Introduction
:
In discharging the
duties and while performing the various function , the
paramount consideration which should weigh with the members
of the profession is that are not merely performing particular
duties to earn emoluments , but that they have to discharge
a wider function and their obligation - a moral one -is
to function in such a way that they are above suspicion
and as members of the learned and an honourable profession
they provide service to the community being accountable
to the authorities and also to the legislature of the
country which has bestowed autonomy on the profession.
G.P. Kapadia
History of the Accountancy Profession in India , 1972
Peer Review :
The concept of Peer Review has been introduction in inquistiveness
India for the first time. There are lots of inquistiveness
about this concept everywhere and a frequently asked question
we are often facing is that whether Peer Review would
tantamount to re-audit of the audit done by an auditor.
It is made very clear that it is not a re-audit of the
financial statements vis-a -vis the book and records of
transactions ; but it is a check on the audit procedure,
programme and maintenance of the audit evidences and working
papers.
Definitions : Let us consider some important definitions
given in the statement of Peer Review issued by the Institute.
Peer Review : Peer
Review means a review of the systems and procedures to
determine whether practice unit has put in implementation
of the Technical Standards as envisaged and implied/ mandated
, effectively to ensure the quality of attestation services.
Practice Unit : Practice Unit means a member in
practice practicing individually or a firm of Chartered
Accountants.
Technical Standards
: Technical Standards includes followings :
• Accounting standards
• Statements on standard
auditing practices (Auditing and Assurance Standards)
• Framework on preparation and presentation of Financial
Statements
• Framework of Statements
on Standards Auditing practices.
• Guidance Notes
• Notifications /Direction
issued by the Institute.
It also includes relevant status and regulations applicable
with reference to specific assignment.
Attestation Services
: Attestation Service means service of auditing or verification
of financial transaction, books, accounts or the preparation,
verification or certification of financial accounting
and related statements as defined under section 2(2)(ii)
of The Chartered Accountants Act, 1949.
However, the service of providing consultancy on management,
taxation or allied issues, representing a client before
authority, engagement for compliance of financial statements
and engagement to assist client in preparing , compiling
information other than financial statemets are specifically
excluded from the definition of attestation services.
Objectives :
The main objectives of
Peer Review are as follows :
• To ensure that, the Practising units while discharging
their attestation function (a) comply with technical standards
(b) follow proper system to maintain the quality of work
.
• To identify areas where
practising member requires guidance and to provide the
guidance to members to improve their performance.
Scope :
The Peer Review shall
basically cover following areas :
• compliance with technical
standards
• Quality of reporting
• Office systems and
procedures
• Qualification and updation
of knowledge of personnel
• Infrustruction facility
Reviewee :
Review of the implementation
of the Peer Review will take place in a phased manner
as indicated in following table :
|
Units
covered
|
date
of implementation |
| Stage
-1 |
• Central Statutory auditors of
banks , public
financial institutions, insurance companies, asset
management companies and mutual funds
|
1st April 2003 |
|
• Statutory auditors of public sector
companies
|
|
|
• Statutory auditors of central
co-operative societies.
|
|
| Stage-II |
• auditors of branches of banks
|
1st April 2004 |
|
• auditors of regional rural and
co-operative banks.
|
|
|
• Auditors of companies , whichhave
raised from public or financial institutions over
Rs. one crore
|
|
| Stage
-III |
all other practice units not covered
above |
1st April 2005 |
In all these stages practice units are selected
on random basis However , the review of practice
its covered in stage-I will performed once in
three years . If any practice unit is not selected
at any stage , it may suo moto apply for Peer
Review. An auditee concern may also request
to conduct the Peer Review of its auditor.
Procedure of Review :
| (i) |
The
Peer Review is conducted according to
a well-defined program, supervised by
Peer Review Board. The reviewer is supposed
to maintain strict confidentially about
the affairs of the practice unit under
the review
|
|
• Obtaining
primary information from the practice
Unit.
• Reviewing general controls and working
papers of selected audit functions.
• Preparation of report
by reviewer.
• Peer Review Board will consider report
of review, and on that basis may make
recommendation for improvement, or if
it feels necessary may order follow
up review after specific period.
|
| (ii) |
The
reviewer evaluates the effectiveness
of general control maintained by practice
unit. On that basis, he will determine
the extent to which reliance can be
placed on them and will also determine
the number of attestation service engagement
to be reviewed. Statements on Peer Review
has identified following core area of
general controls to be reviewed.
|
|
• Independence
• Maintenance of professional
skills and standards
• Outside consultant
• Staff Supervision and
Development
• Office Administration
|
| (iii) |
The reviewer will also review
records and working papers of selected
audit assignment covering different sized
clients from different industries. The
reviewer may use compliance procedure
or substantive procedure. In compliance
approach, reviewer will try to find out
whether proper control is exercised for
orderly maintenance of audit working papers
, in review and evaluation of internal
control system, in performance of substantive
tests , while deriving audit conclusion
, in presentation of financial statement
and in preparation of audit report.
|
In
a case , when the reviewer feels on
the basis of his review of general control
that standards of control are not satisfactory
as required and concludes that he can
not rely on specifie control of practice
unit on his audit engagement, substantive
procedures are followed. In substantive
approach, in order to establish that
the audit work is discharged in compliance
with technical standards, detailed review
of audit working papers is done.
