General program of inspection

Professional inspections are performed in accordance with the Regulation respecting the professional inspection committee of the Ordre des comptables professionnels agréés du Québec and the General professional inspection supervision program developed by the committee pursuant to section 12 of the regulation and approved by the Board of directors of the Order.

Under the program, the committee’s role is to inspect members practicing public accountancy and carrying out other assurance services and engagements within the meaning of the CPA Canada Handbook, as well as members practicing management and management accounting, taxation, financial planning, forensic accounting and business valuations.

The general professional inspection supervision program addresses most of the questions inspected members/firms and the general public may have.

  1. General
  2. Inspection cycles
  3. Notice of inspection
  4. Evaluation criteria to be met to satisfy the inspection program requirements
  5. Procedures respecting inspection, file evaluation and recommendations for a period of refresher training
  6. Remedial actions
  7. Content of the professional inspection file  

1. General

1.1. For the purpose of the general professional inspection supervision program, unless the context indicates otherwise, the following terms mean:

1.1.1. "Board of Directors of the Order": the Board of Directors of the Ordre des comptables professionnels agréés du Québec;

1.1.2. "Order”: the Ordre des comptables professionnels agréés du Québec;

1.1.3. "Committee": the Professional inspection committee;

1.1.4. "Professional Inspection Department": the staff assigned to professional inspection by the Inspection and Professional Practice Vice-Presidency of the Ordre des comptables professionnels agréés du Québec;

1.1.5. “member”: anyone entered on the roll of the Order;

1.1.6. "office": any unit located in a place of business and made up of one or more members offering their services to the public as chartered professional accountants;

1.1.7. "mandatary": shareholders, partners or the equivalent, sole practitioners, and such chartered professional accountant employees of an office whom the committee may deem to have “partner” responsibility; 

1.1.8. "period of refresher training": successful completion of one or more of the following activities: 

1.1.8.1. studies or courses within the framework of the Order’s Professional Education Program;

1.1.8.2. professional development courses;

1.1.8.3. development of control policies and procedures to correct weaknesses for the purpose of providing reasonable assurance that professional standards will be met;

1.1.8.4. quality control of files by the Professional Inspection Department or a person authorized by the Professional inspection committee;

1.1.8.5. performance of work related to the practice of the profession, under the direction of a member designated for such purpose by the Board of the Order.

1.2. A committee member or inspector who is or would be perceived to be in a conflict of interest position shall withdraw from any committee deliberations and actions.

2. Inspection cycles

2.1. An office shall be inspected using a risk-adjusted cycle approach.

2.2. Risk factors are determined by the committee.

2.3. All offices shall fill out a questionnaire each year for the purposes of determining their inspection cycle based on risk factors.

2.4. An office shall be inspected no less than once every four years.

2.5. All new offices shall be inspected in their first year.

2.6. An office that has been found to present certain risks according to the risk factors established in section 2.2 shall be inspected on a minimum three-year cycle or a shorter inspection cycle.

2.7. An office within which chartered professional accountants audit companies that issue shares to the public in accordance with securities legislation applicable in Quebec or outside Quebec shall be inspected no less than once every three years.

3. Notice of inspection

3.1. The committee Secretary shall notify by registered mail the office to be inspected, at least 15 days prior to the anticipated date of inspection. The notice will include information on the inspection fees.

3.2. An office may request, in exceptional circumstances and under the terms and conditions established by the Professional Inspection Department, that the inspection be delayed for a reasonable period of time not to exceed two months from the anticipated date.

3.3. Any undue refusal or delay by the office to submit to the inspection may constitute a hindrance under section 114 of the Professional Code.

4. Evaluation criteria to be met to stisfy the Inspection program requirements

4.1. Professional accounting and assurance standards, the Canadian Standard on Quality Control, practice standards for investigative and forensic accounting engagements and the other standards and rules are those set out in the Institute of Chartered Accountants Handbook (CICA) or that reflect current scientific knowledge.

4.2. The management accounting standards generally accepted in the profession are those set out in the Management Accounting Guidelines or current scientific knowledge.

4.3. Any engagement entrusted shall be documented in accordance with the recommendations set out in the Institute of Chartered Accountants Handbook (CICA), or, where applicable, in accordance with the law, regulations or current scientific knowledge.

5. Procedures respecting inspection, file evaluation and recommendations for a period of refresher training

5.1. Inspection

5.1.1. Each office inspected will be charged an inspection fee for each inspection as established by the Board.

5.1.2. A confidential information questionnaire shall be completed and returned to the Professional Inspection Department 30 days before the anticipated date of inspection.

5.1.3. In addition to the confidential information questionnaire, all other questionnaires and documents required for inspection purposes shall also be completed and returned to the Professional Inspection Department 30 days before the anticipated date of inspection. However, the Department may allow these questionnaires and documents to be returned within a shorter timeframe.

5.1.4. After reviewing the documents and questionnaires provided and considering the other information obtained, the inspector shall complete one or several questionnaires in the course of the inspection to assess whether the office has complied with the professional standards and current scientific knowledge.

