When the Financial Reporting Council asked HSBC FD Douglas Flint to review the 1999 Turnbull Report in light of what has happened since the introduction of Sarbanes-Oxley, it soon became apparent that the man heading the enquiry didn’t want the findings to be known as the Flint Report.
So, briefly, we contented ourselves with referring to the imminent report as Turnbull 2. Now that we’ve had a good look at it, even that might be too ambitious a title.
Instead, you could easily refer to it as Turnbull 1.1 – a subtle upgrade that gets rid of a few inconsistencies with other codes and amends some of the wording. And thank goodness for that. Including the contents page and the preface, the draft Turnbull revision is about 11 pages long in plain English, and it covers all internal controls. Compare that with Sarbanes-Oxley and all the related regulations, which run to hundreds of pages, are unintelligible and only concerned with controls on external financial reporting.
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