It is always a good to remember that auditor independence is not just an issue for auditors but also for audit committees and management.  With the recent auditor independence enforcement actions against RSM and PwC as reminders, all companies, and in particular multinational companies, should review their own processes to assure no company personnel act in a way which could impact on auditor independence.  Particularly, offices outside the United States, where financial and other personnel may not be aware of the more restrictive SEC independence requirements, should be trained about the restrictions in non-audit services and related issues.

As an additional resource in this process, earlier this year the Office of the Chief Accountant updated its auditor independence FAQs, which could be a helpful resource in policy development and training.

As always, your thoughts and comments are welcome!