Client Acceptance and Continuance: Good Practice Guidance

Good Practice Guidance
October 2010
Client Acceptance and Continuance
Forum of Firms
International Federation of Accountants
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New York, New York 10017 USA
The mission of IFAC is to serve the public interest, strengthen the worldwide accountancy
profession and contribute to the development of strong international economies by establishing
and promoting adherence to high quality professional standards, furthering the international
convergence of such standards and speaking out on public interest issues where the professions
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The objective of the Forum of Firms is to promote consistent and high quality standards of
financial reporting and auditing practices world-wide.
Members in the Forum1 have committed to adhere to and promote the consistent application of
high quality audit practices worldwide, including the use of International Standards on Auditing,
and the maintenance of appropriate quality control standards in accordance with International
Standards on Quality Control issued by the International Auditing and Assurance Standards
Board. Through their organizations, members also conduct globally coordinated internal quality
assurance reviews on a regular basis and have policies and methodologies which conform to the
International Ethics Standards Board for Accountants Code of Ethics for Professional
Accountants (IESBA Code).
The Transnational Auditors Committee is the executive committee of the Forum of Firms.
Further information about both can be located at http://ifac.org/Forum_of_Firms/.
This publication may be downloaded free of charge from the IFAC website: http://www.ifac.org.
The approved text is published in the English language.
Copyright October 2010 by the International Federation of Accountants (IFAC). All rights
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ISBN: 978-1-60815-070-0
1
See Appendix 2 for a listing of Full members as of January 1, 2010.
TRANSNATIONAL AUDITORS COMMITTEE

GOOD PRACTICE GUIDANCE
CLIENT ACCEPTANCE AND CONTINUANCE
CONTENTS
Page
Background .................................................................................................................................... 4
Introduction .................................................................................................................................... 5
Approach ........................................................................................................................................ 6
1. Client Acceptance .................................................................................................................... 7
A. Determining the Integrity of the Prospective Client .......................................................... 7
B. Determining Competency of the Firm to Perform the Engagement ................................ 17
C. Compliance with Ethical Requirements ........................................................................... 20
D. Additional Considerations with Client Acceptance ......................................................... 25
2. Client Continuance ................................................................................................................. 28
Appendix 1: External Inspection Reports Reviewed ................................................................... 32
Appendix 2: Full Members of the Forum of Firms (as of January 1, 2010) ................................ 33
Appendix 3: Comparison of Client Acceptance and Continuance Requirements ....................... 34
Appendix 4: Obligations of Membership to the Forum of Firms ................................................ 38
Appendix 5: Requirements of ISA 220, Quality Control for an Audit of Financial
Statements, and ISA 600 Special ConsiderationsAudits of Group
Financial Statements (Including the Work of Component Auditors) ...................... 39
Appendix 6: Guidance in A19 of ISQC 1 .................................................................................... 40
Appendix 7: Guidance in A18 of ISQC 1 .................................................................................... 41
Background
Delivery of high quality services is the driver of success for all professional services firms.
Quality service is important to maintaining client satisfaction, delivering value for money and
establishing professional reputation. For professional accountancy firms2 (and audit firms in
particular), delivering quality service is at the core of the business strategy, and is essential to
satisfy the public interest responsibilities of professional accountants.
As part of its ongoing work program, the Transnational Auditors Committee (TAC) regularly
reviews the inspection reports published by external audit oversight boards and regulators. The
objective of this review is to identify findings common across jurisdictions and to evaluate
whether additional guidance would benefit the members of the Forum of Firms.
One of the issues highlighted in recent reviews of these reports (two reviews were performed in
2008 and 2009)3 related to audit firms and their performance of client acceptance and
continuance procedures. The reviews findings with respect to client acceptance and
continuance included, among other things, matters related to the completeness of documentation,
timeliness of performance of acceptance and continuance considerations and audit team
competency.
Both in response to this and the key role well-developed client acceptance or continuance
procedures play in the overall quality of an audit, the TAC has undertaken to explore current
practice among members of the Forum of Firms. This good practice paper has been prepared
based on the input of 14 Forum members, representing international networks of varying sizes.
Where necessary, Forum members granted interviews and supplied background materials which
have been summarized in this paper on a non-attributed basis.
The TAC believes this paper will be a valuable tool for audit firms of all sizes, in developing and
evolving their policies on client acceptance and continuance, thereby demonstrating their
ongoing commitment to enhancing audit quality.
Due to the variety of sources used to compile this paper, a number of different terms are used to describe the
relevant organization. There is no intent to be either consistent or prescriptive in the usage of terms such as
Firms, members, networks, organizations, etc. Such terms should be interpreted in their customary meaning and
in the particular context.
See Appendix 1 for the listing of External Inspection Reports.
Introduction
Why are client acceptance and continuance policies and procedures so important and
relevant to audit firms?
As discussed in a publication issued by the TAC entitled Tone at the Top and Audit Quality,
Firms note that quality is viewed as a requirement in everything that they do. Notably, quality is
identified as being an essential component of a firms reputation and a prerequisite for a firms survival
and growth.4
As further noted in the same publication:

Firms expect the same commitment to quality and integrity on the part of their clients as they do of
themselves. As a result, many firms have developed and implemented enhanced processes for reviewing
and approving new clients as well as reviewing relationships with existing clients. Several firms state
that they will and have resigned from a client when the client does not meet the firms high standards, or
when the firm cannot commit sufficient resources to deliver quality services to the client.5
From an audit engagement perspective, the absence of a genuine joint commitment to optimal
quality can lead to difficult auditor-client relationships, severe damage to the firms professional
reputation and the profession generally and ultimately to a loss of public confidence. Possessing
as much information as necessary to make an informed assessment about the acceptability of the
potential client and the ability of the audit firm to perform a quality audit helps ensure the
relationship is as beneficial as can befor both the auditor and the client. Bottom line, its just
makes good sense.
As noted in a publication from the American Institute of Certified Public Accountants:
Prudent risk management requires that a firm know as much as possible about what will be involved
with a new client relationship or engagement before the agreement is in place. Not having made a
diligent risk assessment by performing timely client and engagement acceptance procedures almost
guarantees that surprises will follow. And, the result may not only involve an unplanned relationship
termination but could also include significant professional liability issues and concerns. 6
Transnational Auditors Committee, Tone at the Top and Audit Quality, December 2007, Page 10
Ibid, page 12
McFadden, John E, Client and Engagement Acceptance: Only a Public Company Audit Service Concern? The
Practicing CPA, July-August 2003, Volume 27, Number 6
5
Approach
There are several standards published by the International Auditing and Assurance Standards
Board (IAASB) which address client acceptance and continuance. These are:
International Standard on Quality Control (ISQC) 1, Quality Control for Firms that Perform
Audits and Reviews of Financial Statements, and Other Assurance, and Related Services
Engagements;7 and
International Standard on Auditing 220, Quality Control for an Audit of Financial Statements
Further, with respect to the audits of group financial statements, the IAASB has issued:
International Standard on Auditing 600: Special ConsiderationsAudits of Group Financial
Statements (Including the Work of Component Auditors).
Members of the Forum of Firms have committed8 to maintaining appropriate quality control
standards in accordance with ISQC 1 and, through their commitment to having policies that comply
with the ISAs, in accordance with ISA 220 and 600. The latter standards address acceptance and
continuance requirements at the engagement level rather than the firm level, but of course those
requirements fit within the firms overall quality control processes. As such, for convenience, the
requirements particularly of ISQC 19 provide much of the structure in this paper. ISQC 1 states:
26.
27.
The firm shall establish policies and procedures for the acceptance and continuance of client relationships
and specific engagements, designed to provide the firm with reasonable assurance that it will only undertake
or continue relationships and engagements where the firm:
(a)
Is competent to perform the engagement and has the capabilities, including time and resources,
to do so; (Ref: Para. A18, A23)
(b)
Can comply with relevant ethical requirements; and
(c)
Has considered the integrity of the client, and does not have information that would lead it to
conclude that the client lacks integrity. (Ref: Para. A19-A20, A23)
Such policies and procedures shall require:

