1993-10-21 | A 2152Added · Updated
Financial entities must appoint auditors from the Register of Auditors, reporting appointments within 15 business days using forms 3830 and 3831. Auditors must provide a performance guarantee of 0.5% of the entity's net worth, replenishing any 5% drop within 48 business hours. Auditors are prohibited from serving more than five consecutive fiscal years or simultaneously for multiple entities.
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BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
COMUNICACIÓN "A" 2152 21/10/93
TO FINANCIAL ENTITIES
Ref.: Circular ACCOUNTING AND AUDIT – CONAU 1 – 134 Minimum Standards on External Audits
We address you to communicate the modifications that have been resolved to introduce to the Minimum Standards on External Audits, which will take effect as of January 1, 1994.
We point out that within a period of 30 calendar days counted from the date of entry into force of these new minimum standards, you must inform by note the name of the acting professional, accompanied by Forms 3830, 3831, and 1441 (the latter in triplicate), the certification issued by the National Registry of Recidivism and Criminal Statistics, managed by the interested parties themselves, and the record through which the integration of the performance guarantee is verified.
We clarify that the requirements of seniority and minimum experience will not be enforceable for Public Accountants who currently perform external auditing in some financial entity.
Finally, we inform you that the requirement of rotation, every five fiscal years, must be observed at the time of the first hiring subsequent to the date of this communication. For the purposes of its calculation and in the case of audits in force on that date, the fiscal year that is in progress at that moment will be considered.
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Attached are the sheets that correspond to incorporate into Circular CONAU - 1, replacing those previously provided.
We salute you very attentively.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Ricardo O. Maero Liliana M. Conti
Deputy Manager of Regime and Deputy General Manager for Information Systems Area of Development Units of Procedure and Information
ANNEXES: 28 sheets
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
ANNEX I
Circular CONAU 1-134 Page 1 of 7
GENERAL PROVISIONS ON EXTERNAL AUDITS
Financial entities must inform the Central Bank of the Republic Argentina of the name of the Public Accountant appointed to carry out the external audit of their accounting statements and other information requested by this Institution, as well as the term of their hiring. In the cases of professionals acting on behalf of Public Accounting Firms, they must also indicate the denomination of the latter. Such appointment, as well as corresponding subsequent changes, must be reported by note within 15 business days of occurrence, accompanied by forms 3830 and 3831. If changes occur before the expiration of the hiring term, the entities must indicate the causes that gave rise to them.
External auditing must be exercised by public accountants designated by financial entities who are in conditions to be inscribed in the "Register of Auditors" enabled at the Superintendence of Financial Entities and Currency Exchange. These professionals cannot perform simultaneously in more than one financial entity, in which they will not exercise their function for more than 5 consecutive exercises. Upon discontinuing their task due to the fulfillment of that maximum term or a lower term, a period at least equal to their performance must elapse before they can be appointed again in it.
The designated accountant must offer a performance guarantee equivalent to 0.5% of the calculable net worth of the entity to be audited, corresponding to the last balance sheet closing. The guarantee will remain until the passage of the 6-year period referred to in the last paragraph of point 3, counted from the detachment of the professional, and will serve to attend eventual responsibilities towards third parties - including the Central Bank - for the exercise of the audit function. Professionals appointed to audit public financial entities that integrate official oversight bodies are exempt from this requirement.
Such guarantee may consist of:
I) cash deposit in the Central Bank.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
II) deposit of national public securities in Caja de Valores S.A. in the name of the auditor and to the order of the Central Bank, valued at the market quotation (weighted average of quotations immediate spot of the Buenos Aires Stock Market of the last business day prior to the deposit or, if no operation occurred, of the Electronic Open Market). In the event that due to a decrease in the price of the titles offered as guarantee, an impact on the value of the guarantee greater than 5% is recorded, the difference must be replenished within a period of 48 business hours. III) guarantee of a financial entity different from those audited by the professional or some of its partners, if acting in a public accounting firm. IV) surety insurance from an insurance company accepted by the Central Bank.
