ET Section 591 - Ethics Rulings on Other Responsibilities and Practices 


    [1.] Retention of Records

    [.001–.002] [Superseded by interpretation 501-1.]

    [2.] Fees: Collection of Notes Issued in Payment

    [.003–.004] [Deleted August 2011, effective November 30, 2011] 

    3. Employment by Non-CPA Firm

    .005 Question—A member is considering employment with a public accounting firm made up of one or more non-CPA practitioners. If he or she is employed by such a firm, what are his or her responsibilities under the Rules of Conduct?

    .006 Answer—A member so employed must comply with all the Rules of Conduct. If he or she becomes a partner in such a firm, he or she will then in addition be held responsible for compliance with the Rules of Conduct by all persons associated with him or her.

    [4.] Association Employee

    [.007–.008] [Deleted March 1978]

    [5.] Association as an Agent

    [.009–.010] [Deleted March 1978]

    [6.] Associations, Speaking Engagements

    [.011–.012] [Deleted March 1978]

    [7.] Trading Pool

    [.013–.014] [Deleted March 1978]

    [8.] Change of Control of Client Company

    [.015–.016] [Deleted September 1981]

    [9.] Charity Solicitation by Phone

    [.017–.018] [Deleted March 1978]

    [10.] Church Bulletin

    [.019–.020] [Deleted March 1978]

    [11.] Attorney, Clients

    [.021–.022] [Deleted March 1978]

    [12.] Confirmation Requests

    [.023–.024] [Deleted March 1978]

    [13.] Confirmation Stickers

    [.025–.026] [Deleted March 1978]

    [14.] Estate Planning

    [.027–.028] [Deleted March 1978]

    [15.] Golf Outing

    [.029–.030] [Deleted March 1978]

    [16.] Letter on Behalf of Client

    [.031–.032] [Deleted March 1978]

    [17.] Letterhead for Estate Practice

    [.033–.034] [Deleted March 1978]

    [18.] Letterhead for Promotional Material

    [.035–.036] [Deleted March 1978]

    [19.] Mailings to Accountants

    [.037–.038] [Deleted March 1978]

    [20.] Trade Association Analysis

    [.039–.040] [Deleted September 1981]

    [21.] Trade Association Survey

    [.041–.042] [Deleted September 1981]

    [22.] Management Consultant

    [.043–.044] [Deleted March 1978]

    [23.] Tax Work Obtained Through Bookkeeper

    [.045–.046] [Deleted March 1978]

    [24.] Advertising on Tax Broadcast

    [.047–.048] [Deleted March 1978]

    [25.] Alumni Magazine Announcement

    [.049–.050] [Deleted March 1978]

    [26.] Brochure Showing Use of Equipment

    [.051–.052] [Deleted March 1978]

    [27.] Client Publishing Article on Member's Software Program

    [.053–.054] [Deleted March 1978]

    [28.] Business Card on Newsletter

    [.055–.056] [Deleted March 1978]

    [29.] Computer Print-Out

    [.057–.058] [Deleted March 1978]

    [30.] Charitable Contribution

    [.059–.060] [Deleted March 1978]

    [31.] Congratulatory Message

    [.061–.062] [Deleted March 1978]

    [32.] Copyright for Wheel Computer and Tax Withholding Tables

    [.063–.064] [Deleted March 1978]

    [33.] Course Instructor

    [.065–.066] [Deleted August 2011, effective November 30, 2011] 

    [34.] Course Promotional Circular

    [.067–.068] [Deleted March 1978]

    [35.] CPA-Author Credits

    [.069–.070] [Deleted March 1978]

    [36.] CPA-Author of Book Review

    [.071–.072] [Deleted March 1978]

    [37.] CPA-Authored Articles

    [.073–.074] [Deleted March 1978]

    [38.] CPA Title, Controller of Bank

    [.075 .076] [Deleted March 2013, effective May 31, 2013.] 

