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will be submitted on the form approved under the Accountant’s Report Rules (‘the old form’) – from 1st September 1998 this will be the amended form embodying changes in the role of the reporting accountant (as in the form in Bulletin 17).
Accountants’ reports covering a period when a practice was operating the new rules:
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will be prepared in accordance with Part F of the new rules;
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will relate to compliance with the new rules;
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will also report on departures from the guidelines published under the new rules (see Appendix 3 to the rules, Annex 28B at p.734);
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will involve completion of the checklist published under Part F of the new rules (‘the new checklist’ – as in Appendix 4 to the rules, see Annex 28B at p.738); and
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will be submitted on the form published under Part F of the new rules (‘the new form’ – as in Appendix 5 to the rules, see Annex 28B at p.743).
For the procedure where a firm wishes to deliver a single report to cover an accounting period when the firm operated the old rules for part of the accounting period and the new rules for the remainder:
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see option (a) below.
Implementation at beginning of accounting period
If a firm implements the new rules to coincide with the start of its accounting period, the position is simple. The firm will deliver an accountant’s report on the old form to cover the last accounting period when the firm was operating the old rules. The firm will subsequently deliver an accountant’s report on the new form to cover the first accounting period under the new rules.
When reporting on the firm’s last accounting period under the old rules, the reporting accountant should endorse at the top of the form: ‘Last report under the Solicitors’ Accounts Rules 1991’.
Example: The firm implements the new rules on 1st May 2000, and its accounting period runs from 1st May to 30th April. The last report on the old form will cover the 12 months 1st May 1999 to 30th April 2000, to be delivered by 30th October 2000. The first report on the new form will cover the 12 months 1st May 2000 to 30th April 2001, to be delivered by 30th October 2001.
Implementation part way through an accounting period
If a firm introduces the new rules part way through an accounting period, the firm has four options. The accounting period during which the firm introduces the new rules is called ‘the transitional accounting period’.
Option (a)
The firm delivers an accountant’s report covering the whole of the transitional accounting period. The reporting accountant will need to complete the new form. However, the reporting accountant will need to check compliance with the old rules (not the new rules) for that part of the transitional accounting period when the firm was operating under the old rules, and compliance with the new rules for the remainder.
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