DOCSLIB.ORG

Independence and Objectivity

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Independence and Objectivity IPPF – Practice Guide INDEPENDENCE AND OBJECTIVITY OCTOBER 2011 IPPF – Practice Guide Independence and Objectivity Table of Contents Executive Summary ....................................................................................... 1 Introduction .................................................................................................. 2 Guidance on Independence and Objectivity ................................................... 3 Relationship of Independence and Objectivity ............................................... 3 Independence ................................................................................................ 4 Objectivity ..................................................................................................... 7 Considerations for Assurance and Consulting Engagements ....................... 10 Considerations for Rotational Audit Assignments ........................................ 11 Frameworks for Evaluating Independence and Objectivity ........................... 12 Author, Contributors and Reviewers ............................................................ 18 Appendix .................................................................................................... 19 www.theiia.org/guidance / B IPPF – Practice Guide Independence and Objectivity designed to add value and improve an organization’s op- Executive Summary erations.” Objectivity is also one of the four key principles of The IIA’s Code of Ethics (Code), which defines the The importance of independence and objectivity, which rules of conduct that support these principles. The Code has always been significant for internal auditors, con- applies both to organizations and individuals that perform tinues to increase among the challenges facing internal internal audit services. Standards 1100 – Independence audit activities in the constantly changing business envi- and Objectivity; 1110 – Organizational Independence; ronment. An ever-growing number of stakeholders, both 1120 – Individual Objectivity; and 1130 – Impairment to inside and outside an organization, continue to demand Independence or Objectivity outline the specific require- greater transparency, increased disclosures, expanded in- ments for the internal audit activity and internal audit pro- ternal audit services, increased professionalism, improved fessionals. All internal audit practitioners should periodi- coordination among internal and external auditors, greater cally refresh their understanding of this guidance. responsibilities, and more accountability from internal au- dit professionals. This practice guide was developed to ad- This practice guide highlights the IPPF International dress these changes and increased expectations. Standards for the Professional Practice of Internal Audit- ing (Standards) related to independence and objectivity, There are many assurance providers within the organiza- as well as The IIA’s supporting practice advisories. This tion, such as frontline managers and executives, quality guide also acknowledges the confusion that is often pres- assurance staff, health and safety staff, compliance and ent when people use the terms independence and objec- risk management staff. Internal audit is distinguished tivity interchangeably. While independence and objectiv- from many other internal assurance providers by virtue of ity are related, they are distinctly different attributes and a requirement to comply with professional standards and require specific actions and safeguards to ensure auditors a code of ethics that demand independence and objectiv- are both independent and objective. ity. Further, objectivity is a key determinant for whether external auditors can place reliance on work performed by This guide also highlights activities supporting both in- internal audit. As specified in The International Standard dependence and objectivity and discusses various factors on Auditing (ISA) 610 – Using the Work of Internal Audi- that can affect an auditor’s independence and objectivity. tors, issued by The International Auditing and Assurance Combinations of threats, unresolved threats, and consid- Standards Board (IAASB) of the International Federation erations for both assurance and consulting services also of Accountants (IFAC), to determine potential areas of are discussed. reliance, first and foremost, the external auditors have to evaluate the internal audit activity’s degree of objectivity, its Frameworks for evaluating and managing independence level of competence, and the extent to which judgment is and objectivity are presented as models that internal au- involved in planning, performing, and evaluating that work. ditors can use to help ensure that independence and ob- jectivity are promoted and fostered in their own organiza- Independence and objectivity are integral parts of the tions. mandatory guidance of The Institute of Internal Audi- tors’ (IIA) International Professional Practices Framework Key sections that provide further information relating to (IPPF). The use of these terms starts with the definition of considerations about independence and objectivity in- internal auditing, which states that “Internal auditing is an clude: independent, objective assurance and consulting activity www.theiia.org/guidance / 1 IPPF – Practice Guide Independence and Objectivity • Definitions of independence and objectivity, as well es and otherwise changing the internal audit model. This, as related guidance included in the IPPF. in turn, creates additional challenges in managing both • Factors impacting independence, such as the orga- independence and objectivity. nizational reporting relationship of the internal audit activity, access