‘objectives, policies and processes for managing the risk and the methods used to measure the risk’ (paragraph 33). The quantitative disclosures are to be based on the information provided internally to key management personnel (paragraph 34). The Standard includes a requirement for a sensitivity analysis either for each type of market risk (paragraph 40), or one that reflects interdependencies between risk variables, such as value at risk (VAR) (paragraph 41). 6 Unlike the superseded IAS 30, IFRS 7 applies to financial instruments held by all types of entity and not specifically to those held by financial institutions. AUDITING ISSUES 7 This Technical Release considers the following auditing issues: • assessing the risk of material misstatement; • the auditor’s procedures in response to assessed risks; • the relationship between information reported internally and externally; • matters specific to group audits; • qualitative disclosures relating to the risk management process; and • assessing the quality of the disclosures overall. TECHNICAL RELEASE FSF 03/07: Guidance for Auditing Financial Statement Disclosures made under IFRS 7 (FRS 29), Financial Instruments: Disclosures Page 3 ASSESSING THE RISK OF MATERIAL MISSTATEMENT 8 Significant risks are likely to arise in those areas that are subject to significant judgement by management or are complex and properly understood by comparatively few people within the audited entity. The application of IFRS 7 is one such area and may give rise to significant audit risk in respect of the adequacy of financial statement disclosures. ISA (UK and Ireland) 315, Understanding the Entity and its Environment and Assessing the Risks of Material Misstatement, requires that ‘The auditor should obtain an understanding of the entity and its environment, including its internal control, sufficient to identify and assess the risks of material misstatement of the financial statements whether due to fraud or error, and sufficient to design and perform further auditor procedures.’ (ISA (UK and Ireland) 315, paragraph 2) 9 In assessing the risk of material misstatement associated with an entity’s IFRS 7 disclosures, specific considerations for the auditor may include the following: • The entity’s use of financial instruments and its exposure to risk (IN4) • The significance of financial instruments for an entity’s financial position and performance (IN5(a)) • If an entity is close to full utilisation of its internal risk limits, or a Financial Services Authority-regulated entity has little headroom between its actual capital and that required by the regulator, the auditor considers the extent to which the IFRS 7 disclosures may affect economic decisions more than would otherwise be the case, and the adequacy of disclosures explaining the entity’s circumstances. IAS 1, Presentation of Financial Statements, has been amended for periods commencing on or after 1 January 2007 to require additional disclosures in relation to capital (IAS 1, paragraphs 124A-124C). 10 One source of risk under IFRS 7 is the disclosure of the quantification of exposure to risks arising from financial instruments. Guidance in PN 19, developed for auditors considering the valuation techniques used by banks and building societies, provides suggestions for reviewing controls and substantive testing. Whilst this was not written to support the audit of the IFRS 7 disclosures or the audit of entities other than banks and building societies, it may nevertheless be useful to auditors planning their approach to IFRS 7 quantitative disclosures and has been reproduced in the Appendix to this Technical Release. 11 The introduction of the new external disclosures required under IFRS 7 may prompt some preparers to review and supplement their internal processes and controls for managing and reporting risk, in order to conform with emerging industry standards. The auditor considers the implications, if any, of such changes in processes and controls to their assessment of the risk of material misstatement and understanding of the entity’s internal controls (see ISA (UK and Ireland) 315). 12 Subject to the complexity and specialist nature of the risks generated by the financial instruments held by the entity, the extent of the risks and indeed the inherent difficulty in assessing the risks associated with complex financial instruments, auditors should consider whether they need to consult with experts or use work performed by an expert to support their audit. Auditors who are not experienced in auditing financial instruments disclosures may have a particular requirement for expert input. ISA (UK and Ireland) 620, Using the Work of an Expert, provides further guidance. Page 4 TECHNICAL RELEASE FSF 03/07: Guidance for Auditing Financial Statement Disclosures made under IFRS 7 (FRS 29), Financial Instruments: Disclosures THE AUDITOR’S PROCEDURES IN RESPONSE TO ASSESSED RISKS 13 ISA (UK and Ireland) 330, The Auditor’s Procedures in Response to Assessed Risks, provides guidance on audit procedures which test controls and substantive testing and obtaining audit evidence. Suggestions for procedures when auditing market risk information supplied under IFRS 7 by banks and building societies is provided by the APB in PN 19. This is reproduced in the Appendix, but will need to be adapted for entities which are not deposit takers. 