PEEC addresses ‘Records Requests,’ limits on loaning staff to attest clients

By Shannon Ziemba, CPA, CGMA, and Ken Tysiac

The AICPA Professional Ethics Executive Committee (PEEC) issued two new interpretations Wednesday — one related to clients’ records requests and another limiting firms’ ability to loan staff to attest clients.

The responsibilities of AICPA members when responding to client requests for client-provided records are clarified under the amended “Records Requests” interpretation (ET §1.400.200) approved by PEEC. Meanwhile, the “Staff Augmentation Arrangements” interpretation (ET §1.275.007) prohibits CPA firms from loaning staff to an attest client except in very limited circumstances.

‘Records Requests’ interpretation

PEEC clarified that withholding client-provided records is not permitted when responding to a client’s initial request for the records and that a member is permitted to charge for the copying, retrieval, and shipping of these records. However, a member may not withhold client-provided records when responding to an initial request for such records because they are awaiting payment of these fees. If these records were previously made available to the client, then the member may wait until payment is received.

The revised interpretation clarifies that making member-prepared records or work products available to a client (for example, available to be picked up or available in a portal) would satisfy the member’s ethical responsibility under the “Records Requests” interpretation. However, if the client says they cannot access the records or work product, then in order to satisfy the ethical responsibility, the member would need to work with the client to make the records available in a format that the client deems usable and accessible.

When the beneficiary of the member’s professional services is not the engaging entity, the revised interpretation clarifies that, in addition to making the member’s work products available, the member must also respond to requests from the beneficiary for member-prepared records.

The “Records Requests” interpretation will take effect July 31, 2021.

‘Staff Augmentation Arrangements’ interpretation

A staff augmentation arrangement occurs when a CPA firm loans an employee to an attest client and the attest client is responsible for the direction and supervision of their activities.

The “Staff Augmentation” interpretation approved Tuesday states that a staff augmentation arrangement with an attest client would impair independence unless all the following safeguards are in place:

  • The staff augmentation arrangement is being performed due to an unexpected situation that would create a significant hardship for the attest client to make other arrangements.
  • The augmented staff arrangement is not expected to reoccur.
  • The augmented staff arrangement is performed only for a short period. There is a rebuttable presumption that a short period would not exceed 30 days.
  • The augmented staff neither participates in, nor is in a position to influence, an attest engagement covering any period that includes the staff augmentation arrangement.
  • The augmented staff performs only activities that would not be prohibited by the “Nonattest Services” subtopic (ET §1.295) of the “Independence Rule” (ET §1.200.001).
  • The member is satisfied that client management designates an individual or individuals who possess suitable skill, knowledge, and/or experience, preferably within senior management, to be responsible for:
    • Determining the nature and scope of the activities to be provided by the augmented staff;
    • Supervising and overseeing the activities performed by the augmented staff; and
    • Evaluating the adequacy of the activities performed by the augmented staff and the findings resulting from the activities.

PEEC also approved revisions to the “Client Affiliates” interpretation allowing staff augmentation arrangements with certain affiliates, and to “Agreed-Upon Procedures Engagements Performed in Accordance With SSAEs,” permitting staff augmentation arrangements as long as the services provided do not relate to the specific subject matter of the agreed-upon procedures engagement.

The “Staff Augmentation” interpretation will take effect Nov. 30, 2021.

Shannon Ziemba, CPA, CGMA, is a manager on the AICPA Professional Ethics team. Ken Tysiac ( is the JofA’s editorial director.

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