(a)
The firm to obtain such information as it considers necessary in the circumstances before accepting an
engagement with a new client, when deciding whether to continue an existing engagement, and when
considering acceptance of a new engagement with an existing client. (Ref: Para. A21, A23)
(b)
If a potential conflict of interest is identified in accepting an engagement from a new or an

existing client, the firm to determine whether it is appropriate to accept the engagement.
(c)
If issues have been identified, and the firm decides to accept or continue the client relationship or
a specific engagement, the firm to document how the issues were resolved.
ISQC 1, effective December 15, 2009 (clarified ISQC 1) will be referred to throughout this document, given
that upon publication of this paper this will be the version to be complied with. At the time this paper was
developed participating networks were at differing stages of implementing clarified ISQC 1 into their
methodologies. However, given that the client acceptance and continuance dispositions of the clarified ISQC 1
are identical to those in the extant version, other than for the adoption of the clarity conventions, it is felt that
this has no impact on the appropriateness of the material presented in this paper (see appendix 3 for a
comparison). For the purposes of this paper, clarified ISQC 1 has been used as the basis for this papers format,
references and consideration of materials provided by participating networks.
See Appendix 4 for the Forum of Firms membership obligations.
See Appendix 5 for the requirements of ISA 220 and 600.
28.
The firm shall establish policies and procedures on continuing an engagement and the client relationship,
addressing the circumstances where the firm obtains information that would have caused it to decline the
engagement had that information been available earlier. Such policies and procedures shall include
consideration of:
(a)
The professional and legal responsibilities that apply to the circumstances, including whether
there is a requirement for the firm to report to the person or persons who made the appointment
or, in some cases, to regulatory authorities; and
(b)
The possibility of withdrawing from the engagement or from both the engagement and the client
relationship. (Ref: Para. A22-23)
1.
Client Acceptance
A.
Determining the Integrity of the Prospective Client
ISQC 1s paragraph 26(c) notes the need for considering the integrity of the client, and that the firm
does not have information that would lead it to conclude that the client lacks integrity. While
considering client integrity was not noted as a general issue in the TACs review of inspection
reports, one oversight body (Canada) did raise some specific recommendations about the need for the
performance and documentation of an assessment of management and board integrity and reputation.
Further, another recommendation was the need to develop policies for communicating with
predecessor auditors to ascertain whether there are circumstances the firm should take into account in
deciding whether to accept the engagement.
In reviewing the practices and procedures of participating networks for this paper, it was highlighted
in one networks policies that The personal characteristics, philosophy and operating style of the
individuals who comprise an entitys management have a significant influence on the entity as a
whole. The integrity of management and principal owners of an entity is fundamental to the Member
Firms ability to provide professional services and is a key consideration in the assessment of client
risk and, thus, Engagement Risk.
Further, If the Member Firm has reason to question the integrity of the management or principal
owners of a prospective or existing Client and they do not meet an acceptable standard of integrity,
the Member Firm would ordinarily not accept or continue to be associated with the entity, because
the Engagement Risk would be increased beyond an acceptable limit.
These sentiments are representative of the theme throughout all the policies considered in relation to
client integrity. As such, of the 14 networks reviewed, policies and procedures relating to client
integrity (and related to this, the clients industry and operating environment) receive the greatest
degree of focus in forming a conclusion on whether or not to accept or continue with a client.
However, the volume of emphasis and extent of the policies and procedures associated with
establishing client integrity varies considerably across the networks reviewed principally as a
function of size.
It is worth noting that ISQC 1 paragraphs A19-A20 and A23 (A23 focuses on the public sector10)
discusses guidance in support of 26(c) of ISQC 1providing further potentially useful material
10
A23 states: In the public sector, auditors may be appointed in accordance with statutory procedures. Accordingly,
certain of the requirements and considerations regarding the acceptance and continuance of client relationships and
specific engagements as set out paragraphs 26-28 and A18-A22 may not be relevant. Nonetheless, establishing
7
for networks when considering their related policies and procedures. To varying degrees, the
networks reviewed do pick up on the themes listed within A1911 (A20 discussed later).
The illustrative checklist below presents an overall aggregation of questions and matters considered
by the networks12 reviewed to assist them in their determination of client integrity.13 While
mentioned in the checklist below, it should be noted that firms in some jurisdictions are required to
implement extensive procedures to deal with regulations relating to e.g. money laundering, which is
also relevant in the context of knowing the client and client acceptance and continuance.
11
12
13
policies and procedures as described may provide valuable information to public sector auditors in performing risk
assessments and in carrying out reporting responsibilities.
See Appendix 6 for the contents of A19.
In the case of small and medium size practices and clients a reduced checklist could be used to ensure a cost effective
approach that covers all the requirements of the ISAs and ISQC 1.
As can be seen, certain questions and matters in the checklist relate to general risk management concerns (possibility
of a public offering, reliance on other auditors, financial and going concern considerations, etc.) rather than being
specifically related to client integrity. We have chosen to include these questions since, although they may not
respond to specific requirements of ISQC 1 or ISAs, they are clearly matters which Firms need to address in deciding
whether to accept an engagement and, if present, they would certainly have an impact on audit planning activities.
However, it is not the purpose of this paper to address risk management policies and procedures in other respects.
General Information
Response
Provide information regarding:

Which Country is the ultimate parent
company registered in?
Location(s) of entity operations
Industry
Key governance/management of the
entity
o
CEO
CFO
Other
Lawyers
Bankers
Previous Auditor
Entity Financial Information
X1
X0
Total Assets
Current Liabilities
Long Term Liabilities
Working Capital
Equity
Cash Flows from Operations
Revenue
Net Income
What accounting standards are to be applied
to the engagement (international, domestic,
other)?
What auditing standards are to be applied to
the engagement (international, domestic,
other)?
Yes/
No
Are there any planned transactions within the next
year in which the engagement results may be used:
Any Initial Public Offering of any form of
securities in any markets?
Private offering of any form of securities in
cross-border markets?
Other private transaction where a duty-of-care
is expected to be established?
Sale or merger of the entity/net assets?
Will there be reliance on the work of other auditors
for a substantial portion of the engagement?
Will the other auditor be a non-Network Firm?
Will the other Firm be registered with a regulatory body?
Identity and Business Reputation of the Clients
Principal Owners, Key Management, and Those
Charged with its Governance
Do we have any concerns identifying ownership, key
management or those charged with governance?
Is there domination of key management by one/few
individuals?
Do we have concerns regarding managements
competence? Matters to consider include:
Experience
Skill (e.g.: effective budget preparation and
monitoring)
Depth
Background (e.g.: criminal convictions)
10
Other relevant information.

A Yes response in
particular should be further
explainedwhere applicable
supported by how the risk is
to be mitigated to an
acceptable level
Identity and Business Reputation of the Clients

Principal Owners, Key Management, and Those
Charged with its Governance
Does management have an unhealthy tolerance for
business risk?
Are there any personality profiles within the
management which cast a doubt on integrity/pose an
audit risk?
Does managements attitude towards financial
performance and business management cause a
concern?
Are there any expected changes in ownership, key
management or those charged with governance that
give doubt to integrity?
Are there any overall concerns with the integrity or
business reputation of the management or those
charged with governance?
Do we have concerns that management does not
foster and are not supportive of an ethical business
culture?
Financial and Going Concern Considerations
Do we have any concerns with the financial condition
of the entityconsideration includes:
Financial statement analysis
Profitability margins and their consistency
Debt covenants / credit ratings
Dependence upon an important project,
contract, or new business model or concept
Products (current and planned) and services of
the entity/industrymarket presence and
growth stability of industrynature of
industry (litigious)extent of any regulatory
oversight
Regulatorsstatus of regulatory filings
relations with regulatory authorities
11
Financial and Going Concern Considerations

Supplier/customer concentration Planning for
any significant mergers/acquisitions/
disposals/financing
Entity intentions re offering debt or equity
securities
Amount of publicly traded debt outstanding
trading value compared to face value
Listed share price of the entity
Sensitivity of entity assets to market conditions
Expiration or violations of licenses or permits
Presence of off balance sheet financing structures
or similar
Other
Nature of Client Operations
Does the complexity of the entity structure provide us
with any cause for concern (e.g.: is the structure
seemingly unnecessarily complex, off-shore banking
arrangements which seem unnecessary)?
Do the entity operations involve tax complexities?
Is the entity the subsidiary of a public company or a
significant subsidiary?
Is the entity an SEC Registrant or about to become one?
Does the entity operate in a specialist legal or regulatory
environment?
Does the media portrayal of the entity/management
cause concern with respect to the clients integrity?
Was/is the entity involved in any past, current or
impending significant litigation?
12
Attitude Towards Aggressive Interpretation of

