Professional Ethics Executive Committee AICPA Professional Ethics Division Open Meeting Agenda May 9-10, 2013 AICPA Offices - Washington DC

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1 Professional Ethics Executive Committee AICPA Professional Ethics Division Open Meeting Agenda May 9-10, 2013 AICPA Offices - Washington DC Time Agenda Item Related Materials May 9 th 9:00 a.m. 11:15 a.m. (Including 15 minute break) OPEN MEETING BEGINS Subordination of Judgment Mr. Dailey and Mr. West will seek the Committee s approval of the revised interpretation. External Links Required Reading - Exposure Draft and Comment Letters Appendix 1 - The Task Force s recommendations. 11:15 a.m. 12:15 p.m. Interpretation 101-3, Nonattest Services - Cumulative Effect Proposal Ms. Snyder and Mr. Williams will seek the Committee s input on the proposed cumulative effect provision of Interpretation External Links Exposure Draft and Comment Letters 12:15 p.m. 1:15 p.m. LUNCH 1:15 p.m. 2:45 p.m. IFAC Convergence - Conflicts of Interest Mr. Burke and Evans will seek the Committee s input on the IESBA s approved standard and feedback on a revised draft Interpretation Conflicts of Interest for members in public practice and draft new Interpretation Conflicts of interest for members in business. External Link Required Reading - IESBA Approved Standard on Conflicts of Interest External Link PEEC's Comment Letter on IESBA's Conflict of Interest Proposal, Interpretation :45 p.m. 3:45 p.m. IFAC Convergence - Breaches of the Code Mr. Jorth and Mr. Evans will seek the Committee s input on the IESBA s approved standard and feedback on possible new guidance to the Code addressing breaches of the Code. External Link Required Reading -IESBA s Final Breaches Pronouncement External Link - AICPA Private Company Practice Section Inadvertent Independence Violations Practice Tool and Appendix 2 - The Study Group s recommendations and request for feedback. Appendix 3 The Task Force s recommendations and request for feedback. Appendix 4 The Task Force s recommendations and request for feedback.

2 Professional Ethics Executive Committee AICPA Professional Ethics Division Open Meeting Agenda May 9-10, 2013 AICPA Offices - Washington DC IESBA s Basis for Conclusions Document and PEEC's Comment Letter on IESBA's Breaches Proposal. 3:45 p.m. 4:00 p.m. PM BREAK 4:00 p.m. 4:15 p.m. Frequently Asked Question Merged Firms Ms. Goria will seek the Committee s approval of a new FAQ. 4:15 p.m. 5:00 p.m. Codification Ms. Goria will provide the Committee with an update on the status of the project. External Links Exposure Draft and AICPA Codification Project Page 5:00 p.m. OPEN MEETING CONCLUDES FOR THE DAY Appendix 5 - Staff s draft FAQ. May 10 th OPEN MEETING BEGINS 9:00 a.m. 9:15 a.m. SSARS Update Mr. Glynn will provide the Committee with an update on the revised SSARS project. 9:15 a.m. 9:30 a.m. IESBA Update Ms. Snyder will update the Committee on the activities of the IESBA including its March 11-13, 2013 meeting. 9:30 a.m. 9:35 a.m. Professional Ethics Executive Committee Agenda Ms. Goria will review the changes made to the agenda. External Link Required Reading - PEEC Project Agenda Minutes of Professional Ethics Executive Committee Open Meeting The Committee approved the minutes via from the January 28-29, 2013 meeting. External Link - January 28-29, 2013 Minutes Future Meeting Dates August (Providence, RI), November 4-5 (Durham) OPEN MEETING CONCLUDES 2 P a g e

3 APPENDIX 1 To: Professional Ethics Executive Committee From: Jim West, Technical Manager, Independence/Behavioral Standards Date: April 1, 2013 Re: Interpretation 102-4, Subordination of Judgment Task Force Comment Letter Review Task Force Members: Jack Dailey (Chair), Bruce Jorth, Mary Louise Nunes, Tom Volturo, Rich Miller Staff: Jim West Background The Professional Ethics Executive Committee (PEEC) received 9 comment letters addressing the proposed revision of Interpretation Subordination of Judgment by a Member in the AICPA Code of Professional Conduct ( Code ). The Comment Letter (CL) Summary List Exhibit A lists the specific comment letters and includes links to the individual letters; each CL has an assigned number that corresponds to the CL Summary List. The Task Force has reviewed the comments and provided feedback received from the respondents by topic below. The Committee is asked to review the letters, feedback, and the Task Force s recommendations (where provided) and provide its input as to whether revisions should be made to the proposed revised Interpretation Introductory Paragraph One commenter (CL7) recommended changing the phrase on a volunteer basis with while serving as a volunteer. The Task Force believes that the term serving as a volunteer may not be all-inclusive since situations may arise whereby the member may not formerly serve as a volunteer for an organization but may provide uncompensated professional services for the organization. Furthermore, the Task Force believes that the phrase on a volunteer basis captures all situations whereby the member provides uncompensated professional services for the organization. In addition, the term volunteer basis is specifically used in the definition of member in business Action needed: The Task Force has included the comment above for informational purposes only and does not recommend any action by PEEC based on this comment. Second Paragraph Specific comments received on the second paragraph of the revised interpretation include: Clarifying whether the proposed revised interpretation applies to subordination of judgment between a member and his or her client, or whether the revised interpretation is limited to subordination of judgment between members within his or her organization (CL4, CL8). Consider using a word other than supervisor to more accurately describe others in this role such as employers, other superiors, clients, etc. (CL8, CL9). 3 P a g e

