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CONDUCT STATS: TRENDS IN CERTAIN VIOLATIONS
With complaint volume on the rise, CPA Saskatchewan has identified some of the trends in recent cases and compiled the following strategies to assist you in avoiding similar complaints: busy, so it is imperative to set client expectations from the start as to what they can expect in terms of a response time throughout the engagement to questions, etc. Save yourself time in the end and have these critical discussions before beginning the engagement.
3. Think about how the Rules of Professional Conduct (RPCs) apply to your whole situation.
1. Pay attention to the results of practice inspections and practice administration reviews and take action on those results right away.
Both processes are an excellent early warning system, identifying where a firm is at risk of causing harm through an audit or other failure in service delivery or being unable to defend the work performed in the event of a complaint. If practice inspection results have resulted in two or more consecutive corrective action plans, there is a higher risk of the firm ending up in the conduct process. A corrective action plan might be accepted, but if you are not truly embracing and implementing those actions, your risk will not be reduced. In the last year, six complaint cases had client acceptance issues arise in practice inspection that were not dealt with subsequently by the firm. Two other complaint cases had practice inspection results that showed there was a general risk in how the firms operated overall.
2. Set realistic expectations with clients.
Engagement letters are very efficient at documenting this, but there seems to be a real reluctance by firms to discuss billing rates and what the client can expect in terms of time frames. It is important that clients understand up front that several factors will have an impact on the final cost and the time to complete the engagement. Some firms seem to really avoid discussing a fair price with their clients to perform the service and then hope the client doesn’t question the final bill – this is often not the case, so be proactive in discussing pricing ahead of time. Practitioners and staff are also very
The recently adopted format of the RPCs that include guidance is really useful for anyone, whether you are in public practice, employed, consulting, semi-retired, or volunteering – reflect on how you are applying the RPCs in all your activities. There are answers in there to guide you through many activities, including: a. properly handling client responses (always be mindful of courtesy, timeliness, and documentation); b. dealing with issues on confidentiality; c. how to ensure you are advertising appropriately; d. ensuring recruitment activities are carried out professionally; e. situations that you might not think of as ‘professional accounting’.
4. Whenever you are in unfamiliar territory, your risk increases.
Recent conduct matters relate to CPAs using social media, texting sensitive or critical client information, inadequately maintaining data security, taking on contract CFO roles, helping family members and friends in an area of inexperience, running a side business without registering a firm, or taking on a volunteer role. In seven recent matters, we have seen CPAs taking on roles without clearly defining their areas of responsibility, which resulted in CPAs inadvertently taking on responsibilities they did not sign up for. The lack of documentation to support the role resulted in a breach of the requirement for due care.
Taking these proactive measures will greatly reduce your risk of receiving a complaint resulting in conduct review. Refer to the Rules of Professional Conduct often and contact monitoring@cpask.ca for further guidance if there are concerns about a potential issue.