Appendix Request for Specific Comments Do you believe that the proposals in this ED have resulted in any unintended changes in meaning of: The provisions for Part C of the Extant Code, as revised in the document for Part C Phase 1 (see Sections 200-270 in Chapter 1)? The NOCLAR provisions (see Sections 260 and 360 in Chapter 2)? The revised provisions regarding long association (see Sections 540 and 940 in Chapter 3)? The provisions addressing restricted use reports in the extant Code (see Section 800 in Chapter 4)? The provisions relating to independence for other assurance engagements (Part 4B in Chapter 5)? If so, please explain why and suggest alternative wording. We comment as follows: 1.1 Proposed Revisions that Obscure Clarity of Wording in the Extant Code We note a few instances in the ED where the original text was clearer or more precise than the proposed revised wording and where proposed changes impact the meaning: Provisions addressing long association: We appreciate that the IESBA is moving away from the approach that considers the relative significance of threats to an approach to eliminate or reduce threats to an acceptable level. However, we question why the following changes are proposed to a firm decides that the R540.5: “If level of the threats are so significant that created without reference to …” this level not being at an acceptable level i.e., so as to retain the – reference to the of also in respect of “degree significance”. This applies further paragraphs, e.g. 540.5 A1 and A2, 540.4 A3 as well as R940.5 and 940.5 A1 and A2 and 940.4 A3. The original text consistently referred to significance of the threat and so was far clearer in regard to the fact that only threats above a certain threshold (i.e., not at an acceptable level) are to be addressed. The covering letter also questions
Appendix Request for Specific Comments Do you believe that the proposals in this ED have resulted in any unintended changes in meaning of: The provisions for Part C of the Extant Code, as revised in the document for Part C Phase 1 (see Sections 200-270 in Chapter 1)? The NOCLAR provisions (see Sections 260 and 360 in Chapter 2)? The revised provisions regarding long association (see Sections 540 and 940 in Chapter 3)? The provisions addressing restricted use reports in the extant Code (see Section 800 in Chapter 4)? The provisions relating to independence for other assurance engagements (Part 4B in Chapter 5)? If so, please explain why and suggest alternative wording. We comment as follows: 1.1 Proposed Revisions that Obscure Clarity of Wording in the Extant Code We note a few instances in the ED where the original text was clearer or more precise than the proposed revised wording and where proposed changes impact the meaning: Provisions addressing long association: We appreciate that the IESBA is moving away from the approach that considers the relative significance of threats to an approach to eliminate or reduce threats to an acceptable level. However, we question why the following changes are proposed to R540.5: “If a firm decides that the level of the threats are so significant that created …” without reference to this level not being at an acceptable level – i.e., so as to retain the reference to the “degree of significance”. This applies also in respect of further paragraphs, e.g. 540.5 A1 and A2, 540.4 A3 as well as R940.5 and 940.5 A1 and A2 and 940.4 A3. The original text consistently referred to significance of the threat and so was far clearer in regard to the fact that only threats above a certain threshold (i.e., not at an acceptable level) are to be addressed. The covering letter also questions
IDW-CommentLetterImprovingtheStructuresoftheCodephase2osig.docx