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Although the IAIS agrees on the whole with the recommendations made in the ITC, there are a few areas that would benefit from further clarity to ensure consistency of application and to preserve the respective roles of management and auditors:
The IAIS agrees with the concept of Auditor Commentary, however the IAIS feels that the description made in the ITC is broad and could allow the auditor to provide original information about the entity that management has not provided. The IAIS believes that it is the responsibility of management, and not the auditors, to provide information about an entity. In the IAIS's view, Auditor Commentary should provide information to allow users to understand how the auditor concludes on the financial statement as a whole considering specific assessments on the most judgemental aspects of the audit. As such, the IAIS is supportive of Auditor Commentary that follows the example on the valuation of financial instruments included in the illustrative auditor’s report in the ITC.
Where valuations or estimates involve a high degree of subjectivity, the IAIS believes that management should disclose the range of possible outcomes in notes to the financial statements. The IAIS suggests that the IAASB and the IASB work together to improve these disclosures. Audit Commentary should draw attention to those notes and comment on the work the auditor did to satisfy themselves on the range or valuation developed by management.
The IAIS recognises the difficulty in developing standards that achieve the right balance between providing useful information that helps users to understand the financial statements and providing an excessive amount of information that would overwhelm users. As such, the IAIS encourages the IAASB to provide more detail on the objectives of Auditor Commentary, and to set out clear principles and illustrative examples to assist the auditor in identifying the relevant entity-specific matters and in defining the nature and extent of the communication in the auditor’s report. Illustrative examples specific to insurance entities would be helpful.
The IAIS believes that there is a need to preserve mores strongly the separate responsibilities of management and those charged with governance (TCWG). The IAIS views TCWG as independent of management and therefore recommends that the descriptions of the responsibilities of TCWG and management be provided in separate paragraphs in the auditor report to highlight this independence.
Regarding going concern assumptions, the IAIS notes that there is considerable scope for the interpretation of “going concern” and “material uncertainty”. There is a need for consistency and sensitivity in such disclosures for insurance entities. As such, the IAIS encourages the IAASB to work with the IASB towards a common understanding of the purposes of going concern assessments, and financial statement disclosures on going concern and material uncertainty.
As international convergence is important in theses areas, the IAIS encourages the IAASB to liaise with the US PCAOB and the European Commission, as these bodies are also developing requirements regarding the content of the audit reporting.