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The final rule did not define an affiliate of an accounting firm. Does the lack of a definition signal a change in the Commissions approach to this issue?

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The final rule did not define an affiliate of an accounting firm. Does the lack of a definition signal a change in the Commissions approach to this issue?

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No. The final rule’s definition of an “accounting firm” includes the accounting firm’s “associated entities.” As noted in the adopting release, the Commission used this phrase to reflect the staff’s current practice of addressing these questions in light of all relevant facts and circumstances, and by looking to the factors identified in our previous guidance on this subject. Much of this guidance is cited in footnotes 489 and 491 of the adopting release. The staff is available for consultations on this issue.

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