Colegio de Contadores de Chile
Member | Established: 1958 | Member since 1981
The CCCH, created by the Law 13.011 of 1958, is a voluntary professional accountancy organization with responsibilities such as: (i) setting accounting and auditing standards for non-regulated companies; (ii) issuing professional and ethical standards for its members; (iii) establishing membership requirements; (iv) investigating and disciplining its members; (v) providing training programs; and (vi) representing and promoting the accounting profession.
In addition to being an IFAC Member, the CCCH is a member of the Inter-American Accounting Association and the Integration Committee Europe—Latin America, and a member of the Group of Latin-American Accounting Standard Setters.
Statements of Membership Obligation (SMO)
The Statements of Membership Obligations form the basis of the IFAC Member Compliance Program. They serve as a framework for credible and high-quality professional accountancy organizations focused on serving the public interest by adopting, or otherwise incorporating, and supporting implementation of international standards and maintaining adequate enforcement mechanisms to ensure the professional behavior of their individual members.
SMO 1: Quality Assurance
Chilean Law No. 18.045 does set the legal foundation for the establishment of a quality assurance (QA) review system for auditors providing services to listed companies; however, as of 2019 no mandatory a QA review system has been implemented. Only the Financial Market Commission (CMF) and the Superintendent of Banks and Financial Institutions (SBIF) require audit firms listed in the External Audit Firms Register to establish quality control mechanisms but audit reviews are only carried out when a suspicion or risk is identified.
The CCCH states that it regularly promotes the need to adopt a mandatory QA system at the jurisdiction level to the regulators through the Chairman of its Auditing Standards Committee. In addition, the CCCH is offering support to the financial sector regulators for their audit reviews and inspections. Furthermore, the CCCH indicates it plans to support members’ understanding of QA reviews when the regulators eventually adopt a QA system.
The CCCH has adopted and translated audit and quality control standards as issued by the Audit Standards Board of the American Institute of Certified Public Accountants for application by its members, which, in turn, are based on ISA and ISQC1. To support the implementation of the requirements, the CCCH reports that it offers training and courses on effective quality control, and supports audit firms with the implementation of the standards.
The CCCH is encouraged to provide an update on its advocacy and technical support activities with the financial sector regulators, incorporating in its SMO Action Plan specific actions it undertakes to promote the establishment of a mandatory QA review system at the jurisdiction level for all audits and to promote such a system’s compliance with the revised SMO 1 requirements.
SMO 2: International Education Standards
Universities, the National Accreditation Commission and the Ministry of Education have a role in implementing initial professional development (IPD) requirements for all professional fields, including professional accountants. The CCCH reports that the universities providing accounting education programs, have adopted the revised IES requirements. However, according to the CCCH, there are no minimum requirements to practice accountancy in Chile.
In order to implement some educational requirements, the CCCH reports that it requires candidates to hold a bachelor degree in accounting in order to be considered for membership.
The CCCH indicates that its primary activities in this area are centered on promoting the need to implement IES requirements to regulators. In line with this, the CCCH has established a Higher Education Committee (CES) which consists of members from several Chilean universities. In addition, the CCCH established mechanisms, such as its magazine, to distribute information to members regarding recent developments and revisions issued by the IAESB and has translated the 2014 version of the IES.
The CCCH is encouraged to clearly indicate the actions it undertakes to promote changes to the Chilean legal framework that would introduce minimum requirements to practice the profession in Chile. In efforts to achieve this significant change, CCCH is encouraged to collaborate with other stakeholders involved in the education of professional accountants in the jurisdiction, such as other professional organizations, universities, and regulators, to develop a roadmap for bringing national educational requirements for all professional accountants in line with IES—especially in light of the revised IES.
Lastly, the CCCH is also encouraged to promote the IES requirements to the financial sector regulators— Financial Market Commission (CMF) and the Superintendent of Banks and Financial Institutions (SBIF)— that have additional registration requirements for external auditors.
SMO 3: International Standards on Auditing
The CCCH and the financial sector regulators— Financial Market Commission (CMF) and the Superintendent of Banks and Financial Institutions (SBIF)—are responsible for setting auditing standards in Chile. The Auditing Standards Committee (CNA) of the CCCH adopts the Chilean Generally Accepted Auditing Standards (NAGA) which, as reported by the CCCH, are the translation of the standards issued by the Audit Standards Board of the American Institute of Certified Public Accountants (AICPA), which, in turn, are based on ISA. The financial sector regulators require application of standards issued by the CCCH.
The CCCH has been translating the AICPA’s audit standards since 1972 and therefore has an established mechanism in place to monitor, translate, and issue new and revised standards. The institute reports that it continues translating and issuing the AICPA’s audit standards due to the large number of U.S. companies operating in Chile and the large number of Chilean companies participating in the U.S. stock market.
To facilitate members’ implementation of the NAGA, the CCCH offers continuing professional development programming and disseminates information on updates and revisions of NAGA.
Additionally, the CCCH reports that the CNA regulatory communicates with the financial sector regulators around firms’ compliance with the auditing standards.
Despite the fact that the CCCH translates and adopts the AICPA’s audit standards on an ongoing basis, the CCCH is encouraged to raise awareness on ISA as part of its commitment to support the international standard-setting. For example, the CCCH may consider disseminating information on ISA, promoting the inclusion of ISA as part of the accounting curricula, and communicating with the regulators on new IAASB initiatives.
If deemed feasible, it may be beneficial for the CCCH to participate in the international standard-setting process by providing comments on exposure drafts and other IAASB pronouncements to share its experiences and perspective.