to information, control over the scope Management employs internal auditors, yet these same of internal audit activities and content of audit com- internal auditors review the performance of management munications, and the oversight and involvement of and other activities within the organization. In addition, governing bodies. management often relies on internal auditors for consult- ing services and incorporates audit recommendations into • Activities supporting independence, such as organi- the reengineering of business processes. In their role as zational placement, strong governance environment, assurance providers, auditors evaluate management’s hiring practices (including outsourcing, as neces- processes. The combination of the internal auditor as an sary), and a strong audit charter. employee of the organization, the increasing importance • Factors threatening objectivity, such as social pres- of internal audit activities, and the growing demand for sure, economic interests, personal relationships, internal audit consulting activities lead to escalating con- familiarity, cultural and other biases, self-review, and cern about internal auditor independence and objectivity. intimidation and advocacy threats. As internal auditors expand their role in governance and • Managing threats to objectivity through the use of risk management activities, additional challenges are pre- incentives, teams, rotational assignments, training, sented for managing independence and objectivity. The supervision and review, quality assessments, hiring IIA’s Position Paper on the Role of Internal Auditing in practices, and outsourcing. Enterprisewide Risk Management provides an excellent example of the expanded roles for internal audit as well • Unresolved challenges to objectivity and consider- as safeguards needed to address any threats to internal ations for assurance and consulting engagements. audit’s independence and objectivity. • A process for managing threats to independence and objectivity and frameworks for evaluating indepen- As both private and public organizations around the world dence and objectivity at the individual, engagement, grow in size and influence, society is demanding greater activity, organization, and professional levels. accountability. This drive for accountability has led to an increased focus on audit activities as a cornerstone of governance systems and, in some parts of the world, has Introduction resulted in calls for mandating an internal audit activity. The purpose of this practice guide is to: In the midst of a global drive to improve corporate gov- ernance, internal auditors face many challenges and op- • Highlight IIA guidance on independence and objec- portunities, including increasingly complex and perva- tivity. sive use of technology, a need for new and ever-changing skills, flattening organizational structures, demand for an • Discuss potentially confusing aspects encompassing expanding scope of services, and increasing competition independence and objectivity. and globalization. Internal auditors are developing new • Identify activities that support independence and strategies to meet these challenges, and are becoming objectivity. more proactive by providing a broadened variety of servic- www.theiia.org/guidance / 2 IPPF – Practice Guide Independence and Objectivity • Identify various considerations and potential chal- Examples of functional reporting to the board involve the lenges related to independence and objectivity. board: • Provide frameworks for managing independence and • Approving the internal audit charter; objectivity. • Approving the risk-based internal audit plan; • Receiving communications from the chief audit execu- tive on the internal audit activity’s performance relative Guidance on Independence to its plan and other matters; • Approving
Load more

Recommended publications
  • Audit Committees and Auditor Independence Brochure
    relationships with the company, its officers, directors or significant Change of Independent Auditors shareholders. Thus, audit committees should consider whether the company The auditor generally must be independent for has implemented processes that identify the entire engagement period and the period such prohibited relationships. covered by the financial statements being audited. Once this relationship is terminated, z Certain Financial Relationships. Audit there is no continuing requirement for the auditor committees should be aware that certain to remain independent. The auditor may financial relationships between the generally re-issue its former opinions on the company and the independent auditor company’s financial statements. However, if a are prohibited. These include creditor/ restatement of the financial statements becomes debtor relationships, banking, broker- necessary, the auditor must be independent to dealer, futures commission merchant audit the restatement adjustments and re-issue its accounts, insurance products and opinion. Further, if the Board is contemplating or interests in investment companies. plans a change in auditors, the audit committee Communications Between the Audit must consider whether the prospective firm will be independent during the audit engagement period. Committee and the Independent Auditor That is, the prospective firm must cease all Independence Standards Board Standard No. 1 prohibited services and/or sever all prohibited AUDIT COMMITTEES AND requires that the auditor disclose to the audit relationships with the issuer prior to the beginning AUDITOR INDEPENDENCE committee in writing all relationships between of the audit engagement period. Therefore, the the audit firm and the company that may audit committee should consider these issues reasonably be thought to bear on the audit firm’s before hiring a predecessor auditor or a independence.
