As those of you who are licensed by the IPA know, each year you are sent a list of cases that you have to review and then report back on with a note of the matters found during that review. The IPA have indicated that they will give credit to IPs who identify and disclose matters during these annual review, as long as they fix them and they do not subsequently recur. But what happens if you find a significant problem or issue on a case as a result of your own periodic reviews, or following an external review? That happened to one of our clients, and acting on our advice he contacted the IPA, informed them of the problem, how he intended to resolve it and how he intended to ensure that it did not recur. The IPA gave him credit for identifying the issue and did not take any regulatory action against him, although they did include the case on his list of cases for annual review. As with the ICAEW, the IPA are looking for IPs to identify problems and issues themselves, fix them, make disclosure and then ensure that they do not recur, and as long as the IP takes those steps then our experience is that it is highly unlikely that regulatory action will be taken against the IP in respect of those issues.
As an aside, currently we have agreed with the IPA that we will not review cases selected by them for annual review, but if we undertake a review for your practice clearly you will need to bear in mind any matters that we find on cases when you undertake your review of cases selected by the IPA.
