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Assessing the Integrity of Current
Accounting Practices
Nik Mohd Hasyudeen Yusoff
Corporate Governance Summit 2009
29 September 2009




                               Competitiveness Through Innovation and Strategy
Competitiveness Through Innovation and Strategy


Agenda



•   The financial reporting supply chain
•   Stress points in financial reporting
•   The response from the accounting profession
•   Reform in the regulatory landscape
•   Would reporting failure occur again?
•   Moving Forward Thoughts
Competitiveness Through Innovation and Strategy


The financial reporting supply chain
                                      • The accounting and auditing
                                        practices and the accounting
                                        profession itself have been
                                        under scrutiny since the
                                        collapse of Enron in 2001
                                      • Since then the landscape has
                                        changed in line with the
                                        development in corporate
                                        governance globally
Competitiveness Through Innovation and Strategy


The financial reporting supply chain
                                      • A business:
                                          ▫ Need to serve customers
                                          ▫ Need to compete
                                          ▫ Business environment keeps
                                            on changing
                                          ▫ Affected by global
                                            developments
                                          ▫ Stakeholders beyond
                                            shareholders
                                          ▫ Profit is the result of risk
                                            taking
Competitiveness Through Innovation and Strategy


    The financial reporting supply chain
                                               • The financial reporting supply
                                                 chain refers to the people and
                                                 processes involved in the
                                                 preparation, approval, audit,
                                                 analysis and use of financial
                                                 reports. All links in the chain
                                                 need to be of high quality and
                                                 closely connected to supply
                                                 high quality financial
1 Financial Reporting Supply Chain:              reporting 1
Current Perspectives and Direction
International Federation of Accountants 2008
Competitiveness Through Innovation and Strategy


The financial reporting supply chain
Player                                        Role in financial reporting supply chain
Management                                    Prepares financial statements
Board                                         Provides direction and approves
Auditors                                      Provide independent opinion
Media                                         Disseminates financial information
Investors/Stakeholders                        Make economic decisions
Professionals – Valuers, Lawyers              Valuation, professional opinion
Bankers, Rating agencies                      Corporate proposals
Standards setters and Professional bodies     Set standards – financial reporting,
                                              auditing, ethics
                                              Enforce standards
Regulators                                    Ensure market integrity, enforcement
                                              actions
Competitiveness Through Innovation and Strategy


     The financial reporting supply chain

Financial
And Business
Reporting Supply
Chain




Source:
XBRL
International
Competitiveness Through Innovation and Strategy


The financial reporting supply chain
Competitiveness Through Innovation and Strategy


Stress points in financial reporting
                                    • Complexity of business
                                        ▫ Size
                                        ▫ Geographical coverage
                                        ▫ Industry
                                    • Application of financial
                                      reporting standards
                                        ▫   Complexity
                                        ▫   Mark-to-market issues
                                        ▫   Capacity to comply
                                        ▫   Lack of infrastructure
Competitiveness Through Innovation and Strategy


Stress points in financial reporting
                                 • Tone from the boardroom
                                     ▫ Not given enough priority
                                     ▫ Heavy reliance on management’s
                                       assurance without adequate
                                       oversight
                                 • Audit committee ineffectiveness
                                     ▫ Lack of expertise
                                     ▫ Blind reliance on external auditors
                                     ▫ Not enough support from internal
                                       audit
Competitiveness Through Innovation and Strategy


Stress points in financial reporting
                              • Failure of risk management
                                 ▫ Financial reporting risks not
                                   adequately address on timely manner
                                 ▫ Internal control break down
                                 ▫ Fraudulent behaviour not detected
                              • Meeting market expectation
                                 ▫ Attempting to meet analysts’
                                   expectation
                                 ▫ Avoiding consequences of
                                   enforcement actions or debt
                                   covenant
Competitiveness Through Innovation and Strategy


Stress points in financial reporting
                           • Breakdown in auditors’ independence
                              ▫ Financial interests from cross-selling of
                                other services
                              ▫ Major clients
                              ▫ Close relationship between auditors
                                and clients
                           • Quality control practices within
                             auditing firms
                              ▫ Lack of leadership
                              ▫ Inadequate understanding of business
                                and risks
Competitiveness Through Innovation and Strategy


Stress points in financial reporting

                           •Greed!
                              ▫ Unmitigated excessive risk taking
                              ▫ Independent directors turn dependent
                              ▫ Executive incentives linked to
                                performance
                              ▫ Auditors putting business interests
                                above professional values
Competitiveness Through Innovation and Strategy


