Comment letter addresses proposed revisions on Alternative Practice Structures

COCPA recently submitted a comment letter to the AICPA Professional Ethics Executive Committee (PEEC) on its exposure draft covering alternative practice structures. On behalf of our 4,500+ CPA members, we support PEEC's effort to protect independence and public trust as firm structures evolve — but the final standards need to be clear, practical, and workable for CPAs at firms of every size.

Based on feedback from the COCPA Professional Conduct Board, the letter raises two main concerns: the proposed guidance is more complex than it needs to be, and greater alignment is needed with other standard setters like the PCAOB, SEC, and IESBA. Bottom line? These rules should be understandable and usable by an individual CPA in a practice of any size — not just big firms with specialized expertise.

Read the full comment letter here: COCPA Comment Letter — AICPA Ethics Exposure Draft (PDF)