This essay has a total of 2298 words and 14 pages.


In light of a number of high-profile corporate failures during the first half of 2001, a
number of studies have been performed to address the impact of mandatory rotation of audit
firms to ensure the appropriate level of ‘independence' of auditors. Majority of studies
conclude that the detrimental effects of firm rotation on the quality of the audit work by
far outweigh its positive effects as a safeguard against various independence and quality

Frequent changes of audit firms, whether resulting from mandatory rotation or otherwise,
introduce threats to independence and operational difficulties that make audit failure
more likely. Many studies have involved practitioners' opinions on this issue, which have
been based on their experiences and is therefore necessarily more subjective than from
impartial, third party studies. There are differing opinions, as some audit firms wish to
preserve the client bases, while others welcome more market volatility. Mandatory firm
rotation has been concluded as an unnecessary step at present, whose main impact will be
the auditing profession and its ability to attract talent for the future. At a time when
the restoration of public trust in financial reporting is a key priority, such changes
should be avoided.

Backgrou nd
Following the failure of HIH Insurance and other listed Australian companies during the
first half of 2001, concerns were raised about the adequacy of Australian rules governing
audit independence. Auditor independence is fundamental to the credibility and reliability
of auditors' reports. Independence is defined to require "… a freedom from bias,
personal interest, prior commitment to an interest, or susceptibility to undue influence
of pressure, any of which could lead to a belief that the audit opinion was determined
other than by reference to the facts of the audit alone."

With the increasing globalistion of capital markets and the fact that that section 324 of
the Corporations Act in relation to the independence of auditors had not changed in any
substantiative form for at least 40 years, it was recognised that this area required
attention and revision. The existing regulation prior 2004 of the auditing profession was
predominantly the responsibility of the professional accounting bodies. Whereby the
legislative requirements were "minimal" and "piecemeal."

International developments were in progress by International Federation of Accountants
(IFAC) which aimed to update the ethical requirements of audit independence. European
Commission released a consultative paper containing proposals designed to achieve greater
uniformity throughout Europe & United States Securities and Exchange Commission's (SEC)
had decided to remake its rules on audit independence to address issues associated with
recent independence violations by auditors in the US.

As a part of the growing recognition of the desirability of achieving global uniformity
and harmonisation in all areas of financial reporting and auditing, many studies and
discussions including the Ramsay report were instigated since 2001 . The CLERP (Audit
Reform & Corporate Disclosure) Act 2004 implemented the CLERP 9 measures and the
recommendations of the Ramsay Report on the independence of Australian company auditors
and took into account the relevant recommendations of Report 391 of the Joint
Parliamentary Committee of Public Accountants and Audit.

The CLERP 9 Act draws on the HIH Royal Commission (HIHRC) , Cole Royal Commissions Report
and the Ramsay Report in focusing on the importance of an independent audit on capital
market efficiency. This is to be achieved through adding value to financial statements by
improving reliability, which in turn should assist to lower the cost of capital by
reducing information risk and enhancing value to capital market by strengthening the
credibility of financial statements.

The many arguments for and against Mandatory audit firm rotation was considered as part of
this reform however, the Audit Review Working Party concluded that ‘the anticipated
cost, disruption and loss of experience to companies is considered unacceptably high, as
is the unwarranted restriction on the freedom of companies to choose their own auditors'
As an alternative, mandatory rotation of the audit partners was included in the CLERP Act
2004 , whereby rotation is to occur after 5 consecutive years with a 2 year cooling off
period before a person who has played a ‘significant role' in the audit can be
reassigned to that audited body.

Arguments ‘For' & ‘Against' Mandatory rotation of Audit firms

The arguments for and against mandatory rotation of audit firms fundamentally revolves
around the issues of auditor independence, audit quality and increased audit costs.
Compromising either auditor independence or audit quality will adversely effect the
accuracy of audits performed and hence effect the shareholders' future.

The significance of mandatory rotation of audit firms on an auditor's independence and
quality of audit can be evaluated on a large number of factors, such as length of time an
individual has served, the role of the individual, the size and structure of the firm, the
nature of the engagement and whether the client is a public interest entity or not.

There are numerous threats to the independence of auditors which have been identified in
the multiple studies and discussions both in Australia (such as the Ramsay report, CLERP 9
Paper) and internationally by IFAC, the European Commission and SEC. The key threats
identified are over-familiarity, self-interest, advocacy and intimidation of auditors.

Over-fa miliarity
Mandatory firm rotation avoids over-familiarity between the auditor and client and
removing the ‘undesirable nexus between client and auditor'. As the auditor may be
perceived as too trusting because of familiarity, thus resulting in insufficient
professional scepticism or testing of representations made in the firm's disclosure

Self- Interest
This issue of ‘self-interest' by the auditor may potentially influence an audit
judgement arising from the auditor benefiting from a financial interest or self-interest
conflict such as a desire to retain the client.

Advocacy & Intimidation
The independence of auditors can be strengthened through mandatory firm rotation, when the
auditor becomes an advocate for or against a firm's position or opinion to the point that
objectivity is, or is perceived to be, impaired. It also reduces the situations where
auditors are subjected to increased intimidation of clients through actual or perceived
threats by clients.

Negative Economic Impact
It can be argued that as a result of the rotation, especially for clients within
specialised industries , the loss of cumulative knowledge and and the difficulty in
maintaining industry specialisation would increase. The lack of knowledge and
understanding of the firm's operations, information systems and practices can incur
additional risk and time in the initial year's of the new auditor's tenure.

The Bocconi Report on Italy's experience of mandatory rotation found that there was a need
for a "training period" of two to three years for new auditors of complex groups to fully
understand the business. Therefore the significant costs in terms of management time
particularly in terms of working with the new auditors to familiarise them with the
company should not be underestimated, especially when these costs will be incurred "in
each rotation" Bocconi quantified such costs as "15% greater for a new client in a
familiar industry and 25% higher in a new client in a new industry" and reported a 40%
increase in audit hours were invested to familiarise with the fusiness, processes and

To overcome this initial cost, additional procedures can be implemented to develop the new
auditor's knowledge more quickly, however such additional costs and company management
time make the potential benefits of mandatory audit firm rotation harder to predict and
quantify, though GAO is "fairly certain that there will be additional costs."

Despite the initial increased risk and time costs of implementing new auditing firms, the
rotation of audit firms facilitates easier detection of material misstatements of
financial statements through the "fresh look" approach. This approach will avoid any
tendency of an auditor ‘anticipating results' and as a result will be alert to subtle
and often surreptitious, though important, anomalies.

Impact on Market for Audit Services
To negate the above mentioned costs, the mandatory rotation would increase competition and
volatility in the audit market. Bocconi concluded that this had generally led to a
reduction in audit fees. Initially, this would imply that smaller audit firms would be
encouraged to grow and challenge the leading larger audit firms, however studies indicate
Continues for 7 more pages >>

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