14 Preparers which are not financial services institutions may be unfamiliar with disclosing the market risk sensitivity analyses or VAR amounts required by IFRS 7. Entities making these disclosures for the first time may not have established appropriate controls and audit risk in this area for such entities may be higher than for those experienced in providing such disclosures. ISA (UK and Ireland) 545, Auditing Fair Value Measurements and Disclosures, provides guidance on assessing controls over fair value measurements and disclosures. Where the control framework is underdeveloped, the auditor considers the impact of this on their audit approach to IFRS 7 disclosures as well as any wider implications for their audit. 15 Auditors consider whether, in the preparation of sensitivity analysis, all reasonably possible changes have been included. For example, these may be changes in interest rates, foreign exchange rates or price movements, depending on the financial instruments in question. Application guidance to IFRS 7 explains that changes which are remote or ‘worst case’ scenarios should not be considered reasonably possible changes (B19), and gives further direction on how entities might approach sensitivity analyses (B17-21). Auditors also assess whether the market risk disclosures describe the impact of changes in interest rates on both fixed and floating rate assets and liabilities. THE RELATIONSHIP BETWEEN INFORMATION REPORTED INTERNALLY AND EXTERNALLY 16 IFRS 7 requires summary quantitative data about exposure to risk to be ‘based on’ the information reported internally (paragraph 34). Accordingly, auditors consider whether the information disclosed in the financial statements for the purposes of the Standard is based on that used internally, rather than whether it is identical. Differences between the information used internally and reported externally may arise where a simplified version of a measure is used for external purposes, for example, banks may report a simplified VAR. Where such differences exist it will be useful if the client has prepared a reconciliation which the auditor can review. Differences between information used internally and reported externally may also arise where the risks associated with financial instruments are not managed on a similar basis across a company or group, but to avoid generating an unhelpful level of detail in the financial statements, the information is summarised for external reporting. MATTERS SPECIFIC TO GROUP AUDITS 17 IFRS 7 disclosures are required in the financial statements prepared by the parent company for the group, its entity-only statements and in each subsidiary’s individual financial statements, as there is no specific exemption for subsidiaries in IFRS 7. Note that FRS 29 differs from IFRS 7 in this respect as it gives exemptions to subsidiaries where 90% of voting rights are held within the group and the entity-only accounts of parents. Where disclosures are being made by different entities within the group, the auditor considers whether the IFRS 7 disclosures are being made to the appropriate level of materiality and are clearly described. Where internal management reporting lines do not coincide with the legal entities preparing financial statements, for example TECHNICAL RELEASE FSF 03/07: Guidance for Auditing Financial Statement Disclosures made under IFRS 7 (FRS 29), Financial Instruments: Disclosures Page 5 because the group’s activities and risks are managed by type of operation, the auditor considers whether the risk disclosures in the entity-only financial statements are appropriate and complete. QUALITATIVE DISCLOSURES RELATING TO THE RISK MANAGEMENT PROCESS 18 IFRS 7 specifies that for each type of risk arising from financial instruments, an entity shall disclose ‘its objectives, policies and processes for managing the risk and the methods used to measure the risk’ (paragraph 33). Auditors review the disclosures included in the financial statements to ensure they are factual descriptions of the objectives, policies and processes used. More subjective commentary on risks should form part of other narrative documents within the annual report, rather than being part of the audited financial statements. In connection with the financial statement disclosures, the auditor seeks evidence of approval of the disclosures by the directors and those charged with governance. If sufficient evidence is not available the auditor considers whether written representations in respect of disclosures are required. 19 IFRS 7 application guidance specifies that information about the nature and extent of risks arising from financial instruments can be included in the financial statements by way of cross-reference to other documents within the annual report, such as a management commentary or risk report (paragraph B6). To avoid extending the scope of the audit unintentionally, auditors consider whether any such cross-reference is sufficiently specific and does not extend to other information in the management review. 20 A particular instance where additional information could inappropriately be scoped into, or IFRS 7 information left out of, the financial statements arises in relation to directors’ reports. The Companies Act 1985 specifies that a company’s directors’ report should indicate the financial risk management objectives and policies of the company in relation to financial instruments, along with an indication of exposure to price risk, credit risk, liquidity risk and cash flow risks (Companies Act 1985, Schedule 7, 5A).1 Some companies may seek to combine the disclosures required by IFRS 7 with those required by law to be included in the directors’ report, in which case the preceding guidance on a specific cross-reference will be relevant. ASSESSING THE QUALITY OF DISCLOSURES OVERALL 21 The auditor considers whether the IFRS 7 disclosures, taken together, report the entity’s management of risks arising from financial instruments clearly and comprehensively. This is more likely to be the case where the disclosures explain how risks arising from financial instruments relate to other aspects of the business, for example where an instrument is used to hedge the price of raw materials. 