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IAASB rolls out ISSA 5000 sustainability assurance standard

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The International Auditing and Assurance Standards Board is preparing for the adoption of its International Standard on Sustainability Assurance 5000 early next year as companies look to get outside approval from auditing firms on their environmental efforts.

The IAASB approved the standard in September, but is awaiting final approval from the Public Interest Oversight Board, an international body that oversees the IAASB and other standard-setters affiliated with the International Federation of Accountants. The IAASB expects to provide educational materials in January once the PIOB formally approves ISSA 5000, probably by the end of this year. 

Policymakers, regulators and other standard-setting bodies in multiple jurisdictions have already indicated plans to adopt this new standard. Earlier this year the U.S. Securities and Exchange Commission recognized the IAASB’s work and standards in this area for the purpose of allowing assurance on climate disclosures, even though the SEC’s own climate rule is currently on hold pending the outcome of multiple lawsuits. 

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“ISSA 5000, which is our sustainability assurance standard, is meant to serve as a global baseline for sustainability assurance practices,” said IAASB chair Tom Seidenstein. 

Once the PIOB certifies the IAASB standard, the IAASB plans to offer a range of guidance and educational materials to help people and other standard-setters with the application and implementation of ISSA 5000. So far, the IAASB has heard positive responses from standard-setters in various jurisdictions, including Australia, Canada, Brazil, Turkey and the European Union, about their intention of adopting some or all of the standard for their requirements. “That’s just the earliest stages,” said Seidenstein. “They were all waiting for us to finish the standard, and we’ll have to see how those considerations progress.”

ISSA 5000 builds on two of the IAASB’s existing standards on assurance: International Standard on Assurance Engagements 3000, a principles-based standard for assurance for nonfinancial reporting, and ISAE 3410, a specific standard for greenhouse gas reporting assurance.

“With the growing desire to have sustainability reporting throughout the world and the emergence of some of the leading reporting frameworks, we were urged to take what we had and make it specific to sustainability reporting,” said Seidenstein. “We took a pretty broad-based, principles-based framework that applied to all assurance and really focused it in, took our best practices on the assurance side, grabbed some of the key concepts that we’ve brought into the audit side, and made a sustainability-specific standard. Now what’s really important about this is it will work with all sustainability information prepared with any suitable reporting framework.”

That means it would work with not only the SEC’s climate-related disclosure rule, but also with the International Sustainability Standards Board’s S1 and S2 standards on sustainability and climate-related disclosures as well as the European Sustainability Reporting Standards mandated under the European Union’s Corporate Sustainability Reporting Directive, along with other major frameworks like Global Reporting Initiative standards. The IAASB has also been in talks with the American Institute of CPAs’ Auditing Standards Board about incorporating at least some of the ISSA 5000 framework into the ASB’s attestation requirements.

The IAASB developed the standards so they could work with various frameworks. “Our standard covers any sustainability information, so that would be covered as long as the reporting framework fulfills certain criteria, then our standard will work against that,” said Seidenstein. “You’re assuring against a framework. Reporting standard-setters will set the framework.”

ISSA 5000 addresses both limited and reasonable assurance. “Most assurance engagements these days are on a limited assurance basis,” said Seidenstein, noting that both the SEC and CSRD rules require only limited assurance. But he believes investors will eventually be demanding the more stringent “reasonable assurance.” 

“We wanted to have a clear pathway in our standards with a differentiation between limited and reachable assurance requirements, and ISSA 5000 provides both,” said Seidenstein. 

Reasonable assurance is similar to the level of assurance offered in financial audits. “The assurance practitioner does a number of inquiries, does the risk assessment, responds to it and reduces the risk of material misstatement down to an acceptable level,” Seidenstein explained. “That’s really important, and will give a high-level degree of confidence that the sustainability reports are stated correctly. In the world of limited assurance, there’s less work done. It’s stated in a negative way, that there’s nothing that’s come to the attention of the practitioner that would lead them to believe that the statements are materially misstated. That’s really about a different type of risk assessment, different lines of inquiry, in responding to areas of risk, whereas a reasonable assurance engagement is much more robust. Most people are focused on limited right now to develop the capacity, knowledge and understanding as we then transition to reasonable assurance over time.”

