The rules do not define an affiliate of an accounting firm. What is the Staff’s approach to this issue?
The definition of an “accounting firm” includes the accounting firm’s “associated entities.” The Commission uses 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 was cited in footnotes 489 and 491 of the January 16, 2001 adopting release (“Revision of the Commission’s Auditor Independence Requirements”). The staff is available for consultations on this issue.
