Audit firm governance, second consultation

Comments from ACCA to the Financial Reporting Council (FRC), October 2009.

ACCA is pleased to have the opportunity to comment on the above exposure draft.

ACCA is the largest and fastest-growing global professional accountancy body with 131,500 members and 362,000 students in 170 countries.

We aim to offer the first choice qualifications to people of application, ability and ambition around the world who seek a rewarding career in accountancy, finance and management. ACCA works to achieve and promote the highest professional, ethical and governance standards and advance the public interest.

We welcome this consultation, which now presents the Draft Audit Firm Governance Code. We provided extensive comments in relation to the earlier evidence-gathering consultation but do not return to those matters here.

We are able to support the main features of the draft Code and look forward to its early finalisation. Firms will have to surmount potential practical difficulties of independence, conflicts of interest and liability in order to appoint appropriate non-executives to contribute to the successful operation of the Code. The international structures of some firms may also yield practical difficulties as they seek to implement a UK governance mechanism at an appropriate level. It will be for time and experience to determine, therefore, if the Code succeeds in playing a significant part in increasing trust in firms auditing public interest clients.