The record of having integrated the guarantee must be attached to forms 3830 and 3031.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 1st Date: 21.10.93 Communication "A" 2152 d) have been expressly excluded from the "Register of Auditors" by the Superintendence of Financial Entities and Currency Exchange for non-compliance with the provisions contained in article 39 of said law or in this regulation, e) have been expressly disqualified from practicing the profession by any of the Professional Councils of Economic Sciences of the country, f) do not have the independence required by current audit norms recognized or established by the Professional Council of Economic Sciences of the jurisdiction where they act. Among others, it is considered that this requirement is not met when the professional or some of its partners, if acting in a public accounting firm, have credit facilities of any nature granted by the entities they audit, g) belong to accounting firms in which more than one professional excluded from the "Register of Auditors" by the Superintendence of Financial Entities and Currency Exchange participates or has participated, during the period in which some exclusion is in force, h) have a seniority in the license of less than 5 years, or i) do not have an experience of 3 years or more in the performance of audit tasks in financial entities that have covered the different subjects subject to verification,
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 1st Date: 21.10.93 Communication "A" 2152 a) the professionals declare knowing and accepting the obligations established in this regulation, and b) the entities authorize the professionals and these latter, in turn, obligate themselves to attend consultations, agree access to working papers and/or facilitate copies thereof to the Superintendence of Financial Entities and Currency Exchange.
The intervening professional will always keep their working papers in their possession, as evidence of the task performed, for a minimum of 6 years.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 1st Date: 21.10.93 Communication "A" 2152
3) observations made by the inspection of the Superintendence of Financial Entities and Currency Exchange on the external auditor's tasks have revealed serious professional negligence in the application of current audit norms.
4) the external auditor does not manifest in their reports the existence of situations that affect or could significantly affect the functioning of the entity or seriously compromise its assets and that, by usual procedures, should be known to them.
5) working papers supporting their reports are not presented within 5 business days of being requested and at the domicile constituted by the external auditor, or the expansions and clarifications deemed necessary by the Superintendence of Financial Entities and Currency Exchange are not provided.
6) other substantial transgressions to the Minimum Standards on External Audits established by the C.B.R.A. are verified.
4.2. Procedure.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 1st Date: 21.10.93 Communication "A" 2152 In duly founded cases, a 10-day extension may be granted to make such defenses.
3) if within the period established in the previous point, explanations from the external auditor are received and considered sufficient, the proceedings will be archived without further procedure, after review by the Superintendent of Financial Entities and Currency Exchange, notifying the acting professional.
If the defenses are not received in time and form or are not deemed sufficient, the facts and circumstances that would give rise to applying the sanction provided will be communicated to the Professional Council of Economic Sciences of the jurisdiction to which the professional belongs, informing them of what is indicated in the following paragraph.
4) within 90 days of the notification referred to in the previous point, a draft resolution excluding the involved professional from the "Register of Auditors" will be submitted to the Superintendent of Financial Entities and Currency Exchange, in which the validity period of the exclusion and the amount of the offered performance guarantee to be affected must be established. Any eventual presentation that the respective Professional Council may have made, related to the case, will be attached with an opinion. The draft resolution will be previously submitted to a legal opinion. However, if the Council requests it in a duly justified manner, the previous period may be extended by 60 more days.
5) The Superintendent of Financial Entities and Currency Exchange will consider the project cited in the previous point, within 15 days of receipt.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 1st Date: 21.10.93 Communication "A" 2152 If approved, the adopted resolution will be formally communicated to:
a) the excluded external auditor and, if applicable, the accounting firm to which they belonged. b) the entities audited by the said professional or by auditors who integrate together with him the same accounting firm, intimating them to the designation of a new external audit within thirty days of notification, when it concerns the situation provided for in item g) of point 1. c) financial entities in general, through the corresponding communication. d) the Professional Council of Economic Sciences of the jurisdiction in which the excluded professional is registered.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
ANNEX III
Version: 3rd Date: 21.10.93 Communication "A" 2152 MINIMUM AUDIT PROCEDURES
I. APPLICABLE FOR THE EXAMINATION OF YEAR-END ACCOUNTING STATEMENTS
A. SURVEY AND EVALUATION OF INTERNAL CONTROL
The survey and evaluation of the existing internal control system will be the basis for determining the nature, scope, and timing of audit procedures and includes:
In the case of entities that process their transactions totally or partially through electronic data processing equipment, the external auditor must pay special attention to the evaluation of the existing internal control in these processes, according to the "Guidelines for the Examination of Accounting Statements in a Computerized Context" (Report No. 6, Audit Area, Scientific and Technical Research Center of the Argentine Federation of Professional Councils of Economic Sciences).
Likewise, the external auditor will evaluate the work developed by those responsible for internal auditing (as an integrating element of the entity's internal control system) to better specify the nature, scope, and timing of the audit procedures that they must apply.