4 APPENDIX 1 Adding the word rules to all references that incorporates the term applicable laws and regulations (CL4). Inserting the word then in the first sentence of the second paragraph to state (addition in boldface) If a member and his or her supervisor or other person to whom subordination of judgment might occur (supervisor) have a difference of opinion relating to the application of accounting principles; auditing standards; or other relevant standards, including standards applicable to tax and consulting services, or applicable laws or regulations, then self-interest, familiarity, and undue influence threats to the member s compliance with the Integrity and Objectivity rule may exist. (CL4). Reconsidering whether each section of the proposed interpretation effectively covers all applicable membership types. Specifically, some sections within the interpretation clearly relate to members in business but appear to exclude members in public accounting (CL7). Defining each threat and safeguard along with applicable guidance explaining how the terms are to be considered in the assessment process (CL4). Use more specific language in lieu of the phrase other relevant professional standards (CL5). Defining the word subordination (CL5). Identifying only violations of laws and regulations that are material to the financial statements as significant threats to subordination of judgment (CL6). The Task Force believes that the Committee intended for this interpretation not to address differences of opinion between a member and client but rather, only internal firm and company disagreements and that this should be clarified. In addition, The Task Force also believes the phrase If a member and his or her supervisor or other person to whom subordination of judgment might occur (supervisor) could be clarified to indicate that self-interest, familiarity, and undue interest threats to the member s compliance with the Integrity and Objectivity rule may exist if the member has a difference of opinion with any person within the member s organization. The Task Force recommends that the Committee consider inserting the following highlighted text to address these comments: iif a member and his or her supervisor or any other person within the member s organization to whom subordination of judgment might occur (supervisor) have a disagreement or dispute difference of opinion relating to The Task Force recommends the term member s organization continue to be used throughout the interpretation, rather than organization to clarify the differences of opinion relate only to members within the firm or company that employs the member. The Task Force also recommends that a sentence be added to the end of the paragraph stating: This interpretation does not apply to differences of opinion between a member and his or her client. 4 P a g e

5 APPENDIX 1 In previous deliberations, the Committee did not believe that adding the word rules to the term applicable laws and regulations was needed since the interpretation already stated that the member should consider the relevant professional standards in situations whereby the member might have a difference of opinion. The Task Force does not believe that the first sentence of the second paragraph would be clearer by inserting the word then after the phrase applicable laws or regulations. In addition, this would be inconsistent with the drafting of the Codification content. The Task Force believes that the proposed revised interpretation clearly states that the interpretation is applicable to members in public accounting. The Task Force does not recommend including any additional or clarifying language within the interpretation that the interpretation is applicable to members in public accounting. The Task Force does not believe that defining each threat and safeguard within the interpretation is needed. Specifically, the interpretation already identifies the type of threats (i.e., self-interest, familiarity, and undue influence threats) and the safeguards are specifically listed within the proposed revised interpretation. In previous deliberations, the Committee added the phrase other relevant professional standards to capture all situations whereby a member and his or her supervisor have a difference of opinion related to professional services rendered. The Task Force believes that removing other relevant professional standards from the interpretation may create a risk whereby a member subordinates his or her judgment because a specific standard was not mentioned in the interpretation. The Task Force recommends that the phrase other relevant professional standards remain in the interpretation. The Task Force does not believe defining subordination adds value to the proposed revised interpretation and is unnecessary as members should understand the concept of subordination of judgment. The Task Force does not recommend defining subordination within the interpretation. The Task Force does not believe that violations of laws and regulations that are material to the financial statements should be the only significant threat. The Committee specifically addressed this issue and agreed that a violation of law or regulation, even if immaterial, was still an egregious matter and could result in a significant threat. The Task Force recommends not limiting violations of laws and regulations that are material to the financial statements as the only significant threat to compliance with the Integrity and Objectivity rule. The proposed revisions can be seen in Exhibit C. Action needed: The Task Force requests that PEEC consider the comments received on this issue and determine whether the Task Force s proposed revisions (see Exhibit C) are appropriate. 5 P a g e

