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ISCA supports the key proposals relating to definitions of listed entity and PIE. However, we have concerns regarding the requirement for firms to determine if additional entities should be treated as PIEs for independence purposes. We believe that this will cause inconsistency and confusion as different firms may apply different criteria to determine what is a PIE.
Accordingly, we proposed for IESBA to consider requiring firms to:
- Communicate to management and those charged with governance (“TCWG”) that they have the right to request for their entity to be treated as a PIE; and
- Obtain concurrence of management and TCWG on whether an entity should be treated as a PIE and to provide recourse in the event of a disagreement.
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