B. SUBSTANTIVE TESTS
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
7. Review of period movements of public titles and securities for participation in other societies (in pesos and foreign currency), comparing corresponding supporting documentation and verifying correct accounting allocation according to their characteristics and respective B.C.R.A. norms.
8. Review of the adequate valuation and restatement in closing currency of public titles and securities for participation in other societies (in pesos and foreign currency), in accordance with B.C.R.A. norms, as well as the reasonableness of provisions for devaluation risk.
9. Review of the adequate compilation of lists of debtors for loans and other intermediation financial credits (in pesos and foreign currency), through arithmetic control, verification of supporting documentation of a sample thereof, and comparison of corresponding totals with respective control accounts in the general ledger.
10. Surprise inventory of documents, guarantees backing the credit portfolio, financial lease contracts, acceptances, and purchased values (in pesos and foreign currency). Comparison of the results obtained with accounting records and/or corresponding supporting documentation and verification of adequate compliance with legal and tax aspects corresponding.
11. Obtaining direct confirmations from debtors for loans and other intermediation financial credits (in pesos and foreign currency). Analysis of received responses, evaluation of entity explanations on significant differences existing, and performance of alternative procedures on balances corresponding to unreceived confirmations, verifying supporting documentation of operations and/or their cancellations. The scope of this work must cover, at least, the 50 clients with the largest debtor balances with the entity.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 5th Date: 21.10.93 Communication "A" 2152
12. Review of the reasonableness of capitalizations, quotation differences, premium, and accrued interest, in accordance with procedures established by the B.C.R.A., corresponding to all credits that generated them, proving for a sample thereof the correctness of applied interest rates and corresponding calculations.
13. Review of the reasonableness of the "Debtor Status Statement" and "Information on Monthly Averages of Daily Balances and Complementary", prepared according to norms established by the B.C.R.A., verifying - in the first case - correspondence with accounting balances. Review of the reasonableness of information on "Composition of Economic Groups". Verification of compliance with provisions on credit grading and operations with linked firms.
14. Evaluation of the reasonableness of provisions for uncollectibility and devaluation risk, based, among other aspects, on:
14.1. "Debtor Status Statement".
14.2. Information provided by the "risk central" and/or through other publications of similar nature from the B.C.R.A.
14.3. Portfolio composition by types of activities and clients, influence zones, degree of concentration, linked firms, etc.
14.4. Detailed list of debtors in bankruptcy, liquidation, or judicial management and financial entities in liquidation prepared by the entity, with opinion of lawyers and officials on the degree of collectability of their debts.
14.5. Follow-up of the evolution and compliance of debtors with arrangements.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
14.6. Evaluation of antecedents and current situation of debtors with delays or with insolvency risk, as well as extrajudicial actions carried out by the entity for the collection of their debts.
14.7. Norms established by the B.C.R.A. on provisioning matter.
15. Review of swap, pledge, spot purchase and sale for settlement and forward operations of public or private titles and foreign currency, by comparing balances with corresponding supporting documentation, verification of their valuation in accordance with B.C.R.A. norms, and investigation, when appropriate, of the reasons for failure to cancel operations within established deadlines.
16. Review of pending balances from clearing chamber and securities exchange operations, by comparing their cancellation with statements and settlements within corresponding deadlines or investigation of reasons for delay.
17. Review of balances corresponding to payments made through third-party accounts by comparing with supporting documentation of expenditures made and their cancellations within reasonable deadlines.
18. Review of balances with the B.C.R.A. for "Reciprocal Credits - Pending Reimbursements and Refunds", by comparing with corresponding supporting documentation, verification of correct application of exchange rates, and investigation, when appropriate, of causes of delayed items.
19. Review of other credits not mentioned above, through analysis of the reasonableness of included concepts, verification that items not corresponding according to B.C.R.A. norms have not been activated, and evaluation of the need to apply additional procedures, such as verification of corresponding supporting documentation, request for balance confirmation, etc.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 6th. Date: 21.10.93 Communication "A" 2152
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
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BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 5th. Date: 21.10.93 Communication "A" 2152
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 2nd. Date: 21.10.93 Communication "A" 2152
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
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BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 1st. Date: 21.10.93 Communication "A" 2152
44.6. Evaluation of the reasonableness of provisions for contingencies.
44.7. Review of the reasonableness of charges accrued for contributions to the Bank Social Services Institute and comparison of their cancellation in due time with the respective supporting documentation. Additionally verify that the corresponding advances have been paid in due time.
44.8. Review of the monetary result (by financial intermediation, linked to operational expenses and by other operations).
