PEER REVIEW- AN OVERVIEW

PEER REVIEW: GENERAL MEANING

The term Peer means a person of similar standing. The term review means a general survey or assessment of a subject or thing. The term Peer Review would mean review of work done by a professional, by another professional of similar standing.

Definition of Peer Review (Para 3.4)

Peer Review deals with examination and review of systems and procedures to determine whether the systems and procedures are in: Existence Effective Operating continuously during the period under review Put in place by the practice Unit.

NEED FOR PEER REVIEW

Expectation of service Receiver to receive quality service Gap between minimum quality of service and actual service rendered. Reassuring the stake holders and the society at large that the profession is conscious of its responsibilities and strives its best to ensure that the highest standards are observed by all practising members rendering audit and attestion services to the society. The Peer Review process is an endavour to enhance the quality of services rendered by members of ICAI in public practice.
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Global Scenario in Peer Review

Independent Regulator in certain countries In some countries disciplinary action if deficiency in services of Auditor is found. In the US, public accountancy firms are required to enrol in an approved Practice Monitoring Programme in order to be admitted to or retain membership in the AICPA (the professional body in the US). Furthermore, under Sec 104 of the Sarbanes-Oxley Act, 2002 they are additionally liable to be inspected by the PCAOB (Public Companies Accounting Oversight Board), to assess the degree to which each firm and its associated persons comply with the Act, the PCAOB and SEC rules, the professional and reporting standards, etc. Existence in Most of the developed Countries-50 Started 1930 in France.
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U.K. Position

The Audit Inspection Unit (AIU), part of the Professional Oversight Board, is responsible for the monitoring of the audits of all listed and other major public interest entities. The AIU was set up following the Governments post-Enron review of the regulation of the UK accountancy profession which reported in January 2003. The review teams report recommended enhancing the monitoring of the audits of listed and other major public interest entities through a new independent inspection unit (the AIU) reporting to a professional oversight board (the POB) within an integrated independent regulator (the FRC).
The professional accountancy bodies continue to register firms to conduct audit work with their regulatory activities being overseen by the POB. The audit registration committees of the accountancy bodies receive formal reports from the AIU on our monitoring work, with the POB overseeing the action taken by them in response to our recommendations. The Companies (Audit, Investigations and Community Enterprises) Act 2004 implemented the statutory changes necessary to give effect to these arrangements.

Present Peer Review System In India

Supervisor Within Institute of Chartered Accountants of India Chinese Wall between Peer Review process and Disciplinary Mechanism ( No disciplinary action even if there is deficiency in service of Auditor) Audit of accounts after 1st April 2002 only covered Peer Reviewers are Individual Members of the Institute.
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Present Peer Review System In India

Three Stages of Peer Review In India Stage I-Mandatory Peer Review once in three years Stage II-No Time limit, Proposed Once in 5 years Stage III- No Time Limit, Proposed Once in 7 years (Only Attestation services Covered)

The Regulatory Framework to bring the light of the day

The Chartered Accountants (Amendment) Act, 2005 Bill Introduces new Chapter VIIA in Chartered Accountants Act 1949. Chapter VII A consists of Sections 28A to 28D. Central Government will constitute Quality review board consisting of 11 persons.
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The Regulatory Framework to bring the light of the day contd.

Council of ICAI will nominate 5 members on QRB Chairman and other 5 members will be appointed by Central Government All services provided by members( Both attestation and non attestation will be subject to Quality Review) Disciplinary action if there is a deficiency in service.
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Composition of Peer Review Board at Institute of Chartered Accountants of India

The Board consists of 10 members appointed by the Council Of whom atleast six are from amongst the members of the Council. Representatives from the Department of Company Affairs, Comptroller and Auditor General of India and Industry (FICCI/ CII) as members In addition, persons of eminence from legal, banking and education sectors (a retired High Court Judge, CMD, Bank of Maharashtra, CE, Indian Banks Association, Chairman, UGC) and a former President of the Institute assist the Board in its 11 deliberations as Special Invitees.

Salient Features of the Statement on Peer Review

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Some features of the Statement.

Statement on peer review was passed by Council in March 2002 First meeting of Peer Review board took place in July 2002 Statement on Peer Review serves as a mechanism as is intended to further enhance the quality of professional work of practising chartered accountants over a period of time. Thereby ensuring that the profession of chartered accountants continue to serve the society in the manner envisaged. Statement issued under Section 15 of the Institute of Chartered Accountants Act 1949 which provides that the duties of carrying out the provisions of the Act shall be vested in the Council. The section enumerates various duties of the Council. With a view to regulate the profession and in terms of powers vested, this statement has been issued.