6 APPENDIX 1 Third Paragraph Specific comments received on the third paragraph of the revised interpretation include: Addressing situations whereby the laws and regulations of regulatory agencies are in conflict with professional standards (CL7). Clarifying within the interpretation or within non-authoritative guidance that would provide members further guidance on the initial steps to be followed in order to form a conclusion on a disagreement (CL8). Insert and in the opening sentence of the paragraph (addition in boldface) the member should form a conclusion, after appropriate research and/or consultation, about whether the result of the position (CL8). Recommend specifying to whom a member consulted when assessing the significance of any identified threats (CL8). Historically, the Committee has always required that a member must follow the more restrictive rules (i.e. laws and regulations of regulatory agencies) and this has been incorporated into various sections of the Code. The Task Force does not believe that the interpretation should provide additional guidance on matters whereby the laws and regulations of regulatory agencies are in conflict with professional standards. The Task Force recommends that the interpretation not address such conflicts. The Task Force believes that the proposed revised interpretation provides adequate guidance on how a member should form a conclusion on a disagreement. Due to the complexity of the disagreement, the member may elect to consult with other members of the profession or perform research on the matter. The Task Force does not recommend providing additional guidance on the initial steps to be taken when forming a conclusion on a disagreement. The Task Force does not believe that replacing or with and/or in the sentence the member should form a conclusion, after appropriate research or consultation adds additional value or clarity to the interpretation. The Task Force does not recommend incorporating this suggestion. The sixth paragraph of the proposed revised interpretation already includes a safeguard that a member should consider documenting conversations and parties with whom these matters were discussed. The Task Force does not believe that any additional language should be added to the paragraph on documenting the conversations with parties consulted. The Task Force does not recommend adding any additional document requirement or considerations. Action needed: The Task Force has included the comments above for informational purposes only and does not recommend any action by PEEC based on the comments. Fourth and Fifth Paragraphs Specific comments received on the fourth and fifth paragraphs of the revised interpretation include: 6 P a g e

7 APPENDIX 1 In situations whereby the member concludes that the position taken by the supervisor is not in compliance with standards but does not result in a material misrepresentation of fact or violation of applicable laws or regulations, the member should consider documenting his or her understanding of the facts, the accounting principles, auditing standards, or other relevant standards involved or applicable laws or regulations and the conversations and parties with whom these matters were discussed (CL1). Clarity edits to the first sentences of the fourth and fifth paragraphs (CL4). Provide guidance in situations whereby the member incorrectly concludes that the position taken by the supervisor is not in compliance with professional standards or a violation of applicable laws, rules, or regulations (CL4). Provide additional guidance if a member suspects, but cannot determine, that a material misrepresentation of fact or a violation of applicable laws and regulations have occurred (CL6). Require a member to only make reasonable efforts to inform the person taking the contrary or inconsistent position regarding the representation of a known fact or judgment about a fact since it may be difficult for a member to discuss his or her own conclusions on a position taken by a supervisor because of fear of retribution, firing, or performance review degradation (CL8). Provide examples or scenarios within the interpretation or provide informal, nonauthoritative guidance on when a supervisor s position may create a material misrepresentation of fact (CL8). When describing differences of opinion or language concerning the facts or positions taken, consider broadening such phrases to include representation of known facts or professional judgment about such facts, without limitation (CL8). The Task Force does not believe that the interpretation should require that the member should have to consider documenting all relevant information in situations whereby a member concludes that the position taken by the supervisor is not in compliance with standards provided the position does not result in a material misrepresentation of fact or violation of applicable laws or regulations. This was specifically discussed and agreed to by the Task Force and Committee. Furthermore, the interpretation does not preclude a member from documenting such situations. The Task Force recommends not inserting any documentation considerations in matters whereby the position taken by the supervisor does not result in a material misrepresentation of facts or violation of applicable laws or regulations. One commenter (CL4) recommended that the first sentences of both paragraphs be revamped whereby the phrase threats would not be significant/threats would be considered significant be moved to the first part of the sentence. In addition, the commenter recommended that the phrase taken by the supervisor clarifies the position. The Task Force does not believe that these sentences within the proposed revised interpretation need to be further clarified. The Task Force does not recommend editing the first sentences of the fourth and fifth paragraphs. The Task Force does not believe it is practical or necessary to include guidance on situations whereby the member incorrectly concludes that the position taken by the supervisor is not in compliance with professional standards or a violation of applicable laws, rules, or regulations. 7 P a g e