    [Show full text]
  • Supervisory Insights
    Supervisory Insights Devoted to Advancing the Practice of Bank Supervision Vol. 3, Issue 2 Winter 2006 Inside Incident Response Programs Unfair or Deceptive Acts or Practices Understanding BSA Violations Commercial Real Estate Underwriting Practices Auditor Independence Supervisory Insights Supervisory Insights is published by the Division of Supervision and Consumer Protection of the Federal Deposit Insurance Corporation to promote sound principles and best practices for bank supervision. Sheila C. Bair Chairman, FDIC Sandra L. Thompson Director, Division of Supervision and Consumer Protection Journal Executive Board George French, Deputy Director and Executive Editor Christopher J. Spoth, Senior Deputy Director John M. Lane, Deputy Director Robert W. Mooney, Acting Deputy Director William A. Stark, Deputy Director John F. Carter, Regional Director Doreen Eberley, Acting Regional Director Stan R. Ivie, Regional Director James D. LaPierre, Regional Director Sylvia H. Plunkett, Regional Director Mark S. Schmidt, Regional Director Journal Staff Bobbie Jean Norris Managing Editor Christy C. Jacobs Financial Writer Eloy A. Villafranca Financial Writer Supervisory Insights is available online by visiting the FDIC’s website at www.fdic.gov. To provide comments or suggestions for future articles, to request permission to reprint individual articles, or to request print copies, send an e-mail to [email protected]. The views expressed in Supervisory Insights are those of the authors and do not necessarily reflect official positions of the Federal Deposit Insurance Corporation. In particular, articles should not be construed as defini- tive regulatory or supervisory guidance. Some of the information used in the preparation of this publication was obtained from publicly available sources that are considered reliable.
    [Show full text]
  • Factors Affecting Internal Audit Independence: a Case Study of Technical University of Mombasa
    View metadata, citation and similar papers at core.ac.uk brought to you by CORE provided by International Institute for Science, Technology and Education (IISTE): E-Journals European Journal of Business and Management www.iiste.org ISSN 2222-1905 (Paper) ISSN 2222-2839 (Online) Vol.6, No.6, 2014 Factors Affecting Internal Audit Independence: A Case Study of Technical University of Mombasa Thuweba Ndunge Kimotho Department of Commerce and Economics, School of Human Resources Development, Jomo Kenyatta University of Agriculture and Technology, P.O Box 81310, Code 80100, Mombasa E-mail: [email protected] Abstract The main objective of the study was to establish the factors affecting internal audit independence at the Technical University of Mombasa and the various variables that compromised it. Literature review has been conducted on the various independent variables that affect the dependent variable. A descriptive technique was used as the research design. The sampling procedure that was used is stratified sampling technique. Primary data was collected by use of self-administered questionnaire and it was purely quantitative. Data collected was analyzed with the aid of Statistical Package for Social Scientist (SPSS) and the findings of the study has been presented in pie charts, bar graphs, diagrams and figures. Tables were used to summarize responses for further analysis and facilitate comparison. The study concluded that internal audit independence is crucial to the institution to help to enhance accountability and performance the institution by its employees. Keywords: Accountability, Audit, Independence, Governance. 1.0 Background Information and purpose Independence has been described as “avoidance of situations which would tend to impair objectivity or permit personal bias to influence delicate judgment” (Carey et al., 1966).
    [Show full text]
  • Recent Auditor Independence Cases Suggest SEC's 'Operation Broken Gate'
    Securities Regulation & Law Report™ Reproduced with permission from Securities Regulation & Law Report, 46 SRLR 2415, 12/22/2014. Copyright ஽ 2014 by The Bureau of National Affairs, Inc. (800-372-1033) http://www.bna.com ENFORCEMENT Recent Auditor Independence Cases Suggest SEC’s ‘‘Operation Broken Gate’’ Is in Full Swing same time, the Director of the Enforcement Division previewed a renewed ‘‘focus on auditors’’ and, in par- ticular, independence violations.3 And in February, the SEC’s then-Chief Accountant also emphasized that au- ditor independence was a particular concern for the SEC staff.4 The last 18 months of enforcement activity demon- strate that the SEC was not bluffing. As set forth below, the SEC has recently filed multiple auditor indepen- dence cases and released a detailed report with warn- ings for firms that loan staff to their audit clients. Ac- counting firms should note the enforcement activity. BY MATTHEW P. BOSHER s the glut of financial crisis cases approaches the A. Overview of the SEC’s Auditor end of the pipeline, the SEC and other regulators Independence Rules A have inevitably shifted their attention to different targets. At least one of those new targets is an old one: 1 First, a quick refresher on the SEC’s independence accounting firms. rules. Rule 2-01 of Regulation S-X requires auditors to In October 2013, SEC Chair Mary Jo White an- be independent of their SEC audit clients, both in ap- nounced the launch of ‘‘Operation Broken Gate’’—‘‘an initiative to identify auditors who neglect their duties 3 and the required auditing standards.’’2 Around the Ceresny speech, see note 1, supra.