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Paras in Statement on Peer review

1. 2.

3.

1. 2. 3.

Introduction Objectives Definition of Terms (Attestation Services Member, PU, Peer Review, Peer Review Board, Review of Technical Standards) Authority of the statement on Peer review Powers of the Council Peer review Board

7. Scope of peer review 8. Powers of Board 9. Compliance with this statement of Peer review 10. Qualifications of the reviewer 11. Members/ Firms subject to review

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Paras in Statement on Peer review contd.

12. Obligation of the practice17. Referral of Disputes and Appeals Unit 13. Periodicity of Peer Review (Reference to Peer Review Board over the powers of the 14. Cost of Peer Review Reviewer or to conclusions 15. Training and Development reached by Reviewer or any 16. Review Framework other matter related to Review) 18. Immunity (No liability of PU under Code of Ethics) 19. Confidentiality 20. Procedural departures 21. Budget and Finance 22. Secretariat. 15

NOTIFICATIONS AND CIRCULARS ISSUED BY THE PEER REVIEW BOARD

1.
Notification No: PRB/Notfn./001/02-03. issued on January102003 (Cost of Peer Review) Total Revenue from Attestation Service clients of practice units (Honorarium and TA/DA to Reviewer) 2. Notification No: PRB/Notfn./002/02-03. issued on January102003 (Criteria for Stage I, selection for Peer Review) 3. Notification No: PRB/Notfn./003/04-05. dated: 23rd July2004 (Cost for Stage II Review) 4. Notification No: PRB/Notfn./004/04-05. dated: 23rd July2004 (TA/DA for Branch Office of a PU)

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NOTIFICATIONS AND CIRCULARS ISSUED BY THE PEER REVIEW BOARD contd

5. Notification No: PRB/Notfn./005/04-05. dated: 23rd July2004 (Coverage Stage II limits) 6. Notification No: PRB/Notfn./006/04-05. dated: 23rd July2004 (Manner of Referral of disputes-to be filed within 60 days of the receipt of decision of the Board) 7. Notification No. PRB/Notfn./007/05-06. Dated March 27th 2006 (Stage III Cost of Review as per Stage II) 8. Circular No: PRB/Cir./001/02-03. issued on January10 2003 (Declaration to be filed by a Reviewer every year)
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Total revenue from Attestation service clients for Practice Units

Cost Maximum Limit (Range for all (Range Stages in Rs.) for all three Stages in Rs.) 25005000 500010,000 5000-10000 7500- 15000

Less than Rs 10 lacs p.a Between Rs. 10 lacs to 50 lacs p.a Above Rs. 50 lacs p.a.

7500- 15, 10000-20000 000

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Objective of Peer Review (Para 2.1 )

Assessing the maintenance of Quality of Attestation Service Engagements performed by Practice Units through: - Compliance with Technical Standards; and - Existence of proper system (including documentation systems) Not to find out deficiencies but to improve the quality of services rendered by the members Not to identify isolated cases of engagement failure, but to identify weaknesses that are pervasive and chronic in nature
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 Attestation Services Attestation Engagement Records for immediately preceding three completed financial years (Records prior to accounting year beginning 1.04.2002 shall not be subjected to review) Focus Technical Standards compliance Quality of Reporting Office Systems and Procedures (attestation services only) Staff training Programmes (attestation 20 services only)

Scope of Peer Review (Para 7.0)

Attestation Services (Para 3.1)

Include: Auditing or verification of financial transactions/ books/ accounts/ records Verification/ certification of financial accounting & related statements defined under Section 2(2)(ii) of the Chartered Accountants Act, 1949 Internal Audit/Concurrent Audit
Does not include: Management Consulting Engagements Representing a client before the Authorities Continued
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Continued Engagements to prepare tax returns or advising clients in taxation matters Engagements for the compilation of FSs Engagements solely to assist the client in preparing, compiling or collating information other than FSs Testifying as expert witness Providing expert opinion on points of principle (ASs or the applicability of certain laws) on the basis of facts provided by the client

Attestation Services (Para 3.1)

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Technical Standards (Para 3.7)

Accounting Standards Auditing and Assurance Standards Framework for the Accounting, Auditing & Related Services Statements Guidance Notes Notifications/Directions/Announcements including those of self-regulatory nature Relevant Statutes/ Regulations
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Reviewer: Para 10
An individual who is a member possess at least 10 years cumulative experience of audit Need not be continuous Audit experience of less than 2 years not counted currently active in practice of accounting and auditing Reviewer can also take assistance of a CA working with him atleast for one year.
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Allotment of Review Work

