RSM US LLP - AICPA SSARS AR-C Section 70 Comment Letter - December 16, 2024 - Public Interest and Applicability

Sep 16, 2026

Upload by Maeve

RSM US LLP submits comments on the AICPA Accounting and Review Services Committee’s September 23, 2024 exposure draft addressing the applicability of AR-C section 70 to financial statements prepared as part of a consulting services engagement under CS section 100. RSM supports amending SSARS No. 21 to exclude consulting-services engagement preparation from AR-C section 70 requirements, citing no negative impact on the public interest and improved clarity. RSM also answers questions on the effective date and proposed paragraph revisions, recommending additional guidance and noting voluntary application considerations.

LanguageEnglish

CategoryLetters

FormatPDF

Pages3

Reading Time1 min

AccessFree to download

RSM US LLP Comment Letter

Support for amending SSARS and excluding CS Section 100 engagements

Public interest rationale and practical considerations

Effective date of the SSARS

Revisions to paragraph .01 and new application paragraph .A4

December 16 , 2024 Accounting and Review Services Committee American Institute of Certified Public Accountants 1211 Avenue of the Americas, 19th Floor New York, NY 10036 Via email [to commentletters@aicpa.org](to commentletters@aicpa.org) 30 South Wacker Drive Suite 3300 Chicago, IL 60606 [www.rsmus.com](www.rsmus.com) Re: Exposure Draft, Proposed Statement on Standards for Accounting and Review Services, Applicability ofAR-C Section 70 to Financial Statements Prepared as Part ofa Consulting Services Engagement RSM US LLP (RSM) appreciates the opportunity to comment on the American Institute of Certified Public Accountants (AICPA) Accounting and Review Services Committee’s September 23, 2024 , Exposure Draft, Applicability ofAR-C Section 70 to Financial Statements Prepared as Part ofa Consulting Services Engagement (the Exposure Draft) . RSM is a leading provider of audit, tax and consulting services focused on the middle market. We support the Accounting and Review Services Committee’s proposal that would amend Statement on Standards for Accounting and Review Services (SSARS) No. 21, Statements on Standards for Accounting and Review Services: Clarification and Recodification , as amended, AR-C section 70, Preparation of Financial Statements. We believe the amendment provides a helpful clarification in the exclusion of financial statement preparation performed as part of engagements under CS Section 100 , Consulting Services: Definitionsand Standards , and would reduce confusion in the applicability of AR-C section 70 going forward. We support the proposed change as it does not appear to negatively impact the public interest. We provide additional details concerning our thoughts on this matter and the proposed revisions to paragraph .01 and the new application of paragraph .A4 in our detailed responses below. 1. Do respondents believe that it is in the public interest to explicitly exclude financial statements prepared as part of a consulting services engagement performed in accordance with CS section 100 from those engagements for which AR-C section 70 is required to be applied? Please provide your reasons for your position. We believe the proposed change does not appear to negatively impact the public interest (as defined in ET section 0.300.030.02) , as when the certified public accountant (CPA) prepares financial statements as part of either a CS Section 100 engagement or an AR-C section 70 engagement, the CPA: a. Accepted the obligation to act in a way that will serve the public interest, honor the public trust, and demonstrate a commitment to professionalism (i.e. , follow the public interest principle in ET section 0.300.030.01, The Public Interest) and b. Will perform the engagement consistent with acceptable professional behavior with integrity , objectivity and independence and due care in accordance with ET section 0.300.070.02, Scope and Nature of Services. Further, it is our experience that when financial statements are prepared as part of a consulting engagement, the financial statement preparation portion of the engagement often forms a small part or is a byproduct of the overall consulting engagement. As such , it doesn't seem appropriate to subject a small or byproduct portion of a broader engagement to more rigorous requirements than the primary engagement. Additionally, the proposed change provides much needed clarity on a topic that has historically been inconsistently applied. 2. Do respondents believe that the proposed effective date of the SSARS is appropriate? If not, why not? Yes , we believe that the proposed effective date of the SSARS is appropriate. 3. Do respondents believe that the proposed revisions to paragraph .01 and the introduction of new application paragraph .A4 are appropriate? If not, respondents are asked to state their reasons. Yes , we believe that the proposed revisions to paragraph .01 and the introduction of new application paragraph .A4 are app

FAQs

Why does RSM US LLP support excluding consulting-services engagement financial statement preparation from AR-C section 70?

RSM believes the change does not negatively impact the public interest and helps reduce confusion, especially because consulting engagement financial statement preparation is often a small portion or byproduct. RSM also points to improved clarity on historically inconsistent application.

Is RSM US LLP supportive of the proposed effective date for the SSARS?

Yes. RSM states the proposed effective date of the SSARS is appropriate.

What concerns does RSM raise regarding revisions to paragraph .01 and the new application paragraph .A4?

RSM agrees the revisions and the new application paragraph are appropriate, but suggests additional guidance is needed for situations where an accountant voluntarily applies AR-C section 70 when not required. RSM also recommends memorializing voluntary application language before paragraph .A4.

Sep 16, 2026

Upload by Maeve