Specialist Assignment Manual News Welcome to the July 2014 edition of our Specialist Assignment Manual (SAM) newsletter. Inside you will find a review of the updates that have been issued to your manuals over the past 12 months, as well as news about the changes you can expect to see in the year to come. Please forward this newsletter on to any colleagues at your firm who might also find it useful. Keeping you up to date Looking forward at this time last year we noted that the focus of our technical manual updates was set to change, with accounting moving into the spotlight as decisions about the future of UK GAAP were made. Another 12 months on and while we of course now have the suite of FRSs that make up the future of accounting (the ‘new UK GAAP’), the last 12 months have seen consultations begin on how this will be reflected in the SORPs that provide guidance for a number of specialist sectors. As these become finalised over the remainder of 2014, we will incorporate the changes needed into 2015 updates to your SAMs, in time for mandatory adoption for periods commencing on or after 1 January 2015. Waiting for various legislative changes for small companies that might potentially take effect has also been something of a theme in recent newsletters. 2013 saw the legislation on ‘microentities’ introduced but we are still waiting to see how the new EC Accounting Directive will be implemented in the UK. Doubts over the long-term future of the FRSSE have also been raised this year. You can find out more under ‘Audit Exemption’ below. More generally this year we sent email alerts to subscribers of relevant SAMs in respect of: Academies As the academies sector continues to evolve, subscribers to the Academies SAM will start to see more primary converters and multi-academy trusts than in previous years. Though this change to the dynamic of the sector is relatively recent, one thing that has not changed is the high level of public scrutiny into academies, with connected party transactions likely to be a particular area of focus in accounts to August 2014. The Academies Financial Handbook, effective from 1 September 2013 included relaxations to rules that may have impacted on regularity reporting in previous years. This, however, was contrasted by an increased focus on sponsor provided • Statutory Instrument 2013/1970 - The Companies Act 2006 (Strategic Report and Directors’ Report) Regulations 2013), which you may recall from the August 2013 email alert affects narrative reporting requirements for limited companies; and • the revised ISA+ 700 series, which you may recall from the October 2013 email alert affects the scope of your audit reports. As updates incorporating these changes are rolled out, we have also been taking the opportunity to make a number of nontechnical improvements to our audit documentation following changes made in our corporate audit manual. These have resulted from feedback received from subscribers and also from audit quality monitoring file reviews. Finally, looking ahead we will be in touch later in the summer with details of a new SAM to add to our range, covering Assurance. With an ever-increasing number of companies no longer requiring an audit, the option of providing an New alternative, less expensive assurance service Assur could be an attractive option for these clients SAM ance comin as well as your firm. g services, noting that they must not include any element of profit. A further revision to the Handbook, effective 7 November 2013, then cast the net a little further with requirements for all connected party transactions to be conducted ‘at-cost’. The Accounts Direction 2013 to 2014, released in May 2014, also included additional ‘transparency’ requirements for related party transactions disclosures in 2014. These changes complement other amendments made to help focus the work of regularity assurance engagements; improve auditor reporting of issues and enhance transparency within a number of other sensitive accounts disclosures. What’s next? Key developments noted above have been reflected in the July 2014 update (5.0) to the Academies SAM. Headline changes included updated regularity risk assessments and example procedures, essential engagement letter updates and amendments to the accounts disclosure checklist. Subscribers will also see enhanced auditor communication templates to help adhere to best practice recommendations outlined by the Education Funding Agency (EFA). soon! Though, for many, August 2015 may seem dim and distant on the horizon, it is worth noting that a handful of new academies will be amongst the first entities required to apply the new UK GAAP next year. For a majority of academies, however, the first relevant set of new UK GAAP accounts will be for August 2016. We will keep you updated with the EFA’s plans for adoption of a new Charities SORP (or SORPs), as they develop, over the next 12 months. The new UK GAAP If you need to find out more about the new UK GAAP and the changes it will bring, take a look at the free downloads included on our new UK GAAP website page. Following an overview in January, ‘Changes in financial reporting. The time to act is now...’ we have been taking a closer look at a number of areas relating to the most comprehensive changes to accounting requirements in a generation. Audit Exemption It has been another busy year for the Audit Exemption SAM, with the introduction of a subcategory of small company known as a ‘microentity’ and the expected narrative reporting changes implemented. Following the August 2013 email alert outlining the narrative reporting