The AICPA’s Professional Ethics Executive Committee (PEEC) has issued the Exposure Draft, Proposed Revised Interpretation: Records Requests. The comment deadline is September 30, 2020.
The Exposure Draft proposes amendments to the “Records Requests” interpretation under the “Acts Discreditable Rule.” As noted in the PEEC’s explanation of the proposed revisions, the purpose of the amendments is to “help members better understand their ethical responsibilities with respect to requests for records.”
The current interpretation provides that members must return records in their custody or control to clients upon request, with an exception if the client fails to pay the member for the time and expense of retrieving and copying the records.
If adopted as proposed, the amendments would provide that when a client requests client-provided records, the member must return records in their custody or control, regardless of nonpayment of fees. Further, although a member “may charge the client a reasonable fee for the time and expense incurred to retrieve, copy, and ship such records, the client-provided records may not be withheld or delayed due to non-payment of such fees.” Also, the member would be required to make available to the client member-prepared records relating to completed and issued work product, except for certain circumstances under which the work products may be withheld.
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