8 APPENDIX 1 The member s conclusions should be formed from adequate research or consultation. The Task Force does not recommend providing any additional guidance in such situations. The Task Force believes that the proposed revised interpretation addresses situations whereby a member expects, but cannot determine, that a material misrepresentation of fact or violations of applicable laws and regulations have occurred. Specifically, the proposed revised interpretation states that a member must form a conclusion, after appropriate research or consultation, about whether the result of the position fails to comply with professional standards, when applicable; creates a material misrepresentation of fact; or may violate applicable laws or regulations. Based on this requirement, a member would need to perform additional research or consultation to form his or her conclusions. The Task Force does not recommend adding any additional language in matters whereby the member expects, but cannot determine, that a material misrepresentation of fact or violations of applicable laws and regulations have occurred. The Task Force does not believe that the member should only make reasonable efforts to inform the person taking the contrary position of his or her concerns of the position taken because of fear of retribution. The public interest, and not the fear of retribution, should be the member s first priority. The Task Force does not recommend stating that the member should only make reasonable efforts to inform the person taking the contrary position his or her concerns of the position taken. The Task Force does not believe that the interpretation needs to include examples or scenarios on when a supervisor s position may create a material misrepresentation of fact. Professional standards provide adequate guidance on what constitutes a material misrepresentation and members should use professional judgment. The Task Force does not recommend providing any examples within the interpretation on when a supervisor s position may create a material misrepresentation of fact. The Task Force does not believe that adding the phrase representation of known facts or professional judgment about such facts, without limitation would add value to the interpretation. The Task Force does not recommend incorporating this phrase within the interpretation. It was also noted that the term those charged with governance has recently been used within the Code and captures bodies such as the audit committee, board of directors and owners of the company. The Task Force recommends that the Committee consider inserting the term as indicated in highlighted text below: If the difference of opinion is still not resolved, the member should discuss his or her concerns with the appropriate higher level(s) of management within the member s organization (for example, the supervisor's immediate superior, senior management, and those charged with governance the audit committee or equivalent, the board of directors, the company s owners). The proposed revisions can be seen in Exhibit C. 8 P a g e

9 APPENDIX 1 Action needed: The Task Force requests that PEEC consider the comments received on this issue and determine whether the Task Force s proposed revisions (see Exhibit C) are appropriate. Sixth Paragraph Specific comments received on the sixth paragraph of the revised interpretation include: Clarifying language on the documentation safeguard (CL4). Clarification on how safeguards can reduce threats to an acceptable level (CL5). Removing the requirement that a member contact third parties if differences are not resolved (CL6). When communicating to third parties, adding language advising members to be cognizant of Rule 301 Confidential Client Information (CL8). Recommend referencing the requirements of SQCS No. 8, a Firm s System of Quality Control within the proposed revised interpretation (CL8). The Task Force does not believe that the documentation safeguard needs additional clarification. The Task Force does not recommend any additional changes to the documentation safeguard. The Task Force believes that the member should use their professional judgment on how safeguards can reduce identified threats to an an acceptable level. The Task Force does not recommend adding additional guidance on what constitutes an acceptable level since this term is already defined in the Guide for Complying with Rules which will be incorporated into the Codification. The Task Force does not believe it serves the public interest for a member not to consider whether any responsibilities exist to communicate to third parties. The Task Force does not recommend removing this specific safeguard. The Committee intended that the proposed revised interpretation not address member/client issues. In addition, the Task Force has recommended adding language in the second paragraph of the interpretation that clarifies the interpretation does not apply to member-client relationships. As a result, the member would not be breaching confidential client information since the reporting would not concern a client, but instead the member s firm or organization. The Task Force does not recommend adding any language that the member be cognizant of Rule 301. However, Interpretation 501-9, Confidential Information Obtained From Employment or Volunteer Activities, requires that a member maintain the confidentiality of his or her employer s or firm s confidential information but permits disclosure in certain situations such as when disclosure is required by law. The Task Force therefore recommends that a member be reminded of his or her obligations under Interpretation as well as Interpretation and proposes the following highlighted revision: 9 P a g e Determining whether any responsibilities exist to communicate to third parties, such as regulatory authorities or the employer s (former employer s) external accountant. In considering such communications, the member should be cognizant of his or her

