Accounting Report: Analysis of Pioneer Credit and ASIC

This report provides a detailed analysis of the issues presented in an Australian Financial Review article titled "ASIC kept watch on Pioneer Credit for 12 months." The report examines the conflict between the Australian Securities and Investment Commission (ASIC) and Pioneer Credit regarding the company's valuation methods, exploring relevant accounting theories such as regulation, professionalism, ethics, and standard setting. It deconstructs the issues, applying theories like public interest theory, self-interest theory, and deontological theory to explain the behaviors of both parties. The report also discusses the significance of the conflict between the regulator and the regulated, as well as the issues covered in the exposure draft by the International Financial Reporting Standards (IFRS) Foundation. The analysis highlights the importance of ethical conduct, adherence to accounting standards, and the impact of regulatory oversight on financial reporting practices. The report concludes by emphasizing the importance of these issues for maintaining fairness and efficiency in the financial market.

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Question one
This report presents a detailed analysis of finance and accounting article titled as “ASIC
kept watch on Pioneer Credit for 12 months”. This paper will start by giving a detailed
explanation of the issues presented in the article. The report will further look deeply into the
issues discussed using accounting theories. The report will conclude by highlighting the
importance of the article.
Australian Financial Review
Figure 1: ASIC kept watch on Pioneer Credit for 12 months (Frost, 2019a)
a. Key issues as found in the news article
This article captures two players in the financial sector, that is, the regulator and the
regulated. The Australian Security and Investment Commission (ASIC) who is the regulator
have questions on the accounting method adopted by Pioneer credit who is being regulated by
ASIC.
ASIC is the body charged with the responsibility of regulating and ensuring adherence to
the requirements of financial reporting and auditing in Australia. Theyensure that the corporation
Act is adhered to ("About us", 2019a). By ensuring compliance to the law, ASIC promotes fair
play in the market and improves investors’ confidence. Another role played by ASIC is to ensure

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that the audit and the financial report are right and that they can be relied upon and help different
stakeholders in making informed decision.
On the other hand, Pioneer Credit is a company which specializes in the provision of
financial services to customers. It is based in Australia ("Leadership Principles", 2019b). This
company is one of the many others which are listed in the Australian Security exchange and
therefore has an obligation of submitting audited reports to ASIC.
As it recorded, ASIC is concerned about the valuation method used by Pioneer Credit.
They have questions which Pioneer Credit has not responded to fully. Prior to raising the issue
with Pioneer, ASIC has been seeking information about the company accounting standards from
whistle-blowers. Pioneer Credit has no plan of changing the controversial fair value method of
valuation.
Pioneer Credit has not provided enough information to their auditor so that he can rule
whether the accounting policies of the company is the ones accepted. The withholding of
information suggests that there is something malicious with the model. (Frost, 2019a).Despite
the fact that PwC auditor offered a qualified opinion, he declined to give details of the process
involved. Pioneer credit has made efforts to defend the legitimacy of their method by hiring a tax
specialist to defend their valuation method. The financial report by the company showed a
continuous decline in the share price. The company has even gone the extent of leasing property
from one of its directors (Pioneer Credit Limited, 2018). This can be a sign to communicate of
the failure of their valuation method. According to the article, a wife to the director who has
leased a property to the company is trading with the company. This leads to potential conflict of
interest.
The company highlight that their method of debt collection is customer friendly (Frost,
2019b). They also hold that it improves collaboration with the customer, a stand that is contrary
to what the customers say. Most of the customers are not happy at all.
b. Link major issues to topic and theory
i. Identify a range of relevant accounting theories that are applicable to
the issues reported in the news article

