Providing hosting services

Does your firm provide data or records security or back-up services for clients? Does your firm keep client financial data or records (e.g., general ledger, legal documents, or amortization schedules) on the firm’s servers? Does your firm provide bookkeeping services using accounting software, such as QuickBooks? If so, practitioners should be aware of on July 1, 2019, the Professional Ethics Executive Committee (PEEC) new interpretation on hosting services which became effective on July 1, 2019.

As a reminder, this interpretation concludes that independence would be impaired when the member maintains “the attest client’s internal control over its data or records.” Since its issuance, the ethics team and the CPEA have been developing an array of resources related to some of the more commonly asked implementation issues that have arisen.

Our coverage of PEEC interpretation is in three parts:

• Part I provides an initial overview of the PEEC interpretation.

• Part II provides updates from that initial issuance as well as additional resources which are available.

• Part III addresses Q&As related to practice concerns that arose after the PEEC interpretation was initially released and became effective.