Are there additional types of human resource and employee benefit services that impair an auditors independence?
• Are there any particular legal services that should be exempted from the rule? No. The role of an independent third party is totally inconsistent with the role of an attorney who acts as an advocate for his or her client. • Would making the rule’s application depend upon the jurisdiction in which the service is provided leave the rule subject to any significant uncertainty, or pose the prospect of any significant complexity or unfairness? There should be no exceptions granted based on jurisdictional boundaries. There should be no exceptions granted to foreign firms. Prior to 2001, in it’s FRR’s, the Commission had a long stated position that legal services were inconsistent with the notion of independence. Yet a Big five accounting firm acquired a legal practice without first getting Commission approval. Only after such an acquisition did the firm come to the SEC Staff for approval. Even then, the Staff had discussions and without any formal approval of the Commission or its Chief Ac