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There are several theories which are applicable to the issues raised in the news article.
These are the theories of regulation, theories of professionalism and ethics in accounting and
theories of standard setting (ASIC, 2013, pp. 2). Regulation theories include self-interest theory,
public interest theory and capture theory. Theories relating to professionalism and ethics are
teleological and deontological theories. Lastly the theories of accounting standard setting are
the positive accounting theory and normative accounting theory.
ii. Deconstruct and evaluate the issues reported in the news article
through the use of theories
Accounting regulation and politics
The news article above is just a representation of the things that happening in the
corporate Australia. The issues discussed above clearly highlight some of the challenges
experience financial reporting environment in Australia. The most prominent issue raised in the
news article is the concern by Australian Securities and Investment Commission (AISC) over the
method of valuation used by Pioneer Credit.
To begin with, it is necessary for us to understand how the financial and accounting
regulation environment operates in Australia. Accounting regulation is process of providing an
oversight role to the accounting bodies to ensure that the accounting standards, principles and
policies are adhered to by firms ("About ASIC", 2019). Australian Securities and Investment
Commission is one of the bodies charged with the responsibility of regulating financial sector.
To achieve their responsibility, they have the following powers; power to make rules that ensures
integrity is adhered to within the financial markets. They also have powers to do investigation in
case the law has been broken. The main role of ASIC is to ensure that fairness and efficiency is
maintained in the financial sector. The functions, role and power of ASIC can clearly be
explained by the public interest theory. This theory assumes that any regulation brought forward
by the regulator is in the best interest of the public.
It is a requirement of the law that businesses in Australia should prepare and submit their
financial report to the Australian Investments and Securities Commission (AISC). This reporting
is supposed to be done annually. It is also important to note that for a company to be listed in the
Stock exchange Market, it must first comply with the reporting requirement ("Who we are",

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2019d). Another requirement for a company to be listed in the Stock market is that, it must abide
by the rule of periodic disclosure. Pioneer Credit limited as a financial institution has the
responsibility of preparing and submitting their financial report as stipulated in the law.
AISC has raised concerns about the method of valuation used by Pioneer Credit. The
method of valuation is in accordance with the set standards and policies. This is the reason why
ASIC is concerned. It has also been observed that this method is exploitative to the customers.
Despite failure of this method of valuation to yield positive results, Pioneer Credit has vowed not
change it current policy. The company has even gone a step further to seek the services of a tax
specialist to defend their method. The behaviors of Pioneer Credit can be explained by the self-
interest theory which states that people or institution only takes action which they feel with
benefit them.
PwC is an Audit Company which audited the financial reports of Pioneer credit. PwC has
a role of auditing the accounts of Pioneer Credit and giving their opinion concerning the state of
the account. In one of the report given by PwC, it stated that they had not received enough
information to enable judge where the accounting policies were the right one. Australian security
exchange (ASX) is the listing company. Their role in the current issue at hand is state whether
the reports provided by Pioneer Credit are comparable with those from other institution.
The standard and setting processes
A definition by the IFRS Foundation defines accounting standards as set of principles
that guides a company when preparing financial statements so that they can be in standardized
way. Standards in accounting facilitate easy comparison of financial reports. This is because the
procedure followed in their preparation is the same.
In Australia, the body charge with the responsibility of setting up standards is known as
the Australian Accounting Standards Board (AASB). This is a government agency which serves
the interest of the public. While AASB is concerned with the responsibility of formulation of
standards, ASIC is concerned with the enforcement of the standards set by AASB. On the other
hand International Accounting Standards Board formulates standards at international level.
AASB ensures that the local standards conform to the international standards ("About the
AASB", 2019). From the information provided, Pioneer Credit is not conformance to the

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accounting standards. The breach of accounting standards by Pioneer may cause it to be banned
from operating.
Professionalism and ethics in accounting
ASIC has a moral obligation of questioning of Pioneer Credit with regard to their method
of valuation. This is because it the body mandated by the law to do that. This can be effectively
explained by the deontological theory of ethic. This is doing right out of an intrinsic value in an
individual. PwC issued a qualified opinion on a controversial method of valuation (Henderson et
al, 2014, pp. 950-971). This may be explained by the egoistic theory. In this theory, an action is
termed moral if the end result of the action will be a benefit. Pioneer Credit also uses a
controversial valuation method out of the benefit that they seek to get. The tax specialist also acts
egoistically by defending Pioneer Credit. These behaviors can also be illustrated by the egoistic
theory.
The financial statements prepared do not provide enough information to the user. An
example is when PwC say that they have not been provided with sufficient information to enable
them to draw a reasonable conclusion. There is also conflict of interest when one of the directors
of Pioneer Credit leases his own property to the business.
iii. Present a logical conclusion regarding the significance of the issue
reported in the news article
The main issue that the clearly presents, is the conflict that arises between the regulator
and the regulated. In the financial market, there are several regulators. These regulators ensure
that there is fairness in the market and that public interest is taken care of. It is the duty of the
firms to ensure that they abide by the regulation provided by the regulators. Abiding by this
regulations and standards will reduce the conflict that may arise. Acting ethically and following
professional standards will also prevent occurrence of any conflict.
Question two
a. Outline the major issues covered in the exposure draft
There are different stakeholders involved in the current exposure draft. One of the
stakeholders in involved is the International Financial Reporting Standards (IFRS) Foundation
(IFRS, 2018c, pp. 1-4). It is an international body concerned with the responsibility of