changes, version 11.0 (December 2013) of the Audit Exemption SAM contained changes which reflected SI 2013/1970 as well as SI 2013/3008 - The Small Companies (Micro-Entities’ Accounts) Regulations 2013, which introduced the new reporting framework for the UK’s smallest companies (‘micro-entities’), essentially for financial years ending on or after 30 September 2013. SI 2013/3008 amends the Companies Act 2006 and the Small Companies and Groups (Accounts and Directors’ Report) Regulations 2008 to allow qualifying micro-entity companies to prepare and publish simplified primary financial statements with a very limited number of notes instead of the usual small company accounts for members. The updated manual contained guidance, proforma accounts and a disclosure checklist for companies adopting these micro-entity provisions. At the time of publication, the FRSSE had not been updated for the micro-entity provisions. Once it had been updated, following consultation, a minor update (version 11.1, revised May 2014) to the manual was issued, reflecting the changes made in the FRSSE. At this stage we also revised our Micro-Entities Q&A and Sample Accounts download, published in our May 2014 Newswire. Registered Social Housing Providers (RSHP) Version 7.0 of the RSHP SAM was issued in May 2014. The update incorporated guidance from the new version of Practice Note 14 published by the FRC - The Audit of Housing Associations in the United Kingdom. It also reflected updated guidance from the Homes and Communities Agency (HCA) - Regulating the Standards 2014, as well as the general updates and improvements being made across Mercia’s range of audit manuals. Looking ahead In accordance with the advent of new UK GAAP, the new RSHP SORP is expected to be published in autumn 2014. The HCA has also announced that a new Accounting Direction will be issued to reflect the changes. Ahead of this we will be updating the manual for changes resulting from the introduction of the Co-operatives and Community Benefit Societies Act 2014 discussed under ‘Clubs and Friendly and Industrial and Provident Societies’ below. What’s next? Estate Agents You may recall that back in 2013 the European Council, Parliament and Commission reached a compromise agreement on the new EC Accounting Directive. The implications of the new Directive were potentially far reaching. The text includes provisions which could increase the small company limits for turnover and balance sheet total and reduce the length and complexity of small company statutory accounts. Or should we say ‘Property Professionals’ as this will be the new name for this SAM when the next update is issued later in July. The manual is being expanded to include guidance and documentation for clients who are members of the Association of Residential Managing Agents (ARMA), as well as for those who have been asked to provide a factual report of findings on service charge accounts. We have been expecting the government to consult on the implementation of these provisions in the UK for some time now. As we await this consultation from BIS, the FRC has also outlined the scope of its own summer consultation on the future of the FRSSE. Further to seeking views on plans to bring small entities within the scope of FRS 102 (with reduced disclosures), views on a new Financial Reporting Standard for Micro-entities (FRSME) will also be sought. The FRSME would be based on the micro-entities regime, currently reflected in the FRSSE and may include further recognition and measurement simplifications. We can expect to see these consultations issued alongside each other over the summer. Further updates to the Audit Exemption SAM will follow. What’s next? You can see what our technical team think of the on-going changes affecting small companies in their blogs. We still await final guidance on the statutory accounts of Residential Management Companies! The withdrawal of UITF Draft Abstract 49, and subsequently FRED 50 (Draft FRC Abstract 1), have again left this area in doubt. The FRC has indicated that it will look to provide some guidance in the specialised activities section of FRS 102 in the future. We will keep you up to date with any developments. The guidance provided for ARMA clients in the forthcoming update covers the current requirements. Those already acting in this area may be aware that a new system, ‘ARMA-Q’, will arrive in January 2015. Your manual will be updated to reflect the changes introduced as they happen. Clubs and Friendly and Industrial and Provident Societies Changes are afoot for industrial and provident societies as we finally see some long-awaited legislative changes take place. The Co-operatives and Community Benefit Societies Act 2014 received Royal Assent in May 2014. As it is a consolidating Act, the 1965, 1967, 1975, 1978 and 2002 Industrial and Provident Societies Acts; the Friendly and Industrial and Provident Societies Act 1968; the Co-operatives and Community Benefit Societies Act 2003 and parts of the Co operative and Community Benefit Societies and Credit Unions Act 2010 will be repealed and replaced with the new Act, which comes into effect on 1 August 2014. As it is consolidating legislation, the new Act will not bring about substantive changes to the law. Its aims are to reproduce the effects of the existing legislation but use updated and simplified language where possible. We are updating your SAMs to take account of the new Act and adding supplementary documentation on Community Interest Companies to the FIPS SAM. The updated SAMs will be with you later in the summer. 