    [Show full text]
  • AUDITOR INDEPENDENCE in TIMES of CRISIS COVID-19’S Impact on Internal Audit’S Roles and Responsibilities
    GLOBAL ADVOCACY AUDITOR INDEPENDENCE IN TIMES OF CRISIS COVID-19’s impact on internal audit’s roles and responsibilities Table of Contents Introduction ................................................................................................................................................... 3 Independence: Shield or barrier? ....................................................................................................... 3 The three roles of governance ..................................................................................................................... 4 Independence through the governance prism ................................................................................... 4 Objectivity ............................................................................................................................................. 4 Understanding advisory services ................................................................................................................ 5 Insights, advice enhance internal audit’s value ................................................................................ 5 Going beyond assurance, advice ................................................................................................................ 6 Pandemic thrusts internal audit into unfamiliar roles ....................................................................... 6 Conclusion ...................................................................................................................................................
    [Show full text]
  • Auditor Independence Education Materials: the Importance of Being Independent
    Independence Auditor independence education materials: The importance of being independent Video discussion questions: Section III — Independence at work Developed in conjunction with the University of Illinois Center for Professional Responsibility in Business and Society. Video discussion questions Section III — Independence at work Section III focuses on personal independence, application of independence rules, and the five primary areas of independence. V3.1) Certain “personal” independence rules (such as prohibitions on stock ownership in an audit client) apply to a professional’s close family members. State why you believe this is so. V3.2) All professionals in public accounting firms, whether they provide audit, tax, or consulting services, should comply with the accounting firm’s independence policies and applicable independence rules. Why do you think this is? V3.3) In which situations might a firm’s independence be affected by the type of nonaudit services provided to an audit client? V3.4) Do you consider any of the “five areas of independence,” described in the Video, a greater threat to independence than any of the other areas? V3.5) Your audit client, Ben’s Auto Dealership, offers you and other members of your firm a deep discount on vehicles remaining on their lot at year­end. These discounts are not available to anyone else. Fresh out of college, your car is old and unreliable and you are tempted to purchase one of these cars. Personally, you do not believe purchasing the car would have any affect on your objectivity. If you take the discount, have you compromised your independence? Why or why not? V3.6) An audit client of Lindsay & Lee, CPA’s wants the firm to perform tax services but insists that the services be billed only if the client receives certain tax benefits as a result of the firm’s services (i.e., a “contingent fee”).
    [Show full text]
  • Indepedence Standard Board Standard No. 3, Employment With
    Important Note: The Securities and Exchange Commission recently released a comprehensive revision to its auditor independence requirements (the Revision). The Revision contains provisions covering settlement of capital and retirement interests when former firm professionals join firm audit clients, which supercede the requirements described in paragraph 2.b.iv of this standard. Consequently, at the next ISB meeting, the ISB staff will recommend that the Board delete paragraph 2.b.iv of this standard. All other provisions of this standard remain in effect. The Revision can be found at the SEC’s website at www.sec.gov. Independence Standard No. 3 Employment with Audit Clients July 2000 Independence Standards Board Standard No. 3 Employment with Audit Clients July 2000 SUMMARY This standard describes safeguards that firms should implement when their professionals join firm audit clients. These safeguards are designed to assist in ensuring that: professionals who are broadly evaluating their career options will exercise an appropriate level of skepticism while performing audits prior to their departure from the firm; a former firm professional now employed by the client cannot circumvent the audit because of familiarity with its design, approach, or testing strategy; and the remaining members of the audit team maintain objectivity when evaluating the work and representations of a former firm professional now employed by the audit client. The procedures should be adapted depending on several factors, including whether the professional served as a member of the audit team, the positions he or she held at the firm and has accepted at the client, the length of time that has elapsed since the professional left the firm, and the circumstances of his or her departure.