Accounting Standards and the Internal Control
Environment
Is there an attitude towards aggressive interpretation
of accounting standards (e.g.: revenue recognition)?
Is there a concerning attitude towards the internal
control environment (or its improvement)?
Is there a history of a lack of reliability of past
accounting estimates by management (possibly
resulting in disputes with past auditors)?
Does management propose accounting policies or
treatment of specific transactions which cast a doubt
on their integrity?
Do we have any concerns about attitudes within the
entity that controls are unimportant or should be
circumvented?
Do we have any concerns that management turnover
has had a negative impact on the internal control
environment?
Are there indications of the ineffectiveness of the
Chief Financial Officer in enforcing controls or
ineffectiveness of the internal control environment
generally?
Payment of Fees
Have there been any concerns over managements
ability and willingness to pay for professional
services rendered in the last year?
Scope Limitation
Is there any indication of an inappropriate limitation in
the scope of work/access to records?
Money Laundering or Other Criminal Activities
Is the entity operating in an industry or sector which
has an exposure to fraud or illegal acts?
13
Money Laundering or Other Criminal Activities

Does the mode of the clients operations or business
practices cast doubt on its integrity?
Reason for Proposed Appointment/
Non-Reappointment of the Previous Firm
Have our dealings with the predecessor auditor raised
any concerns?
Have the quality of any of our dealings with the
predecessor auditor raised any concerns?
Is there any concerning reason(s) why the previous
auditors have not been re-appointed?
Why have not been reappointed?
Are there matters for concern in prior year(s) audit

report?
Has there been a frequency of changing auditors?
Was the manner in which we were introduced to the
entity a matter of concern?
Have other Firms refused to provide services to this
entity?
Do we have any history of disputes dealing with the
entity?
Identity and Business Reputation
of Related Parties
Do we have any concerns with related party
transactions outside the ordinary course of business?
Does the complexity of related party transactions give
concern with respect to integrity?
14
How were we introduced?
Overall Assessment
Does the integrity of the entity, its principal owners,
key management, or those charged with its
governance create an unacceptable risk?
Please rate the client risk?
(Where applicable) Does the Firms Risk Specialist
agree with plans to reduce risks to an acceptable
level? (document in the working file)
Having access to sufficient sources of information or most appropriate persons within the entity
to enable a thorough assessment
Full and open access to key personnel and information within the prospective client is desirable to
enable gaining necessary client knowledge and aiding an assessment of the clients/management
integrity. To assist in this respect, the Networks provided some practical insights, as follows:
Access to all the relevant resources within a potential client to enable a thorough assessment
can never be guaranteed for every engagement being considered. However, the onus is on the
Firm to maximize their contact with the prospective client in order to obtain as much
information as possible.
The critical nature of these assessments in the context of overall risk management should be
emphasized. Getting to know and better understand the client is a key component of the
assessment and one that generally also enables the provision of a higher quality service by
the Network. As such, it is mutually beneficial for the entity to be as open and transparent as
possible about itself and its operations.
One Network highlighted that an indication that the client is not willingly providing
information to assist with the assessment could be viewed as an indicator of higher risk.
Dependent upon the nature of the entitys actions, this may justify engaging the advice and
guidance of the Firms risk management specialists.
Many of the Networks highlighted that there are numerous avenues open to the auditor
beyond direct client contact to enable the assessment to be made and that these could be
pursued in support of (and to verify) representations made by the entity. Discussions with the
prior auditor, lawyers, and other service providers as well as researching publicly available
information are all avenues that could be pursued (further discussion provided below).
Related to this is the use of in-house or third party research and investigation services to
assist in performing background checks and seeking credible evidence to corroborate other
aspects of an informed assessment.
Sources of information to assist in determining client integrity
Paragraph A20 of ISQC 1 provides the following guidance on sources of information that could
be used to assist the Firm in performing an assessment as to client integrity.
15
Communications with existing or previous providers of professional accountancy services to the client
in accordance with relevant ethical requirements, and discussions with other third parties.
Inquiry of other Firm personnel or third parties such as bankers, legal counsel and industry peers.
Background searches of relevant databases.
These suggested sources are, not surprisingly, referenced by most of the Networks reviewed.
One Network notes however that, in relation to the performance of background checks, this may
be of a sensitive nature in some jurisdictions. As such each Firm should establish policies and
guidance for (1) the collection and confidentiality of background information obtained in
performing the checks and (2) the documentation and retention of such information. Each Firm
should establish that the policies and procedures comply with local laws.
Networks note that background checks may be performed using both publicly available information
sources and non-publicly available information sources, as appropriate. The extent of the procedures
performed and data obtained will depend on the specific circumstances of the entity (e.g., public
interest entities versus nonpublic interest entities) and the regulatory and legal environment in which
the check is to be performed but could also include one or more of the following:
Information obtained from sources inside the Firm:
o
Audit partner knowledge of the entity and its Principal Officers/Owners based on
prior professional or personal relationships
Discussions with Partners within the Firm who have had professional or personal
experiences with the entity and its Principal Officers/Owners
Information obtained from sources external to the Firm:

o
Inquiries of third parties who may have knowledge of the individuals and/or entities.
Third parties could include individuals in the business community, lawyers, bankers,
industry leaders, or others.
Searches of the following:
Public databases
Regulatory filings
Newspapers
Published articles
Keyword internet searches
Inquiries performed by outside investigative agencies or credit agencies.
Finally, in forming an assessment as to client integrity, paragraph A20 notes:

The extent of knowledge a Firm will have regarding the integrity of a client will generally grow within
the context of an ongoing relationship with that client.
We will see later that such knowledge is consequently a key element in the context of client
continuance decisions.
16
B.
Determining Competency of the Firm to Perform the Engagement
While paragraph 26(c) focuses on determining client integrity, paragraph 26(a) of ISQC 1
focuses on the need for the Firm to ensure it is in fact competent to perform the engagement in
the first place and has the capabilities, including time and resources, to do so. The need to have
the necessary competence under paragraph 26(a) is supported by paragraph A1814 providing
further guidance which Networks could find useful in considering their policies and procedures
as they relate to competence.
The TACs review of external inspection reports did note a couple of issues specifically related
to determining competency. One finding (more in relation to continuance) was that a few Firms
were not assessing whether they have the language capability to perform an audit when key
evidence is in a foreign language. A further recommendation was to require an assessment of
whether the Firm/engagement team has the necessary linguistic skills and that additional training
be provided on the need to consider and document whether the engagement team has the
requisite skills to conduct the engagement.
Key to enabling a meaningful determination of the Networks competency is a thorough
understanding of the entity and its industry. As such, a necessary component of competency
considerations are questions associated with knowledge of the client, which can be noted in
several of the questions used in the illustrative checklist to assist in determining client integrity.
Indicators that extra consideration needs to be given to the competencies within the Network to
perform the engagement to the necessary quality are as follows:
Complexity of the entitys structure
Complexity of the entitys transactions, or transactions for which the related accounting is
complex, emerging or subject to significant professional judgment/interpretation
Entity involvement with off-shore transactions
Complex tax arrangements
Entities operating within specialized industries such as banking/finance/insurance, real
estate/construction, gaming/gambling, government/public sector enterprises, leasing,
agriculture, etc.
An entity which is (or is a significant component of) a public interest entity
Armed with a solid foundation of client knowledge, the Networks reviewed asked questions in the
following areas to further determine their competency to undertake the engagementagain, as with
client integrity, presented as an illustrative checklist.
14
See Appendix 7 for the guidance in A18 of ISQC 1.

