ACCA responds to the FRC's consultation on, Enhancing confidence in audit - the Financial Reporting Council’s audit enforcement procedures.
ACCA welcomes the opportunity to comment on the proposals issued by the Financial Reporting Council (the FRC).
While we acknowledge that the FRC has been hampered by not having the final legislation on which to base these proposals, we consider the consultation document lacks clarity, which presents a considerable challenge when combined with a very short consultation period.
Our understanding is that the FRC is proposing a four-layer process (excluding the appeal process), in which there are three opportunities for the FRC to avoid the expense of a public hearing at a tribunal.
Apart from the lack of clarity in the proposed Audit Enforcement Procedure, the process itself would be vulnerable to criticism of being cumbersome and lacking transparency and balance. It may also be criticised for handing too much power to Executive Counsel.
Our detailed comments in respect of specific questions within the consultation are set out in the attached document.