45. Review of the settlement of remuneration to personnel.
46. Comparison of the supporting documentation and detailed verification of the most significant amounts charged to the results of the fiscal year of the accounts that:
46.1. Have abnormal variations between months within the fiscal year or with respect to the previous fiscal year without apparent justification.
46.2. Have significant differences in the global tests carried out or that do not relate to the balances of the equity accounts that generated them.
46.3. By their nature and/or significance require the carrying out of a detailed examination in the judgment of the professional.
47. Review of facts and transactions occurring after the end of the period and up to the date of the auditor's report, in order to determine if they significantly affect the figures of the accounting statements at that date or require additional exposure within the corresponding complementary information.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 1st. Date: 21.10.93 Communication "A" 2152
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 1st. Date: 21.10.93 Communication "A" 2152
II. APPLICABLE FOR THE EXAMINATION OF QUARTERLY ACCOUNTING STATEMENTS
The examination of the accounting statements at the end of each quarter will consist of a limited review of them, in which:
A. A part of the survey and evaluation of the entity's internal control will be carried out, according to the scope determined by the auditor, in such a way that at the end of the fiscal year the point I -A required for the examination of the accounting statements at the corresponding closing is completed, in all that relates to the significant transactions developed by the entity. B. The substantive tests mentioned in points I-B, sections 3, 4, 8, 9, 12, 13, 14, 15, 20, 21, 22, 24, 27, 28, 29, 31, 32, 40, 41, 43, 44, 46, 47, 50, 51, 52, 53, 54 and 55 will be carried out.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 3rd. Date: 21.10.93 Communication "A" 2152
EXTERNAL AUDITORS' REPORTS
As a conclusion of the task carried out, external auditors must send the following reports to the financial entities:
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 2nd. Date: 21.10.93 Communication "A" 2152
When it is necessary to formulate a qualification for lack of uniformity, with respect to the guidelines or accounting criteria used in the previous exercise, a specific paragraph will be included that clearly describes the change, the causes that originated them, their quantitative effects and the opinion that the external auditor deems the modification performed, except that the situation has been exposed in a note to the accounting statements.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 3rd. Date: 21.10.93 Communication "A" 2152
The qualifications to the main opinion, that is, on the reasonableness of the accounting statements, can have two different meanings:
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 3rd. Date: 21.10.93 Communication "A" 2152
Typical cases of this type are the resolution of pending lawsuits, summaries being processed in the Superintendence of Financial and Exchange Entities, differences of interpretation on tax issues, doubts about the collectability of loans, etc.
The qualifications must be adequately justified, specifying the accounts or items involved, the nature of the exception and its amount. When there is impossibility to reasonably quantify the corresponding amounts, the external auditor must explain the reasons for it in his opinion. The exposure of the causes of the qualifications in notes to the entity's accounting statements will excuse their repetition in the opinion, but this must indicate the existence of the qualification and refer to the respective notes.
2. Reports with the results of the limited reviews of the entity's accounting statements at the end of each quarter, which will include as a minimum the following:
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 2nd. Date: 21.10.93 Communication "A" 2152
corresponding date and the results of its operations for the period ended on that date.
BANCO CENTRAL DE LA REPÚBLICA ARGENTINA
Version: 1st. Date: 21.10.93 Communication "A" 2152
The Board of Directors, the Board of Administration or the competent local authority, as the case may be, will be responsible for analyzing the received memorandum and in case of sharing the external auditor's opinion, develop a plan with the intervention of the internal audit managers so that, within 180 days, the observed deficiencies are corrected. The aforementioned memorandum must be transcribed in the Book of Minutes of the meetings of the Board of Directors or Board of Administration of the entity or, in its defect, in a special book enabled for such purpose. If the external auditor had not observed significant deficiencies in the accounting internal control system, he must also send a letter to the entity informing about said situation.
4. Special reports, which, in addition to what is provided for each particular case, must contain as a minimum the following:
Version: 1st. Date: 21.10.93 Communication "A" 2152
The external auditor will prepare a report stating whether all and each of the data contained in the aforementioned information, corresponding to the last month of each calendar semester, agree with those obtained from their own examination, noting any discrepancies observed.
Version: 1st. Date: 21.10.93 Communication "A" 2152
These reports, as well as those mentioned in points 1 and 2, must be sent by the financial entities to the Central Bank of the Republic of Argentina, together with the corresponding financial statements, signed by the Public Accountant, for the purpose of identification with the respective report.
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