|
Ramallah on January 19, 2010
To the Technical Director
International Auditing and Assurance Standard Board
International Federation of Accountants
545 Fifth Avenue, 14th floor
New York, New York 10017 USA
Subject: comments on the exposure drafts and consultation paper
Assurance on a Greenhouse Statement
Dear Sir,
Reference is made to the exposure draft and consultation paper
issued in October 2009 requesting comments on Assurance on a Greenhouse
Statement, kindly find the attached comments on the draft made on behalf of
Talal Abu-Ghazaleh and Co. International (TAGI), an international audit firm.
We think it is good idea to develop this statement (the Assurance
for GHG Engagements), the statement was well-drafted on which we agree and we
provide some comments on certain issues in the statement.
Sincerely,
Talal Abu Ghazaleh
International
Jamal Milhem, CPA
Executive Director
Vice President of Palestinian Association of Certified Public Accounting (PACPA)
|
Reference
|
Description
|
Comment
|
|
Paragraph 7(c)
|
Voluntary reporting
|
We suggest that the
reporting on Greenhouse Gas emissions to be compulsory for certain activities
or industries
|
|
Question 1
|
competency
|
The required skills and
experience of the engagement partner are suitable
|
|
Question 2
|
Appropriate place to bench
mark the further guidance
|
Yes, ISAE is an
appropriate to include further guidance regarding the skills, knowledge and
experience
We think points mentioned
in paragraph 12 are enough
|
|
Question 4
|
Additional guidance on
objectivity
|
Not necessary to provide
additional guidance regarding the measure of objectivity to be applied with
respect to external experts.
|
|
Question 5
|
External expert
independency
|
Not necessary for the
external expert to be independent as,
·
the engagement
partner and the CPA firm are independent and they can judge objectively on
the statement
·
It is also clear
that in case of referring to the expert in the report will not imply that the
practitioner responsibility is reduced (paragraph 112)
·
In the cases were
reporting is voluntary, independency will not be as necessary as where the
reporting is compulsory .
|
|
Question 6
|
Cost of reasonable
assurances
|
The cost will be
proportionate to the benefits to be derived.
|
|
Question 9
|
In cases of voluntary
reporting
|
The paragraphs are enough.
|
|
Question 10
|
Substantive analytical
procedures
|
Substantive analytical
procedures paragraphs 59 and 60 are appropriate.
|
|
Question 11
|
Internal control approach
|
The approach used to
internal control is appropriate
|
|
Question 12
|
Risk assessment
|
Yes, it is appropriate to
perform risk assessment procedures.
|
|
Question 13
|
The most significant risks
|
The most significant risk,
the quantification methods used
Other important risks, The
applicable criteria relevant to estimates.
|
|
Question 15
|
Assurance procedures
regarding estimate
|
Assurance procedures
regarding estimates paragraphs 62 and 63 are appropriate
|
|
Question 18
|
Report (ethics paragraph)
Reference to baseline
|
It is suggested To
delete the paragraph on ethics (We have complied with international
federation of accountants……and professional behavior)
| | 