QUALITY CONTROL DOCUMENT
KAYE KENDRICK ENTERPRISES, LLC
The firm’s quality control policies and procedures for the six elements of quality control are presented below. All employees of the firm are provided a copy of this document and are responsible for understanding, implementing, and adhering to these policies and procedures.
The firm is a member of the AICPA Governmental Audit Quality Center (Center) and has agreed to establish policies and procedures specific to the firm’s governmental audit practice (as defined in the membership requirements) to comply with the applicable professional standards and the membership requirements of the Center. These policies and procedures are documented and communicated by this document.
As required by the membership requirements of the Center, I am a member of the AICPA and have firm-wide responsibility for the quality of the firm’s governmental audit practice.
It is the firm’s policy to adhere to all applicable unconditional and presumptively mandatory requirements of SQCS No. 8 (QC 10), A Firm’s System of Quality Control, as evidenced by the policies and procedures within this quality control document. It is also the firm’s policy to adhere to all applicable unconditional and presumptively mandatory requirements of other relevant professional standards. Any questions, concerns, or recommendations about the firm’s quality control system should be communicated to me.
LEADERSHIP RESPONSIBILITIES FOR QUALITY WITHIN THE FIRM
It is the firm’s policy to promote a culture of quality that is pervasive throughout the firm’s operations through the development of its system of quality control. I assume responsibility for the firm’s system of quality control and design the system to (1) emphasize the importance of performing work that complies with professional standards and applicable legal and regulatory requirements and (2) issue reports that are appropriate in the circumstances. In maintaining a culture of quality, I emphasize the importance of ethics and integrity in every decision that personnel make, particularly at the engagement level. I ensure compliance with this policy by implementing the following procedures:
I dedicate sufficient and suitable resources to the firm’s quality control system and quality initiative and identify, develop, and implement the necessary QC policies and procedures based upon my comprehensive understanding of QC 10. I communicate clear, consistent, and frequent actions and messages that emphasize the expectation that each individual is to follow the firm’s quality control policies and procedures. Such actions and messages include—
Providing a copy of the firm’s system of quality control document to all new professional employees and reviewing the document and its importance with them and obtaining acknowledgement of their understanding.
Updating the firm’s quality control policies and procedures, as needed, to implement new authoritative guidance or address questions or issues that have arisen, , and promptly notifying firm personnel (and providing training when appropriate) about those revisions. .
Conducting an annual training session that reviews the firm’s QC document with firm personnel and requires them to acknowledge receipt of the QC document.
I evaluate client relationships and engagements to ensure that commercial considerations are not placed ahead of the firm’s commitment to quality control. Additionally, the firm’s performance evaluation, compensation, and advancement policy and procedures (covered in the Human Resources section of this document) do not place commercial considerations ahead of the quality of work performed.
I demonstrate the importance of quality by my actions.
I establish a formal code of conduct that reflects the firm’s core value of quality and guides personnel to make appropriate decisions throughout their workday. The code of conduct is regularly communicated and reiterated to all employees and is posted in common areas throughout the office.
The firm rewards personnel who demonstrate a commitment to quality through its performance evaluation, compensation, and advancement system, as covered in the Human Resources section of this document.
I do not allow unethical behavior to occur unchallenged and address instances of noncompliance with the firm’s quality control system through swift disciplinary action or, in extreme cases, termination of the offending employee.
At least annually, the firm’s leadership responsibilities for quality within the firm policy and procedures are reviewed to determine if they are appropriate and operating effectively, as covered in the Monitoring section of this document.
RELEVANT ETHICAL REQUIREMENTS
It is the firm’s policy that all professional personnel be familiar with and follow relevant ethical requirements of the AICPA, contained in the Code of Professional Conduct, the State of Florida Board of Accountancy, and the State of Florida CPA Society in performing their professional responsibilities. Furthermore, it is the policy of the firm that, for engagements subject to Government Auditing Standards and other applicable regulatory agencies, all professional personnel be familiar with and adhere to the relevant ethical requirements included in those standards, including any that may be more restrictive. Additionally, when the firm and its professional personnel encounter situations that raise potential independence threats, but such situations are not specifically addressed by the interpretations of the Independence Rule of the AICPA Code of Professional Conduct, the situation will be evaluated by referring to the Conceptual Framework for Independence and applying professional judgment to determine whether an independence breach exists. The firm takes appropriate action to eliminate threats to independence or mitigate them to an acceptable level by applying safeguards. If effective safeguards cannot be applied, the firm will withdraw from the engagement or take other corrective actions as appropriate to eliminate the breach. The firm ensures compliance with this policy by implementing the following procedures:
All personnel have access to the relevant ethical requirements to which the firm is subject. The firm expects its personnel to be familiar with those relevant ethical requirements.