Receipt of Empanelment Form Issue of Empanelment Letter Filing of Declaration which is to the following effect: (i.) that no disciplinary action was pending (ii) have not been convicted by a competent court whether within or without India, of an offence involving moral turpitude and punishable with transportation or imprisonment or of an offence, not of a technical nature, committed by you in your professional capacity unless in respect of the offence committed you have either been granted a pardon or, on an application made by you in this behalf, the central government has, by an order in writing , removed the disability (the conviction here means conviction at the first court) Undergoing training Intimation of 3 names of reviewers to the PU Selection of a reviewer by the PU 25

Firms covered under Peer Review : Para 11

Stage I PUs conducting: Central Statutory Audit of Public Sector Banks/ Private Sector Banks/ Foreign Banks/ Public Financial Institutions Central Statutory Audit of Central & State Public Sector Undertakings and Central Cooperative Societies having paid up capital of over Rs. 5 crores and an annual turnover of more than Rs. 50 crores

Continued
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Firms covered under Peer Review contd

Central Statutory Audit of Insurance Companies Audit of Companies having paid up capital of over Rs. 5 crores and an annual turnover of more than Rs. 50 crores Audits or rendering attestation functions for asset management companies and mutual funds schemes (Implementation commenced from 1st April 2003)

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Firms covered under Peer Review contd

Stage II PUs conducting statutory audit: Branches of Public Sector Banks Branches of Private Sector and Foreign Banks Regional Rural Banks/Co-operative Banks Non-Banking Financial Companies (NBFCs) listed on the Stock Exchanges and not covered under Stage I
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Firms covered under Peer Review contd

Companies having paid-up capital of Rs. 2 to 5 crores and turnover above Rs. 20 crores (Implementation commenced from 1st April 2004) Stage III PUs not covered under Stage I or Stage II (Implementation to commence from 1st April 2005)

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Selection of PU

Random sample basis Stage I PUs, mandatory review once in a block of three years or at shorter intervals on request of the PU or decision of the Board Stages II/ III PUs - may not be subjected to review every three years

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Selection of PU contd.
Board decides the proportion of PUs to be reviewed during each phase A PU may also, suo motu, apply to the Board for the getting reviewed An auditee concern may request the Board for the conduct of peer review of its auditor (PU)

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Confidentiality: Para 19
Reviewers access only to working papers of the PU Reviewer cannot carry extracts of clients working papers & records acquired by him while conducting peer review, as part of his working papers Reviewer bound by a Code of Ethics Reviewer bound by secrecy provision enshrined in the Statement on Peer Review

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Format of Statement of Confidentiality To, The Chairman, Peer Review Board, The Institute of Chartered Accountants of India. New Delhi Sir, I hereby declare that my attention has been drawn to the need for confidentiality in the conduct of peer reviews. I therefore undertake and assure that in so far as any or all of the following relate to me or are brought to my knowledge/attention, in any manner whatsoever, when so ever, I will ensure that on my part Working papers shall always be kept securely so that unauthorized access is not gained by anyone. The practice unit's attestation services procedures shall not be disclosed to third parties. Any information with regard to any matter coming to my knowledge in the performance or in assisting in the performance of any function during the conduct of peer reviews shall not be disclosed to any person. Access to any record, document or any other material, in any form which is in my possession, or under my control, by virtue of my being or having been so appointed or my having performed or having assisted any other person in the performance of such a function, shall not at any time be permitted to any other person. I understand that any breach of the provisions regarding confidential information contained in the Statement on Peer Review will be considered as gross negligence and, subject to investigation, will result in appropriate action. Signature : Name : Designation : Date : Place : Taken on record on (date) By Signature : Name : Designation :

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FAQs

What is the time period for which records of attestation services are subjected to peer review? Ans : While attestation engagements for the Three immediately completed financial years are subjected to Peer Review, the records of audit Reports/ attestation services relating to years prior to the accounting year beginning 1st April2002 shall not be subjected to review.
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FAQs

How will a PU be selected for review? Ans: At each stage of Peer review , certain PUs , satisfying the criteria laid down in the statement would be selected for peer review on a random sample basis. The board is empowered to decide the proportion of Pus to be included in the selection during each phase of Implementation. A PU can also suo moto apply.
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FAQs

Can a reviewer visit clients of the PU Ans: No, he cannot , under any circumstances , communicate with or visit the clients of the PU Can a reviewer visit branches of a PU? Ans: Yes, he may visit a branch if the turnover of attestation functions of that branch is more than one million Rupees.