    [39.] CPA Title Imprinted on Checks

    [.077–.078] [Deleted March 1978]

    [40.] CPA Title in Campaign for School Board Membership

    [.079–.080] [Deleted March 1978]

    [41.] CPA Title in Lecture Ad

    [.081–.082] [Deleted March 1978]

    [42.] CPA Title in Political Endorsement

    [.083–.084] [Deleted March 1978]

    [43.] CPA Designation in Speaker's Qualifications

    [.085–.086] [Deleted March 1978]

    [44.] CPA Designation of Speaker Named in Tax Forum Ad

    [.087–.088] [Deleted March 1978]

    [45.] CPA Title on Agency Letterhead

    [.089–.090] [Superseded August 1975]

    [46.] CPA Title on Employment Agency Letterhead

    [.091–.092] [Deleted March 1978]

    [47.] Low-Income Taxpayers

    [.093–.094] [Deleted March 1978]

    [48.] CPA Title on Public Official's Match Folder

    [.095–.096] [Deleted March 1978]

    [49.] CPA Designation on Research Reports

    [.097–.098] [Deleted March 1978]

    [50.] Data Processing Program Ad in Technical Publications

    [.099–.100] [Deleted March 1978]

    [51.] Directories in Elevator

    [.101–.102] [Deleted March 1978]

    [52.] Directory, Alphabetical

    [.103–.104] [Deleted March 1978]

    [53.] Directory, Chamber of Commerce Buyer's Guide

    [.105–.106] [Deleted March 1978]

    [54.] Directory, Trade Association

    [.107–.108] [Deleted March 1978]

    [55.] Directory Listing, Bank Auditors

    [.109–.110] [Deleted March 1978]

    [56.] Directory Listing, Change in Telephone Number Announcements

    [.111–.112] [Deleted March 1978]

    [57.] Directory Listing, Fraternity

    [.113–.114] [Deleted March 1978]

    [58.] Directory Listing, "Lawyer-CPA-Tax Attorney"

    [.115–.116] [Deleted March 1978]

    [59.] Directory Listing, Membership Designation

    [.117–.118] [Deleted March 1978]

    [60.] Directory Listing, Multiple

    [.119–.120] [Deleted March 1978]

    [61.] Directory Listings

    [.121–.122] [Deleted March 1978]

    [62.] Directory Listing, Partners' Names

    [.123–.124] [Deleted March 1978]

    [63.] Directory Listing, White Pages

    [.125–.126] [Superseded February 1976]

    [64.] Directory, Trade Association

    [.127–.128] [Deleted March 1978]

    [65.] Distribution of Firm Bulletin to Publisher

    [.129–.130] [Deleted March 1978]

    [66.] Distribution of Firm Literature

    [.131–.132] [Deleted March 1978]

    [67.] Firm Publications: Annual Financial Report

    [.133–.134] [Deleted March 1978]

    [68.] Employment Ads: "Situations Wanted"

    [.135–.136] [Deleted March 1978]

    [69.] Firm Name in Staff Training Manual

    [.137–.138] [Deleted March 1978]

    [70.] CPA Title on License Plates

    [.139–.140] [Deleted March 1978]

    [71.] Firm Name on Bowling Shirts

    [.141–.142] [Deleted March 1978]

    [72.] Firm Name on Desk Calendars

    [.143–.144] [Deleted March 1978]

    [73.] Firm Name on EDP Publication

    [.145–.146] [Deleted March 1978]

    [74.] Firm Name on Tax Booklet

    [.147–.148] [Deleted September 1981]

    [75.] Greeting Cards to Clients

    [.149–.150] [Deleted March 1978]

    [76.] Letterhead

    [.151–.152] [Deleted March 1978]

    [77.] Letterhead: Academic Degrees

    [.153–.154] [Deleted March 1978]

    [78.] Letterhead: Lawyer-CPA

    [.155 .156] [Deleted March 2013, effective May 31, 2013.]

    [79.] Letterhead: Tax Specialization

    [.157–.158] [Deleted March 1978]

    [80.] Management Letter

    [.159–.160] [Deleted March 1978]

    [81.] Medicare Booklet

    [.161–.162] [Deleted March 1978]

    [.163–.164] [Deleted November 1997]

    [83.] Nonpractitioner in Sales Brochure

    [.165–.166] [Deleted March 1978]

    [84.] Paid for by Others, Member's Testimonial Letter

    [.167–.168] [Deleted March 1978]

    [85.] Paid for by Others, Member's Testimonial Letter

    [.169–.170] [Deleted March 1978]

    [86.] Paid for by Others, Name in Client Ad

    [.171–.172] [Deleted August 1989]

    [87.] Paid for by Others, Radio Program Dedication

    [.173–.174] [Deleted March 1978]