SMO 4: Code of Ethics for Professional Accountants
The CCCH is responsible for setting ethical requirements for its members and has developed its own Code of Ethics, and indicates it utilizes the 2009 IESBA Code of Ethics as a supplement to its own code. In addition, while the financial sector regulators—Financial Market Commission (CMF) and the Superintendent of Banks and Financial Institutions (SBIF)—have not issued a specific regulation related ethical requirements, in practice, audit firms listed in on their registers, apply the CCCH Code of Ethics.
The CCCH reports that it has ongoing processes in place to monitor changes to the IESBA Code of Ethics in order to review, approve, and subsequently issue new sections of its Code of Ethics or amend existing parts when necessary.
To support the effective implementation of the Code, the CCCH: (i) raises awareness of the Code among the financial sector regulators, universities, judiciary and legislative powers, and government; (ii) disseminates information to relevant stakeholders about the changes to its Code and new, proposed, and revised provisions of the IESBA Code of Ethics; and (iii) includes ethical requirements in its training programs.
The CCCH is encouraged to update the version of the IESBA Code of Ethics that it is uses as supplement of its own Code of Ethics, especially given the significant changes within the 2016 and 2018 IESBA Code of Ethics. The CCCH is also encouraged to consider entering into mutual agreements with financial sectors regulators to officially adopt the IESBA Code of Ethics or require application of ethical requirements issued by the CCCH.
If deemed feasible, the CCCH is encouraged to consider plans to participate in the international standard-setting process by providing comments on exposure drafts and other IESBA pronouncements to share its experiences and perspective.
SMO 5: International Public Sector Accounting Standards
The CCCH is not responsible for the adoption of public sector accounting standards in Chile, which are adopted by the Controller General of the Republic of Chile. The Controller General developed accrual -basis national standards based on the IPSAS (2013) as the applicable public sector accounting standards. The CCCH notes that it was active during the convergence process with IPSAS by participating in meetings and providing advice to the Controller General.
The CCCH indicates that it has established mechanisms to distribute information regarding recent developments and revisions issued by the IPSASB. Additionally, the CCCH’s Higher Education Committee is considering how to incorporate IPSAS into educational programming. However, apart from these general statements, no other specific activities have been outlined in its SMO Action Plan.
During the next submission of its Action Plan, the CCCH is encouraged to consider, if deemed relevant and necessary, a strategy outlining its involvement in public sector accounting issues and support it can provide to public sector accountants in the jurisdiction. For example, the CCCH is encouraged to indicate if it provides trainings on IPSAS for its members that may work in the public sector, update its website to include relevant information on IPSAS, and demonstrate how it has engaged with universities to incorporate the standards into accounting education curriculum.
SMO 6: Investigation and Discipline
The CCCH is responsible for establishing and operating an investigative and disciplinary (I&D) system for its members and has established and implemented I&D procedures accordingly. In addition, the financial sector regulators— Financial Market Commission (CMF) and the Superintendent of Banks and Financial Institutions (SBIF)—have responsibility for the I&D of audit firms (not individual audit professionals) registered in the External Audit Firms Register; however, the extent to which the I&D systems established by the respective regulators are in line with the best practices of SMO 6 is unclear.
The CCCH conducted an assessment of its I&D policies and processes against the requirements of SMO 6 and has identified gaps. These include the composition of members of the I&D committee (i.e. no non-accountants); public interest considerations (results of the proceedings are not publicly available) and the CCCH is prohibited by the Chilean Constitution to impose penalties such as loss of professional designation or exclusion from membership, among others.
The CCCH reports it has issued procedures and guidance for the establishment of I&D systems at regional councils, that will be incorporated under the unmbrella of the CCCH.
The CCCH is strongly encouraged to develop and include a plan to address the existing gaps of its I&D policies based on its self-assessment against the requirements of SMO 6. In addition, the CCCH is encouraged to consider its role in regards to SMO 6 at the jurisdictional level and provide more details and information about its plans either to recommend and support the implementation of I&D processes in line with the SMO 6 requirements to the financial sector regulators; or to promote a unified national system that can investigate and discipline all professional accountants while being in line with SMO 6. Once its role is defined, the CCCH is encouraged to create a strategic plan with the actions it will undertake to fulfill its mandate.
SMO 7: International Financial Reporting Standards
The CCCH is mandated by law to adopt corporate accounting standards for non–regulated companies and has accordingly adopted IFRS and IFRS for Small- and Medium-sized Entities (SMEs) by reference. The financial sector regulators are empowered to set accounting and financial reporting requirements for companies under their supervision. The Financial Market Commission (CMF) and the Superintendent of Banks and Financial Institutions (SBIF) have adopted IFRS since 2009. When adopting IFRS, the SBIF made two significant modifications which consequently makes its standards differ from IFRS.
To support the adoption of the standards, the CCCH reports that it has a permanent Accounting Principles and Standards Committee that reviews and approves accounting standards on an ongoing basis. The committee also has developed presentations for the financial sector regulators on IFRS, reviewed the translations of the standards in order to detect errors that may cause confusion in the application of the standards and will send the analysis to the IASB, and participated remotely in the IASB meetings.
The CCCH states that it holds regular meetings with regulators to partake in technical discussions regarding analysis of issues or rules that affect the application of the regulations, and does the same with educational institutions with the objective of communicating changes to the IFRS and to ensure that universities have included this subject into their accounting curriculum. Additionally, the institute indicates that it supports members’ implementation and compliance with IFRS by disseminating information on new and modified IASB pronouncements, making the translated standards available on its website, and providing training courses.
Furthermore, the CCCH is a member of the Latin American Accounting Standard Setters Group and participates in the international standard-setting process by providing comments to exposure drafts on a regional level.
If deemed feasible, the CCCH is encouraged to consider how it might promote the need for the full adoption of IFRS for banks and other financial institutions in the jurisdiction to the SBIF.
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