1. Long Association Task Force
Marisa Orbea,
Task Force Chair
IESBA Meeting
September 15-16, 2015
New York, USA

2. Some comments on cooling-off periods for EQCR
Long Association
Some comments on cooling-off periods for EQCR
Proposal is reasonable and provides balanced approach
Good job trying to steer down the middle
Should be striving for harmonisation
Too complex to apply
Adding complexity is not in the Public Interest
Concern about non-PIE approach with respect to banks
Minimum only and should encourage higher standards

3. Some comments on cooling-off periods for EQCR
Long Association
Some comments on cooling-off periods for EQCR
EQCR role is different and additional year off non-PIEs will mean hardship for SMPs
Consider what adoption and implementation will look like
Do some work on illustrating what good practices look like
Proposals should be re-exposed

4. Some comments on jurisdictional clause
Long Association
Some comments on jurisdictional clause
Deals with EU therefore supported
Be clearer about pointing to EU situation to inform the discussion
What should regulatory inspection regime look like?
Can see logic but are objectives sufficiently similar between firm and partner rotation?
Is Board comfortable with specificity of 10 years?

5. Some comments on activities during cooling-off
Long Association
Some comments on activities during cooling-off
Limited consultation clause not supported by some:
Relationship continues to exist
Clouds ultimate principle
Off means off
Don’t want someone in the background calling the shots

6. Some comments on activities during cooling-off
Long Association
Some comments on activities during cooling-off
But limited consultation also considered practical by a few:
No evidence hasn’t worked in the UK
Could be OK as long as not part of decision making
Its about how it is implemented and deployed
More audit quality delivered if right people involved and have the right safeguards
Other restrictions generally supported

7. Is possibility of rotation of non-KAPs emphasised sufficiently?
Long Association
Other comments
Is possibility of rotation of non-KAPs emphasised sufficiently?
Consider adding concurrence of TCWG in (the exemption could be a one off).