However, the standards should help investors assess the reliability of a company’s sustainability reporting. 

“What these standards will do, just like audit standards and just like assurance today, but in a much more specific way, will give the users of information more confidence that an external third party that’s independent and expert has reviewed the sustainability reports and can either provide a limited assurance or reasonable assurance opinion against the sustainability report, and that should give confidence,” said Seidenstein. “It’s the same thing as you would expect on the financial reporting side. It’s precisely why audits are important that you have an independent expert third party look at it to make sure that there’s no material misstatements.” 

An IFAC report that was released in June aims to help those who use sustainability reporting understand what to expect from sustainability assurance, addressing limited vs. reasonable assurance and explaining what different types of conclusions can indicate.

Auditors would follow many of the same basic approaches and methodologies in the world of financial auditing, from the planning to the conclusion to the reporting stages. “We focus very much on the planning, the risk assessment phase, the risk response phase of audits, so it’s very similar in many concepts, but translated to a sustainability context,” said Seidenstein. “What is slightly different in this world is first of all, you have much more qualitative and prospective information than you would in the financial reporting context, so you’re very focused on the process, the controls, the approach to making sure that the disclosures are materially correct.”

The IAASB wrote the standard so it can be used by both accountants and non-accountants since some other types of consulting firms that aren’t accounting firms have also been providing assurance on sustainability reporting, particularly when it comes to greenhouse gas emissions. IFAC’s State of Play in Sustainability Assurance report found that 689 of 1,187 (for 950 companies) assurance reports were signed by audit firms in 2022. 

The report found the IAASB’s assurance standard, International Standard on Assurance Engagements 3000 (Revised), continues to be used most frequently. In the most recent year for which data is available (2022), 92% of firms applied ISAE 3000 (Revised) in their sustainability assurance engagements, 98% of companies reported some level of detail on sustainability, and 69% obtained assurance on at least some of their sustainability disclosures. But the mix of reporting standards used by companies remains fragmented

For ISSA 5000, non-accountant practitioners would still need to adhere to the IAASB’s quality management standards as well as the ethics standards developed by its sister standard-setting board, the International Ethics Standards Board for Accountants. IESBA has also been developing ethics standards for sustainability reporting. The International Organization of Securities Commissions has encouraged both the IAASB and IESBA to develop sustainability assurance and ethics standards since September 2022. IESBA is expected to approve its standards in December, and the PIOB will meet to certify them in January. 

“We’re clearly proud of this work, that we were able to turn this around in under two years’ time with robust due process, and we met the timeline particularly set forward by IOSCO in their recommendation to both us and IESBA in terms of supporting sustainability reporting requirements,” said Seidenstein.

Even though the SEC’s climate rule is on hold, he believes the standards will still be useful for U.S. accountants. 

“In the United States, there are many different companies that will be seeking assurance, or already do seek assurance, on their sustainability reporting,” said Seidenstein. “So many companies have ESG reports or sustainability reports on a voluntary basis. There are a number of companies that are likely to adopt ISSB standards beyond that on a voluntary basis, or report on some other set of standards currently and are seeking assurance. There are many companies that will be required to conform with the European Corporate Sustainability Reporting Directive, and they will be required to have assurance under the CSRD and potentially be required to use our set of standards. The European Commission asked the CEAOB, which is the Committee of European Audit Oversight Boards, to advise the Commission on how to implement assurance requirements. It said specifically to look at our work on 5000 in that regard. American companies may have that requirement and could be in the value chain of companies that require sustainability reporting, whether it’s in Europe or elsewhere, and would also require assurance. There are a number of ways that our work could be relevant to American companies, irrespective of the climate rule.”

A recent report from the Visual Lease Data Institute found that a little over half (55%) of finance executives who were surveyed reported that the pause on the SEC climate disclosure rule has impacted their organization’s climate-related reporting efforts, and only 43% say their companies have established related benchmarks (a 4% increase from 2023).

ISSA 5000 promises to be widely useful for auditing firms in providing assurance on these important metrics. “We believe that this will establish a global baseline on the assurance side to complement what’s happening on the reporting side, and you really can’t have one without the other,” said Seidenstein.