17
Competence to Perform the Engagement
Response
Indicate the number of years of experience the

engagement partner has in the entitys industry.
Is this engagement subject to partner rotation
requirements?
Indicate the number of years of experience the
engagement manager has in the entitys industry.
Yes/
No
Does the entity have operations in any of the following
high risk industries or portfolios?
Banks, financial institutions
Insurance providers
Mutual funds
Gambling/gaming
Brokers/dealers
Real estate/construction
Leasing
Public sector not-for-profit
High litigation industries
Software development
Sport franchises
Businesses with going concern issues
Does the entity recognize revenue applying complex
or evolving accounting conventions?
Does the entity have significant activities related to
any of the following areas:
Acquisition accounting
18
Other relevant information. A

Yes response in particular
should be further explained
where applicable supported
by how the risk is to be
mitigated to an acceptable level
Competence to Perform the Engagement
Response
Reorganization
Restructuring charges
Self-insurance
Use of derivatives
Debt covenants
Other
Will the engagement require the use of work of
experts?
Are there any concerns regarding the availability of
professional staff to enable completion of the
engagement to a both a quality standard and in a
timely manner?
Are there any concerns regarding the partner and staff
having sufficient knowledge and experience for the
engagement?
Are there any matters related to staffing the
engagement which would indicate that the engagement
should not be accepted or why such acceptance needs
to be considered by a second partner or head of
specialization?
Are any special licenses or permits or approvals
required for our staff to carry-out the engagement in
the jurisdiction where the work will be performed?
Overall Assessment
Does the engagement team, including appropriate
industry and specialty experts who will be part of the
team, have the relevant experience and competence
and sufficient available time to:
Address the primary and other industries noted
above?
Address any risks or issues noted in the above?
Reduce any competency risks associated with the
engagement to an acceptable level?
19
Reducing risks associated with competency and performance

As alluded to above, various facets of the structure, transactions, or industry of a potential client
can pose challenges to the adequacy of competencies within the Firm, often requiring the need to
further consult specialists or others within the Firm hierarchy (discussed further later).
A common theme noted by the Networks reviewed is an emphasis on the importance of audit
quality per se. As one Network puts it The best way to control factors related to performance is
by adopting and applying the highest technical standards, policies, and procedures; assigning
appropriate, competent, and properly trained personnel; encouraging consultation; and
establishing strong review and approval procedures.
However, the Networks acknowledge that the risk of being exposed to criticism and negative
publicity associated with the adequacy and quality of professional services cannot be completely
eliminated. Factors which may contribute to reduced exposure to this risk include:
Diligent investigation of the background and reputation of the potential client;
Avoiding engagements that involve undue risks;
Clearly establishing the terms of engagement and setting out unambiguous, achievable terms
of reference;
Applying a sound audit methodology; and
Sensitivity to clients and users perception of the Firms performance.
C.
Compliance with Ethical Requirements
Paragraph 26(b) of ISQC 1 requires that the Firm have policies and procedures to ensure
compliance with relevant ethical requirements. This is supported by further extensive discussion
within ISQC 1, notably paragraphs 2025 which is further supported by explanatory paragraphs
A7A17. The explanatory paragraphs outline the key principles and tenets of the International
Ethics Standards Board for Accountants Code of Ethics (IESBA Code):15
Integrity
Objectivity
Professional Competence and Due Care
Confidentiality
Professional Behavior
Ethical requirements, and more specifically, independence, was an issue noted in the TACs
review of inspection reports. One comment noted the general lack of rigor in some of the Firms
which included failing to consult personnel prior to accepting engagements to determine if there
were any independence concerns.
15
20
At the time this paper was developed, the IESBA Code (revised July 2000the revised Code) was not yet
effective (effective from January 1, 2011). As such, material provided by Networks participating in the
development of this paper would not have necessarily reflected all revisions to the Code. IESBA staff have
prepared materials to support implementation of the revised Code including comparative analysis between the
current code and the revised code. See http://www.ifac.org/Ethics/Resources.php#implementation-and-adoption
The Networks reviewed for this paper place significant focus on identifying issues associated
with independence and conflict of interest. The checklist below illustrates the types of enquiries
made by the Networks in this respect.

Are we aware of the independence rules to be applied
in this engagement?
Yes/
No

where applicable supported by
how the risk is to be mitigated
to an acceptable level
Give detail
Has our research (including enquiry, common sense

knowledge) into the ownership and broader structure
within which the entity operates highlighted other
entities within the ownership and affiliation structure
which might be affected by the proposed engagement?
Have we identified any potential independenceimpairments with the entity and the Network that
would preclude the Firm from performing the
engagement?
Have we identified any potential conflict of interest
with the entity and our Network that would preclude
the Firm from performing the engagement?
Is the Firm or the Network in any way connected with
the entity equivalent to an employee or management?
Consider:
Committing the entity to transactions
Having authority or custody over entity assets
Authority to make decisions for the entity
Preparing source documents for entity
transactions
Does the Network have any business relationships,
financial interests or loans with this entity?
Are we aware of any member of the Firms
engagement team having any potential employment
with the entity, or been employed by the entity in the
21

last 2 years?
Does any partner of the Firm have family or personal
relationships with the entity or any direct financial or
indirect financial interest in the entity?
Does any of the Firms staff that will be part of the
engagement have family or personal relationships
with the entity or any financial interest in the entity?
Does the Firm have any former Partner or practice
staff members who are in a director/executive role or
employee of the entity?
Does the Firm have a commission contingent fee
arrangement with the entity on any attest or non-attest
service?
Does the Firm have deferred credit terms with the
entity or unpaid fees which extend beyond one year?
Does the Firm deliver non-audit services to the entity
in a manner that non-audit fees may exceed audit fees
or be seen to impair auditor independence?
Will acceptance of the audit engagement potentially
preclude under-taking a significant assignment for
another part of the Network?
Does the Firm perform ANY of the following
services for the entityfor example, though not
limited to:
Bookkeeping
Internal audit
Actuarial services
Financial advisory of valuation services
Legal services
Financial information systems design and
22
Yes/
No

Yes/
No

implementation
Executive recruiting
Contingent fee arrangements
Limitation of liability arrangements
Does the entitys audit committee have any issue
regarding this engagement?
Does the Firm have any issues with respect to meeting
the independence rules of other regulatory bodies?
Is the Firm aware of any other possible issues which
require the need for further research about our
independence or the need for further consultation
with an Independence Specialist?
Is the entity subject to SEC or regulatory rules?
Is there actual or threatened significant
disputes/litigation involving the entity and the Firm?
Does this engagement involve a limitation of liability?
Is the Firm providing litigation support or dispute
analysis services to another client that might be
considered to be in conflict with the interests of this
entity?
Overall Assessment
Will acceptance of this engagement create an
independence violation?
Will acceptance of this engagement create a conflict of
interest?
Please rate the independence risk?
23
Please rate the potential conflict of interest risk?

(Where applicable) Does the Independence Specialist
agree with plans to reduce identified risks to an
acceptable level (document in the working file)
Additional resources employed by networks to assist in reducing risk associated with ethical
considerations
To aid assessing compliance with ethical requirements, some Networks have developed
resources which assist in helping to match or identify possible conflicts. The degree of
sophistication and maturity of these systems vary. These additional resources, essentially IT
based, help to ensure possible issues are brought to the attention of the Network early in the
assessment process. The practical devices some of the Networks reviewed have developed to
help them achieve better risk management with respect to ethical compliance include:
Creating and regularly maintaining a client services database serving as a reference point
which the Network Firm must access and consider as part of the assessment when
contemplating providing new services. When consideration is being given to accepting a new
engagement with a client already present within the database, consultation with those
responsible for those existing services must be performed and include involvement of inhouse Independence Specialists;
Use of automated systems which electronically match the Networks database of clients (or
potential clients) with the investment portfolios of designated Network staff and designated
others (e.g.: their immediate family members) highlighting possible risks for further
consideration. The need and size of such a system was viewed by one Network as arguably
scalable dependent upon the investment culture or focus in the jurisdiction/area where the
Firm operates. For example, the need and usefulness of such a system would arguably be
more necessary and beneficial in an environment which has more of an investment culture in
stocks/shares vs. one which may, for example, focus more on non-share based investments
such as real estate;
One Network highlighted that a very simple approach to assisting with highlighting conflicts
was to e-mail other Network Firms in the jurisdiction(s) where the potential client has
operations, as well as enquiry from the potential client as to whether they are aware of other
services offered by Network Firms to entities in the group.
Safeguards to consider in addressing conflicts of interest
Should issues with respect to independence or conflicts of interest be noted in considering client
acceptance, there are actions that could be taken by Networks which could help mitigate those
risks to reduce them to an acceptable level. As noted by one Network, these would depend upon
the environment in which a Firm operates and especially whether the service can be performed
with the necessary objectivity. As such, this Network indicates that it may be possible to
implement and maintain safeguards that are designed to manage conflicts and protect client
confidentiality in relation to a specific engagement, thereby enabling it to:
24
(a)
Act for two or more parties to a transaction or other matter or
(b)
Accept other prospective engagements where they could not do so in the absence of such
safeguards. These safeguards would ordinarily include but are not limited to the following:
(i)
subject to entity and other confidentiality obligations, disclosing the facts and
circumstances of the conflict to the entities concerned (understanding any entityimposed confidentiality requirements and obtain consent, as appropriate);
(ii)
obtain the consent of each of the parties concerned.
After obtaining consents from the parties concerned, the Network highlights that the following
safeguards would ordinarily be considered:
Using entirely separate engagement teams to serve each respective client;
Establishing effective ethical walls and confidentiality safeguards, such as information and
physical barriers separating engagement teams designed to prevent the sharing of confidential
information;
Information technology safeguards such as passwords, limited network access, and separate
printers and fax machines; and
Instructing individuals on the engagement team, including administrative personnel who assist
the engagement team on the importance of maintaining confidentiality, including custody of
client documents and communication protocols, such as restricting discussion to those who
need-to-know.
However, the Network further notes that not all conflicts can be waived by a client and/or
managed by implementing safeguards. As such, if they are unable to implement appropriate
safeguards to manage a conflict, the prospective engagement should be declined.
D.
Additional Considerations with Client Acceptance
Who is Involved in Completing Client Acceptance Assessments/Documentation?

