Association of Small Accounting Practitioners in the Philippines, Inc.

JSP Mango Plaza, General Maxilom Avenue corner Echavez St.,

Cebu City Philippines

November 21, 2014

Honorable Chairman Joel Tan Torres

Board of Accountancy
Professional Regulations Commission
Manila, Philippines
Chairman Torres:
In response to the call for comments on the draft proposed resolution by the Board of
Accountancy (BOA) on the Requirement For The Submission Of Certificate By The
Responsible Certified Public Accountants In The Preparation Of The Financial
Statements And Notes Thereto, the Association of Small Accounting Practitioners in
the Philippines, Inc. (the Association) have noted the following concerns and
comments which we have divided into two (2) key categories for better understanding
and delivery:
A. Manner of Dissemination of Proposed Resolution
1. The proposed resolution is un-numbered, incomplete and duly unsigned.
Considering the manner of which it is being presented and disseminated through a
social media platform (Facebook), would this manner of presentation deemed
considered official as far as the BOA-PRC is concerned?
2. What is the objective and purpose of dissemination?
In relation of item A1, we would like to verify if the intention of which the
process was done is to gather ideas and sentiments as far as initial response to the
draft proposed resolution and thus comments thereof should not be considered
official at all.
3. What is the official process BOA and/or PRC follows in terms of
disseminating proposed resolutions for comments?
We would like to know and understand as to the official procedures wherein BOA
and/or PRC study, craft, review and approve proposed/draft resolutions to
disseminate for comments by the concerned parties.

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Association of Small Accounting Practitioners in the Philippines, Inc.

JSP Mango Plaza, General Maxilom Avenue corner Echavez St.,
Cebu City Philippines

B. Key Questions on Certain Provisions as Provided for in the Draft Proposed

Resolution.
1. Are there similar cases, provisions and/or resolutions on other countries
concerning the self-review threat that this draft proposed resolution being
patterned into? What makes the Philippine setting unique wherein this proposed
action is deemed relevant?
2. Does this draft proposed resolution purports to transfer the responsibility of the
financial statements and the notes thereto from the management to the CPA? How
does it affect as to the preparation of the statement of management responsibility
(SMR) and management letters as signed by the key officials of the companies?
How will the CPAs responsibility be affected when he/she will no longer be
connected with the client and/or employer?
3. Will the audited financial statements and notes prepared covers across all
businesses irregardless of nature, size and/or classification?
4. Will this cover a new set of accreditation process for CPAs specific for a certain
sector(s)? Are the BOA accredited CPAs automatically recognized to have
complied such requirements or file a new one if necessary?
5. Has BOA and/or PRC considered the economic and regulatory impact this draft
proposed resolution have on the affected parties particularly of those CPAs in the
commerce and industry sector, nonstock-nonprofit entities and the SMEs as to
those having limited resources, family and closely-held businesses and
corporations?
Based on the manner of which this draft proposed resolution is duly disseminated and
with the relevant key questions that need to be addressed, we deemed improper to make
an official point by point comment on the said document. However, we would like to
make certain recommendations to BOA and/or PRC we believe could assist them in
crafting and disseminating proposed resolutions.
With this, we recommend that the Board of Accountancy to:
1. Coordinate with various agencies and accounting and business organizations in
the conduct of studies and analysis with regards to certain matters that BOA
and/or PRC can help improve the CPA professionals development and the
financial statements appreciation by both the CPAs and business owners;
2. Study and explore various options that can help in minimizing and/or eliminating
self-review threats without the need to setup additional burdens and other
bureaucratic regulations and compliance requirements. This is to consider that the
CPAs in the Philippines has been the most and highly regulated profession

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Association of Small Accounting Practitioners in the Philippines, Inc.

JSP Mango Plaza, General Maxilom Avenue corner Echavez St.,
Cebu City Philippines

whether justifiably meant to be or not. Likewise, punitive penalty and

imprisonment clauses should be duly studied and reviewed to avoid burdensome
legal proceedings and claims for both BOA and the CPAs on the questions on
constitutionality and basic human rights; and
3. Review and study cost considerations and impacts towards not only to CPAs but
likewise businesses on proposed resolutions that can affect all parties concerned.
The Association supports BOA in its programs to help improve the quality and relevance
of the professional CPAs. However, we likewise believe that a clear, concise and
knowledgeable study is a must and should not be compromised. Rest assured that the
Association will do its utmost best to become a partner in the development and
enhancement of the accounting practice and the CPA profession as a whole.
We look forward that our initial comments will provide the necessary insights in order to
assist BOA on its draft proposed resolution.
Respectfully yours,
For and in behalf of ASAPP:

Noe Jude B. Peas Jr.

Corporate Secretary

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Association of Small Accounting Practitioners in the Philippines, Inc.

JSP Mango Plaza, General Maxilom Avenue corner Echavez St.,
Cebu City Philippines

Copies to be furnished for:

Office of the President Malacanan

Office of the Executive Secretary - Malacanan
Office of the Secretary Department of Labor and Employment
Office of the Secretary Department of Finance
Office of the Secretary Department of Justice
Office of the Secretary Department of Social Welfare and Development
Commissioner Commission of Human Rights
Commissioner Office of the Ombudsman
Commissioner Securities and Exchange Commission
Commissioner Civil Service Commission
Chairman Professional Regulations Commission
Chairman Cooperative Development Authority
Philippine Institute of Certified Public Accountants
Association of Certified Public Accountants in Commerce and Industry
Association of Certified Public Accountants in Public Practice
Auditing and Assurance Standards Council
Federation of Filipino-Chinese Chamber of Commerce and Industry
Philippine Chamber of Commerce and Industry
Financial Executives of the Philippines
University of the Philippines Institute for Small Scale Industries

Enclosed herewith:
A. BOA Resolution copy
B. BOA Facebook page screenshot

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