Engagement Letters Required
Under the matrix of Federal and state regulations applicable to the accounting profession, accountants are now confronted with making material adjustments in the ways they conduct their business. Non-attest services generate significant revenues for accountants, but they also raise significant potential professional risks. While Interpretation 101-3 under the AICPA Code of Professional Conduct, by its terms, applies only to the provision of non-attest services for attest clients, its substantive provisions will most likely be considered a "best practice" for all accountants who provide non-attest services for any client.
The performance of non-attest services for an SEC audit client of an accounting firm is strictly limited by Federal securities laws. Item 2-01(c) of Regulation S-X lists the non-attest services which, if performed for an issuer by the issuer’s audit firm, will impair the audit firm’s independence under the securities laws. Furthermore,