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developing accounting standards. There are several issues which have been captured in the
Onerous Contract exposure draft which seek to amend the provisions contained in IAS 37 of the
onerous contract ("Exposure Draft IAS 37: About", IFRS, 2019d). The current provision does
not highlight the cost that should be included in the determination of the ‘cost of fulfilling’ a
contract so as to help in the determination of which contract maybe onerous. The proposed
changes seek to fill that gap by specifying the costs to be included.
A request was tabled before the IFRS interpretation committee seeks a clarification on
the type of costs to include when founding out the cost of fulfilling construction contracts. IAS
11 which previously provided a guideline has already been withdrawn. Different stakeholders
had different views on the type of cost to be included. These differences probably may lead to a
potential material difference in the financial documents of firms. Material difference is has an
adverse effect to the materiality of the documents. This will further impact on the relevance of
the financial statements.
To address this accounting concern, the interpretation requested for comments from
different stakeholders. This would enable them to factor in thought from different parties and
therefore come up with an acceptable amendment. Basically, it can clearly be seen that this
exposure draft is trying to introduce a clause which will give clarity to the current AIS 37
provision.
b. Is there agreement among the various groups? Describe the issues where
there is agreement / disagreement and provide examples.
Different groups have provided their thought with regard to the proposed amendment.
Some have agreed with all the questions, other has agreed to some while others have totally
disagreed completely with the proposed amendment ("Exposure Draft IAS 37: View the
comment letters", IFRS, 2019c). This section will review comment by this different groups.
i. CPA Australia 2019
This body based in Australia supports the proposal of question 1 that the cost
of fulfilling a contract comprises the cost that relate directly to the contract. They also
give their thought of the recommendation that they think are necessary. They

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recommend that IASB should define what economic benefit arising from a contract
entails. Without this clarification, then materiality problem will not have been solved.
CPA Australia
Figure 1: Exposure Draft ED/2018/2 - Onerous Contracts - Cost of Fulfilling a Contract:
CPA Australia (Pflugrath, 2019)
ii. CA Sri Lanka 2019
This the body established in Sri Lanka. This body speaks on behalf of a
country. They agree with the proposed charges and give a go ahead to the IFRS to
implement the charges. There however give suggestion on what should be added.
They are concerned that the proposal only targets construction industries. They
suggest that the scope should be widened to other industries as well.

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CA Sri Lanka
Figure 2: Exposure Draft ED/2018/2 - Onerous Contracts - Cost of Fulfilling a Contract:
CPA Australia (Jeyesinghe, 2019)
iii. Rio Tinto 2019
Rio Tinto is an industry which is involved in the production of goods. This
respondent has provided a comprehensive comment with regard to the proposed
changes. The respondent cites the limitation of the current proposal and gives his
alternative solution. In response to the first question, this responded raises several

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concerns. One of the concerns is that they do not concur with the preference given to
directly related costs as opposed to incremental costs. The respondent provides the
following solution to the concern raised. One of them is the use of both incremental
and directly related costs when measuring onerous provision.