2 Solicitors’ Accounts Rules Charities The current version of the Solicitors’ Accounts Rules SAM (7.0) was issued in November 2013. We were able to remove all references to the now expired 1998 Solicitors Accounts Rules in this update. Up until fairly recently, it had been a quiet year and despite the Solicitors Regulation Authority (SRA) issuing version 10 of the SRA Handbook in July 2014, there have been no changes to the Accounts Rules. However, this all looks likely to change in the not too distant future. The main update to the Charities SAM issued in March 2014 incorporated the general improvements being made across our range of specialist audit manuals, as well as the technical changes affecting audit reports and corresponding documents. Looking ahead The SRA is continuing its process of regulatory reform and at the time of writing, there are two closed consultations, the results of which are being analysed and which look likely to impact on the work that you undertake for solicitors. The first, relatively minor proposal is to make changes to the rules regarding residual balances. Currently, Rule 20.1(j) allows residual balances below £50 to be paid to charity without permission from the SRA provided the solicitor has made a reasonable attempt to repay them to the client. The proposal is to increase this figure to £500. At the same time, the question as to whether there should be some restriction on the nature of the charity, for example those involved in access to justice issues, is being considered. The future of the Accounts Rules? The second, and much more fundamental matter under consideration, is whether to remove the mandatory requirement for all firms of solicitors who hold client money to submit an annual accountant’s report to the SRA. It is proposed to replace this with the requirement for the COFA to sign an annual declaration that client money is being managed satisfactorily. The SRA may impose requirements for an external accountant’s report but this would be on a risk basis rather than the current blanket requirement. The suggested timescale, should this proposal be accepted, is October 2014, although it is not clear whether this applies to accounting periods ending or reports submitted after this date. Not surprisingly there is a great deal of opposition to this proposal from many in the accountancy profession who feel that client money will be put at risk without the discipline of external scrutiny and we have submitted our views on this to the SRA. If, however, this proposal is implemented in its current form there will clearly be a significant impact for you and your clients. Whilst some solicitors will see the benefit of retaining an external and independent check on their handling of clients’ money and continue to require some form of accountant’s report, it is likely that others may not. For those that do continue to have external scrutiny (either voluntarily or because of SRA requirement) the nature of the assignment may be somewhat different from the current, very specific, rules based approach. Once the outcome of the consultation is known we will be able to consider the impact on your manual and make any necessary changes to enable you to respond as required. This update also dealt with the changes relevant to charitable companies in light of the SI 2013/1970. You may recall that these regulations require medium and large sized companies to include a Strategic Report, rather than a business review, within their financial statements. In light of this change the Charity Commission (CC) and the Office of the Scottish Charity Regulator (OSCR) published specific supporting guidance for charities in a new SORP Information Sheet (5), which was incorporated into the update. Changes in regulation in Northern Ireland were also covered in this update. The current version of the manual (10.1) revised the March 2014 update, in a small number of areas, in May 2014 following the publication of FRC Bulletin 4, which affected the limited company audit reports in the manual. What’s next? The FRC Board has already considered and approved the Charities SORP for the new Financial Reporting Standard (FRS 102) as well as the Charities SORP for the Financial Reporting Standard for Smaller Entities (FRSSE)! Having two SORPs in this way is something of a change for the sector, although with the future of the FRSSE currently uncertain, the longevity of the FRSSE SORP is unclear. The new SORPs are expected to be published shortly. Limited Liability Partnerships (LLP) Version 9.0 of the LLP SAM was issued in March 2014. This update reflected the improvements and general updates being made across Mercia’s range of audit manuals. We will have to wait and see if the changes introduced for micro-entity companies discussed under ‘Audit Exemption’ above are applied to LLPs, as they have not been to date. What’s next? We will be looking out for the publication of the final LLP SORP, following the autumn 2013 consultation on the new UK GAAP update. Other changes that may affect limited companies over the next 12 months are also likely to affect LLPs, so we will be looking out for news on the implementation of EC Accounting Directive in the UK, as well as news about the FRSSE as discussed under ‘Audit Exemption’ above. Details of this consultation can be found on the SRA’s website. Stop Press! The SRA Board met in early July to discuss the changes to reporting accounting requirements and decided to defer a decision on this proposal until its next meeting. The Board recognised the need to ensure that, where firms choose to hold client