Audit reporting rules could see duel accounting

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Montgomery concedes that auditor liability is a "difficult and complex" issue and auditors seem split on what they make of it. Some, such as Richard Sexton, head of reputation and policy at PwC, perceive it as a threat that the profession is "willing to manage", while others, such as Herbinet, think it could actually limit liability.

"Clearly, auditor liability needs to be put on the table and should not be ignored. It may be that the more auditors disclose the less liability they will face," Herbinet says.

There is also a fear that provision of certain information could end up competing with management's disclosures, thereby resulting in "duelling information" representing two versions of the truth.

According to Montgomery, duelling information will be impossible to avoid. However, most of the issues thrown up can be dealt with by the right level of communication between auditors, management and those charged with governance, while Sexton says there should be a clear demarcation between the statements being made by auditors and management.

"Ideally, the auditor's commentary is designed to draw attention to things already discussed in the financial statement. It should point attention towards key disclosures," Sexton says. "I don't think it is a case of two versions of the truth."

There is also a risk of increasing the expectation gap, to the extent that readers interpret the inclusion of auditor commentary as providing assurance on individual accounts or disclosures, while the fear of standardised wording creeping in and auditor statements reverting to boilerplate is never far away.

It is hoped that the risk of boilerplate should be negated because auditors are commenting on client-specific audit issues, but many of the issues will nevertheless crop up on a company-by-company basis – such as goodwill impairments, financial instruments and the valuation of intangibles.

Once again, this is an issue the IAASB recognises as needing some clarification – auditors would not be expected to create new language to add to the wording of the report – particularly around differences in how boilerplate is viewed.

"I don't think all users' view is the same," says Montgomery. "If you look at some of the more standardised language in the audit report, such as auditors' responsibilities, most agree that uses boilerplate language.

"But even if auditors might comment in largely the same way on the same type of matters, some have indicated they don't believe that to be boilerplate. They perceive value in auditors commenting on these areas that users might find important."

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