Stress points in financial reporting

                                  Business        Oversight
                                   failure         failure




                Governance
                  failure                         Audit failure
Competitiveness Through Innovation and Strategy


The response from the accounting profession
                                                  • “You never want a
                                                    serious crisis to go to
                                                    waste. And what I mean
                                                    by that is an
                                                    opportunity to do
                                                    things you think you
                                                    could not do before”

                                                           Rahm Emanuel
                                                      White House Chief of
                                                                     Staff
Competitiveness Through Innovation and Strategy


The response from the accounting profession
                                   • Improvement in audit standards
                                     setting process, International
                                     Auditing and Assurance
                                     Standards Board (IAASB)
                                     reconstituted in 2002
                                   • IAASB came under the preview
                                     of the Public Interest Oversight
                                     Board in 2005
                                   • Completed the auditing
                                     standards clarity project in 2008
Competitiveness Through Innovation and Strategy


The response from the accounting profession
                         • Forum of Firms, which was established in
                           2002, is an association of international
                           networks of accounting firms that perform
                           audits of financial statements that are or may
                           be used across national borders
                         • The obligations of members include:
                           ▫ Maintain appropriate quality control
                           ▫ Policies and methodologies based on ISAs
                           ▫ Policies and methodologies conform with
                             IFAC’s code of ethics for professional
                             accountants
                           ▫ Submit annual report on meeting
                             obligations
Competitiveness Through Innovation and Strategy


The response from the accounting profession
                             • Improvements in ethical standards
                               including:
                                 ▫ Strengthening of the independence
                                   requirements by using the threats-
                                   safeguards approach
                                 ▫ Auditors rotation
                                 ▫ Network firm rules
                                 ▫ Clarifying guidance on non-assurance
                                   services
                                 ▫ Relative fee size
Competitiveness Through Innovation and Strategy


The response from the accounting profession
 Identify                 Evaluate                Apply           Decide on
 Threats                  Threats                 Safeguards      Engagements

 Self-Review


Self-Interest                                     Profession or
                                                   legislation
                          Significant?
  Advocacy                 Assurance               Assurance
                          team, firm,                client       Eliminate
                         network firm?
                                                     Firm’s
                                                                  the threats
 Familiarity                                                      or withdraw
                                                    Internal
                                                   procedures     from
Intimidation                                                      engagement
Competitiveness Through Innovation and Strategy


The response from the accounting profession
                             • Competency requirements for audit
                               professional standard was issued in
                               2006
                                 ▫   Knowledge content
                                 ▫   Professional skills
                                 ▫   Professional values, ethics and attitude
                                 ▫   Continuing professional education
                                 ▫   Assessment
                                 ▫   Competent requirement for engagement
                                     partner
Competitiveness Through Innovation and Strategy


The response from the accounting profession
                             • International Standards on Quality
                               Control
                                 ▫ Leadership Responsibilities for Quality
                                   within the Firm
                                 ▫ Ethical requirements
                                 ▫ Acceptance of Continuance of Clients
                                   Relationships and Specific Engagement
                                 ▫ Human Resources
                                 ▫ Engagement Performance
                                 ▫ Monitoring
                                 ▫ Documentation
Competitiveness Through Innovation and Strategy


The response from the accounting profession
                             • The Malaysian Institute of
                               Accountants has also been active in
                               improving audit quality in Malaysia
                               through:
                                 ▫ Increased education activities on audit
                                   quality and ethics
                                 ▫ Adopting international auditing standards
                                 ▫ Financial Reporting Standards
                                   Implementation Committee
                                 ▫ Establishment of Ethics Standards Board
                                   and Audit and Assurance Standards
                                   Board
Competitiveness Through Innovation and Strategy


Reform in the regulatory landscape
Competitiveness Through Innovation and Strategy


Reform in the regulatory landscape
                                    • The regulatory landscape has
                                      changed and will continue to
                                      change such as:
                                      ▫ Incorporation of whistle blowing
                                        provisions in the securities law
                                        and company law
                                      ▫ Independent audit oversight such
                                        as the PCAOB, the Malaysian
                                        Audit Oversight Board will be
                                        established soon
                                      ▫ Making auditing standards law
                                        e.g. Australia
Competitiveness Through Innovation and Strategy


