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Structure of the Code

Don ThomsonIESBA March 2013New York, USA

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• February 2012: How to improve structure of Code to raise the visibility of its requirements and prohibitions, and clarify who is responsible for meeting them.

• June 2012: An example of a possible reformatting approach. Additional clarity steps should be considered.

• December 2012: Briefly discussed aspects of this initiative and supported establishment of the Working Group.

BackgroundStructure of the Code

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• Limited to brief agreed in February 2012, visibility and responsibility, or extended to clarity and understandability?

• Propose: Scope of initiative should address broader matters of clarity and usability.

• Changes to enhance clarity and usability may impact interpretations.

• Consider whether any changes would be better handled by separate projects.

Proposed Terms of ReferenceStructure of the Code

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• “The Working Group will focus in particular on drafting conventions, format, structure, and delivery media taking into account impediments identified by stakeholders. It will develop and validate findings and recommendations based on research and communication with stakeholders.”

Proposed Terms of Reference: ApproachStructure of the Code

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• Member Bodies, in conjunction with CAP• Regulators• IESBA CAG• NSS liaison group• Firms• IFAC SMP Committee• IFAC PAIB Committee

Research PlanStructure of the Code

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• Drafting Conventions: e.g. drafting conventions to encourage the use of plain English and to discourage long and complex sentences.

• Reformatting: e.g. visibility of the requirements and prohibitions in the Code.

• Responsibility: e.g. who should bear responsibility for complying with the requirements and prohibitions in the Code.

Key Elements - Short TermStructure of the Code

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• Restructuring: e.g. incorporating Part C within Part A. • Packaging: e.g. separating the Code into distinct booklets. • “Clarity” project: e.g. a project similar to IAASB or

complementary materials. • Delivery Media: e.g. electronic Code.

Key Elements - Longer Term Structure of the Code

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• September 2013: A status report.• December 2013: A preliminary report on the findings of the

research.• March 2014 A final report and recommendations of short

term and longer term elements, and draft consultation paper on the longer term elements.

• June 2014: Final draft of the consultation paper on the longer term elements for approval.

Proposed TimelineStructure of the Code

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IESBA members are asked to comment on:• Proposed Terms of Reference. • Research plan.• Key elements.• Any other key elements.• Timeline.

Questions for IESBAStructure of the Code