The level and extent of involvement of Firm personnel in the performance of client acceptance
determinations varies across the Networks reviewedthough commonality does exist. Some
factors in assessing the entity can result in risk associated with the overall engagement being
such that the views and approval of others within the Network must be obtained in order for a
final decision on whether to accept the engagement can be made.
As explained by one Network, the underlying approach in completing client acceptance (and also
continuance) assessments is that the higher the risk associated with the potential (or continuing)
client, there was a corresponding need for additional involvement, consultation and approval by
others within the Firm. It was noted that it would be in rare circumstances that there would not be the
need to have at least one other Partner, who is not associated with introducing the potential client to
the Firm or the performance of the initial acceptance assessment, to perform their own independent
review and concur with the decision to accept the potential client.
While there is variation amongst the Networks considered, the following provides an overall
general illustrative framework followed by many of the Networks reviewed in the completion of
their client acceptance assessments:
25
All client acceptance assessments must include Partner level involvement as a minimum
(involvement of the Audit Manager is also noted by some Networks). While the need for
Partner level involvement was consistent across Networks, the nature of who the Partner
could be varied from the Recommending Partner to the prospective Engagement Partner;
The need for second/additional Partner involvement (and concurrence) was also commonly
noted with the need for their participation required across a range of risk thresholds varying
from when engagement risk was assessed from normal to high;
Where the assessment is being made within an industry for which an industry/sector
specialist exists, then the input of the specialist should be sought in particular in instances
involving a risk assessment beyond normal;
Should the engagement risk be above normal, then there is a need to involve and gain the
concurrence of more specialized Firm personnel. The title of those to be consulted varied, but
could be characterized as the local Firms audit risk specialist (or person of equivalent
role)/specialist for quality control; and
If the risk is considered extremely high, then involvement of the Firms country level audit
risk specialist/head of risk management should be sought. The existence of a National
Committee was also noted to assist in reviewing potentially higher risk clients.
Documentation
ISQC 1 contains requirements specifically with respect to documentation. Paragraph 27 (c) notes:
If issues have been identified, and the Firm decides to accept or continue the client relationship or a
specific engagement, the Firm (shall) document how the issues were resolved.
Documentation in general with respect to client acceptance and continuance was an area for which
the TACs review of external quality assurance reports indicated was a notable issuean absence of
recording within the audit file corresponding to a lack of documented evidence.
As noted in the South African review report:
While quality audit work was evident throughout our reviews, we continue to identify a number of
instances where engagement files do not adequately comply with the professional standards in relation to
documentation. The requirement for the auditor to document matters providing evidence to support the
audit opinion has existed for many years and the lack of such documentation remains unacceptable.
A similar comment was noted from Australias oversight body:

Across most Firms, we continue to note deficiencies in the application of policy for both the adequacy of
documentation supporting the decision to provide non-audit services for audit clients
Further, reviews performed by the PCAOB in the US noted several instances where the broader more
general issue of adequacy of documentation associated with several review findings was also evident.
In developing this paper, one of the Networks highlighted, more with respect to client continuance
considerations, that the thorough documentation of thought processes can be a challenge. While all
the necessary considerations may have taken place and rationale determined in deciding on the future
relationship with a client, ensuring all those thought-processes are actually documented in the audit
file can be an issue.
26
To assist ensuring that all aspects of the Networks client acceptance and continuance policies are
addressed and documented, all Networks employ checklists. The use of software applications to
assist in the completion of such checklists can be an added feature.
Where the use of electronic checklists is available, this can not only enhance documentation but also
be a useful tool for risk assessment purposes. As noted in some Networks, each individual question
can be linked to a related numeric risk indicator and assist in forming the overall risk assessment for
that particular client the general idea being the client achieves a risk score, different scores
contributing to (but not determining) the final assessment of risk associated with that client. The
score can then be subsequently reduced by the nature of any risk mitigating solutions implemented.
Timing of Procedures Associated With Client Acceptance
As with documentation, the timing of completion of acceptance and continuance procedures was
also a key finding in the TACs review of external inspection reports. Some comments were:
In some situations, the detailed consideration of the factors affecting a decision to continue
an existing client audit relationship normally occurs after the Firm has been appointed as
auditor at the clients Annual General Meeting (AGM), but before detailed audit planning
commences. In some cases, the continuance procedures may not be documented until well
after the completion of the planning phase (Canada).
Across most Firms, we continue to note deficiencies in thetiming of issuance of engagement
letters, for both new clients and new services to existing clients, before completing the relevant
continuance or acceptance processes. (Australia).
Networks emphasized that it was important for client acceptance evaluations to be completed before
proposing or committing to accept the engagement. Further, they highlighted that in situations where
all necessary procedures have not been completed, consideration should be given to disclosing that
the Firms proposal or commitment to perform the engagement is subject to satisfactory completion
of engagement acceptance procedures.
Once acceptance procedures have been completed, the general requirement amongst the Networks is
that only continuance procedures need be subsequently used, though it was noted that at least one
Network does require that once a client has been accepted, re-performance of the complete client
acceptance process be carried out at least once every five years over and above the usual annual
client continuance assessment.
One Network acknowledged that client acceptance requirements not being completed before starting
an engagement may have been an issue some years ago but was seemingly not a significant problem
area today. To help reach this level of compliance the Network had implemented, as a key part of
their corporate climate, a strong element of training to emphasize the risks associated with not
completing required procedures within the appropriate timeframe and the accountability of staff for
not doing so.
Despite this it was acknowledged by some Networks that timely performance of acceptance
procedures can still pose difficulties in practice. As such, some Networks have adopted tools to
assist in ensuring that such departures from policy are minimized. Practical steps that Networks
could consider to reduce the likelihood of timing issues include:
27
In those parts of the business where these types of issues arise, ensuring that a dedicated
resource is available to assist in the quick completion of the acceptance process; and
Ensuring there is frequent communication between the Quality Assurance function and the
engagement partners to ensure at least an established minimum threshold of procedures is
completed on time. If not fully completed within 30 days after a job coding has been created,
a policy requirement that the engagement must be suspended.
Generic, Sector-Specific and SME Policies and Procedures
While many of the Networks reviewed have more of a one size fits all approach to their acceptance
and continuance policies and related questionnaires, some Networks have invested in the
development of industry specific client acceptance toolsfocusing in on the key risk areas
associated with that particular sector which should be given special consideration in determining
client acceptance.
An approach used by one Network is the development of global template assessment forms which
differ by industry and can be tailored by each territory for local purposes. At this Network, there are
several assessment forms ranging from industry specific forms for bank and capital market clients to
generic forms (intended for consumer & industrial products, manufacturing, and technology industry
clients). In providing these sector-specific forms, the Network emphasizes that the underlying client
acceptance and continuance policies are the same across all industries.
A further approach to tailoring policies and procedures at one Network is the issuance of specific
guidance documents in response to industries experiencing heightened risk. This Network has
issued, for example, acceptance/re-acceptance guidance specifically for the financial industry,
given recent developments in that industry.
Tailored policies and procedures for smaller lower risk clients is an area of growing interest for
several Networks reviewed. A couple of Networks do provide for a simplified process for
assessing acceptance although, as with the industry specific templates discussed above, the
underlying acceptance policies in relation to that assessment are no different to the regular
generic acceptance assessments. One Network noted that their procedures are currently designed
to address all acceptances but theoretically, in an SME context, would be quicker to complete
with less elevated sign-off where the business is simpler in nature.
2.
Client Continuance
Common across the Networks reviewed is that the general themes underlying considerations for
determining client continuance are essentially the same as those applied in determining client
acceptance. Central to the continuance assessment is an evaluation of new or changed potential risks
of association with the client.
As noted by one Network, the Partners on the engagement should be alert to and monitor changes in
factors and conditions occurring during the engagement that could negatively impact the initial
assessment of engagement risk. Of the Networks reviewed this would particularly include monitoring
of changes associated with:
Principal decision makers, directors and officers, or owners;
Financial condition;
28
Industry and business environment issues that increase risk (e.g. economic trends, inflation or
deflation, industry consolidation, litigation, regulatory environment, expansion into new areas
of business);
Auditor-client relationship; and
Business and reputation of the client.
Where changes are considered significant, then consideration is given as to whether the significance
of the change justifies a complete reassessment of the client using a Networks more detailed
acceptance questionnaire. One Network highlights that this is an approach required in those
circumstances where an existing private audit client is considering going public, or where an existing
audit client is acquiring, or is being acquired by an entity that is public.
In reviewing the checklists of the participating Networks, the following were noted as areas of
enquiry focused more specifically on continuance, presented below as an illustrative checklist:
Client Continuance
Yes/
No

