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Deloitte comment letter on the proposal to revise Practice Note 19

Published on: 14 Mar 2019

We have published our comment letter on the Financial Reporting Council's (FRC's) consultation paper proposing to update its Practice Note on The Audit of Banks and Building Societies in the United Kingdom.

Overall we agree that the Practice Note would benefit from being updated to reflect the revisions to the UK auditing standards and to reflect other changes in the regulatory environment and legislation. It is also our view that it is right to focus more attention in the Practice Note to the application of ISA (UK) 540 (Revised December 2018), Auditing Accounting Estimates and Related Disclosures given the level of judgement and estimation that is involved in some of the key account balances and disclosures in a bank’s or building society’s financial statements particularly following the implementation of IFRS 9 Financial Instruments.

Download the full comment letter below.

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