The Professional Ethics Executive Committee (PEEC) is seeking comment on an exposure draft related to simultaneous employment.
Comments are due March 16, 2025, and can be sent to ethics-exposuredraft@aicpa.org.
PEEC is asking for input on the following questions and welcomes any other comments AICPA members and interested parties may wish to provide:
Do you agree that covered members should be prohibited from being simultaneously employed or associated with an attest client? If not, please explain.
Do you agree all partners and professional employees should be restricted from holding a key position or serving in a governance role at an attest client? If not, please explain.
Do you agree with the new definition of simultaneously employed or associated? If not, please explain your rationale and suggest possible adjustments.
Do you agree that a partner or professional employee of a firm should report to the appropriate person at the firm the intention to accept an offer to become simultaneously employed or associated with an attest client?
Paragraph .03 of the proposed interpretation provides for an inadvertent breach related to the reporting requirement. Do you agree with this inclusion?
Paragraph .04 of the proposed interpretation provides examples of how an individual might assess facts and circumstances when evaluating threats. Do you find these examples helpful? Are there any you would suggest be added or deleted?
Paragraphs .04–.06 of the proposed interpretation outline factors to consider when assessing threats and potential safeguards. Are these factors appropriate? Are there any factors to consider that are not addressed?
Do you believe that the conceptual framework can appropriately address the threats created by a partner or professional employee (who is not also simultaneously employed or associated with the attest client in a key position) carrying out activities considered to be management responsibilities as described in the “Management Responsibilities” interpretation (ET sec. 1.295.030)? If not, please explain.
Do you believe the adoption of the proposed interpretation would create inconsistency with the “Staff Augmentation Arrangements” interpretation (ET sec. 1.295.007)? If so, please explain.
Do you agree with the proposed guidance for independent contractors? If not, please explain.
PEEC initially charged the task force with determining whether an exception should exist for individuals employed by the armed services. The proposed interpretation extends this exception to include conflicts with other relevant employment laws or regulations at the federal, state, and local levels. Do you agree that the exceptions presented in the exposure draft are appropriate? If not, please explain.
Are there any issues unaddressed by the proposed definition and interpretation that should be addressed?