AICPA Committee Issues Revised Exposure Draft on Independence Requirements for Governments

February 5, 2019

The Professional Ethics Executive Committee of the American Institute of Certified Public Accountants (“AICPA”) has issued a revised exposure draft on the independence requirements for state and local governments.

Published as  Proposed Interpretation: State and Local Government Client Affiliations (formerly Entities Included in State and Local Government Financial Statements), the exposure draft features significant changes to the original July 2017 proposal, which aims to replace current interpretive guidance in “Entities Included in State and Local Government Financial Statements.” The AICPA is proposing the amendments to address concerns regarding an accountant’s independence on a financial statement attest client that is a state or local government entity.

Since existing interpretation does not specify when accountants should review the “Conceptual Framework for Independence” when maintaining relationships with entities outside of those stated in the interpretation, the initial proposal featured language to outline the provisions to assess the relationships via the conceptual framework. However, feedback on the first exposure draft indicated complying with the new requirement for certain upstream entities proved more expensive than beneficial.

In response, the new exposure draft substitutes the requirement with examples of relationships or situations that members could have with upstream entities (and other entities deemed “nonaffiliates”) that may result in consulting the “Conceptual Framework for Independence.”

Comments on the updated exposure draft are due Monday, March 11.