The standard wording in an independent auditors report states that the financial statements are the responsibility of the company's management. If management employs consulting services in order to assist the company with its ongoing operations, it seems to me the impact of those services migrate into the financial statements. The lending office told me that the purpose of the form was to disclose whether the lender had any ongoing relationship to service providers involved in the transaction. I believe the same congressional intent can be found when it comes to insider transactions both in banking and securities transactions.
Consulting firms become insiders to a degree in a company's operations.
Having an affiliate of an insider render an opinion on the fairness of the financial statements removes any pretense of independence in my opinion. Please continue with your pursuit of the proposed rule and re-establish the independence of outside accounting firms. I do not feel a simple disclosure of the consulting relationship would suffice. I feel an outright prohibition should be enforced in order to regard the opinion of an accounting firm as truly independent. Thank you for any consideration you may give to my comments.