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Rio Tinto
Figure 3: Exposure Draft ED/2018/2 - Onerous Contracts - Cost of Fulfilling a
Contract: CPA Australia (Thomas, 2019, p.1)
iv. Vodafone 2019
This respondent is in agreement with the proposed changes. He concurs with
the proposals of question 1. He is however concerned about the use of the words ‘all
costs’ and issues to do with direct costs verses incremental cost. The responded feels
that this wording may lead to several changes in accounting. The respondent all cites
that reporting challenges my arise if the wording is not reviewed. Another challenge

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that may arise is the practicability of the proposal in some situations which he clearly
highlights. To address the highlighted concerns, the respondent proposes that
incremental cost should be allowed when conducting an onerous assessment in some
circumstances.
Vodafone 2019
Figure 4: Exposure Draft ED/2018/2 - Onerous Contracts - Cost of Fulfilling a Contract:
CPA Australia (Stephenson, 2019)
i. Can the behavior of the regulator be explained by ‘public interest theory’?
Justify your position.
The public interest theory of regulation holds that when a regulation is introduced by the
regulators, it is usually for the benefit of the public and not for self-interest. A regulation is said
have the interest of the public if the cost associated with implementing it is less when compared

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to the benefits accrued from the implementation (Deegan, 2014, pp. 45-47). In the context of the
exposure draft, the regulator is the IFRS Foundation. IFRS was form to serve the public and not
a group of individuals.
There are several things which illustrate how IFRS work to ensure that they represent the
interest of the public when setting up standards. To start with, IFRS Foundation is an
organization which was formed to serve the interest of the public and not to make profit. This
helps in the prevention of conflict of interest. The structure adopted in the leadership of IFRS
Foundation plays a significant role in ensuring that the independence of the Foundation achieved
and maintained. This help in preventing influence that may be caused by people or different
stakeholders who may have their own self-interest. Secondly, it is a global body which is not
related to any specific country. Another reason which shows that IFRS Foundation is acting in
the best interest of the public is the process through which they set their standard.
IFRS standards are set through a series of steps which facilitate public participation.
There is often a thorough global consultation which is done before standards are adopted ("How
we work in the public interest", 2019c). Comments are usually received from different
stakeholders such as institutions, professional bodies and even from individuals. These
comments are usually factored in by IFRS Foundation and usually inform the final standards
formulated by IFRS.
In Australian context, the Australian Accounting Standards Board (AASB) is the
regulator tasked with the responsibility of formulating standards for use within Australia. This
body is independent and their function is free from influence by different interest groups.
From the discussion above, we have seen that before the regulator sets up standards, there
is a thorough process which is followed (Hoogervorst & Prada, 2015, pp. 1-12). Different
stakeholders are involved in the formulation process. The purpose for which the regulators are
formed is to serve the public. We can therefore conclusively say that the behavior of the
regulators is governed by the public interest theory.
ii. Apply each of the theory of regulation to the comment letters.

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There are three theories of regulation. They are the public interest, private interest and
capture theory. To start with, the public interest theory states that any regulation put forward by
the regulator is always after consideration of the public interest. The regulator will only enact a
regulation that will benefit the public. On the other hand, private interest theory is contrary to the
public interest theory. In private theory of regulation, it is assumed everyone, inclusive of the
regulator act so as to be benefit themselves. For the case of the regulators, they will support only
regulations which will protect their interests such as being re-elected.
According to the capture theory of regulation, first, as the word suggests there is an
aspect of capturing. The regulator introduces a regulation with the public interest in mind. On the
other hand, the regulated captures the regulatory process after operationalization of the
regulation (Deegan, 2014, pp. 79-80). They capture the process for their own benefit.
With regard to the comment letters, it can simply be said that the respondent responds by
giving comments which takes care of their own interest. Their comments are meant to ensure that
the standards to be set favor them. Their reaction can simply be explained by the private interest
theory where by individuals’ acts out of their own interest. An example of this is Rio Tinto and
Vodafone who responds buts keeps in mind that their companies’ interest is taken care of.
Vodafone and Rio Tinto are companies which are in business to make profit. Their comments
therefore ensure that they are not disadvantaged. This can clearly be illustrated by the kind of
concern they raises. Vodafone quote the kind of change they will face if their concerns are not
considered.
When we look keenly at the comments made by CPA Australia and CA Sri Lanka, both
of them agree with the proposed changed. They go ahead and raise their concerns for the area in
which they feel should be improved. These two bodies have a common characteristic. Both of
them are professional bodies representing a large group of professional. Their reaction can be
explained by both self-interest theories and public interest theory. Self-interest is manifested
where the two bodies’ raises concerns which they think will protect the people they represent. On
the other hand, public interest is manifested whereby they agree with the proposal with the
intention of protection the large professionals they represent

