6 May 2010

Audit Quality Strategy Review
Corporations and Financial Services Division
The Treasury
Langton Crescent
PARKES ACT 2600

Dear Sir/Madam

Audit Quality Strategy Review

The Group The Group of 100 (G100) is an organization of chief financial officers from Australia’s largest business enterprises with the purpose of advancing Australia’s financial competitiveness. The G100 is pleased to comment on the auditor rotation proposals in the Audit Quality Review.

The G100 supports the retention of the current auditor rotation requirements in Australia, namely that rotation should occur after five successive years (consistent with USA, UK and Canada) and that there is a two-year time-out period (five years in USA, UK and Canada) before reappointment can occur.

We agree that the present requirements provide a reasonable balance between continuity, the familiarity threat and audit quality.

While these requirements are less than the seven year rotation period in the EU’s directive, a similar outcome would be achieved if a company had the discretion to extend the appointment of an audit partner for an additional two years provided that the reasons for doing so are explained in the annual report and approved at the annual general meeting. We consider such discretion would provide flexibility in those circumstances where specialized expertise and experience for certain industries is scarce.

Yours sincerely
Group of 100 Inc

Peter Lewis
National President