Comment: PEEC’s executive or employee recruiting proposal

In our comments responding to the AICPA’s Professional Ethics Executive Committee’s (PEEC’s) proposal revising the “Executive or Employee Recruiting” interpretation (ET sec. 1.295.135) of the Independence Rule (ET sec. 1.200.001), we support the Committee’s efforts and agree that the proposed revisions would provide members with additional guidance to address potential familiarity and undue influence threats to independence when they perform executive or employee recruiting services to attest clients. Further, we believe that the additional guidance would engender the consistent application of the revised interpretation across the public practice.

We ask, however, that PEEC consider adding nonauthoritative guidance in the form of frequently asked questions (FAQs) to the proposal presenting additional factors for members to consider when evaluating certain recruiting related activities. For example, a member may need to recuse themselves from interviewing certain candidates and advising on their competency if the member has a current or prior relationship with the candidate, such as a close friend or a previous colleague, which could be covered in an FAQ.

To read our comments in full, download our comment letter.