This would increase competition and allow other APS structures to compete in the audit arena. If we opt for the niche approach, then the limitations on non-attest services should be evaluated so that firms that opt to make auditing their prime functions have sufficient other service capabilities to continue to attract the best and the brightest. Further evaluation and explanation is required. Financial Relationships - ISB should complete its work. I object to percentage limitations.
Percentages are too hard to monitor both by the CPA firms and by regulators.
I favor giving the regulators the ability to judge when minor violations are inadvertent or represent a pattern of abuse. If that is the concept that is finally accepted, then I support the changes. If the niche approach were embraced, I would favor the historic restrictive regulations. Exceptions - I oppose the more liberal rules on audits of inheritance and gifts and new audit engagements. I believe that there is a potential infringement on the appearance of Independence even if the CPA is independent in fact.