Comments on proposal to revise AICPA interpretation

On September 30, Grant Thornton issued a comment letter in response to the AICPA Professional Ethics Executive Committee’s (PEEC’s) May 2020 Exposure Draft proposing a revised interpretation of the AICPA Code of Professional Conduct.

Grant Thornton supports PEEC’s proposed revisions to help AICPA members better understand their ethical responsibilities related to requests for records and other information created during a professional engagement. We agree that the proposed revisions to the extant interpretation updates the rules to clarify when withholding records is permitted if the client does not pay the member for the time and expense to retrieve and copy the client-provided records. Additionally, we agree with PEEC’s proposal to allow members to (a) charge for shipping fees since these fees reflect an additional cost incurred when providing records to clients, and (b) make information available for the client to either pick up or access via a portal to satisfy the ethical requirement.

Grant Thornton suggests that PEEC consider developing nonauthoritative guidance, in the form of frequently asked questions (FAQs), to highlight various scenarios and examples where withholding client-provided records is permitted or prohibited under the revised interpretation.

Download our comment letter to read our complete comments.