On 7 October 2016 the AICD lodged its submission to ASIC on CP 265 Communicating audit findings to directors, audit committees or senior managers.
The AICD is generally supportive of the policy aims of the Consultation Paper. In developing the proposed Regulatory Guide, the AICD has identified areas that may warrant further review, and could be explored in roundtables with stakeholders. These issues include:
- Greater clarity on ASIC’s priorities in applying the proposed criteria;
- Formalising a process for liaison with auditors on proposed communication, which we envisage would occur prior to contact with company directors or officers;
- Expectations on timeliness of communication, versus the timing of the audit inspection program and company reporting cycles;
- Interaction with continuous disclosure obligations where relevant; and
- ASIC’s proposed approach to circumstances where a disagreement exists between the regulator and an auditor.
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