Would reporting failure occur again?
                                                  • Unfortunately, the answer is
                                                    YES
                                                  • While the structure and
                                                    form of governance,
                                                    standards and regulation
                                                    are there, it is the PEOPLE
                                                    that would eventually
                                                    determine whether future
                                                    shocks could be avoided
                                                  • If the root cause is greed,
                                                    how do we overcome this?
Competitiveness Through Innovation and Strategy


Would reporting failure occur again?
                                    • Is there another way of guiding
                                      people to perform?
                                    • MIA published a monograph on
                                      human governance which focuses
                                      on the inside-out approach instead
                                      of parameter-driven rule-based
                                      governance
                                    • Spiritual aspect is recognised
Competitiveness Through Innovation and Strategy


Moving Forward Thoughts
                               • Audit quality is the responsibility
                                 of every player in the financial
                                 reporting supply chain
                               • If a component fails, the stress
                                 would be transferred to the next
                                 component until the chain breaks
                               • While regulatory reform and
                                 response from the accountancy
                                 profession has improved audit
                                 practices, the threat of future
                                 failures remain real
Competitiveness Through Innovation and Strategy


Moving Forward Thoughts
Competitiveness Through Innovation and Strategy

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Assessing The Integrity Of Current Accounting Practices

  • 1. Assessing the Integrity of Current Accounting Practices Nik Mohd Hasyudeen Yusoff Corporate Governance Summit 2009 29 September 2009 Competitiveness Through Innovation and Strategy
  • 2. Competitiveness Through Innovation and Strategy Agenda • The financial reporting supply chain • Stress points in financial reporting • The response from the accounting profession • Reform in the regulatory landscape • Would reporting failure occur again? • Moving Forward Thoughts
  • 3. Competitiveness Through Innovation and Strategy The financial reporting supply chain • The accounting and auditing practices and the accounting profession itself have been under scrutiny since the collapse of Enron in 2001 • Since then the landscape has changed in line with the development in corporate governance globally
  • 4. Competitiveness Through Innovation and Strategy The financial reporting supply chain • A business: ▫ Need to serve customers ▫ Need to compete ▫ Business environment keeps on changing ▫ Affected by global developments ▫ Stakeholders beyond shareholders ▫ Profit is the result of risk taking
  • 5. Competitiveness Through Innovation and Strategy The financial reporting supply chain • The financial reporting supply chain refers to the people and processes involved in the preparation, approval, audit, analysis and use of financial reports. All links in the chain need to be of high quality and closely connected to supply high quality financial 1 Financial Reporting Supply Chain: reporting 1 Current Perspectives and Direction International Federation of Accountants 2008
  • 6. Competitiveness Through Innovation and Strategy The financial reporting supply chain Player Role in financial reporting supply chain Management Prepares financial statements Board Provides direction and approves Auditors Provide independent opinion Media Disseminates financial information Investors/Stakeholders Make economic decisions Professionals – Valuers, Lawyers Valuation, professional opinion Bankers, Rating agencies Corporate proposals Standards setters and Professional bodies Set standards – financial reporting, auditing, ethics Enforce standards Regulators Ensure market integrity, enforcement actions
  • 7. Competitiveness Through Innovation and Strategy The financial reporting supply chain Financial And Business Reporting Supply Chain Source: XBRL International
  • 8. Competitiveness Through Innovation and Strategy The financial reporting supply chain
  • 9. Competitiveness Through Innovation and Strategy Stress points in financial reporting • Complexity of business ▫ Size ▫ Geographical coverage ▫ Industry • Application of financial reporting standards ▫ Complexity ▫ Mark-to-market issues ▫ Capacity to comply ▫ Lack of infrastructure
  • 10. Competitiveness Through Innovation and Strategy Stress points in financial reporting • Tone from the boardroom ▫ Not given enough priority ▫ Heavy reliance on management’s assurance without adequate oversight • Audit committee ineffectiveness ▫ Lack of expertise ▫ Blind reliance on external auditors ▫ Not enough support from internal audit
  • 11. Competitiveness Through Innovation and Strategy Stress points in financial reporting • Failure of risk management ▫ Financial reporting risks not adequately address on timely manner ▫ Internal control break down ▫ Fraudulent behaviour not detected • Meeting market expectation ▫ Attempting to meet analysts’ expectation ▫ Avoiding consequences of enforcement actions or debt covenant