Compared to the previous year, and based on your

enquiries, are there any new circumstances that might
impair our independence as auditors of this entity
under the Firms policies or the applicable
professional or regulatory independence
requirements? Consider in particular any changes in
the clients structure, circumstances, ownership or
management.
Has the entity recently had significant and numerous
acquisitions?
Is there any indication that in the past three years, the
entity requested a change in Engagement Leader or
Team Manager?
Have we had any disagreement with the entity or
communicated a significant matter to the entitys
regulator?
Has the chief executive officer or controller (or the
equivalent) been replaced within the last year?
Are there any issues related to payment of audit fees?
29
Client Continuance
Yes/
No

Is there any issue on any imposed scope limitation?

Are there any issues in relation to being able to
adequately staff the audit?
Timing of Procedures
Networks reviewed require the completion of continuance assessments at least annually with the
understanding that the factors considered under client acceptance should be kept under continuous
review. This is particularly important in the early years of a client relationship as the extent of
knowledge a Network will have regarding the client will generally grow within the context of the ongoing relationship.
As to when exactly during the year performance of the continuance considerations are to be formally
performed and documented - this varies between Networks. However, those reviewed generally
consider the timing to be most effective if performed/approved either directly after completion of the
last audit and no later than three months prior to the end of the financial period to be audited. The
general themes noted with respect to who is involved and approvals required in completing the
continuance assessment were noted by one Network as being similar to those when contemplating
initial client acceptancerepeating the underlying concept that the higher the assessed risk
associated with continuing with the client, there was a corresponding need for additional
involvement, consultation and approval by others within the Firm.
As an added assurance that there have been no circumstances that have developed which could
affect the continuance of the engagement, it was already noted earlier in the paper that at least
one Network requires that the complete client acceptance questionnaire be completed in totality
at least once every five years.
The formal establishment of a continuance review process for engagements spanning more than
one year was also noted as a mandatory requirement at one Network. Establishment of the
process involves senior risk management and audit personnel of the Firm.
Termination/Withdrawal
As part of the establishment of policies and procedures on continuing an engagement, paragraph 28
of ISQC 1 requires those policies to address circumstances where the Firm obtains information that
would have caused it to decline the engagement had that information been available earlierand
should cover:
(a)
30
The professional and legal responsibilities that apply to the circumstances, including
whether there is a requirement to report to those who made the appointment or, in some
cases, to regulatory authorities; and
(b)
The possibility of withdrawing from the engagement or from both the engagement and the
client relationship.
This is supported by paragraphs A22A2316 which highlight that those policies and procedures
address issues that include the following:
Discussing with the appropriate level of the clients management and those charged with its
governance the appropriate action that the Firm might take based on the relevant facts and
circumstances.
If the Firm determines that it is appropriate to withdraw, discussing with the appropriate level
of the clients management and those charged with its governance withdrawal from the
engagement or from both the engagement and the client relationship, and the reasons for the
withdrawal.
Considering whether there is a professional, legal or regulatory requirement for the Firm to
remain in place, or for the Firm to report the withdrawal from the engagement, or from both the
engagement and the client relationship, together with the reasons for the withdrawal, to
regulatory authorities.
Documenting significant matters, consultations, conclusions and the basis for the conclusions.
Some additional requirements noted in reviewing the Networks were the need to give consideration
to:
Seeking legal counsel where warranted by the circumstances; and
At a minimum, seeking the concurrence of the Risk Specialist/Partner. In addition, concurrence
of the Firms Assurance Leader can also be required.
With particular respect to international engagements, it was noted:
communicate, if permissible, with the participating Firms as to the implications of
withdrawing; and
where applicable, consulting with the referring member Firm before reaching a final decision.
If the termination is being driven by the discovery of a conflict, an option noted was that subject
to local laws, giving consideration to obtaining an engagement letter with terms that provide the
right to terminate an engagement in the event that a conflict arises that cannot be resolved.
However, it was noted that in some circumstances, it may be possible to continue with the
engagement by disclosing the conflict to the client and obtaining the clients waiver or consent to
continuance of the engagement by adopting other safeguards as appropriate.
16
A23 highlights public sector considerationssee footnote 10.

31
Appendix 1: External Inspection Reports Reviewed

Name of Body
Country
Name of Report
Australian Securities & Investments

Commission (ASIC)
http://www.asic.gov.au
Australia
Audit inspection program
Canadian Public Accountability

Board (CPAB)
www.cpab-ccrc.ca
Canada
Fifth (February 2008) and Sixth

(March 2009) Public
ReportsInspections of the Quality of
Audits Conducted by Public
Accounting Firms
Hong Kong Institute of Certified

Public Accountants (HKICPA)
http://www.hkicpa.org.hk/
Hong Kong
Practice Review Committees Report

2007
Japanese Institute of Certified Public

Accountants (JICPA)
http://www.fsa.go.jp/cpaaob/english/i
ndex.html
Japan
Overview of the Results of Quality

Control Review for the Year Ended
March 31, 2007
Accounting and Corporate

Regulatory Authority (ACRA)
www.acra.gov.sg
Singapore
Practice Monitoring Progamme Public

Report July 2007 and July 2008
Independent Regulatory Board for

Auditors (IRBA)
http://irba.co.za/
South Africa
Practice Review Department
Public report for 200607. Dated June

2008
2007 to 2008 Reviews

Public Report
May 2009
Audit Inspection Unit (AIU)

www.frc.org.uk/poba
United Kingdom
2006/07 Audit Quality Inspections

Public Report - June 2007
2007/8 Audit Quality Inspections (An
Overview) with the related individual
reports for individual Firms (BDO,
DTT, EY, GT, KPMG, PKF &
PWC)December 8 2008
Public Company Oversight Board

(PCAOB)
www.pcaobus.org
32
United States
PCAOB Inspection Reports
Appendix 2: Full Members of the Forum of Firms (as of January 1, 2010)

BDO
Constantin Associates Network
Crowe Horwath International
Deloitte Touche Tohmatsu Limited
Ernst & Young Global Limited
Grant Thornton International Ltd
HLB International
IEC
INPACT Audit Limited
JHI
JPA International
KPMG International Cooperative
Mazars
Moore Stephens International Limited
PKF International Limited
PricewaterhouseCoopers International
RSM International Limited
Russell Bedford International
SMS Latinoamrica
Talal Abu Ghazaleh & Co. International
UHY International Limited
33
Appendix 3: Comparison of Client Acceptance and Continuance Requirements