    [88.] Political Endorsement

    [.175–.176] [Deleted March 1978]

    [89.] Postage Meter Machines

    [.177–.178] [Deleted March 1978]

    [90.] Open House

    [.179–.180] [Deleted March 1978]

    [91.] Press Release on Change in Staff

    [.181–.182] [Superseded March 1975]

    [92.] Press Release on Change in Staff

    [.183–.184] [Superseded March 1975]

    [93.] Press Release on Society Chapter Meeting

    [.185–.186] [Deleted March 1978]

    [94.] Professorship Named After CPA

    [.187–.188] [Deleted March 1978]

    [95.] Qualifications as Attachment to Report

    [.189–.190] [Deleted March 1978]

    [96.] Resume for Lender's Information

    [.191–.192] [Deleted March 1978]

    [97.] Seminar Announcement

    [.193–.194] [Deleted March 1978]

    [98.] Signs on Office Premises

    [.195–.196] [Deleted March 1978]

    [99.] Signs on Office Premises

    [.197–.198] [Deleted March 1978]

    [100.] Specialization on Business Card

    [.199–.200] [Deleted March 1978]

    [101.] Specialization, Acquisitions & Mergers

    [.201–.202] [Deleted June 1982]

    [102.] Specialization: "Tax Accountant" Designation by Non-practitioner

    [.203–.204] [Deleted March 1978]

    [103.] Recruiting Ad in Employment Guide or Career Opportunity Guide

    [.205–.206] [Deleted March 1978]

    [104.] Staff Recruiting in University Publication

    [.207–.208] [Deleted March 1978]

    [105.] Announcement Card: Elected to Vice Presidency

    [.209–.210] [Deleted March 1978]

    [106.] Information Under Telephone Directory Heading

    [.211–.212] [Deleted March 1978]

    [107.] Member as Consultant for Client's Customers

    [.213–.214] [Deleted March 1978]

    [108.] Member Interviewed by the Press

    [.215–.216] [Deleted August 2011, effective November 30, 2011] 

    [109.] Compensation From Non-practitioners

    [.217–.218] [Deleted June 1991]

    [110.] Computer Service Franchise

    [.219–.220] [Deleted June 1991]

    [111.] Purchase of Bookkeeping Practice

    [.221–.222] [Deleted June 1991]

    [112.] Referral

    [.223–.224] [Deleted June 1991]

    [113.] Member's Spouse as Insurance Agent

    [.225–.226] [Deleted June 1991]

    [114.] Member's Firm Paying Employee Bonuses

    [.227–.228] [Deleted June 1991]

    [115.] Actuary

    [.229–.230] [Deleted December 1992]

    [116.] Bank Director

    [.231–.232] [Superseded June 1976]

    [117.] Consumer Credit Company Director

    [.233–.234] [Deleted August 2011, effective November 30, 2011] 

    [118.] Employment Agency

    [.235–.236] [Deleted March 1978]

    [119.] Finance Company

    [.237–.238] [Deleted March 1978]

    [120.] Insurance Broker

    [.239–.240] [Deleted March 1978]

    [121.] Insurance Salesman

    [.241–.242] [Deleted March 1978]

    [122.] Investment Advisor

    [.243–.244] [Deleted March 1978]

    [123.] Loan Broker

    [.245–.246] [Deleted March 1978]

    [124.] Mutual Fund Salesman

    [.247–.248] [Deleted March 1978]

    [125.] Private Investor in Business and Real Estate

    [.249–.250] [Deleted March 1978]

    [126.] Real Estate Broker

    [.251–.252] [Deleted March 1978]

    [127.] State Controller

    [.253–.254] [Deleted August 1989]

    [128.] State Secretary of Revenue

    [.255–.256] [Deleted March 1978]

    [129.] Travel Agency

    [.257–.258] [Deleted March 1978]

    [130.] Collection Agent

    [.259–.260] [Deleted March 1978]

    [131.] Bookkeeping Service as Feeder

    [.261–.262] [Deleted March 1978]

    [132.] Tax Practice: Conflict of Interest

    [.263–.264] [Deleted August 1989]

    [133.] Member Employed by Incorporated Law Firm

    [.265–.266] [Deleted March 1978]

    [134.] Association of Accountants Not Partners

    [.267–.268] [Deleted August 2012]

    [135.] Association of Firms Not Partners

    [.269 .270]  [Deleted April 2012].