10 APPENDIX 1 obligations under Interpretation 501-9, Confidential Information Obtained From Employment or Volunteer Activities and When dealing with the employer s external accountant, the member should at all times be cognizant of his or her obligation under Interpretation No , Obligations of a member to his or her employer's external accountant [ET section ]. The Committee previously noted that SQCS No. 8 specifically refers to firms as opposed to individuals. However, the Committee believes that members should consider referring to their firm s internal policy and procedures manual, and, as a result, added a safeguard to the revised interpretation that a member determine whether any additional requirements exists under his employer s internal policies and procedures for reporting differences of opinion. The Task Force does not recommend referencing the requirements of SQCS No. 8 within the interpretation. The proposed revisions can be seen in Exhibit C. Action needed: The Task Force requests that PEEC consider the comments received on this issue and determine whether the Task Force s proposed revisions (see Exhibit C) are appropriate. Seventh Paragraph Specific comments received on the seventh paragraph of the revised interpretation include: Further guidance with respect to the appropriate documentation and other steps to be taken when a member continues his or her relationship with an organization after the member concluded that no safeguards can eliminate or reduce the threats to an acceptable level or if the appropriate action was not taken by the organization (CL4). Editing the seventh paragraph as follows (additions are in boldface and deletions are stricken): If the member concludes that no safeguards can eliminate or reduce the threats to an acceptable level which will reasonably cause the member to not be in compliance with the Integrity and Objectivity rule, or if the member reasonably concludes that reasonable appropriate action was not taken in response to actions taken by responsible parties, he or she the member should consider the appropriateness of his or her continued relationship within the organization (CL8). The Task Force does not believe further guidance is necessary on situations whereby a member continues his or her relationship with an organization after the member concluded that no safeguards can eliminate or reduce the threats to an acceptable level or if the appropriate action was not taken by the organization. The interpretation states that a member should consider his or her continuing relationship with the organization as opposed to discontinuing the relationship. Furthermore, the Task Force believes that the member should use his or her professional judgment on whether to continue the relationship. The Task Force does not recommend adding any further guidance in such situations. 10 P a g e

11 APPENDIX 1 The Task Force believes that paragraph seven of the proposed revised interpretation does not need further clarification. The Task Force does not recommend implementing any changes to this paragraph. Action needed: The Task Force has included the comments above for informational purposes only and does not recommend any action by PEEC based on the comments. Closing Paragraph Three commenters (CL4, CL6, CL7) recommended that the closing paragraph be deleted or to provide guidance on how a member should apply similar safeguards, as appropriate, to other situations involving a difference of opinion so that the member does not subordinate his or her judgment. The Task Force believes that the member should consider whether additional safeguards not listed in the interpretation may be implemented to reduce or eliminate threats to the member s compliance with the Integrity and Objectivity rule. The Task Force does not recommend deleting this paragraph or providing examples of similar safeguards. However, the Task Force recommends the following highlighted clarity edit to the closing paragraph: A member should use professional judgment and apply similar safeguards, as appropriate, to other situations involving a difference of opinion so that the member does not subordinate his or her judgment. The proposed revisions can be seen in Exhibit C. Action needed: The Task Force requests that PEEC consider the comments received on this issue and determine whether the Task Force s proposed revisions (see Exhibit C) are appropriate. Effective Date Specific comments received on the effective date of the revised interpretation include: Clarification on whether the revised interpretation is effective for differences of opinion that have arisen but are not resolved as of the effective date (CL5). Consider whether employing organizations, other than firms complying with SQCS No. 8, may need additional time to build into their policies these requirements. In addition, consider whether additional time may be necessary for the firms to better educate their partners and employees if differences are deemed to exist between the AICPA quality control standards and the revised interpretation (CL8). The Task Force believes that the proposed revised interpretation would not add any additional requirements to the member in resolving differences of opinion than the current interpretation. The Task force also does not believe that the proposed revised interpretation would take significant time for employing organizations to create and implement internal policies on how to effectively resolve differences of opinion. In addition, the Task Force does not believe that the AICPA quality control standards should be referred to in the revised interpretation. The Task 11 P a g e

12 APPENDIX 1 Force recommends that the proposed revised interpretation not be delayed for any transition purposes and therefore be effective the last day of the month when it is issued in the Journal of Accountancy. Action needed: The Task Force has included the comments above for informational purposes only and does not recommend any action by PEEC based on the comments. Materials presented: Exhibit A Comment letter summary with links to individual letters Exhibit B Exposed revised Interpretation Exhibit C Proposed revisions to exposed Interpretation P a g e

13 APPENDIX 1 COMMENT LETTER SUMMARY LIST Exhibit A Comment Letter 1.North Carolina State Board of Examiners Support with Comments 2. NASBA Support 3. Ohio Society of CPAs Professional Ethics Committee Support 4. New York State Society of CPAs Professional Ethics Committee Support with Recommendations Feedback Highlights Assessment of Position Taken by the Supervisor Noted that even when the member concludes that the position taken by the supervisor is not in compliance with standards but does not result in a material misrepresentation of fact or a violation of applicable laws or regulations, the member should consider documenting his or her understanding of facts, the accounting principles, auditing standards, or other relevant standards involved or applicable laws or regulations and the conversations and parties with whom these matters were discussed. Scope Recommend clarifying whether the scope of the revised interpretation applies to subordination of judgment between a member and his or her client, or is limited to the subordination of judgment between members within his or her organization. Recommend adding the word rules to all references that incorporates the term applicable laws and regulations. Recommend adding the word then in the first sentence of the second paragraph (additions in boldface) If a member and his or her supervisor or other person to whom subordination of judgment might occur (supervisor) have a difference of opinion relating to the application of accounting principles; auditing standards; or other relevant standards, including standards applicable to tax and consulting services, or applicable laws or regulations, then selfinterest, familiarity, and undue influence threats to the member s compliance with the Integrity and Objectivity rule may exist.. Threats and Safeguards Recommend defining each threat and safeguard along with applicable guidance explaining how they are to be considered in the assessment process. Recommend adding clarification to the safeguard Documenting his or her understanding of the facts, the accounting principles, auditing standards, or other relevant professional standards involved or applicable laws or regulations and the conversations 13 P a g e