All professional personnel who work on attest engagements and are required to be independent sign a representation letter when hired and annually thereafter acknowledging their familiarity with the firm’s relevant ethical requirements policy and procedures, particularly with regard to independence. The representation letter also lists known circumstances and relationships that may create a potential threat to independence or violate the firm’s relevant ethical requirements policy.
Ethics training is provided for professional personnel, as required by the State of Florida Board of Accountancy.
Certain relevant ethical requirements are addressed by procedures within the work programs and standard forms in the accounting and auditing manuals used by the firm. Such procedures:
Determine compliance with relevant ethical requirements, including independence, on each new and recurring attest client as part of the acceptance and continuance decision. For clients of whom I am not independent, the only attest service I perform is a compilation and I disclose my lack of independence in the related report.
Consider unpaid fees (billed and unbilled).
Consider any familiarity threat related to senior personnel recurring on an attest engagement for five years or more.
Annually confirm the independence of another accountant performing work on a group audit, or a segment of a review or attestation engagement.
Identify nonattest services performed for attest clients and determine if the services threaten independence with respect to that client (including how the firm was satisfied that client personnel had the skills, knowledge, or experience to oversee the nonattest services). The firm will only provide nonattest services to an attest client when the client accepts its responsibilities. Where applicable, this includes determining whether such nonattest (nonaudit) services impair independence under the independence rules in Government Auditing Standards.
Consider the firm’s independence of attest clients at which professional personnel have been offered management positions or have accepted offers of employment.
Consider whether actual or threatened litigation has an effect on the firm’s independence with respect to the client.
Determine whether all professional personnel are independent of the financial reporting entity, if the firm is engaged as the group auditor to report on the basic financial statements of the financial reporting entity.
Consider whether the firm was party to a cooperative arrangement with a client that was material to the firm or the client.
I require the staff to promptly communicate to me identified breaches of independence and circumstances and relationships that create a threat to independence so that I may take appropriate action.
If a potential threat to, or breach of, independence is identified, the firm accumulates and communicates relevant information to appropriate personnel so I can (a) with the assistance of other personnel, determine whether we satisfy independence requirements, (b) take appropriate action to address identified threats to, or breaches of, independence, (c) communicate the matter to those charged with governance at the attest client, and (d) maintain current independence information.
All relevant ethical requirements matters (including potential issues from the employee independence representation letters and those from other sources) are resolved by me. I am responsible for determining actions to be taken when professional personnel violate firm independence policies and procedures. Documentation of the resolution of a relevant ethical requirements matter is filed in the client’s workpaper files and retained in accordance with the firm's document retention policy.
At least annually, the firm’s relevant ethical requirements policy and procedures are reviewed to determine if they are appropriate and operating effectively, as covered in the Monitoring section of this document.
ACCEPTANCE AND CONTINUANCE OF CLIENT RELATIONSHIPS AND SPECIFIC ENGAGEMENTS
It is the firm’s policy that, for all audit, attestation, review, compilation, and preparation service engagements, the acceptability of the client and the engagement be evaluated before the firm agrees to provide professional services. The firm will accept and continue only client relationships and specific engagements when it has determined that the requisite competence and capabilities (including adequate time, resources, and licensure) exist within the firm to perform the engagement and the firm can comply with legal and relevant ethical requirements, as explained in the Assignment of Engagement Teams activity within the Human Resources section of this document. Additionally, the firm will only undertake or continue relationships and engagements when the firm has considered the integrity of the client and does not obtain information indicating that the client lacks integrity. The firm ensures compliance with this policy by implementing the following procedures:
For each prospective client that requests for the first time a preparation, compilation, review, attestation, or audit service, the professional making initial contact with the client is required to notify me and complete an engagement acceptance and continuance form for my approval.