money, appropriate safeguards are in place to assure the safety of that money. Further analysis of the consultation responses and consideration of options will be undertaken before the Board reaches its decision. Keeping up to date Remember that you can check that you are using the latest versions of our manuals on our website at www.merciagroup.co.uk/technical_ manuals/updates.htm 3 Financial Conduct Authority regulated firms Following the significant changes to the overall regulation of the financial services sector that took place on 1 April 2013, including the introduction of the Financial Conduct Authority (FCA), detailed changes to the CASS rules were expected to follow in due course. As you will know from our recent email alert, for DIFs, the wait is over! FCA Designated Investment Firms (DIFs) On 10 June 2014, the FCA issued Policy Statement 14/9, which introduces widespread changes to the CASS rules for investment business. The changes are being introduced in three phases: from 1 July 2014, 1 December 2014 and 1 June 2015 (the latter date representing the bulk of the substantial change). Whilst these final rules have been anticipated for some months, the publication of PS 14/9 allows little time before the first changes take effect. We will be updating the reasonable assurance programmes contained in your SAM as needed for the first phase of changes over the summer. FCA Mortgage and General Insurance Intermediaries (MGIs) Widespread changes to the CASS 5 rules for insurance intermediaries were expected following Consultation Paper 12/20 (August 2012) but these have not yet been announced and it is not clear what the expected timetable will be. Mortgage intermediaries have, however, been getting to grips with the Mortgage Market Review (MMR), a thorough review of the way in which mortgages are sold to the public, similar to the Retail Distribution Review (RDR) that has effected sweeping changes for financial advisers. The MMR largely took effect at the end of April 2014. It does not directly affect your work for MGI clients but should provide some key talking points when understanding changes in their business. Pension Schemes Accessing your manuals online The next update to the Pension Schemes SAM will reflect the general improvements being rolled out across our specialist audit manuals. Following that, we will await the publication of a finalised Pensions SORP, updated for the new UK GAAP. The Pensions Research Accountants Group (PRAG) has now published an Exposure Draft of this, with the exposure period closing later in July 2014. Email alerts announcing the release of an update will continue to be sent to the email contact supplied to us either through your initial order or by subsequent instruction from you. Over the next 12 months we will replace our follow up letter system with a second reminder email alert that an update has been issued. Specialist Conferences and Training It is therefore as important as ever that you keep us up to date with your contact details. Should these change, please let Karina Johnston know, in writing, by email at karina@mercia-group.co.uk or by fax on 0116 258 1250. We run a number of courses over the year that cover specialist sectors through our specialist course programme as well as specific conferences and webinars. Details of our current programme can be found on our website. Solicitors Conference 2014 For Accountants with Solicitor Clients An essential practical update covering: ¡ An update from the SRA ¡ ‘Survive and Thrive’ the New Legal Market ¡ Improving Financial Results through Risk Management ¡ Professional Indemnity Insurance ¡ COLP and COFA update ¡ Partnerships and LLPs – the Tax changes Follow us on Twitter @merciagroup Read our Blog on “Best solicitors conference that I have attended.” James Burrett, Peters Elworthy & Moore www.mercia-group.co.uk/blog Like us on www.facebook.com/merciagroup The Midlands 14 May 2014 Hilton National, East Midlands For more information on QR Codes, please visit www.mercia-group.co.uk/blog For further details on this conference please contact Felicity Kedward on 0116 258 1200 or email felicity.kedward@mercia-group.co.uk Full Day Conference £290 (including lunch) plus VAT per person £50 for MembershipPLUS • 25% Discount for Members www.mercia-group.co.uk Mercia’s paperless audit software partners An increasing number of firms are introducing paperless audit software to their practices in order to improve efficiency. At Mercia we have believed in this concept for a long time and have worked closely with three software houses to develop truly paperless audit systems. We believe these three approaches offer firms a choice of platforms from which to use the Mercia audit methodology. You can find out more on our website at www.mercia-group.co.uk and also from our partners’ websites below. If you would like to discuss the options available please contact David Smith or Emma McDonough on 0116 258 1200. Caseware Paperless Audit CCH Audit Automation IRIS OpenAudit Visit www.caseware.co.uk Visit www.cch.co.uk Visit www.iris.co.uk Disclaimer - for information of users: This newsletter is published for the information of clients. It provides only an overview of regulations in force at the date of publication and no action should be taken without consulting the detailed legislation or seeking professional advice. Therefore no responsibility for loss occasioned by any person acting or refraining from action as a result of the material contained in this newsletter can be accepted by the authors or the firm. 4
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