In the countries of Anglo-Saxon culture, mechanisms are implemented to regulate the activity of the auditors within their professional self-regulation, while in many continental European countries, quasi-governmental agencies play a better role in this area.
Required:
Briefly describe the main differences between the regulatory
mechanisms of the United States and Germany.
Compare the regulatory mechanisms of the United States and the
United Kingdom.
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a. in the U.S., audit regulation is within the framework of professional self-regulation. For example, the PCAOB is an independent body, which has the authority to take the necessary steps as the main oversight body. In Germany, audit regulation is through legal means, rather than within the framework of professional self-regulation. While in many continental European countries, quasi-government agencies play a better role in this area. For example, there are specific legal provisions concerning admission requirements, auditor's rights and duties. disciplinary measures, mechanisms are implemented to regulate the activity of the auditors. Statutory auditors in Germany are required to register with a public law body, whereas in the U.S., the statutory auditors are required to obtain membership in the PCAOB.
b. As two countries that follow the Anglo-Saxon traditions, the U.K. and U.S: have many similarities in the mechanisms put in place to regulate auditing. However, there are also some differences. Unlike in the U.S., there is no uniform system of examination in the U.K. for entry into the profession as an auditor. Four professional bodies in U.K. conduct their own entrance examinations.
The Accounting Foundation, which performs the public oversight function in the U.K., is funded by the accounting profession and other interested parties, whereas its U.S. equivalent, the PCOB, is funded by government.
in the U.K., to become a Registered Auditor auditors are required to register with one of the four professional bodies recognized for this purpose (namely, the Institutes of Chartered Accounting in England and Wales, Scotland and Ireland and the Association of Chartered Corporate Accountants). On the contrary in the U.S., statutory auditors of all SEC registered companies including foreign companies must be members of the PCAOB.
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