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Senate unveils plan to fast-track tax cuts, debt limit hike

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Senate Republicans unveiled a budget blueprint designed to fast-track a renewal of President Donald Trump’s tax cuts and an increase to the nation’s borrowing limit, ahead of a planned vote on the resolution later this week. 

The Senate plan will allow for a $4 trillion extension of Trump’s tax cuts and an additional $1.5 trillion in further levy reductions. The House plan called for $4.5 trillion in total cuts.

Republicans say they are assuming that the cost of extending the expiring 2017 Trump tax cuts will cost zero dollars.

The draft is a sign that divisions within the Senate GOP over the size and scope of spending cuts to offset tax reductions are closer to being resolved. 

Lawmakers, however, have yet to face some of the most difficult decisions, including which spending to cut and which tax reductions to prioritize. That will be negotiated in the coming weeks after both chambers approve identical budget resolutions unlocking the process.

The Senate budget plan would also increase the debt ceiling by up to $5 trillion, compared with the $4 trillion hike in the House plan. Senate Republicans say they want to ensure that Congress does not need to vote on the debt ceiling again before the 2026 midterm elections. 

“This budget resolution unlocks the process to permanently extend proven, pro-growth tax policy,” Senate Finance Chairman Mike Crapo, an Idaho Republican, said. 

The blueprint is the latest in a multi-step legislative process for Republicans to pass a renewal of Trump’s tax cuts through Congress. The bill will renew the president’s 2017 reductions set to expire at the end of this year, which include lower rates for households and deductions for privately held businesses. 

Republicans are also hoping to include additional tax measures to the bill, including raising the state and local tax deduction cap and some of Trump’s campaign pledges to eliminate taxes on certain categories of income, including tips and overtime pay.

The plan would allow for the debt ceiling hike to be vote on separately from the rest of the tax and spending package. That gives lawmakers flexibility to move more quickly on the debt ceiling piece if a federal default looms before lawmakers can agree on the tax package.

Political realities

Senate Majority Leader John Thune told reporters on Wednesday, after meeting with Trump at the White House to discuss the tax blueprint, that he’s not sure yet if he has the votes to pass the measure.

Thune in a statement said the budget has been blessed by the top Senate ruleskeeper but Democrats said that it is still vulnerable to being challenged later.

The biggest differences in the Senate budget from the competing House plan are in the directives for spending cuts, a reflection of divisions among lawmakers over reductions to benefit programs, including Medicaid and food stamps. 

The Senate plan pares back a House measure that calls for at least $2 trillion in spending reductions over a decade, a massive reduction that would likely mean curbing popular entitlement programs.

The Senate GOP budget grants significantly more flexibility. It instructs key committees that oversee entitlement programs to come up with at least $4 billion in cuts. Republicans say they expect the final tax package to contain much larger curbs on spending.

The Senate budget would also allow $150 billion in new spending for the military and $175 billion for border and immigration enforcement.

If the minimum spending cuts are achieved along with the maximum tax cuts, the plan would add $5.8 trillion in new deficits over 10 years, according to the Committee for a Responsible Federal Budget.

The Senate is planning a vote on the plan in the coming days. Then it goes to the House for a vote as soon as next week. There, it could face opposition from spending hawks like South Carolina’s Ralph Norman, who are signaling they want more aggressive cuts. 

House Speaker Mike Johnson can likely afford just two or three defections on the budget vote given his slim majority and unified Democratic opposition.

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How asset location decides bond ladder taxes

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Financial advisors and clients worried about stock volatility and inflation can climb bond ladders to safety — but they won’t find any, if those steps lead to a place with higher taxes.

The choice of asset location for bond ladders in a client portfolio can prove so important that some wealthy customers holding them in a taxable brokerage account may wind up losing money in an inflationary period due to the payments to Uncle Sam, according to a new academic study. And those taxes, due to what the author described as the “dead loss” from the so-called original issue discount compared to the value, come with an extra sting if advisors and clients thought the bond ladder had prepared for the rise in inflation.

Bond ladders — whether they are based on Treasury inflation-protected securities like the strategy described in the study or another fixed-income security — provide small but steady returns tied to the regular cadence of maturities in the debt-based products. However, advisors and their clients need to consider where any interest payments, coupon income or principal accretion from the bond ladders could wind up as ordinary income, said Cal Spranger, a fixed income and wealth manager with Seattle-based Badgley + Phelps Wealth Managers.