5.1.5. At least one mandatary practicing at the place of business being inspected shall be present during the inspection. The Professional Inspection Department can, however, require the presence of one or more persons practicing at the place of business.

5.1.6. Upon completion of the inspection, the inspector shall submit to the Professional Inspection Department the completed documents and questionnaires as well as any written report of the findings yielded by the inspection. Once these documents have been filed, any report submitted to the Professional Inspection Department shall be forwarded to the office.

5.1.7. Upon receiving an inspection report, the inspected office may send a comment letter or plan of action that will be included in the inspection file to be reviewed and evaluated in accordance with the process established below.

5.2. Review and evaluation of the inspection file

5.2.1. Prior to each committee meeting, the Professional Inspection Department shall proceed with the preliminary evaluation of each file and classify each office in one of the following categories:

5.2.1.1. approved as having satisfied the inspection program requirements for the current cycle;

5.2.1.2. provisionally approved as having satisfied the inspection program requirements and required to take a specified course of action to meet the requirements for the current cycle in full;

5.2.1.3. not approved as having satisfied the inspection program requirements for the current cycle.

5.2.2. Files classified in the category of offices approved as having satisfied the inspection program requirements shall be reviewed by at least one committee member:

5.2.2.1. if the committee member agrees with the preliminary evaluation of the Professional Inspection Department, this classification shall be maintained with no further evaluation;

5.2.2.2. if the committee member disagrees with the preliminary evaluation of the Professional Inspection Department, the file shall be further evaluated by at least one other committee member. The final classification of the office shall be based on the opinion of the majority of members who evaluated the file.

5.2.3. All other files shall be reviewed by at least two committee members:

5.2.3.1. if the two committee members agree with the preliminary evaluation of the Professional Inspection Department, this classification shall be submitted to the full committee for action;

5.2.3.2. if one of the committee members disagrees with the preliminary evaluation of the Professional Inspection Department, the file shall be further evaluated by at least one other committee member. The recommendation of the majority of members who evaluated the file shall be submitted to the full committee for action;

5.2.3.3. if the two committee members do not agree with one another, the file shall be further evaluated by at least one other committee member. The recommendation of the majority of members who evaluated the file shall be submitted to the full committee for action.

5.2.4. The review and evaluation of an inspection file by committee members shall be made without the identity of either the office or its clients having been disclosed.

5.3. Recommendation for a period of refresher training and appeal procedures

5.3.1. Members who have been notified by letter that the committee will recommend to the Board that they complete a period of refresher training with or without the limitation of their right to practice may, under the terms and conditions set out in the letter, request in writing to be heard by the committee or by a small group of committee members. Their response must outline the reasons for which a hearing is requested and shall be sent by registered mail to the offices of the Order.

5.3.2. In the case where a member requests to be heard, the committee shall notify the member of the date and time of the hearing at which the evaluation of the member’s office will be discussed.

5.3.3. The committee shall advise the members of its decision.

5.3.4. The committee shall submit all recommendations for a period of refresher training to the Board for action.

6. Remedial actions

6.1. If an office does not satisfy the inspection program requirements, the committee shall recommend that it be reinspected within a reasonable period of time following the inspection or that the Board impose either one or both of the following measures with respect to the members of the office that it designates:

6.1.1. A period of refresher training with or without limitation of the right to practice will be imposed. A full reinspection may follow within a reasonable period of time after the period of refresher training. Should a member fail to successfully complete the training period within the prescribed time, the training period will automatically be extended for an additional period equal to the preceding, subject to new conditions that may be imposed by the Board;

6.1.2. A complaint will be lodged with the syndic of the Order for appropriate action.

6.2. If an office still does not satisfy the inspection program requirements upon reinspection, the committee may recommend that the Board impose a second period of refresher training with or without limitation of the right to practice. The second period of refresher training shall also be followed by a third inspection within a reasonable period of time after the period of refresher training.

6.3. If an office still does not satisfy the inspection program requirements after a third inspection, the committee shall recommend that the Board impose a period of refresher training with limitation of the right to practice. The office shall be inspected a fourth time within a reasonable period of time following the period of refresher training.

6.4. If a member refuses to comply, in whole or in part, with the terms and conditions of the period of refresher training, the committee shall recommend that the Board submit the file to the syndic of the Order for appropriate action. All decisions of the Board shall be sent without delay to the office.

6.5. All letters dealing with the inspection results shall be sent by registered mail.

7. Content of the Professional inspection file

7.1. An inspection file shall include:

7.1.1. all questionnaires duly completed by the office or by the inspector;

7.1.2. all correspondence dealing with the inspection;

7.1.3. inspector reports and reviewer evaluations.

7.2. Once the evaluations have been ratified, the inspection questionnaires completed by the inspector and the financial statements examined during the inspection shall be destroyed.

7.3. Members who have been inspected may have access to their professional inspection file at the offices of the Order.

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