14 APPENDIX 1 Comment Letter 5.Missouri Society of CPAs Professional Ethics Committee Support with Recommendations Feedback Highlights and parties with whom these matters were discussed. Recommend providing further guidance with respect to the appropriate documentation and other steps to be taken when a member continues his or her relationship with an organization after the member concluded that no safeguards can eliminate or reduce the threats to an acceptable level or if the appropriate action was not taken by the organization. Assessment of Position Taken by the Supervisor Recommend editing the following sentence (proposed additions are in boldface and deletions are stricken) Threats would not be significant Iif the member concludes that the position taken by the supervisor is not in compliance with professional standards but does result in a material misrepresentation of fact or a violation of applicable laws, rules, or regulations, threats would not be considered significant.. Recommend editing the following sentence (proposed additions are in boldface and deletions are stricken) Threats would be significant if If the member concludes that the position taken by the supervisor is not in compliance with professional standards because it results in a material misrepresentation of fact or a violation of applicable laws, rules or regulations., threats would be considered significant. Recommend additional guidance in situations whereby a member incorrectly concludes that the position taken by the supervisor is not in compliance with professional standards or a violation of applicable laws, rules, or regulations. Closing Paragraph Recommend deleting the closing paragraph or to provide additional guidance on how a member should apply similar safeguards, as appropriate, to other situations involving a difference of opinion so that the member does not subordinate his or her judgment. Effective Date Recommend clarification on whether the revised interpretation is effective for disputes that have arisen but not resolved as of the issue date. Other Relevant Standards Recommend more specific language as opposed to using the phrase other relevant professional standards. Threats and Safeguards Recommend clarifying how safeguards can reduce threats to an acceptable level. In addition, provide additional 14 P a g e

15 APPENDIX 1 Comment Letter 6. AICPA PCPS Technical Issues Committee Support with Recommendations 7. Pennsylvania Institute of CPAs Professional Ethics Committee Support with Recommendations Feedback Highlights guidance on the phrase an acceptable level. Definition of Subordination Recommend defining the word subordination. Notification to Third Parties Recommend not requiring a member to contact third parties if differences are not resolved. While requiring a member to contact third parties would seem to be an appropriate moral obligation of the member, it may be difficult to place a subordinate in that position. Threats and Safeguards Recommend identifying only violations of laws and regulations that are material to the financial statements as significant threats to subordination of judgment. Assessment of Position Taken by the Supervisor Recommend additional guidance if a member suspects, but cannot determine, that a material misrepresentation of fact or a violation of applicable laws and regulations have occurred. Closing Paragraph Recommend providing examples to help members implement the guidance in other situations involving a difference of opinion that result in subordination of judgment. Volunteer Basis Recommend changing the phrase or on a volunteer basis with while serving as a volunteer Second Paragraph Recommend re-wording the second paragraph for improved clarity. Scope Recommend considering whether the term supervisor effectively covers a member-client relationship. In addition, recommend adding a notation that members should consider the need to further discuss clearly inconsequential differences of opinion on professional standards with the person taking the different position. Recommend reconsidering whether each section of the proposed Interpretation effectively covers all applicable membership types. Specifically, some sections within the interpretation clearly relate to members in business and industry but appear to exclude members in public accounting. Closing Paragraph Recommend reconsidering whether the closing paragraph is needed. Conflicts Between Regulatory Agencies and Accounting Standards Recommend addressing situations whereby the laws and regulations of regulatory agencies are in conflict with accounting professional standards. 15 P a g e

