2015 Small Firm Compliance, December - Clarifying Email

SMALL FIRM COMPLIANCE CORNER
CLARIFYING EMAIL
 
ACTION ITEM:  STATEMENT ON INDEPENDENT PUBLIC ACCOUNTANT DUE DEC. 10th
 
I would like to take this opportunity to revisit this item for everyone, I'm afraid my synopsis paragraph may have been misleading.
 
The sentence from my prior email that states that "Firms are required to file the statement regarding its independent public accountant no later than December 10 each year" appears to need further clairification.
 
Many, but not all, audit engagement letters are of a continuing nature.  If a firm filed the  STATEMENT ON INDEPENDENT PUBLIC ACCOUNTANT on the proper form in 2014 and if the engagement with the auditor is of a continuing nature, there is no need to refile in 2015.
 
 "A broker-dealer need not file a new statement regarding its independent public accountant under paragraph (f)(2) until after the amendments to this paragraph become effective on June 1, 2014.  For a broker-dealer with a 2014 fiscal year end between June and December 2014, the new statement must be filed on or before the 10th day of the month in which the broker-dealer's fiscal year ends because the representations in the statement need to address the work that the accountant will perform with respect to the broker-dealer's annual reports for its fiscal year ending in 2014.
 
Broker-dealers that file their new statement between June and December 2014 for their 2014 fiscal year annual audit do not need to file a second new statement for their 2015 fiscal year by December 10, 2014 if the contractual commitment between the broker-dealer and independent public accountant is of a continuing nature.  If the contractual commitment between the broker-dealer and independent public accountant is not of a continuing nature, then the broker-dealer must file a new statement under paragraph (f)(2) for the annual audit to be conducted the following calendar year no later than December 10, 2014."
  
I apologize for unintentionally creating some confusion on this "Action Item" and I hope this clarifies the matter. Also, thank you to those of you who reached out to me to bring this to my attention.
 
All the best,
PAIGE W. PIERCE