22 Risk systems will vary as to whether they report gross risk positions or the net position after offsetting equal and opposite positions. IFRS 7 does not specify whether the gross or net amount should be shown for many of the quantitative disclosures it requires. Subject to the specific risks associated with an entity’s financial instruments, the presentation of either net or gross information may be more relevant. In some cases, it may be useful to disclose both. For example, where there is a significant risk which has been fully hedged, gross disclosures showing both the position giving rise to the risk and the hedge being used to manage this risk are likely to better reflect the scale of activity in financial instruments than would a net disclosure. Accordingly, auditors 1 The draft regulations which set out the detailed accounting rules under the Companies Act 2006 retain this requirement; Draft Statutory Instrument, ‘The Large and Medium-sized Companies and Groups (Accounts and Reports) Regulations’ 2008. Page 6 TECHNICAL RELEASE FSF 03/07: Guidance for Auditing Financial Statement Disclosures made under IFRS 7 (FRS 29), Financial Instruments: Disclosures may wish to consider whether the provision of net or gross information significantly affects the usefulness of the disclosures. 23 The auditor assesses whether the classification of financial instruments for financial reporting purposes is appropriate to the nature of the information disclosed and takes into account the characteristics of those financial instruments. The auditor also considers whether sufficient information has been provided to permit reconciliation from the IFRS 7 disclosures to the line items in the balance sheet, where this is relevant (IFRS 7, paragraph 6). TECHNICAL RELEASE FSF 03/07: Guidance for Auditing Financial Statement Disclosures made under IFRS 7 (FRS 29), Financial Instruments: Disclosures Page 7 APPENDIX Extracts from Practice Note 19, The Audit of Banks and Building Societies in the United Kingdom, are reproduced below. The PN was written specifically for the audit of banks and building societies (‘deposit takers’). However, the extracts below are also relevant to the audit of businesses which are not deposit takers, but which have significant financial instrument activity. Clearly, the application of the guidance will need to be assessed in the context of the specific audit. References in the PN to the ‘deposit taker’ should be interpreted as referring to the audited entity. In addition, existing guidance in PN 23, Auditing Derivative Financial Instruments, may be useful to the audit of IFRS 7 information, including its suggestions for audit procedures in relation to valuation and measurement (paragraphs 82-87). Those using this PN should, however, be aware that parts of it are now out of date. EXTRACTS FROM PRACTICE NOTE 19 ISA (UK and Ireland) 330, The Auditor’s Procedures in Response to Assessed Risks Disclosure of market risk information under IFRS 7 and FRS 29 113 IFRS 7/FRS 29 Financial instruments: Disclosures may give rise to particular issues for the auditor, particularly in relation to market risk sensitivity analysis. Understanding the risk measurement method adopted by the management 114 A deposit taker applying IFRS 7/FRS 29, where appropriate, discloses a sensitivity analysis for each type of market risk to which the entity is exposed. Where a deposit taker uses sensitivity analysis, such as value at risk (‘VAR’) that reflects interdependencies between risk variables and this is the method used to manage the financial risks of the business, disclosures based on these measures may be used instead of the standard method prescribed by IFRS 7/FRS 29 paragraph 40. 115 The auditor obtains an understanding of the method adopted by the management to develop the market price risk information to be disclosed. This may be done in conjunction with obtaining an understanding of the deposit taker’s accounting and internal control systems. For example, the auditor considers the independence of the deposit taker’s risk management function from the front office in the context of their understanding of the control environment. Considering the skills needed by the audit team 116 The audit team is assembled on the basis of the skills needed. The auditor’s approach to the market price risk disclosures is normally based on reviewing and testing the process used by the management to develop the information to be disclosed, rather than on re-performing the calculations (or making or obtaining an independent assessment). However, obtaining an understanding of that process and assumptions used may require technical knowledge of risk measurement methodologies; these can be complex, especially where a VAR model is adopted. Accordingly, when planning the audit, the auditor considers the skills needed in order to obtain and evaluate audit evidence in this part of the engagement. Page 8 TECHNICAL RELEASE FSF 03/07: Guidance for Auditing Financial Statement Disclosures made under IFRS 7 (FRS 29), Financial Instruments: Disclosures 117 The nature and extent of any technical knowledge of risk measurement methodologies that are required depends on the circumstances. The auditor takes into account such factors as the complexity of the model used and whether the model has received regulatory recognition. Where appropriate, the auditor may involve an expert in elements of this work (see ISA (UK and Ireland) 620 section). Considering the application of the risk measurement method 118 The auditor considers whether the risk measurement method adopted