Clarified ISQC 1
Effective December 15, 2009
ISQC 1
2009 Handbook of International Auditing, Assurance,

and Ethics Pronouncements

26. The Firm shall establish policies and procedures for

the acceptance and continuance of client
relationships and specific engagements, designed to
provide the Firm with reasonable assurance that it
will only undertake or continue relationships and
engagements where the Firm:
28. The Firm should establish policies and procedures

for the acceptance and continuance of client
relationships and specific engagements, designed to
provide it with reasonable assurance that it will
only undertake or continue relationships and
engagements where it:
(a)
Is competent to perform the engagement and

has the capabilities, including time and
resources, to do so; (Ref: Para. A18, A23)
(b)
Can comply with relevant ethical requirements;

and
(c)
Has considered the integrity of the client

and does not have information that would
lead it to conclude that the client lacks
integrity;
(b) Is competent to perform the engagement

and has the capabilities, time and resources
to do so; and
Has considered the integrity of the client, and

does not have information that would lead it to
conclude that the client lacks integrity. (Ref:
Para. A19-A20, A23)
27. Such policies and procedures shall require:
(c)
28
Can comply with ethical requirements.
(contd) The Firm should obtain such information as

it considers necessary in the circumstances before
accepting an engagement with a new client, when
deciding whether to continue an existing
engagement, and when considering acceptance of a
new engagement with an existing client.
(a)
The Firm to obtain such information as it

considers necessary in the circumstances before
accepting an engagement with a new client, when
deciding whether to continue an existing
engagement, and when considering acceptance of
a new engagement with an existing client. (Ref:
Para. A21, A23)
(b)
If a potential conflict of interest is identified in

accepting an engagement from a new or an
existing client, the Firm to determine whether it is
appropriate to accept the engagement.
32. The Firm also considers whether accepting an

engagement from a new or an existing client may give
rise to an actual or perceived conflict of interest. Where
a potential conflict is identified, the Firm considers
whether it is appropriate to accept the engagement.
(c)
If issues have been identified, and the Firm

decides to accept or continue the client
relationship or a specific engagement, the Firm to
document how the issues were resolved.
28
28. The Firm shall establish policies and procedures on

continuing an engagement and the client relationship,
addressing the circumstances where the Firm obtains
information that would have caused it to decline the
engagement had that information been available earlier.
Such policies and procedures shall include
consideration of:
34
(a)
(contd) Where issues have been identified, and the

Firm decides to accept or continue the client
relationship or a specific engagement, it should
document how the issues were resolved.
34. Where the Firm obtains information that would

have caused it to decline an engagement if that
information had been available earlier, policies and
procedures on the continuance of the engagement
and the client relationship should include
consideration of:
Clarified ISQC 1
ISQC 1


(a)
The professional and legal responsibilities that

apply to the circumstances, including whether
there is a requirement for the Firm to report to the
person or persons who made the appointment or,
in some cases, to regulatory authorities; and
(a)
(b)
The possibility of withdrawing from the

engagement or from both the engagement and the
client relationship. (Ref: Para. A22-23)
(b) The possibility of withdrawing from the

engagement or from both the engagement
and the client relationship.
Competence, Capabilities, and Resources (Ref: Para. 26(a))

A18. Consideration of whether the Firm has the
competence, capabilities, and resources to undertake
a new engagement from a new or an existing client
involves reviewing the specific requirements of the
engagement and the existing partner and staff
profiles at all relevant levels, and including whether:
Firm personnel have knowledge of relevant
industries or subject matters;
Firm personnel have experience with relevant
regulatory or reporting requirements, or the
ability to gain the necessary skills and knowledge
effectively;
The Firm has sufficient personnel with the
necessary competence and capabilities;
Experts are available, if needed;
Individuals meeting the criteria and eligibility
requirements to perform engagement quality
control review are available, where applicable;
and
The Firm is able to complete the engagement
within the reporting deadline.
Integrity of Client (Ref: Para. 26(c))
A19. With regard to the integrity of a client, matters to
consider include, for example:
The identity and business reputation of the
clients principal owners, key management, and
those charged with its governance.
The nature of the clients operations, including its
business practices.
Information concerning the attitude of the clients
The professional and legal responsibilities that

apply to the circumstances, including whether
there is a requirement for the Firm to report
to the person or persons who made the
appointment or, in some cases, to regulatory
authorities; and
31. In considering whether the Firm has the capabilities,

competence, time and resources to undertake a new
engagement from a new or an existing client, the Firm
reviews the specific requirements of the engagement
and existing partner and staff profiles at all relevant
levels. Matters the Firm considers include whether:
Firm personnel have knowledge of relevant
industries or subject matters;
Firm personnel have experience with relevant
regulatory or reporting requirements, or the
ability to gain the necessary skills and
knowledge effectively;
The Firm has sufficient personnel with the
necessary capabilities and competence;
Individuals meeting the criteria and eligibility
requirements to perform engagement quality
control review are available, where applicable;
and
The Firm is able to complete the engagement
within the reporting deadline.
29. With regard to the integrity of a client, matters that

the Firm considers include, for example:
The identity and business reputation of the
clients principal owners, key management,
related parties and those charged with its
governance.
The nature of the clients operations, including
its business practices.
Information concerning the attitude of the
35
Clarified ISQC 1
ISQC 1


principal owners, key management and those

charged with its governance towards such matters
as aggressive interpretation of accounting
standards and the internal control environment.
clients principal owners, key management and

those charged with its governance towards
such matters as aggressive interpretation of
accounting standards and the internal control
environment.
Whether the client is aggressively concerned with

maintaining the Firms fees as low as possible.
Indications of an inappropriate limitation in the
scope of work.
Indications that the client might be involved in
money laundering or other criminal activities.
The reasons for the proposed appointment of the
Firm and non reappointment of the previous
Firm.
Whether the client is aggressively concerned

with maintaining the Firms fees as low as
possible.
Indications of an inappropriate limitation in the
scope of work.
Indications that the client might be involved in
money laundering or other criminal activities.
The identity and business reputation of related

parties.
The reasons for the proposed appointment of

the Firm and non reappointment of the
previous Firm.
The extent of knowledge a Firm will have regarding the

integrity of a client will generally grow within the context of
an ongoing relationship with that client.
The extent of knowledge a Firm will have regarding the

integrity of a client will generally grow within the context
of an ongoing relationship with that client.
A20. Sources of information on such matters obtained by the

Firm may include the following:
30. Information on such matters that the Firm obtains may

come from, for example:
Communications with existing or previous

providers of professional accountancy services to
the client in accordance with relevant ethical
requirements, and discussions with other third
parties.
Communications with existing or previous

providers of professional accountancy services to
the client in accordance with the Code, and
discussions with other third parties.
Inquiry of other Firm personnel or third parties

such as bankers, legal counsel and industry peers.
Inquiry of other Firm personnel or third parties

such as bankers, legal counsel and industry peers.

Continuance of Client Relationship (Ref: Para. 27(a))
A21. Deciding whether to continue a client relationship
includes consideration of significant matters that
have arisen during the current or previous
engagements, and their implications for continuing
the relationship. For example, a client may have
started to expand its business operations into an area
where the Firm does not possess the necessary
expertise.
Withdrawal (Ref: Para. 28)
A22. Policies and procedures on withdrawal from an
engagement or from both the engagement and the client
relationship address issues that include the following:
36
33. Deciding whether to continue a client relationship

includes consideration of significant matters that
have arisen during the current or previous
engagements, and their implications for continuing
the relationship. For example, a client may have
started to expand its business operations into an area
where the Firm does not possess the necessary
knowledge or expertise.
35. Policies and procedures on withdrawal from an

engagement or from both the engagement and the
client relationship address issues that include the
following:
Clarified ISQC 1
ISQC 1


Discussing with the appropriate level of the

clients management and those charged with its
governance the appropriate action that the Firm
might take based on the relevant facts and
circumstances.
Discussing with the appropriate level of the

clients management and those charged with its
governance regarding the appropriate action that
the Firm might take based on the relevant facts
and circumstances.
If the Firm determines that it is appropriate to

withdraw, discussing with the appropriate level of
the clients management and those charged with
its governance withdrawal from the engagement
or from both the engagement and the client
relationship, and the reasons for the withdrawal.
If the Firm determines that it is appropriate to

withdraw, discussing with the appropriate level of
the clients management and those charged with
its governance withdrawal from the engagement
or from both the engagement and the client
relationship, and the reasons for the withdrawal.
Considering whether there is a professional, legal

or regulatory requirement for the Firm to remain
in place, or for the Firm to report the withdrawal
from the engagement, or from both the
engagement and the client relationship, together
with the reasons for the withdrawal, to regulatory
authorities.
Considering whether there is a professional,

regulatory or legal requirement for the Firm to
remain in place, or for the Firm to report the
withdrawal from the engagement, or from both
the engagement and the client relationship,
together with the reasons for the withdrawal, to
regulatory authorities.
Documenting significant matters, consultations,

conclusions and the basis for the conclusions.
Documenting significant issues, consultations,

conclusions and the basis for the conclusions.
Considerations Specific to
Organizations (Ref: Para. 26-28)
Public
Sector
Audit
A23. In the public sector, auditors may be appointed in

accordance with statutory procedures. Accordingly,
certain of the requirements and considerations
regarding the acceptance and continuance of client
relationships and specific engagements as set out
paragraphs 26-28 and A18-A22 may not be relevant.
Public Sector Perspective