16 APPENDIX 1 Comment Letter 8. Grant Thornton Support with Recommendations Feedback Highlights Assessment of Position Taken by the Supervisor Recommend clarifying whether the professional disagreement extends beyond one s immediate supervisor to others within the employing organization or others at a client s organization. Specifically, consider using a word other than supervisor to more accurately describe others in this role such as employers, other superiors, clients, attorneys, and elected officials as examples, or clarify in non-authoritative guidance the types of roles or positions that may constitute a supervisor. Recommend having a member make reasonable efforts to inform the person taking the contrary or inconsistent position regarding the representation of a known fact or judgment about a fact since it may be difficult for a member to discuss his or her own conclusions on a position taken by a supervisor because of fear of retribution, firing, or performance review degradation. Recommend clarifying within the revised interpretation or within non-authoritative guidance that would provide members further guidance on the initial steps to be followed in order to make a conclusion on a disagreement. When describing differences of opinion or language concerning the facts or positions taken within the interpretation, consider broadening such phrases to include representation of known facts or professional judgment about such facts, without limitation. Recommend providing specific examples or scenarios on when a supervisor s position may create a material misrepresentation of fact within the interpretation or non-authoritative guidance. Quality Control Standards Recommend referencing the requirements of SQCS No. 8, a Firm s System of Quality of Control within the proposed interpretation. Threats and Safeguards Recommend that the member, in forming his or her conclusion, also consider research and/or consultation. Recommend specifying to whom a member should consult when assessing the significance of any identified threats. Recommend adding the word disclosed to the phrase with whom these matters were discussed to the fourth safeguard. Scope 16 P a g e

17 APPENDIX 1 Comment Letter 9. Illinois CPA Society Ethics Committee Support with Comments Feedback Highlights Recommend further clarification in describing the organization. For example, if the person to whom subordination of judgment might occur is the client, it is not clear if the organization represents the client or the member s public accounting firm. Notification to Third Parties Recommend advising members to be cognizant of Rule 301 Confidential Client Information when considering whether there is a need to disclose or communicate subordination of judgment matters to third parties and that, before a member takes such a position, he or she should consider consulting with legal counsel. Continued Relationship with the Organization Recommend the following changes to paragraph 7 in order to clarify the further steps to be considered by a member (additions are in boldface and deletions are stricken): If the member concludes that no safeguards can eliminate or reduce the threats to an acceptable level which will reasonably cause the member to not be in compliance with the Integrity and Objectivity rule, or if the member reasonably concludes that reasonable appropriate action was not taken in response to actions taken by responsible parties, he or she the member should consider the appropriateness of his or her continued relationship within the organization. Effective Date Recommend considering whether many employing organizations, other than firms complying with SQCS 8, may need additional time to build into their policies these requirements. In addition, recommend considering whether additional time may be necessary for the firms to better educate their partners and employees if differences are deemed to exist between the AICPA quality control standards and the revised interpretation. Scope Recommend editing the following sentence (proposed additions in boldface and deletions are stricken) If a member and his or her supervisor or other person to whom subordination of judgment might occur (supervisor higher level(s) of management) have a difference of opinion 17 P a g e

18 Text of Proposed Revision (Additions appear in boldface italic, and deletions are stricken.) Subordination of Judgment by a Member APPENDIX 1 Exhibit B Rule 102 The Integrity and Objectivity rule [ET section ] prohibits a member from knowingly misrepresenting facts or subordinating his or her judgment when performing professional services for a client, an employer, or on a volunteer basis. Under this rule, iif a member and his or her supervisor or other person to whom subordination of judgment might occur (supervisor) have a disagreement or dispute difference of opinion relating to the preparation of financial statements or the recording of transactions, application of accounting principles; auditing standards; or other relevant professional standards, including standards applicable to tax and consulting services, or applicable laws or regulations, selfinterest, familiarity, and undue influence threats to the member s compliance with the Integrity and Objectivity rule may exist. the member should take the following steps to ensure that the situation does not constitute a subordination of judgment: 1 Accordingly, the member should apply appropriate safeguards so that the member does not subordinate his or her judgment when the member concludes that threats are significant. In assessing the significance of any identified threats the member should form a conclusion, after appropriate research or consultation, about whether the result of the position a. fails to comply with professional standards, when applicable; b. creates a material misrepresentation of fact; or c. may violate applicable laws or regulations. If the member concludes that the position taken is not in compliance with professional standards but does not result in a material misrepresentation of fact or a violation of applicable laws or regulations, threats would not be considered significant. However, the member should discuss his or her conclusions with the person taking the position. If the member concludes that the position results in a material misrepresentation of fact or a violation of applicable laws or regulations, threats would be considered significant. In such circumstances, the member should discuss his or her concerns with the supervisor. If the difference of opinion is still not resolved, the member should discuss his or her concerns with the appropriate higher level(s) of management within the organization (for example, the supervisor's immediate superior, senior management, the audit committee or equivalent, the board of directors, the company s owners). 1 1A member in the practice of public accounting should refer to the Statements on Auditing Standards. For example, see SAS No. 22, Planning and Supervision [AU section 311], which discusses what the auditor should do when there are differences of opinion concerning accounting and auditing standards. 18 P a g e