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Appendix 1: News Article
ASIC kept watch on Pioneer Credit for 12 months
James Frost
3 April, 2019
The corporate regulator has been in discussions with a whistle-blower over accounting standards at
Perth-based buyer of bad debt portfolios Pioneer Credit since November 2017 but did not contact the
company to express its concerns until a year later, The Australian Financial Review can reveal.
A spokesman for the Australian Securities and Investments Commission said it approached the company
in October 2018 after it made statements in its 2017-18 annual report that it had no plans to change a
controversial valuation method which subsequently has attracted the attention of its auditor and the
ASX.
“ASIC raised questions with Pioneer Credit as part of our routine surveillance of financial reports ... We
are awaiting further information from the company at this time,” the ASIC spokesman said.
Documents obtained by The Australian Financial Review, however, reveal ASIC was aware of concerns
about the company and its methods dating back almost a year earlier with the regulator asking a
whistle-blower for more information in November 2017.
Pioneer Credit buys impaired books of retail credit from banks and utilities, often at cents in the dollar,
before working with the debtor to collect the outstanding debt. It is the only operator in the space
globally that values its debt portfolios at fair value or the price agreed between buyer and seller rather
than amortised cost, which writes down the value of the asset over time.
Pioneer Credit’s business model has been under the spotlight since auditor PwC declared earlier this
year “sufficient and appropriate information was not yet available to them to determine whether the
group’s accounting policy is appropriate”.
'Appropriate technique'
The qualified audit from February 25 was produced by PwC partner Douglas Craig who also oversaw the
annual report for 2017-18 that attracted ASIC’s attention. PwC has declined the opportunity to answer
questions about the process, saying “we don’t comment on client matters”.
The company hired international tax specialist David Russell, QC to defend its approach earlier this year.
The subsequent opinion from counsel – which backs fair value as an appropriate technique – has been
delivered to both PwC and ASIC but has not been made public.
Sources within Pioneer Credit say the reason the company uses fair value and everyone else uses
amortised credit is because the company is “a disrupter” and it is a case of “we are right and everyone
else is wrong”.
Billionaire Kerry Stokes is among Pioneer’s shareholders with a 5 per cent stake through Wroxby Pty Ltd
with the Seven Network holding another 5 per cent stake valued at a combined $14.2 million on

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Tuesday's prices. Managing director and founder Keith John also holds 10 per cent, with 8.29 per cent in
his own name and another 1.69 per cent held in a related company with the two parcels of shares also
worth $14.2 million. Former chief operating officer Lisa Stedman, who left the company in February,
holds 0.51 per cent worth $727,000.
Potential red flags
Although thinly traded, short interest in Pioneer Credit has surged in recent months, with investors
taking short positions representing anywhere up to 54 per cent of daily traded stock.
Critics of the company say it has a history of making promises that it does not fulfil, including plans to
launch a credit card which have been spruiked at regular intervals since its 2014 prospectus but appear
to have been abandoned by 2017. They also highlight other potential red flags such as the abundance of
related-party deals including the leasing of properties owned by managing director Keith John to the
company.
- In the 2014 prospectus it was disclosed that Mr John’s spouse, Alana John, was paid $10,000 a
month plus GST for the “the provision of design and project management services”.
- The 2015 annual report discloses that Alana John Design was paid $160,917 between November
2013 and June 2015.
- The 2018 annual report also discloses that Alana John Design was paid $55,000 to fit out one
floor of 108 St Georges Terrace.
Complained of being harassed
Pioneer Credit says its approach to debt collection is different from other operators in the space because
it works with “all of our customers individually to develop the right solution” and “there is nothing we
love more than seeing our customers achieve financial recovery”. Unhappy clients of Pioneer Credit say
there is little evidence of that collaborative approach in their business practices.

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Appendix 2: Comment Letters

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