3.
In the public sector, auditors may be appointed in

accordance with statutory procedures. Accordingly,
considerations regarding the acceptance and
continuance of client relationships and specific
engagements, as set out in paragraphs 2835 of ISQC
1, may not apply.
Nonetheless, establishing policies and procedures as

described may provide valuable information to public
sector auditors in performing risk assessments and in
carrying out reporting responsibilities.
37
Appendix 4: Obligations of Membership to the Forum of Firms

The Forums membership obligations, with respect to transnational audits require Members to:
1.
Maintain appropriate quality control standards in accordance with International Standards

on Quality Control issued by the IAASB in addition to relevant national quality control
standards and conduct, to the extent not prohibited by national regulation, regular globally
coordinated internal quality assurance reviews.
2.
Have policies and methodologies for the conduct of such audits that are based, to the extent
practicable, on ISAs
3.
Have policies and methodologies which conform to the IESBA Code of Ethics for
Professional Accountants and national codes of ethics.
Refer to the Forum of Firms Constitution for further detail:

http://www.ifac.org/Forum_of_Firms/FoF_Constitution_February_22_2007_Final.pdf
38
Appendix 5: Requirements of ISA 220, Quality Control for an Audit of

Financial Statements, and ISA 600 Special ConsiderationsAudits of Group
Financial Statements (Including the Work of Component Auditors)
ISA 220:
With respect to client acceptance and continuance, ISA 220 states:
12.
The engagement partner shall be satisfied that appropriate procedures regarding the acceptance
and continuance of client relationships and audit engagements have been followed, and shall
determine that conclusions reached in this regard are appropriate. (Ref: Para. A8-A9)
13.
If the engagement partner obtains information that would have caused the Firm to decline the
audit engagement had that information been available earlier, the engagement partner shall
communicate that information promptly to the Firm, so that the Firm and the engagement partner
can take the necessary action. (Ref: Para. A9)
ISA 600:
With respect to client acceptance and continuance, ISA 600 states:
12.
In applying ISA 220, the group engagement partner shall determine whether sufficient
appropriate audit evidence can reasonably be expected to be obtained in relation to the
consolidation process and the financial information of the components on which to base the group
audit opinion. For this purpose, the group engagement team shall obtain an understanding of the
group, its components, and their environments that is sufficient to identify components that are
likely to be significant components. Where component auditors will perform work on the
financial information of such components, the group engagement partner shall evaluate whether
the group engagement team will be able to be involved in the work of those component auditors
to the extent necessary to obtain sufficient appropriate audit evidence. (Ref: Para. A10A12)
13.
If the group engagement partner concludes that:

(a)
it will not be possible for the group engagement team to obtain sufficient appropriate audit
evidence due to restrictions imposed by group management; and
(b)
the possible effect of this inability will result in a disclaimer of opinion on the group financial
statements,17
the group engagement partner shall either:
(a)
in the case of a new engagement, not accept the engagement, or, in the case of a continuing
engagement, withdraw from the engagement, where withdrawal is possible under applicable law
or regulation; or
(b)
where law or regulation prohibits an auditor from declining an engagement or where withdrawal
from an engagement is not otherwise possible, having performed the audit of the group financial
statements to the extent possible, disclaim an opinion on the group financial statements. (Ref:
Para. A13A19)
Terms of Engagement
14.
The group engagement partner shall agree on the terms of the group audit engagement in
accordance with ISA 210.18 (Ref: Para. A20A21)
17
ISA 705, Modifications to the Opinion in the Independent Auditors Report
18
ISA 210, Agreeing the Terms of Audit Engagements

39
Appendix 6: Guidance in A19 of ISQC 1

With regard to the integrity of a client, matters to consider include, for example:
The identity and business reputation of the clients principal owners, key management, and those
charged with its governance.
The nature of the clients operations, including its business practices.
Information concerning the attitude of the clients principal owners, key management and those
charged with its governance towards such matters as aggressive interpretation of accounting standards
and the internal control environment.
Whether the client is aggressively concerned with maintaining the Firms fees as low as possible.
Indications of an inappropriate limitation in the scope of work.
Indications that the client might be involved in money laundering or other criminal activities.
The reasons for the proposed appointment of the Firm and non-reappointment of the previous Firm.
The identity and business reputation of related parties.
The extent of knowledge a Firm will have regarding the integrity of a client will generally grow within
the context of an ongoing relationship with that client.
40
Appendix 7: Guidance in A18 of ISQC 1

Consideration of whether the Firm has the competence, capabilities, and resources to undertake a
new engagement from a new or an existing client involves reviewing the specific requirements of the
engagement and the existing partner and staff profiles at all relevant levels, and including whether:
Firm personnel have knowledge of relevant industries or subject matters;
Firm personnel have experience with relevant regulatory or reporting requirements, or the ability to
gain the necessary skills and knowledge effectively;
The Firm has sufficient personnel with the necessary competence and capabilities;
Individuals meeting the criteria and eligibility requirements to perform engagement quality control
review are available, where applicable; and
The Firm is able to complete the engagement within the reporting deadline.
41
International Federation of Accountants

545 Fifth Avenue, 14th Floor, New York, NY 10017 USA
Tel +1 (212) 286-9344 Fax +1(212) 286-9570 www.ifac.org

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Good Practice Guidance

Client Acceptance and Continuance

See Appendix 2 for a listing of Full members as of January 1, 2010.

TRANSNATIONAL AUDITORS COMMITTEE

CLIENT ACCEPTANCE AND CONTINUANCE

See Appendix 1 for the listing of External Inspection Reports.

CLIENT ACCEPTANCE AND CONTINUANCE

As further noted in the same publication:

CLIENT ACCEPTANCE AND CONTINUANCE

Can comply with relevant ethical requirements; and

Such policies and procedures shall require:

If a potential conflict of interest is identified in accepting an engagement from a new or an

See Appendix 4 for the Forum of Firms membership obligations.

See Appendix 5 for the requirements of ISA 220 and 600.

CLIENT ACCEPTANCE AND CONTINUANCE

Determining the Integrity of the Prospective Client

CLIENT ACCEPTANCE AND CONTINUANCE

CLIENT ACCEPTANCE AND CONTINUANCE

Provide information regarding:

CLIENT ACCEPTANCE AND CONTINUANCE

Other relevant information.

CLIENT ACCEPTANCE AND CONTINUANCE

Identity and Business Reputation of the Clients

CLIENT ACCEPTANCE AND CONTINUANCE

Financial and Going Concern Considerations

CLIENT ACCEPTANCE AND CONTINUANCE

Attitude Towards Aggressive Interpretation of

CLIENT ACCEPTANCE AND CONTINUANCE

Money Laundering or Other Criminal Activities

Why have not been reappointed?

Are there matters for concern in prior year(s) audit

How were we introduced?

CLIENT ACCEPTANCE AND CONTINUANCE

CLIENT ACCEPTANCE AND CONTINUANCE

Information obtained from sources external to the Firm:

Searches of the following:

Keyword internet searches

Inquiries performed by outside investigative agencies or credit agencies.

Finally, in forming an assessment as to client integrity, paragraph A20 notes:

CLIENT ACCEPTANCE AND CONTINUANCE

Determining Competency of the Firm to Perform the Engagement

See Appendix 7 for the guidance in A18 of ISQC 1.

CLIENT ACCEPTANCE AND CONTINUANCE

Competence to Perform the Engagement

Indicate the number of years of experience the

Other relevant information. A

CLIENT ACCEPTANCE AND CONTINUANCE

Competence to Perform the Engagement

CLIENT ACCEPTANCE AND CONTINUANCE

Reducing risks associated with competency and performance

Compliance with Ethical Requirements

CLIENT ACCEPTANCE AND CONTINUANCE

Compliance with Ethical Requirements

Other relevant information. A

Has our research (including enquiry, common sense

CLIENT ACCEPTANCE AND CONTINUANCE

Compliance with Ethical Requirements

Other relevant information. A

CLIENT ACCEPTANCE AND CONTINUANCE