    136. Audit with Former Partner

    .271 Question—A member's firm consisting of one certified and one noncertified partner has been dissolved. One account was retained which the two practitioners plan to continue to service together. Should the audit report be submitted on partnership stationery?

    .272 Answer—It would appear proper for the audit to be carried out jointly by the two former partners. The opinion should be presented on plain paper and signed somewhat as follows:

    John Doe, Certified Public Accountant

    Richard Roe, Accountant

    Such a signature would leave no doubt as to whether a partnership existed, and the client and others would have the assurance that both accountants participated in the audit.

    137. Nonproprietary Partners

    .273 Question—A member's firm wishes to institute the designation "nonproprietary partner" to describe certain high-ranking staff who were former partners of merged firms who did not qualify for partnership in the merging firm. With this title, they would be eligible to participate in the firm's pension plan. In holding themselves out to the public they would be required to use this designation. Is there any impropriety in the proposed title?

    .274 Answer—The use of the designation "partner" should be restricted to those members of the firm who are legally partners. Those who are not parties to the partnership agreement should not hold themselves out in any manner which might lead others to believe that they are partners. The use of the designation "nonproprietary partner" by one who is not in fact a partner is considered misleading and therefore is not permitted.

    138. Partner Having Separate Proprietorship

    .275 Question—May a member be a partner of a firm of public accountants, all other members of which are noncertified, and at the same time retain for him or herself a practice of his or her own as a CPA?

    .276 Answer—Rule 505 [ET section 505.01] would not prohibit such a practice. However, clients and others interested should be advised about the dual position of the member to prevent any misunderstanding or misrepresentation.

    [139.] Partnership with Non-CPA

    [.277-.278] [Deleted December 1998]

    [140.] Political Election

    [.279–.280] [Deleted August 2011, effective November 30, 2011] 

    141. Responsibility for Non-CPA Partner

    .281 Question—Is a member who has formed a partnership with a noncertified public accountant ethically responsible for all the acts of the partnership?

    .282 Answer—Yes. If the noncertified partner should violate the Code, the member would be held accountable.

    [142.] Retired Partners

    [.283–.284] [Deleted March 1978]

    [143.] Partnership With Non-CPA

    [.285–.286] [Deleted March 1978]

    [144.] Title: Partnership Roster

    [.287–.288] [Deleted August 2011, effective November 30, 2011] 

    145. Firm Name of Merged Partnerships

    .289 Question—When two partnerships merge, is it permissible for the newly merged firm to practice under a title which includes the name of a partner who had retired from one of the two firms prior to the merger?

    .290 Answer—Rule 505 [ET section 505.01] of the Code of Professional Conduct states that partnerships may practice under a firm title which includes the name or names of former partners. Since the retired partner was once a partner in one of the merged firms, it would be proper for his or her name to appear in the title of a newly created firm.

    [146.] Membership Designation

    [.291–.292] [Deleted September 1999]

    [147.] Firm Designation

    [.293–.294] [Deleted November 1989]

    [148.] Firm Designation

    [.295–.296] [Deleted November 1989]

    [149.] Data Processing: Accounting and Bookkeeping Assistance

    [.297–.298] [Deleted March 1978]

    [150.] Data Processing: Billing Service

    [.299–.300] [Deleted March 1978]

    [151.] Data Processing: Computer Center

    [.301–.302] [Deleted March 1978]

    [152.] Data Processing: Computer Center

    [.303–.304] [Deleted March 1978]

    [153.] Data Processing: Computer Center

    [.305–.306] [Deleted March 1978]

    [154.] Data Processing: Computer Center, Service Bureau as Client

    [.307–.308] [Deleted March 1978]

    [155.] Data Processing: Computer Corporation

    [.309–.310] [Deleted December 1992]

    [156.] Data Processing: Consultant to Service Bureaus

    [.311–.312] [Deleted December 1992]

    [157.] Data Processing: Employee Not in Practice

    [.313–.314] [Deleted March 1978]

    [158.] Operation of Separate Data Processing Business by a Public Practitioner

    [.315–.316] [Deleted December 1998]

    [159.] Data Processing: Fees Paid to Other CPAs

    [.317–.318] [Deleted June 1991]

