APC 12-69 files: Financial Services Act 1986.

Scope and Content

Includes files of a related number, ie APC 12-69a, and APC 12-69(2),.

These 22 files relate to the APC's work on the Financial Services Act 1986, which produced: an exposure draft guideline, The implications for auditors of the Financial Services Act 1986 [published February 1988]; the auditing guideline, Communications between auditors and regulators under sections 109 and 180(1)(q) of the Financial Services Act 1986 [published July 1990]; and an APC practice note, Client assets - Guidance for auditors of investment business [published December 1991].

The files are in no clear order, [bearing several different titles] and do not contain clear information on the working parties which produced the above documents. There are references to a 'Financial Services Act' working party, an 'investment businesses' working party, and to several changes in working party. It was necessary to refer to the APC minutes and project lists found in the agenda papers [see the APC/2 files] in order to grasp a little of the context of these documents' development. There appear to have been 2 working parties in terms of membership, and work on the Act appears in the project lists under 2 different headings; 'Investment Businesses subject to the Financial Services Act' and 'Implications of the Financial Services Act'. Unfortunately the change of working party does not coincide with the change in project heading. The first working party was chaired by a Mr J. Pilkington, and appeared in the project lists from November 1986 to December 1988. Mr Pilkington's working party appeared under both the project headings of 'Investment Businesses subject to the Financial Services Act' and 'Implications of the Financial Services Act'. It appeared under the former heading until the APC meeting of November 1987 when the draft paper, 'Audit of investment business' had its title changed to 'The implications of the Financial Services Act 1986' [later to become the exposure draft of the same name]. From November 1987 to its disbandment in December 1988 the working party then appeared under the second project heading. For January and February 1989 the project has no working party listed next to it, and in April 1989 a new working party, chaired first by Mr Ian Brindle, [later to become APC chairman] and then by working party member Mr D. Crowther, appears under the heading 'Implications of the Financial Services Act'. This second working party completed the drafting of the auditing guideline, Communications between auditors and regulators under sections 109, and 180(1)(q) of the Financial Services Act 1986, the drafting of which was begun by the first working party following the comments received on the 'Implications' exposure draft. Under Mr Crowther the second working party also developed the practice note on client assets. Both of the working parties included Securities and Investment Board [SIB] and Department of Trade and Industry [DTI] representatives amongst their membership at some point in their histories.

Arrangement

Although APC working parties are usually referred to by their original name in the archive list, due to the confusing nature of these files the working parties will be referred to as: the Financial Services Act Working Party 1 [FSAWP1]; and the Financial Services Act Working Party 2 [FSAWP2]. An attempt has been made to put the files into chronological order, although files with the same titles have been kept together creating some problems with regard to chronology. [For an example see the Client Assets files APC/1/43/18-APC/1/43/22].