Long Association Task Force Marisa Orbea Task Force
Long Association Task Force Marisa Orbea, Task Force Chair IESBA Meeting September 15 -16, 2015 New York, USA Page 1 | Proprietary and Copyrighted Information
Long Association Some comments on cooling-off periods for EQCR • • Proposal is reasonable and provides balanced approach Good job trying to steer down the middle Should be striving for harmonisation Too complex to apply Adding complexity is not in the Public Interest Concern about non-PIE approach with respect to banks Minimum only and should encourage higher standards Page 2 | Proprietary and Copyrighted Information
Long Association Some comments on cooling-off periods for EQCR • EQCR role is different and additional year off non-PIEs will mean hardship for SMPs • Consider what adoption and implementation will look like • Do some work on illustrating what good practices look like • Proposals should be re-exposed Page 3 | Proprietary and Copyrighted Information
Long Association Some comments on jurisdictional clause • Deals with EU therefore supported • Be clearer about pointing to EU situation to inform the discussion • What should regulatory inspection regime look like? • Can see logic but are objectives sufficiently similar between firm and partner rotation? • Is Board comfortable with specificity of 10 years? Page 4 | Proprietary and Copyrighted Information
Long Association Some comments on activities during cooling-off • Limited consultation clause not supported by some: – Relationship continues to exist – Clouds ultimate principle – Off means off – Don’t want someone in the background calling the shots Page 5 | Proprietary and Copyrighted Information
Long Association Some comments on activities during cooling-off • But limited consultation also considered practical by a few: – No evidence hasn’t worked in the UK – Could be OK as long as not part of decision making – Its about how it is implemented and deployed – More audit quality delivered if right people involved and have the right safeguards • Other restrictions generally supported Page 6 | Proprietary and Copyrighted Information
Long Association Other comments • Is possibility of rotation of non-KAPs emphasised sufficiently? • Consider adding concurrence of TCWG in 290. 153 (the exemption could be a one off). Page 7 | Proprietary and Copyrighted Information
The Ethics Board www. ethicsboard. org
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