In our comment letter, we support the AICPA’s Professional Ethics Executive Committee’s (PEEC’s) proposed new definition of “simultaneously employed or associated” as well as the revised interpretation on “Simultaneous Employment or Association With an Attest Client.” We believe the proposal would align the existing guidance with independence threats and allow firms to evaluate these threats while limiting the strictest prohibitions to covered members. We believe that the proposed revisions would provide members with additional guidance to address when members hold simultaneous employment or association with attest clients, including associated potential threats to independence. The additional guidance will also assist in the consistent application of the revised interpretation across members in public practice.
We asked PEEC, however, to consider providing nonauthoritative guidance in the form of frequently asked questions (FAQs) as well as examples of individual positions at the attest client and firm, including accounting roles not covered by key positions, and potential activities performed that would create increased threats.
Read our comments in full here.
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