Today in accountant anxiety, a new Big 4 audit manager is perplexed as to why the firm is requiring the movement of their brokerage accounts, which on the surface, don't result in any independence conflicts.
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Back to our muddled manager:
I'm a new audit manager at a Big 4 firm. As a new manager, my firm is requiring me to move all of my brokerage accounts (even those for which I'm the trustee but have no beneficial interest in) to a firm approved by the company and which participates in their daily transaction import program so they can keep daily track of all of my holdings. How is this legal? I'm not allowed to do business with a brokerage firm of my choice, even when there are no independence conflicts? Doesn't this violate some law or something!?!?! Advice please!
Frankly, we're a little surprised that you're surprised about your firm's requests in this matter. After all, you're a manager. In the audit practice. We realize it's been awhile since you've cracked an audit textbook but we're curious if you're delegating your annual independence refresher to a lowly staff because you can't be bothered with it.
As you may recall, audit firms have to be independent in fact and appearance. Your brokerage accounts - both your personal and the accounts that you serve as a trustee - are a huge risk to your firm's ability to maintain that independence. Your personal accounts are a no brainer - a firm simply cannot have anyone with assets with a broker that your firm has some sort of professional relationship with that could be perceived as conflict of interest.
As far as the accounts that you serve as the trustee for - Wiktionary defines trustee as follows:
A person to whom property is legally committed in trust, to be applied either for the benefit of specified individuals, or for public uses; one who is intrusted with property for the benefit of another; also, a person in whose hands the effects of another are attached in a trustee process.
So in other words, you are legally obligated to invest on behalf of the beneficiary in their best interest. This could possibly put you in direct conflict to act in a manner that would risk the independence of your firm.
And as everyone knows, an audit firm's reputation as an independent third party that provides an objective opinion is paramount to the industry. Whether they are truly independent is a matter that Francine McKenna would be happy to take up with you on any day of the week but all the firms have a platoon of attorneys and other professionals that monitor the risk of independence violations for their respective firms constantly.
And as long as you're an employee of the firm, the firm's interests will trump yours. We suggest paying closer attention at your next ethics training.