2014年-IMF国际货币组织全球_Proposed_Modification_of_the_Policy_on_Provision_of_Consulting_Services_by_the_External_Audit_Firm_23页_514kb

IMF Policy Paper Summary: Proposed Modification of the Policy on Provision of Consulting Services by the External Audit Firm

Core Content

This document outlines the IMF's proposed modification to its policy on the provision of consulting services by the external audit firm. The main goal is to align the Fund's policy with international standards and reduce the risk of compromising auditor independence.

Main Views and Key Points

1. Policy Change Overview

• The current blanket prohibition on non-audit-related consulting services by the external audit firm is proposed to be replaced with a blacklist approach.
• The blacklist would include services that could threaten the independence of the external audit firm, such as bookkeeping, financial statement preparation, internal control design, and advisory services.
• The policy change would be implemented before the upcoming mandatory rotation of the external audit firm.

2. Key Safeguards Proposed

• Independence Declaration: Audit firms must declare their independence and internal controls before entering into any consulting service contract.
• Fee Limitation: The total consulting fees for the external audit firm should not exceed 70% of the audit fees over the same contract period.
• EAC Oversight: The External Audit Committee (EAC) would be involved in reviewing all proposed consulting services and providing written opinions to the Executive Board.
• Review of Existing Services: Before selecting a new external audit firm, the EAC would review all existing consulting services provided by potential bidders to ensure compliance with the new policy.

3. Global Context

• The proposed policy is consistent with international practices, including those in the United States, European Union, China, Japan, and Mexico.
• The U.S. Sarbanes-Oxley Act and the EU's amended Directive on Statutory Audit serve as references for the blacklist and fee cap approach.

4. Implementation Modalities

• The implementation would require close coordination between the IMF staff, particularly the TGS procurement and Finance Department, and the EAC.
• The process would include:
  • Identifying audit firms eligible for future contracts.
  • Clarifying blacklisted services.
  • Assessing fee consistency with the cap.
  • Preparing independence declarations.

5. EAC Views

• The EAC supports the proposed changes and believes the safeguards are sufficient to maintain auditor independence.
• The EAC also recommends strengthening its role, such as prolonging the term or increasing the number of members, to handle the increased workload.

Proposed Decision

The following decision is proposed for adoption by the Executive Board:

• Paragraph 3 of Decision No. 13323-(04/78) is amended to allow the external audit firm to provide consulting services subject to specific conditions.
• Paragraph 4 is deleted.

Amended Paragraph 3

• The external audit firm may provide consulting services to the Fund if they are not on the blacklist and do not compromise independence.
• A written declaration of independence must be provided.
• Consulting fees should not exceed 70% of audit fees.
• The EAC must review and approve all consulting services within the 70% cap.
• In exceptional circumstances, the Executive Board's approval is required for fees exceeding the 70% cap, but not more than 100% of audit fees.
• The EAC must report on audit and consulting fees and confirm independence in its annual report to the Executive Board.
• The EAC must provide an opinion on whether existing consulting contracts could compromise independence if the firm is selected as the new external audit firm.

Key Information

• Blacklist Services: These are services that could result in self-review, self-interest, or management responsibility, such as bookkeeping, financial statement preparation, and internal control design.
• Fee Cap: The proposed cap of 70% is intended to ensure that the audit remains the primary focus of the external audit firm.
• EAC Role: The EAC will have an explicit oversight role, including reviewing proposals, providing opinions, and confirming independence.
• Consulting Services Review: All consulting services provided by the current and potential external audit firms will be reviewed to ensure they do not compromise independence.
• Implementation Timeline: The new policy is intended to be applied before the next external audit firm rotation, which occurs every ten years.

Attachments

• Attachment I: Revised version of Decision No. 13323-(04/78) with the proposed amendments.
• Attachment II: Comparison of non-audit service restrictions across selected countries.
• Attachment III: Sample declaration of independence by audit firms.
• Attachment IV: Analysis of consulting fees from FY 2010 to FY 2014, showing that they were generally below the 70% cap.