This report is an independent, qualitative and quantitative analysis by Gibson Dunn of the public responses to the Consultation Paper published by the Monitoring Group.
The volume and diversity of responses to the Consultation Paper made it clear that there was not only keen interest among a broad range of stakeholders but also a need for substantial analysis and interpretation of the feedback received. The goal in asking a respected, independent organization, such as Gibson Dunn, to undertake a fair and objective analysis was to provide a constructive contribution to this important ongoing dialogue.
- This report reviews and summarizes the public comments submitted in response to the recent Consultation Paper published by the Monitoring Group, Strengthening the Governance and Oversight of the International Audit‐related Standard‐setting Boards in the Public Interest.
- The Monitoring Group is responsible for the overall governance of the process used to set international auditing standards and international ethics standards for accountants, and the overall governance of setting international accounting education standards. The Monitoring Group is a collaboration of a number of international financial institutions and regulatory bodies.The Monitoring Group’s Consultation Paper (Consultation Paper) has as its primary stated purpose to help ensure that international standard setting serves the public interest. Among other things, the Consultation Paper expresses concern with possible undue influence —and the perception of undue influence— by the accounting profession on the development of standards, as well as concern with the relevance and timeliness of the standards established under the current standard‐setting process.
- In response to these and other concerns, the Consultation Paper suggests several changes to the current international standard‐setting process related to audits and ethics for accountants, andseeks views on whether there should be continued public‐interest oversight of international standard setting for accounting education. The proposed changes include altering:
- the number of and the responsibilities of the standard‐settingboards;
- the process for choosing the members of the standard‐settingboards;
- the size and composition of the standard‐settingboards;
- the focus of the standard‐settingboards;
- the remuneration of board members;
- the standard‐settingboards’ voting procedures;
- the role and composition of the body tasked with overseeing the standard‐setting boards; and
- the standard‐settingboards’ source of
This report summarizes and analyzes the positions taken in the comments submitted with respect to each of these proposed changes. The report also examines the positions taken by commenters on broader issues raised by the Consultation Paper:
- whether there are problems with the current standard‐setting process; and
- whether the principles regarding public interest discussed in the Consultation Paper should form the foundation of a yet‐to‐be developed public‐interest framework, which then could be used as a rubric for proposing and evaluating changes to the standard‐setting
This report refers to these 10 issues (the 2 broader questions and the 8 proposed changes listed above) as “topic areas”.
- To date, the Consultation Paper has elicited 179 public comments, representing views from commenters across a wide range of geographies and stakeholder groups. As discussed in the body of the report, commenters positions varied widely on the different topic areas of the Consultation Paper, but generally provided significant criticism of the broader changes proposed by the Consultation Paper. In contrast, a few of the less controversial, operational recommendations in the Consultation Paper received favorable comments from a majority of commenters addressing those recommendations.
- Section II of this report contains an executive summary that describes the current standard‐setting process; provides a detailed summary of the Monitoring Group Consultation Paper; recounts the timeline of the release of the Monitoring Group Consultation Paper and the subsequent meetings held to discuss the Consultation Paper; explains the methodology used in this report to analyze the comments to the Consultation Paper; and provides a summary of the commenters’ observations and positions in response to the Consultation Paper, as well as commenters’ proposals for next steps.Section III begins with a summary of the general degree of support expressed in the comments for the Consultation Paper’s various proposals and a description of the recurring themes in the comments. Section III then provides in‐depth analysis on the comments in each of the 10 selected topic areas included in the Consultation Paper, providing a quantitative description of the commenters’ positions as well as a qualitative summary of the reasons the commenters gave to support their positions.Section IV summarizes the next steps proposed by the comments. Section V concludes this report with a brief summary of the commenters’ reactions to the Consultation Paper, identifying those topic areas for which the Consultation Paper’s positions received widespread support and identifying those topic areas for which additional discussion and deliberation are encouraged to reach consensus. Finally, Section VI includes appendices that provide additional detail regarding the geographic regions and stakeholder groups of the commenters.
A Summary of Public Comments on the MG