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RE1 Blueprint Series · Task 9 of 16

Manage and Oversee the Accounting and Auditing Requirements

A focused task on the FSP's financial reporting obligations — particularly where the FSP receives and holds client funds, where the requirements go beyond a generic annual financial audit.

The 4 QCs, in full:
QC1 — Describe the accounting and auditing requirements prescribed by the FAIS Act
QC2 — Check that accounting and auditing requirements are in place and carried out accurately and timeously
QC3 — Describe the requirements for appointing an auditor or accounting officer
QC4 — Ensure the audit report submitted to the FSCA (where funds are received) meets regulatory requirements

QC1 & QC4: Beyond the Generic Annual Audit

Where an FSP receives and holds client funds, specific accounting and auditing requirements apply on top of standard annual financial statements — connecting directly to the custody-of-funds obligations covered in Task 6. QC4 is explicit: a generic financial audit is not automatically sufficient in this situation. The report actually submitted to the FSCA must meet the specific regulatory standard that circumstance requires.

QC2: This Stays the KI's Job, Not the Accountant's Alone

It's tempting to treat accounting compliance as a specialist silo, fully delegated to an external accountant or auditor. That's a mistake.

Real scenario: An FSP delays submitting its annual financial statements because the appointed accountant was slow to finalise them. The KI treats this as purely the accountant's problem. It isn't — timely submission sits within the KI's broader oversight function, and a competent external professional handling the technical work doesn't remove the KI's obligation to actually track whether it happens on schedule.

QC3: Who May Be Appointed

Specific requirements govern who may act as the FSP's auditor or accounting officer — this isn't an open commercial choice made purely on cost or convenience. The appointee must meet prescribed criteria, similar in spirit to how a Compliance Officer must meet Board Notice 127's approval criteria before they can act in that role.

Exam trap: Assuming any qualified, registered auditor is automatically acceptable for this specific purpose. The criteria for appointment in this context are prescribed, not a matter of general professional competence alone.

Quick Recap

A Competent Accountant Doesn't Remove Your Oversight Duty

RE Mastery Hub's Task Quizzes test exactly this "who's actually accountable when a specialist function is delegated" pattern.

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