has been applied reasonably by, for example: • reviewing, and where necessary testing, the internal controls relating to the operation of the deposit taker’s risk management system, in order to obtain evidence that the data used in developing the market price risk information are reliable. This may be done in conjunction with the auditor obtaining an understanding of control procedures including those over the data fed into the risk management system, pricing, and independent review of the algorithms. If the deposit taker has applied for regulatory recognition of the method used, the auditor reviews correspondence with the regulator regarding such matters; • reviewing, and where necessary testing, the internal controls relating to changes in the deposit taker’s risk management system (for example, controls over changes to algorithms and assumptions); • if a VAR model is used, performing analytical review of the model’s predictions during the year against actual outcomes (a process commonly referred to as ‘backtesting’). The auditor normally reviews any comparisons made by the deposit taker as part of its own backtesting procedures (for a deposit taker to receive regulatory recognition of the model used it is required to undertake backtesting procedures); • agreeing the amount disclosed to the output of the risk management system. 119 If an approach based upon internal controls and backtesting proves to be unsatisfactory, the auditor may wish to consider testing the accuracy of the calculations used to develop the required information. However, this situation may indicate that it would be more appropriate for the deposit taker to make disclosures on the simpler basis described in IFRS 7/FRS 29 paragraph 40. Considering the adequacy of disclosures 120 Market price risk information is subject to a number of significant limitations which are inherent in the risk measurement methods used. For example: • there are different VAR models and methods of presenting sensitivity analyses. It is to be expected that, in any particular case, the management of a deposit taker will make an informed choice of the method that it considers to be most suitable. Normally, for the purpose of developing the market price risk information to be disclosed, the management will use the risk measurement method that is used in the deposit taker’s risk management system. It would, for example, be reasonable to expect the appropriateness of this method in the past to be supported by the deposit taker’s own backtesting procedures, where such procedures are performed. However, in the absence of recognised industry standards on VAR, there is no objective benchmark against which to assess the future appropriateness of management’s choice; • both VAR models and sensitivity analyses involve the management making a number of important assumptions in order to develop the disclosures. These are, by their nature, hypothetical and based on management’s judgment (for example, TECHNICAL RELEASE FSF 03/07: Guidance for Auditing Financial Statement Disclosures made under IFRS 7 (FRS 29), Financial Instruments: Disclosures Page 9 when using a VAR model, assumptions are made concerning the appropriate holding period, confidence level and data set); • both VAR models and, to a limited extent, sensitivity analyses are based on historical data and cannot take account of the fact that future market price movements, correlations between markets and levels of market liquidity in conditions of market stress may bear no relation to historical patterns; and • Each of the methods permitted for developing market price risk information may lead to a deposit taker reporting significantly different information, depending on the choice made by the management. IFRS 7/FRS 29 paragraph 41 requires the market price risk information disclosed to be supplemented by other disclosures, including explanations of: – the method used in preparing such sensitivity analysis and of the main parameters and assumptions underlying the data provided in the disclosures; and – the objective of the method used and the limitations that may result in the information not fully reflecting the fair values of assets and liabilities involved. 121 The auditor considers the overall adequacy of the disclosures made by the deposit taker in response to the requirements of IFRS 7/FRS 29 and whether the market risk information is presented fairly so that its limitations can be understood. In particular, the auditor considers whether it is sufficiently clear that: • the market price risk information is a relative estimate of risk rather than a precise and accurate number; • the market price risk information represents a hypothetical outcome and is not intended to be predictive (in the case of probability-based methods, such as VAR, profits and losses are almost certain to exceed the reported amount with a frequency depending on the confidence interval chosen); and • future market conditions could vary significantly from those experienced in the past. 122 In many deposit takers and related groups, market price risk is primarily managed at the level of individual business units rather than on a legal entity or group-wide basis. Therefore, the auditor considers the appropriateness of the basis on which the market risk information to be disclosed in the financial statements is to be compiled. It may well be inappropriate simply to aggregate the operating unit information to arrive at the information to be disclosed for the deposit taker or group as a whole. Considering the consistency of the risk measurement method adopted 123 The main purpose of the disclosure of market price risk information is to provide users of a deposit taker’s financial statements with a better understanding of the relationship between the deposit taker’s profitability and its exposure to risk. For example, an increase in profitability may be achieved by taking on increased risk. IFRS 7/FRS 29 paragraph 40(c) requires disclosure of any changes in the methods and assumptions used and the reasons for the changes. Therefore, the auditor considers the consistency of the method, the main assumptions and parameters with those used in previous years. 