  • 12. Competitiveness Through Innovation and Strategy Stress points in financial reporting • Breakdown in auditors’ independence ▫ Financial interests from cross-selling of other services ▫ Major clients ▫ Close relationship between auditors and clients • Quality control practices within auditing firms ▫ Lack of leadership ▫ Inadequate understanding of business and risks
  • 13. Competitiveness Through Innovation and Strategy Stress points in financial reporting •Greed! ▫ Unmitigated excessive risk taking ▫ Independent directors turn dependent ▫ Executive incentives linked to performance ▫ Auditors putting business interests above professional values
  • 14. Competitiveness Through Innovation and Strategy Stress points in financial reporting Business Oversight failure failure Governance failure Audit failure
  • 15. Competitiveness Through Innovation and Strategy The response from the accounting profession • “You never want a serious crisis to go to waste. And what I mean by that is an opportunity to do things you think you could not do before” Rahm Emanuel White House Chief of Staff
  • 16. Competitiveness Through Innovation and Strategy The response from the accounting profession • Improvement in audit standards setting process, International Auditing and Assurance Standards Board (IAASB) reconstituted in 2002 • IAASB came under the preview of the Public Interest Oversight Board in 2005 • Completed the auditing standards clarity project in 2008
  • 17. Competitiveness Through Innovation and Strategy The response from the accounting profession • Forum of Firms, which was established in 2002, is an association of international networks of accounting firms that perform audits of financial statements that are or may be used across national borders • The obligations of members include: ▫ Maintain appropriate quality control ▫ Policies and methodologies based on ISAs ▫ Policies and methodologies conform with IFAC’s code of ethics for professional accountants ▫ Submit annual report on meeting obligations
  • 18. Competitiveness Through Innovation and Strategy The response from the accounting profession • Improvements in ethical standards including: ▫ Strengthening of the independence requirements by using the threats- safeguards approach ▫ Auditors rotation ▫ Network firm rules ▫ Clarifying guidance on non-assurance services ▫ Relative fee size
  • 19. Competitiveness Through Innovation and Strategy The response from the accounting profession Identify Evaluate Apply Decide on Threats Threats Safeguards Engagements Self-Review Self-Interest Profession or legislation Significant? Advocacy Assurance Assurance team, firm, client Eliminate network firm? Firm’s the threats Familiarity or withdraw Internal procedures from Intimidation engagement
  • 20. Competitiveness Through Innovation and Strategy The response from the accounting profession • Competency requirements for audit professional standard was issued in 2006 ▫ Knowledge content ▫ Professional skills ▫ Professional values, ethics and attitude ▫ Continuing professional education ▫ Assessment ▫ Competent requirement for engagement partner
  • 21. Competitiveness Through Innovation and Strategy The response from the accounting profession • International Standards on Quality Control ▫ Leadership Responsibilities for Quality within the Firm ▫ Ethical requirements ▫ Acceptance of Continuance of Clients Relationships and Specific Engagement ▫ Human Resources ▫ Engagement Performance ▫ Monitoring ▫ Documentation
  • 22. Competitiveness Through Innovation and Strategy The response from the accounting profession • The Malaysian Institute of Accountants has also been active in improving audit quality in Malaysia through: ▫ Increased education activities on audit quality and ethics ▫ Adopting international auditing standards ▫ Financial Reporting Standards Implementation Committee ▫ Establishment of Ethics Standards Board and Audit and Assurance Standards Board
  • 23. Competitiveness Through Innovation and Strategy Reform in the regulatory landscape
  • 24. Competitiveness Through Innovation and Strategy Reform in the regulatory landscape • The regulatory landscape has changed and will continue to change such as: ▫ Incorporation of whistle blowing provisions in the securities law and company law ▫ Independent audit oversight such as the PCAOB, the Malaysian Audit Oversight Board will be established soon ▫ Making auditing standards law e.g. Australia
  • 25. Competitiveness Through Innovation and Strategy Would reporting failure occur again? • Unfortunately, the answer is YES • While the structure and form of governance, standards and regulation are there, it is the PEOPLE that would eventually determine whether future shocks could be avoided • If the root cause is greed, how do we overcome this?
  • 26. Competitiveness Through Innovation and Strategy Would reporting failure occur again? • Is there another way of guiding people to perform? • MIA published a monograph on human governance which focuses on the inside-out approach instead of parameter-driven rule-based governance • Spiritual aspect is recognised
  • 27. Competitiveness Through Innovation and Strategy Moving Forward Thoughts • Audit quality is the responsibility of every player in the financial reporting supply chain • If a component fails, the stress would be transferred to the next component until the chain breaks • While regulatory reform and response from the accountancy profession has improved audit practices, the threat of future failures remain real
  • 28. Competitiveness Through Innovation and Strategy Moving Forward Thoughts