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Preliminary Report

After on-site review, reviewer may communicate with PU and seek clarifications and consider sending a preliminary report if replies not found satisfactory After on-site review, in case of deficiencies in systems and procedures or non-compliances the reviewer to issue preliminary report to PU immediately Reviewer to take care not to mention any names Scope of review performed and scope limitations, if any, to be mentioned
Continued
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Contd.

Prepare report on letterhead of reviewer (individual)

Dated/

signed

(Membership

no.

and

Reviewer code no.)

PU to reply in writing within 21 days of receipt of preliminary report on areas mentioned in it

Continued
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Interim Report

Reviewer to issue interim report if not satisfied with reply of the PU and deficiencies are of such serious nature that they do not ensure quality of attestation services performed by the PU -weakness in compliance with technical standards and/ or in internal quality control systems Report to clearly indicate "Interim Report" On receipt of interim report by the Board or receipt of response from the PU, the Board may instruct the reviewer to carry out a follow up review after a period ranging from 6 months to 12 months at the discretion of the Board

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Final Report
Reviewer to submit Final Report to the Board with a copy to the PU Final Report should incorporate the findings as discussed with the PU Final report to be submitted to the Board should also contain an annexure forming part of it w.e.f 1st July, 2005, notified on the Institutes website (See Page 43-45 of this presentation)

Continued
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Contd.

Reviewer may issue a clean report, if of the opinion that PU is conducting its affairs in a manner that ensures quality of services rendered by it a qualified report A qualified report may be issued: Non-compliance with technical standards QC system design deficiency Non-compliance with QC policies and procedures
Continued
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Contd.
Non-existence of adequate staff training programmes

The deficiencies are not of such serious nature to vitiate the efficacy of the key control objectives

The Board shall consider the report and if satisfied, will issue Peer Review Certificate If not satisfied, the Board may issue recommendations to the PU and direct the reviewer for further review

Continued
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Annexure to the Final Report of M/s___________________ General instructions: Tick Yes / No, wherever applicable. Sl. No. 1 2 3 (a) (b) 4 5 (a) Particulars Observations

Date on which questionnaire is received Number of initial samples selected for review Was there any change made in initial sample selected by the Reviewer? If Yes, specify the number selected, after change Name of the person (if any) who helped in the conduct of review Whether general controls are in existence and operating effectively during the period under review?

Yes

No

(b)

If No, please specify areas:

(i) Independence (ii) Professional Skills and Standards (iii) Outside Consultation (iv) Staff Supervision and Development (v) Office Administration

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6 7 8 9 (a) (b)

Whether audit records administration is satisfactory? Whether working papers are properly maintained? Whether review of internal control systems was carried out properly in performing attestation engagement? Whether proper systems and procedures exist within the PU to ensure compliance with technical standards? If No, specify areas: (i) Accounting Standards including Interpretations thereof (ii) Auditing and Assurance Standards including General Clarifications thereof Yes Yes Yes No No No

(iii) Statements
(iv) Guidance Notes (v) Institutes Notifications/ Directions (vi) Self Regulatory Measures 10 11 12 13 (a) (b) Whether overall presentation of financial statements conforms to statutory requirements of presentation under various Statutes? Whether audit conclusions drawn are duly supported by audit queries/observations? Whether the quality of audit reports in respect of format and content found proper? Whether the Reviewer has issued preliminary report? Whether the preliminary report issued by the Reviewer contained any deficiencies? Yes Yes Yes Yes Yes No No No No No

(c)

If Yes, please specify the areas of deficiencies .has responded to the preliminary report? Whether PU Whether the . Reviewer is satisfied with the response received from the PU? If the Reviewer is not satisfied with the response of the PU, whether interim report or qualified report has been issued? Is the Final Report qualified? If Yes, specify the reasons . . Reviewer received full co-operation from the PU? Whether the

14 (a) (b) 15 (a) (b) (c)

Yes Yes Yes Yes

No No No No

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during review Is there any point which the Reviewer wants to bring to the notice of the Board? If . yes,Please elaborate separately.

Yes

No

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Basic Elements of Reviewer's Report

Title Scope Paragraph Opinion Paragraph Limitations Suggestions Reference to preliminary report Date of the report
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Guidelines for Qualifying Review Report

Compliance with technical standards

Compliance with quality control policies Compliance with documentation Compliance with relevant regulations

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Illustrative Reports

See ICAI's Peer Review Manual Appendixes V to VII

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QUESTIONS! QUERIES! SUGGESTIONS!

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THANK YOU!

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