September 16, 2014, letter commenting on the AICPA Professional Ethics Division's June 2014 Exposure Draft, "Breach of an Independence Interpretation, Proposed Interpretation of the AICPA Professional Ethics Division"
This letter provides the U.S. Government Accountability Office's comments on the Breach of an Independence Interpretation exposure draft prepared by the American Institute of Certified Public Accountants' Professional Ethics Executive Committee (PEEC). GAO shares the PEEC's view that the public interest is not served if a firm is forced to resign from an engagement because of a breach of an independence interpretation if the consequences of the breach are such that they do not affect the attest engagement team's integrity, objectivity, and professional skepticism. As noted below, GAO is suggesting that the PEEC consider expanding the applicability of the specific steps to be taken in response to identification of a breach of an independence requirement to other breaches of the code. GAO is also suggesting that the PEEC consider adding guidance on attributes that would be desirable or necessary in a "responsible individual."