124 If the method used for developing the market risk information is also used in the deposit taker’s risk management system, modifications will be made to the method as the need arises. If the deposit taker performs its own backtesting procedures, this Page 10 TECHNICAL RELEASE FSF 03/07: Guidance for Auditing Financial Statement Disclosures made under IFRS 7 (FRS 29), Financial Instruments: Disclosures may lead to modification of, for example, the algorithm used, the assumptions and parameters specified or the parts of the trading book covered. Where modifications have been made, the auditor considers their effect on the market risk measures and whether appropriate disclosures about the changes have been made. 125 In some cases, re-statement may not be possible if the relevant data for the previous year cannot be constructed and in this case the auditor considers whether the disclosures provide sufficient information about the nature and extent of any change in the entity’s risk profile. For example, as well as providing the current year figure on the ‘new’ basis, it may be relevant to show both the current year and the previous year figure on the ‘old’ basis. In all such cases, the auditor considers whether the disclosures contain sufficient narrative explanation of the change. ISA (UK and Ireland) 545, Auditing Fair Value Measurements and Disclosures 143 The valuation of derivative and other financial instruments which are not traded in an active market and so for which valuation techniques are required is an activity that can give rise to significant audit risk. Such financial instruments are priced using valuation techniques such as discounted cashflow models, options pricing models or by reference to another instrument that is substantially the same as the financial instrument subject to valuation. The auditor reviews the controls, procedures and testing of the valuation techniques used by the deposit taker. Controls and substantive testing could include focussing on: • Valuation technique and approval and testing procedures used by the deposit taker; • The independence of review, sourcing and reasonableness of observable market data and other parameters used in the valuation techniques; • Calibration techniques used by the deposit taker to test the validity of valuation techniques applied by comparing outputs to observable market transactions; • Completeness and appropriate inclusion of all relevant observable market data; • The observability in practice of data classified by the deposit taker as observable market data; • The appropriateness and validity of classification of instrument designated as being traded in a non active and in an active market; • The appropriateness and validity of the validity of the particular valuation technique applied to particular financial instruments; • The appropriateness and validity of the parameters used by the deposit taker to designate an instrument as substantially the same as the financial instrument being valued; • Mathematical integrity of the valuation models; and • Access controls over valuation models. © Auditing Practices Board Ltd (APB). Adapted and reproduced with the kind permission of the Financial Reporting Council. All rights reserved. TECHNICAL RELEASE FSF 03/07: Guidance for Auditing Financial Statement Disclosures made under IFRS 7 (FRS 29), Financial Instruments: Disclosures Page 11 All rights reserved. © Institute of Chartered Accountants in England and Wales 2007 No responsibility for loss occasioned to any person acting or refraining from action as a result of any material in this publication can be accepted by the Institute. Where third-party copyright material has been identified application for permission must be made to the copyright holder. www.icaew.com GUIDANCE FOR AUDITING FINANCIAL STATEMENT DISCLOSURES MADE UNDER IFRS 7 (FRS 29), FINANCIAL INSTRUMENTS: DISCLOSURES Status of Guidance FSF 3/07 is issued as interim guidance to assist auditors of entities applying IFRS 7 for the first time. The Institute of Chartered Accountants in England and Wales (ICAEW) is not responsible for setting Financial Reporting Standards, which are set in the UK by the Accounting Standards Board (ASB), or for the International Financial Reporting Standards set by the International Accounting Standards Board (IASB). Nor is it responsible for International Standards on Auditing (ISAs) which are set by the International Auditing and Assurance Standards Board (IAASB) or for ISAs (UK and Ireland), which are set by the Auditing Practices Board (APB). Our role includes providing guidance to our members where we consider such guidance is necessary and is not provided elsewhere, in order to enhance the consistency and quality of auditing. The content of this Technical Release has no formal or mandatory status beyond that of guidance to our members. Final guidance will only be issued if further issues arise or significant comments are received in respect of this interim guidance. Financial Services Faculty The Institute of Chartered Accountants in England and Wales Chartered Accountants’ Hall PO Box 433 Moorgate Place London EC2P 2BJ T: +44 (0)20 7920 8417 F: +44 (0)20 7638 6009 E: [email protected] DX 877 London/City www.icaew.com/fsf TECPLM6667 10/07