For existing attest clients, I annually review the firm’s client list and reevaluate the acceptability of each client and engagement. In addition, prior to commencing the engagement, I ensure that the relevant section of the engagement acceptance and continuance form has been completed. (The engagement acceptance and continuance form is located in the accounting and auditing resources used by the firm.)
I document how issues identified during the acceptance and continuance process, if any, were overcome and resolved so that I decided to accept or continue the client relationship or specific engagement. Such documentation includes discussion of significant issues, consultations, conclusions, and the basis for the conclusions.
If situations occur after the commencement of an engagement and while work is in process that indicate the firm should consider withdrawing from the engagement, I am notified of the circumstances. In that situation, I consider whether there are any professional, regulatory, or legal responsibilities for the firm to remain associated with the client and the engagement or to report the withdrawal to regulatory authorities. In addition, I consider whether withdrawing from the engagement or discontinuing the client relationship is appropriate. Significant issues, consultations, conclusions, and the basis for the conclusions are documented when withdrawal from an engagement or from both the engagement and the client relationship occurs.
I am responsible for ensuring that an engagement letter is obtained for each client. The engagement letter documents the firm’s agreement with the client regarding the nature, scope, and limitations of the services to be performed, as well as my role as engagement partner.
If the firm discovers a potential conflict of interest during the acceptance and continuance decision, I determine whether it is appropriate to accept or continue the engagement. If the engagement is accepted or continued, the ethical requirements under ET 1.110.010, Conflicts of Interest , are considered, including whether a conflict of interest that might be perceived as impairing objectivity was disclosed and consented to by the client or other appropriate parties.
At least annually, the firm’s acceptance and continuance of client relationships and specific engagements policy and procedures are reviewed to determine if they are appropriate and operating effectively, as covered in the Monitoring section of this document.
HUMAN RESOURCES
Overall
The success of the firm is dependent upon its professional staff. It is the firm’s intent to succeed in the marketplace by having staff who possess the competence, capabilities, and commitment to ethical principles to assure that engagements performed by the firm are in accordance with professional standards and applicable legal and regulatory requirements and that appropriate reports are issued in the circumstances. Having effective QC policies and procedures over the human resources element helps to ensure the proficiency of personnel. The activities of our human resources QC system include—
Recruitment and hiring.
Determining competencies and capabilities.
Assignment of engagement teams.
Professional development.
Performance evaluation, compensation, and advancement.
Policies and procedures for each of these activities are described below. At least annually, the firm’s human resources policies and procedures are reviewed to determine if they are appropriate and operating effectively, as covered in the Monitoring section of this document.
Recruitment and Hiring
It is the firm’s policy that recruitment and hiring decisions for the professional staff be based on an objective evaluation of the firm’s personnel needs; that candidates possess the appropriate characteristics to perform competently; and that new employees are adequately informed of the firm’s policies and procedures. The firm ensures compliance with this policy by implementing the following procedures:
I make recruitment and hiring decisions after considering the needs of the firm.
An Interview and Evaluation Checklist is prepared for each applicant.
The firm’s personnel policies and procedures relevant to applicants and new employees are communicated to them.
Determining Competencies and Capabilities
It is the firm’s policy to determine whether personnel possess the requisite competencies and capabilities. In making this determination, the firm primarily considers qualitative measures, as opposed to quantitative ones. The firm ensures compliance with this policy by implementing the following procedures:
Periodically, I assess the competencies and capabilities that I should possess in order to supervise accounting, auditing, and attestation engagements and ensure that engagements are performed in accordance with professional standards and applicable legal and regulatory requirements, and appropriate reports are issued in the circumstances. I annually review my performance (by means of self-assessment and peer evaluation) and my competencies and capabilities. I compare the competencies and capabilities I possess to the requirements of my current and prospective engagements to determine whether I should continue to perform those current engagements or to pursue a prospective engagement. This assessment includes my—
Understanding of the role of the firm’s QC system and the AICPA Code of Professional Conduct.
Understanding of the service to be performed.
Technical proficiency.