“Thats going to be the No. 1 concern about, where is the optimal place to hold them,” Spranger said in an interview. “One of our primary objectives for a bond portfolio is to smooth out that volatility. … We’re trying to reduce risk with the bond portfolio, not increase risks.”

READ MORE: Why laddered bond portfolios cover all the bases

The ‘peculiarly bad location’ for a bond ladder

Risk-averse planners, then, could likely predict the conclusion of the working academic paper, which was posted in late February by Edward McQuarrie, a professor emeritus in the Leavey School of Business at Santa Clara University: Tax-deferred retirement accounts such as a 401(k) or a traditional individual retirement account are usually the best location for a Treasury inflation-protected securities ladder. The appreciation attributes available through an after-tax Roth IRA work better for equities than a bond ladder designed for decumulation, and the potential payments to Uncle Sam in brokerage accounts make them an even worse asset location.

“Few planners will be surprised to learn that locating a TIPS ladder in a taxable account leads to phantom income and excess payment of tax, with a consequent reduction in after-tax real spending power,” McQuarrie writes. “Some may be surprised to learn just how baleful that mistake in account location can be, up to and including negative payouts in the early years for high tax brackets and very high rates of inflation. In the worst cases, more is due in tax than the ladder payout provides. And many will be surprised to learn how rapidly the penalty for choosing the wrong asset location increases at higher rates of inflation — precisely the motivation for setting up a TIPS ladder in the first place. Perhaps the most surprising result of all was the discovery that excess tax payments in the early years are never made up. [Original issue discount] causes a dead loss.”

The Roth account may look like a healthy alternative, since the clients wouldn’t owe any further taxes on distributions from them in retirement. But the bond ladder would defeat the whole purpose of that vehicle, McQuarrie writes.

“Planners should recognize that a Roth account is a peculiarly bad location for a bond ladder, whether real or nominal,” he writes. “Ladders are decumulation tools designed to provide a stream of distributions, which the Roth account does not otherwise require. Locating a bond ladder in the Roth thus forfeits what some consider to be one of the most valuable features of the Roth account. If the bond ladder is the only asset in the Roth, then the Roth itself will have been liquidated as the ladder reaches its end.”

READ MORE: How to hedge risk with annuity ladders

RMD advantages

That means that the Treasury inflation-protected securities ladder will add the most value to portfolios in a tax-deferred account (TDA), which McQuarrie acknowledges is not a shocking recommendation to anyone familiar with them. On the other hand, some planners with clients who need to begin required minimum distributions from their traditional IRA may reap further benefits than expected from that location.

“More interesting is the demonstration that the after-tax real income received from a TIPS ladder located in a TDA does not vary with the rate of inflation, in contrast to what happens in a taxable account,” McQuarrie writes. “Also of note was the ability of most TIPS ladders to handle the RMDs due, and, at higher rates of inflation, to shelter other assets from the need to take RMDs.”

The present time of high yields from Treasury inflation-protected securities could represent an ample opportunity to tap into that scenario.

“If TIPS yields are attractive when the ladder is set up, distributions from the ladder will typically satisfy RMDs on the ladder balance throughout the 30 years,” McQuarrie writes. “The higher the inflation experienced, the greater the surplus coverage, allowing other assets in the account to be sheltered in part from RMDs by means of the TIPS ladder payout. However, if TIPS yields are borderline unattractive at ladder set up, and if the ladder proved unnecessary because inflation fell to historically low levels, then there may be a shortfall in RMD coverage in the middle years, requiring either that TIPS bonds be sold prematurely, or that other assets in the TDA be tapped to cover the RMD.”

READ MORE: A primer on the IRA ‘bridge’ to bigger Social Security benefits

The key takeaways on bond ladders

Other caveats to the strategies revolve around any possible state taxes on withdrawals or any number of client circumstances ruling out a universal recommendation. The main message of McQuarrie’s study serves as a warning against putting the ladder in a taxable brokerage account.