    [Show full text]
  • PCAOB February 2006 SAG Meeting Briefing Paper
    1666 K Street, NW Washington, D.C. 20006 Telephone: (202) 207-9100 Facsimile: (202) 862-8430 www.pcaobus.org STANDING ADVISORY GROUP MEETING EMERGING ISSUE – THE EFFECTS ON INDEPENDENCE OF INDEMNIFICATION, LIMITATION OF LIABILITY, AND OTHER LITIGATION-RELATED CLAUSES IN AUDIT ENGAGEMENT LETTERS FEBRUARY 9, 2006 Introduction The Standing Advisory Group ("SAG") will discuss the possible effects of the inclusion of indemnification, limitation of liability, and other litigation-related clauses (collectively referred to as "litigation-related clauses") in audit engagement letters. The discussion will focus on how these clauses relate to the independence and objectivity of the auditor. This briefing paper provides background information about the existing independence guidance, new proposals currently under consideration by other standards-setting bodies, and the types of litigation-related clauses that currently are used. Background Audit engagement letters sometimes include provisions that seek to manage the external auditor's liability risk in an audit in various ways, including, in some cases, express limitations on liability. As used in this paper, an indemnification clause is an agreement in which the audit client agrees to compensate the auditor for any losses resulting from litigation arising out of the engagement, including losses to third parties such as investors. Other limitations on liability may protect the auditor only from liability to the audit client, or only against certain kinds of damages. For example, an engagement letter might cap the auditor's liability to the client at the amount of audit fees that the client paid. Such a provision would not limit any exposure that the auditor This paper was developed by the staff of the Office of the Chief Auditor to foster discussion among the members of the Standing Advisory Group.
    [Show full text]
  • Public Sector Audit Activities Must Configured Appropriately to Enable Public Sector Entities to Fulfill Their Duty to Be Accoun
    The International Standards of Supreme Audit Institutions, ISSAIs, are issued by the International Organization of Supreme Audit Institutions, INTOSAI GOV 9140 INTOSAI. For more information visit www.issai.org I N T O S A I Internal Audit Independence in the Public Sector INTOSAI Professional Standards Committee PSC-Secretariat Rigsrevisionen • Landgreven 4 • P.O. Box 9009 • 1022 Copenhagen K • Denmark Tel.:+45 3392 8400 • Fax:+45 3311 0415 •E-mail: [email protected] I N T O S A I EXPERIENTIA MUTUA EXPERIENTIA MUTUA OMNIBUS PRODEST OMNIBUS PRODEST INTOSAI General Secretariat - RECHNUNGSHOF (Austrian Court of Audit) DAMPFSCHIFFSTRASSE 2 A-1033 VIENNA AUSTRIA Tel.: ++43 (1) 711 71 • Fax: ++43 (1) 718 09 69 E-MAIL: [email protected]; WORLD WIDE WEB: http://www.intosai.org 1. INTRODUCTION 1.1 This paper on internal audit independence in the public sector addresses concerns related to independence and objectivity and methods to achieve independence. 1.2 Internal auditing is performed in diverse environments and within organizations that vary in purpose, size, and structure. In addition, the laws and regulations within various countries differ from one another. Particularly, public sector auditors operate in organizational structures that are as complex and varied as the many forms of government that exist throughout the world today. 1.3 The International Standards of Supreme Audit Institutions (ISSAI) and the Institute of Internal Auditors’ (the IIA’s) International Standards for the Professional Practice of Internal Auditing (Standards), present general terms to allow adoption in different national contexts with the understanding that implementation will be governed by the environment in which the internal audit activity carries out their responsibilities and in accordance with the applicable laws and regulations.
