Deloitte Audit

We recommend that:

• Audit Firms be allowed to admit a [limited] number of partners (or directors for incorporated Firms) who are not themselves Registered Auditors, provided all partners subscribe to the Code of Ethics and Other Pronouncements of IRBA and its sub-committees, and the majority of the partners by number are Registered Auditors.
• The relevant provisions of the Auditing Profession Bill should establish clearly the ability of Registered Auditors to share profits with persons not registered as auditors.

Reportable irregularities

• The definition of a reportable irregularity should be amended
• There needs to be a level of materiality relative to the entity being audited
• Concepts which are vague, such as a “dishonest” act are not capable of consistent results
• The Auditing Profession Bill allows for an auditor to be liable for failing to report a reportable irregularity – this is not a reasonable requirement. While an auditor should be professionally accountable for his actions in this area – he should not be financially liable

We recommend that:

• A reportable event should only occur if the matter is material in the context of the financial information of the entity being audited (and not if material to the individual creditor or shareholder as this would be impossible to establish).
• A reportable event should only exist if the matters considered fraudulent or amounting to theft exceed a predetermined level, which level may be consistent with the Prevention and Combating of Corrupt Practices Act.
• We do not believe that the requirement to report conduct that is “otherwise dishonest” will be capable of consistent application by Registered Auditors and the requirement should be deleted.

We recommend that:

• Where there are reporting requirements in other legislation or regulation, such as the Banks Act, the Financial Advisors and Intermediaries Act, The Pension Fund Act, the Auditing Profession Bill should be amended to merely require the auditor to also submit a copy of the report so required to IRBA when despatched to the entity subject to audit and/or for the auditor to follow the reporting requirements of the other legislation where there is an overlap.
• Auditors should be protected from any potential financial liability for acting or failing to act in terms of reporting irregularities.