As those of you who are licensed by the ICAEW know, you are given creit for defaults that you identify and fix so that they do not recur. We always understood that you merely made disclosure as part of your annual return each year, but it now appears that whilst the current version of the annual return asks you if you have undertaken a compliance review during the year, there is no space for you to actually make disclosure of the matters identified. We understand that this omission is being addressed, but in the meantime you should make disclosure by sending a covering letter with your annual return.
This letter should set out the deficiencies found; indicate what steps you have taken to remedy those deficiencies on the case(s) where they were found; indicate if the deficiency was systemic or isolated; and set out the steps you have taken to make sure that the deficiency does not recur. Remember though, that the ICAEW have indicated that they do not need you to make disclosure of routine compliance defults.