Liability of the Practice Unit :
Proprietor or Partners of the practice
unit will produce to the reviewer all
documents which reviewer requires for
Peer Review, allow him access to or
to abstract from any of them, no matter
even if these documents are available
at different offices, in case when practice
units have more than one office . Proprietors
or partners of practice unit will also
provide the reviewer such explanation
or further particulars as may be required
respect in of documents produced before
him.
Reviewer :
The nature and complexity of Peer
Review require the exercise of professional
judgement. Accordingly, an individual
serving as a reviewer shall :
i. be a member
ii. possess at least
fifteen years of experience of audit;
and
iii. be currently active
in the practice of accounting and auditing.
Cost of Peer Review
:
The cost of Peer Review
including honorarium and TA/DA for the
reviewer and his qualified assistants
may be decided from time to time by
the peer Review Board. In case reviewer
has to conduct the review for the second
time , the same rate would apply. Each
of the branches/considered under review
would be considered separately.
Immunity :
Either of the practice
unit, the reviewer and the members of
the review board shall not incur any
liability under the Code of Ethics under
the Chartered Accountants Act, 1949.
Confidentiality :
Strict confidentiality provisions
shall apply to all those involved in
the Peer Review process, namely, reviewers,
members of the board , the council or
any person who assists any of these
parties. Non-compliance with the secrecy
provisions shall amount to professional
misconduct as defined under Section
22 of the Chartered Accountants Act,1949.
The Global Scenario :
At this stage ,it will be relevant
to know what type of system for Peer
Review is adopted globally. As mentioned
earlier, concept of Peer Review is just
introduced in India, but in other countries
it is a well-recognized practice. For
example , in USA Peer Review was introduced
first time in 1997, in UK from 1991,
in France from 1969, in Japan 1998.
Recently, the International Federation
of Accountants (IFAC) has approved the
Constitution of the forum of firms and
provided for their global Peer Review.
So far as the object of Peer Review
is concerned, more or less it is the
same i.e. compliance of technical standards,
in all countries, But their approach
differs . In USA review includes review
of working papers rather than specific
case. While in India, according to statement
on Peer Review, audit assignment will
be randomly selected for review. In
USA and also in
Global peer Review (IFAC), the review
is directed towards the professional
aspects of reviewed firm's accounting
and auditing practice, it will not include
the business aspects of the firm.
In all countries, only the auditing
services provided are covered and not
other services provided to client. In
India the Institute has adopted the
same criteria.
One of the important variance of Indian
Peer Review system from global practice
is that, there are no penal provisions.
As, this concept is in nascent state,
no penal provisions are applied, if
the reviewed firm's report of Peer Review
is not satisfactory. There are very
strict provisions in this regard in
other countries.
In USA failure to maintain appropriate
quality control attracts imposition
of sanction. In Belgium the council
of the institute takes action on the
Peer Review reports. In Canada review
can also lead to the disciplinary action.
In Sweden persistent deficiencies can
lead to expulsion from membership. The
newly created Public Accounting Board
replaced the Public Oversight Board
to administer Peer Review. It is sought
to be made independent of accounting
profession. The independent Board is
composed of non-industry appointees.
In India, majority of members will be
appointed by the Council of the Institute.
2/3 of members of Peer Review Board
shall hold certificate of practice,
and Chairman and vice Chairman shall
be from members appointed by the Council.
Conclusion :
High quality financial statements
depend on high quality accounting standards
and legislation , which keep pace with
the changing needs and expectations
of those who rely on financial data.
Good quality audit is a key. Ensuring
quality audit requires the accountancy
profession to have high criteria for
education and experience; appropriate
standard of audit methodology; consistent
principles for ethical behaviour ; a
credible disciplinary process to deal
with complaints and problems; and a
systematic and satisfactory approach
to securing audit quality . These quality
control programs have been designed
to require firms of practicing accountants
to establish appropriate Quality Control
Policies and procedures so as to provide
reasonable assurance to the outside
world about conformance with the professional
standards in the services rendered to
them. These practices expected to bolster
the confidence of the society in the
quality of work of the practicing accountants
around the world. |
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