    [160.] Data Processing: Forwarding Fees

    [.319–.320] [Deleted March 1978]

    [161.] Time-Sharing Computer Programs Developed by Member's Firm

    [.321–.322] [Deleted March 1978]

    [162.] CPA Designation on Professional Organization Letterhead

    [.323–.324] [Superseded August 1975]

    [163.] Distribution of Firm Publications to News Media

    [.325–.326] [Deleted March 1978]

    [164.] Nonclients on Firm Publication Mailing List

    [.327–.328] [Deleted March 1978]

    [165.] Sale of Firm Publications

    [.329–.330] [Deleted March 1978]

    [166.] Announcement of Member's Withdrawal from Firm

    [.331–.332] [Deleted March 1978]

    [167.] Member Receiving Payment for Referral of Client to Others

    [.333–.334] [Deleted June 1991]

    [168.] Audit Guides Issued by Governmental Agencies

    [.335–.336] [Superseded by interpretation 501-3.]

    [169.] Firm Publications, Distribution to Client's Board of Directors

    [.337–.338] [Deleted March 1978]

    [170.] Sponsor's Announcement of Member's Participation in Educational Seminar

    [.339–.340] [Deleted March 1978]

    [171.] CPA Designation on Professional Organization or Corporation Letterhead

    [.341–.342] [Deleted March 1978]

    [172.] Outside Review of Firm Publication

    [.343–.344] [Deleted March 1978]

    [173.] Use of Credit Cards for Payment of Professional Services

    [.345–.346] [Deleted March 1978]

    [174.] Directory Listing, White Pages

    [.347–.348] [Deleted March 1978]

    [175.] Bank Director

    [.349–.350] [Replaced by ruling No. 85 under rule of conduct 102 and ruling No. 18 under rule of conduct 301.]

    [176.] Member's Association With Newsletters and Publications

    [.351–.352] [Deleted August 2011, effective November 30, 2011] 

    [177.] Data Processing: Billing Services

    [.353–.354] [Deleted August 2011, effective November 30, 2011] 

    [178.] Location of Separate Business

    [.355–.356] [Deleted December 1992]

    [179.] Practice of Public Accounting Under Name of Association or Group

    [.357–.358] [Deleted August 2011, effective November 30, 2011] 

    [180.] Side Business Which Offers Services of a Type Performed by CPAs

    [.359–.360] [Deleted November 1993]

    [181.] Sale of a Practice—Purchase of Accounts

    [.361–.362] [Deleted June 1991]

    [182.] Termination of Engagement Prior to Completion

    [.363–.364] [Deleted April 30, 2006.]

    183. Use of the AICPA Personal Financial Specialist Designation

    .365 Question—In what circumstances may a firm include the AICPA-awarded designation "Personal Financial Specialists" on the firm's letterhead and in marketing materials?

    .366 Answer—It is permissible under rule 502 [ET section 502.01] for the designation "Personal Financial Specialists" (PFS) to be used on a firm's letterhead and in marketing materials if all partners or shareholders of the firm currently have the AICPA-awarded designation. An individual member who holds the designation may use it after his or her name.

    184. Definition of the Receipt of a Contingent Fee or a Commission

    .367 Question—Rules 302 [ET section 302.01] and 503 [ET section 503.01] prohibit, among other acts, the receipt of contingent fees for the performance of certain services and the receipt of a commission for the referral of products or services under certain circumstances. When is a contingent fee or commission deemed to be received?

    .368 Answer—A contingent fee or commission is deemed to be received when the performance of the related services is complete and the fee or the commission is determined. For example, if in one year a member sells a life insurance policy to a client and the member's commission payments are determined to be a fixed percentage of future years' renewal premiums, the commission is deemed to be received in the year the policy is sold.

    185. Sale of Products to Clients

    .369 Question—May a member purchase a product from a third-party supplier and resell the product to a client without violating rule 503 [ET section 503.01]?

    .370 Answer—Yes. If a member purchases a product and resells it to a client, any profit on the sale would not constitute a commission. Purchasing entails taking title to the product and having all the associated risks of ownership.

    186. Billing for Subcontractor's Services

    .371 Question—A member has contracted with a computer-hardware maintenance servicer to provide support for a client's computer operations. Would it be a violation of rule 503 [ET section 503.01] for that member to bill the client a higher service fee than that charged the member by the service provider?