Familiarity with the industries that I serve.
Professional judgment.
Understanding of the organization’s information technology systems.
I determine how professional staff can best obtain additionally needed competencies and capabilities. If I lack recent experience in the assigned industry or area, I obtain appropriate education and/or experience before performing engagement planning procedures.
In the unusual situation where an engagement is found to be materially nonconforming after report issuance (such as during monitoring or in connection with a peer review or regulatory inspection), I take appropriate action, as further described in the Monitoring section of this document.
I schedule strategic planning, goal setting, and mutual evaluations with individuals as needed throughout the year.
In the unusual situation where I accept an audit in an industry that the firm’s personnel have not previously audited and professional education is insufficient for the engagement team to obtain the requisite competence to perform the engagement, I engage a suitably qualified external individual to assist with the performance of the audit as a member of the engagement team.
Assignment of Engagement Teams
It is the firm’s policy that staff assigned to engagements possess the necessary competence and capabilities to perform engagements that comply with professional standards and applicable legal and regulatory requirements (including licensing requirements) and enable the firm to issue reports that are appropriate in the circumstances. The firm ensures compliance with this policy by implementing the following procedure:
1) My role as the engagement partner is communicated to client management and those charged with governance through a written engagement letter.
2) I assign staff to engagements based on the considerations included in the above policy and verbally communicate the assignments to the staff.
Professional Development
It is the firm’s policy that all professional personnel comply with the continuing professional education requirements of the AICPA, the State of Florida Board of Accountancy, the AICPA Governmental Audit Quality Center, the AICPA Employee Benefit Plan Audit Quality Center, the U.S. Government Accountability Office, and other regulatory agencies, if applicable; that all professional staff maintain an adequate awareness and understanding of current developments in professional standards, including developments that support the levels of service and industries of engagements provided; that all non-licensed professional staff work toward passing the CPA exam; and that all professional staff assist in the training and development of staff members under their supervision. The firm ensures compliance with this policy by implementing the following procedures:
An Individual CPE record worksheet is prepared by each professional staff member annually.
All professional personnel are to obtain at least the minimum number of CPE required each year by the Florida State Board of Accountancy (or, alternatively, meet the CPE requirements of the AICPA) in programs that qualify for credit under the CPE rules that govern the firm.
Individuals who work on audits subject to the Government Auditing Standards, including planning, directing, performing audit procedures, or reporting, complete at least 24 hours of CPE every two years that directly relates to government auditing, the government environment, or the specific or unique environment in which the audited entity operates. In addition, auditors who do any amount of planning, directing, or reporting on Yellow Book audits and auditors who are not involved in those activities but charge at least 20% of their time annually to Yellow Book audits also obtain at least another 56 hours (for a total of 80 hours) of CPE that enhances their professional proficiency to perform audits. However, the 2018 Yellow Book allows an exemption from those CPE requirements for nonsupervisory auditors who charge less than 40 hours of time annually to Yellow Book engagements.
In accordance with the membership requirements of the AICPA Governmental Audit Quality Center’s membership requirements, I meet both the 24-hour and 80-hour CPE requirements.
Appropriate CPE documentation is maintained for each professional for the most recent five years.
The firm maintains a current on-line resource guide, circulates within the firm important news about new or emerging changes in professional literature or business activities, and conducts staff training on significant changes if necessary.
The firm recognizes the importance of on-the-job training and encourages personnel with supervisory responsibility to be aware of situations where it can be provided.
The firm recognizes the benefit of other professional development activities and encourages personnel at each staff level to participate in such activities.
Performance Evaluation, Compensation, and Advancement
It is the firm’s policy that performance evaluation, compensation, and advancement decisions for professional personnel be based on a timely and objective evaluation of individual performance, that the professional personnel selected for advancement have the necessary qualifications to fulfill their assigned responsibilities, and that compensation of personnel be based on the quality of their work. The firm ensures compliance with this policy by implementing the following procedures:
The following personnel levels and related performance criteria are used by the firm:
Staff Accountant—Assume responsibility for unaudited financial statement engagements and segments of audits.
Senior (In-charge)—Assume responsibility for the supervision of unaudited financial statement engagements and audits.