    [Show full text]
  • Auditor Independence Rules.Indd
    Securities Law and Tax Advisory December 6, 2002 SEC Proposes Auditor Independence Rules As directed by Section 208(a) of the Sarbanes-Oxley Act of 2002 (the Act),1 on December 2, 2002, the SEC released proposed amendments to its existing requirements regarding auditor independence to enhance the independence of accountants that audit and review financial statements and prepare attestation reports filed with the SEC.2 The proposed rules enable the provisions of the Act regarding the independence of accountants based on four guiding principles: an audit firm should not audit its own work, serve as a part of management, act as an advocate of the audit client, or be a promoter of the issuer’s stock or other financial interests. The proposed rules also recognize the critical role played by audit committees in the financial reporting process and in assuring auditor independence. Summary of Key Provisions Key provisions of the proposed rules include: Services Affected • In defining the various services that are prohibited if provided by an audit firm to its public client, the regulations are to be interpreted in a manner consistent with the guiding principles that the accounting firm should not advocate for the client, function as an employee/manager of the client, audit its own work, or be a promoter the issuer’s stock or financial interests. • Valuation services where there is a reasonable likelihood that the results will be subject to audit pro- cedures are banned; non-financial reporting valuation services such as transfer pricing services are not covered by this prohibition. 1 Section 208(a) of the Act provides, in relevant part, that: Not later than 180 days after the date of enactment of this Act, the Commission shall issue final regulations to carry out each of subsections (g) through (l) of section 10A of the Securities Exchange Act of 1934, as added by this title.
    [Show full text]
  • Interagency Advisory on the Unsafe and Unsound Use of Limitation of Liability Provisions in External Audit Engagement Letters
    INTERAGENCY ADVISORY ON THE UNSAFE AND UNSOUND USE OF LIMITATION OF LIABILITY PROVISIONS IN EXTERNAL AUDIT ENGAGEMENT LETTERS PURPOSE This Advisory, issued jointly by the Office of Thrift Supervision (OTS), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC) (collectively, the "Agencies"), alerts financial institutions'[See Footnote1] boards of directors, audit committees, management, and external auditors to the safety and soundness implications of provisions that limit external auditors' liability in audit engagements. Limits on external auditors' liability may weaken the external auditors' objectivity, impartiality, and performance and, thus, reduce the Agencies' ability to rely on Audits. Therefore, certain limitation of liability provisions (described in this Advisory and Appendix A) are unsafe and unsound. In addition, such provisions may not be consistent with the auditor independence standards of the U.S. Securities and Exchange Commission (SEC), the Public Company Accounting Oversight Board (PCAOB), and the American Institute of Certified Public Accountants (AICPA). SCOPE This Advisory applies to engagement letters between financial institutions and external auditors with respect to financial statement audits, audits of internal control over financial reporting, and attestations on management's assessment of internal control over financial reporting (collectively, "Audit" or "Audits"). This Advisory does not apply to: • Non-Audit services that may be performed by financial institutions' external auditors; • Audits of financial institutions' 401K plans, pension plans, and other similar audits; • Services performed by accountants who are not engaged to perform financial institutions' Audits (e.g., outsourced internal audits, loan reviews); and • Other service providers (e.g., software consultants, legal advisors).
    [Show full text]
  • Auditor Independence with Respect to Certain Loans Or Debtor-Creditor Relationships
    Conformed to Federal Register version SECURITIES AND EXCHANGE COMMISSION 17 CFR Part 210 Release No. 33-10648; 34-86127; FR-85; IA-5255; IC-33511; File No. S7-10-18 RIN 3235-AM01 Auditor Independence With Respect to Certain Loans or Debtor-Creditor Relationships AGENCY: Securities and Exchange Commission. ACTION: Final rule. SUMMARY: The Securities and Exchange Commission (“Commission”) is adopting amendments to its auditor independence rules to refocus the analysis that must be conducted to determine whether an auditor is independent when the auditor has a lending relationship with certain shareholders of an audit client at any time during an audit or professional engagement period. The amendments focus the analysis on beneficial ownership rather than on both record and beneficial ownership; replace the existing 10 percent bright-line shareholder ownership test with a “significant influence” test; add a “known through reasonable inquiry” standard with respect to identifying beneficial owners of the audit client’s equity securities; and exclude from the definition of “audit client,” for a fund under audit, any other funds, that otherwise would be considered affiliates of the audit client under the rules for certain lending relationships. The amendments will more effectively identify debtor-creditor relationships that could impair an auditor’s objectivity and impartiality, as opposed to certain more attenuated relationships that are unlikely to pose such threats, and thus will focus the analysis on those borrowing relationships that are important to investors. DATES: The final rules are effective on October 3, 2019. FOR FURTHER INFORMATION CONTACT: Peggy Kim, Senior Special Counsel, Office of the Chief Accountant, or Giles T.
    [Show full text]