19 APPENDIX 1 If after discussing such concerns with the supervisor and appropriate higher level(s) of management within the organization, the member concludes that appropriate action was not taken, the member should consider, in no specific order, the following safeguards to ensure that threats to the member s compliance with the Integrity and Objectivity rule are eliminated or reduced to an acceptable level: 19 P a g e Determining whether any additional requirements exist under his or her employer s internal policies and procedures for reporting differences of opinion. Determining whether any responsibilities exist to communicate to third parties, such as regulatory authorities or the employer s (former employer s) external accountant. When dealing with the employer s external accountant, the member should at all times be cognizant of his or her obligation under Interpretation No [ET section ]. Consulting with his or her legal counsel regarding his or her responsibilities. Documenting his or her understanding of the facts, the accounting principles, auditing standards, or other relevant professional standards involved or applicable laws or regulations and the conversations and parties with whom these matters were discussed. If the member concludes that no safeguards can eliminate or reduce the threats to an acceptable level or if the member concludes that appropriate action was not taken, he or she should consider his or her continuing relationship with the organization. Nothing in this interpretation would preclude a member from resigning from the organization at any time. However, resignation may not relieve the member of his or her responsibilities in the situation, including any responsibility to disclose to third parties, such as regulatory authorities or the employer s (former employer s) external accountant. A member should apply similar safeguards, as appropriate, to other situations involving a difference of opinion so that the member does not subordinate his or her judgment. 1. The member should consider whether (a) the entry or the failure to record a transaction in the records, or (b) the financial statement presentation or the nature or omission of disclosure in the financial statements, as proposed by the supervisor, represents the use of an acceptable alternative and does not materially misrepresent the facts. If, after appropriate research or consultation, the member concludes that the matter has authoritative support and/or does not result in a material misrepresentation, the member need do nothing further. 2. If the member concludes that the financial statements or records could be materially misstated, the member should make his or her concerns known to the appropriate higher level(s) of management within the organization (for example, the supervisor s immediate superior, senior management, the audit committee or equivalent, the board of directors, the company s owners). The member should consider documenting his or her understanding of the facts, the accounting principles involved, the application of those principles to the facts, and the parties with whom these matters were discussed. 3. If, after discussing his or her concerns with the appropriate person(s) in the organization, the member concludes that appropriate action was not taken, he or she should consider

20 APPENDIX 1 his or her continuing relationship with the employer. The member also should consider any responsibility that may exist to communicate to third parties, such as regulatory authorities or the employer s (former employer s) external accountant. In this connection, the member may wish to consult with his or her legal counsel. 4. The member should at all times be cognizant of his or her obligations under interpretation [ET section ]. 20 P a g e

21 APPENDIX 1 Exhibit C Text of Proposed Revision (The Task force s recommendations are highlighted) Subordination of Judgment by a Member Rule 102 The Integrity and Objectivity rule [ET section ] prohibits a member from knowingly misrepresenting facts or subordinating his or her judgment when performing professional services for a client, an employer, or on a volunteer basis. Under this rule, iif a member and his or her supervisor or any other person to whom subordination of judgment might occur (supervisor) within the member s organization ( member s organization ) have a disagreement or dispute difference of opinion relating to the preparation of financial statements or the recording of transactions, application of accounting principles; auditing standards; or other relevant professional standards, including standards applicable to tax and consulting services, or applicable laws or regulations, self-interest, familiarity, and undue influence threats to the member s compliance with the Integrity and Objectivity rule may exist. the member should take the following steps to ensure that the situation does not constitute a subordination of judgment: 2 Accordingly, the member should apply appropriate safeguards so that the member does not subordinate his or her judgment when the member concludes that threats are significant. This interpretation does not apply to differences of opinion between a member and his or her client. In assessing the significance of any identified threats the member should form a conclusion, after appropriate research or consultation, about whether the result of the position d. fails to comply with professional standards, when applicable; e. creates a material misrepresentation of fact; or f. may violate applicable laws or regulations. If the member concludes that the position taken is not in compliance with professional standards but does not result in a material misrepresentation of fact or a violation of applicable laws or regulations, threats would not be considered significant. However, the member should discuss his or her conclusions with the person taking the position. If the member concludes that the position results in a material misrepresentation of fact or a violation of applicable laws or regulations, threats would be considered significant. In such circumstances, the member should discuss his or her concerns with the supervisor. If the difference of opinion is still not resolved, the member should discuss his or her concerns with the appropriate higher level(s) of management within the member s organization (for 2 1A member in the practice of public accounting should refer to the Statements on Auditing Standards. For example, see SAS No. 22, Planning and Supervision [AU section 311], which discusses what the auditor should do when there are differences of opinion concerning accounting and auditing standards. 21 P a g e

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