“Unsurprisingly, the higher the client’s tax rate, the worse the outcomes from locating a TIPS ladder in taxable when inflation rages,” he writes. “High-bracket taxpayers who accurately foresee a surge in future inflation, and take steps to defend against it, but who make the mistake of locating their TIPS ladder in taxable, can end up paying more in tax to the government than is received from the TIPS ladder during the first year or two.”

For municipal or other types of tax-exempt bonds, though, a taxable account is “the optimal place,” Spranger said. Convertible Treasury or corporate bonds show more similarity with the Treasury inflation-protected securities in that their ideal location is in a tax-deferred account, he noted.

Regardless, bonds act as a crucial core to a client’s portfolio, tamping down on the risk of volatility and sensitivity to interest rates. And the right ladder strategies yield more reliable future rates of returns for clients than a bond ETF or mutual fund, Spranger said.

“We’re strong proponents of using individual bonds, No. 1 so that we can create bond ladders, but, most importantly, for the certainty that individual bonds provide,” he said.

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Why IRS cuts may spare a unit that facilitates mortgages

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Loan applicants and mortgage companies often rely on an Internal Revenue Service that’s dramatically downsizing to help facilitate the lending process, but they may be in luck.

That’s because the division responsible for the main form used to allow consumers to authorize the release of income-tax information to lenders is tied to essential IRS operations.

The Income Verification Express Service could be insulated from what NMN affiliate Accounting Today has described of a series of fluctuating IRS cuts because it’s part of the submission processing unit within wage and investment, a division central to the tax bureau’s purpose.

“It’s unlikely that IVES will be impacted due to association within submission processing,” said Curtis Knuth, president and CEO of NCS, a consumer reporting agency. “Processing tax returns and collecting revenue is the core function and purpose of the IRS.”

Knuth is a member of the IVES participant working group, which is comprised of representatives from companies that facilitate processing of 4506-C forms used to request tax transcripts for mortgages. Those involved represent a range of company sizes and business models.

The IRS has planned to slash thousands of jobs and make billions of dollars of cuts that are still in process, some of which have been successfully challenged in court.

While the current cuts might not be a concern for processing the main form of tax transcript requests this time around, there have been past issues with it in other situations like 2019’s lengthy government shutdown.

President Trump recently signed a continuing funding resolution to avert a shutdown. But it will run out later this year, so the issue could re-emerge if there’s an impasse in Congress at that time. Republicans largely dominate Congress but their lead is thinner in the Senate.

The mortgage industry will likely have an additional option it didn’t have in 2019 if another extended deadlock on the budget emerges and impedes processing of the central tax transcript form.

“It absolutely affected closings, because you couldn’t get the transcripts. You couldn’t get anybody on the phone,” said Phil Crescenzo Jr., vice president of National One Mortgage Corp.’s Southeast division.

There is an automated, free way for consumers to release their transcripts that may still operate when there are issues with the 4506-C process, which has a $4 surcharge. However, the alternative to the 4506-C form is less straightforward and objective as it’s done outside of the mortgage process, requiring a separate logon and actions.

Some of the most recent IRS cuts have targeted technology jobs and could have an impact on systems, so it’s also worth noting that another option lenders have sometimes elected to use is to allow loans temporarily move forward when transcript access is interrupted and verified later. 

There is a risk to waiting for verification or not getting it directly from the IRS, however, as government-related agencies hold mortgage lenders responsible for the accuracy of borrower income information. That risk could increase if loan performance issues become more prevalent.

Currently, tax transcripts primarily come into play for government-related loans made to contract workers, said Crescenzo.

“That’s the only receipt that you have for a self-employed client’s income to know it’s valid,” he said.

The home affordability crunch and rise of gig work like Uber driving has increased interest in these types of mortgages, he said. 

Contract workers can alternatively seek financing from the private non-qualified mortgage market where bank statements could be used to verify self-employment income, but Crescenzo said that has disadvantages related to government-related loans.

“Non QM requires higher downpayments and interest rates than traditional financing,” he said.

In the next couple years, regional demand for loans based on self-employment income could rise given the federal job cuts planned broadly at public agencies, depending on the extent to which court challenges to them go through.

Those potential borrowers will find it difficult to get new mortgages until they can establish more of a track record with their new sources of income, in most cases two years from a tax filing perspective. 

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