    .372 Answer—No. The increased fee would not constitute a commission.

    187. Receipt of Contingent Fees or Commissions by Member's Spouse

    .373 Question—May a member's spouse provide services to the member's attest client for a contingent fee or refer products or services for a commission to or from the member's attest client without causing the member to be in violation of rule 302 [ET section 302.01] or rule 503 [ET section 503.01]?

    .374 Answer—Yes, if the activities of the member's spouse are separate from the member's practice and the member is not significantly involved in those activities. The member, however, should consider whether a conflict of interest may exist as described in rule 102 [ET section 102.01] and interpretation 102-2 [ET section 102.03].

    188. Referral of Products of Others

    .375 Question—A member refers computer products of wholesalers to clients of the firm through distributors and agents. A payment is received by the member from the wholesaler if the clients purchase the computer products. Must the member consider rule 503 [ET section 503.01] in connection with this payment?

    .376 Answer—Yes. Section 91.02 [ET section 91.02] of the Code of Professional Conduct provides that a member shall not permit others to perform acts on behalf of the member that, if carried out by the member, would place the member in violation of the rules. Therefore, the member would be held responsible for the actions of the distributors and agents.

    Rule 503 [ET section 503.01] provides that, if a member or the member's firm performs for a client a service described in rule 503 [ET section 503.01], the member may not recommend or refer to that client for a commission any product or service, or receive a commission for a recommendation or referral. This prohibition applies during the period in which the member is engaged to perform any of the services described in rule 503 [ET section 503.01] and during the period covered by any historical financial statements in such services.

    If the products are referred on a commission basis to clients for which the member is not engaged to perform any of the services described in rule 503 [ET section 503.01], rule 503 [ET section 503.01] would not be violated as long as the commission is disclosed to the client. However, any subsequent performance of services described in rule 503 [ET section 503.01] during a period in which the commission was received would constitute a violation of rule 503 [ET section 503.01].

    189. Requests for Records Pursuant to Interpretation 501-1

    .377 Question—Individuals associated with a client entity who are currently on opposing sides in an internal dispute have each issued separate requests calling for the member to supply them with records pursuant to interpretation 501-1 [ET section 501.02]. Does the member have to comply with all such requests?

    .378 Answer—In providing professional services to individuals, partnerships, or corporations, a member will usually deal with an individual who has been designated or held out as the client's representative. Such a representative might include, for example, a general partner or a majority shareholder. A member who has provided the records to the individual designated or held out as the client’s representative has no obligation to provide such records to other individuals associated with the client.

    [Revised, effective April 30, 2006, by the Professional Ethics Executive Committee.]

    190. Non-CPA Partner

    .379 Question—May a member who is in partnership with non-CPAs sign reports with the firm name and below it affix his or her own signature with the designation "Certified Public Accountant"?

    .380 Answer—This would not be improper, provided it is clear that the partnership itself is not being held out as composed entirely of CPAs.

    [Formerly ruling No. 7 under section 291. Transferred from section 291.013-.014, April 1995.]

    191. Member Removing Client Files From an Accounting Firm

    .381 Question—If the relationship of a member who is not an owner of a firm is terminated, may he or she take or retain originals or copies from the firm's client files or proprietary information without the firm's permission?

    .382 Answer—No, except where permitted by contractual arrangement.

    [Revised, effective December 31, 1998, by the Professional Ethics Executive Committee.]

    192. Commission and Contingent Fee Arrangements With Nonattest Client

    .383 Question—A member or member’s firm (member) provides for a contingent fee investment advisory services, or refers for a commission products or services of a nonclient or a nonattest client, to the owners, officers, or employees of an attest client or to a nonattest client employee benefit plan sponsored by an attest client. Would the member be considered to be in violation of either rule 302 [ET section 302.01] or rule 503 [ET section 503.01]?

    .384 AnswerNo. The member would not be in violation of either rule 302 [ET section 302.01] or rule 503 [ET section 503.01] provided that, with respect to rule 503 [ET section 503.01], the member discloses the commission to the owners, officers, or employees or to the employee benefit plan. The member should also consider the applicability of interpretation 102-2, Conflicts of Interest [ET section 102.03], and his or her professional responsibility to clients under Rule 301, Confidential Client Information [ET section 301.01].




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