Manager/Senior Manager—Plan and supervise assigned engagements, as well as assist in administrative functions of the office and the development of new practice opportunities.
All professional staff are verbally evaluated at the completion of engagements of approximately 150 or more hours, or more frequently as needed.
ENGAGEMENT PERFORMANCE
Overall
Engagement performance encompasses many aspects of performing an engagement, from the initial planning stages to the issuance of the report and assembly of the workpapers. Additionally, it is not uncommon for the firm’s engagement teams to occasionally encounter difficult or contentious issues that result in the need for consultation or that create differences of opinion. The firm believes in a strong quality control system and supports frequent engagement quality control review. While all of these activities are part of the engagement performance element of the QC system, the firm has chosen to differentiate certain activities within this section of the QC document for ease of understanding. The activities are segregated as follows:
Engagement performance and documentation.
Engagement quality control review.
Consultation and differences of opinion.
Policies and procedures for each of those engagement performance activities are described below. At least annually, the firm’s engagement performance policies and procedures are reviewed to determine if they are appropriate and operating effectively, as covered in the Monitoring section of this document.
Engagement Performance and Documentation
It is the firm’s policy that all audit, attestation, review, compilation, and preparation service engagements be properly planned, performed, supervised, reviewed, documented, and reported or communicated in accordance with the requirements of professional standards, applicable legal and regulatory requirements, and the firm. The firm ensures compliance with this policy by implementing the following procedures:
The firm uses PPC’s accounting and auditing manuals and practice aids as an integral part of its quality control system to assist with promoting consistency in the quality of engagement performance. I ensure the reliability of such materials, as needed, and their suitability to the firm’s practice, including updating and modifying the materials, if needed, for the firm’s engagements.
The firm’s engagement performance quality control (QC) steps are documented in the engagement performance bridging documents.
After evaluating the reliability and suitability of PPC accounting and auditing manuals and practice aids, the firm adopts and integrates within its quality control system the use of such materials as more fully described in the engagement performance bridging documents. The firm maintains separate bridging documents for engagements performed under the AU-Cs, AT-Cs, and AR-Cs. Those bridging documents are located at KKE Quality Control shared site. The use of such bridging documents facilitates consistency in the quality of engagement performance and application of engagement procedures. This QC document, the PPC manuals, and any other practice aids used by the firm are intended solely to assist us in achieving compliance with professional standards. Accordingly, nothing within this QC document should be construed as (1) requiring a higher level of performance or documentation than the minimum specifically required by the firm’s QC policies and procedures, or (2) overriding the exercise of professional judgment.
Engagement Quality Control Review
It is the firm’s policy to evaluate all engagements against criteria established by the firm to determine whether an engagement quality control review should be performed and to perform an engagement quality control review for all engagements that meet those criteria. Engagement quality control reviews will be completed by a suitably qualified individual with no association to the engagement and before the report is released. Based on the current composition of the firm’s accounting and auditing practice, I have concluded that engagement quality control review should be performed when it is a more complex or specialized audit engagements than those in which we are accustomed. The performance of engagement quality control review is appropriately documented.
I contract with a suitably qualified external individual (OR I contract with a suitably qualified internal senior-level individual with no association to the engagement) who possesses the technical qualifications necessary to perform the engagement quality control review as required by . The engagement quality control reviewer performs, and documents review procedures required by professional standards.
Consultation and Differences of Opinion
It is the firm’s policy that personnel refer to authoritative literature or other sources when appropriate. It is also the firm’s policy that all professional personnel seek consultation on a timely basis, within or outside the firm, whenever differences of opinion or uncertainty exist regarding a technical issue. The firm ensures compliance with this policy by implementing the following procedures:
The firm maintains or provides ready access to an adequate and up-to-date on-line reference library that includes current authoritative reference materials, as well as industry and other specializes materials related to clients served. Professional staff consult those materials to research technical issues.
Issues requiring consultation are first discussed among members of the engagement team or between the engagement quality control reviewer and me. Consultations with individuals outside of the firm who have relevant specialized expertise, including nonaccounting or non auditing specialists, are approved by me. Before using an outside individual or specialist, I evaluate whether the external provider is qualified for the specific purpose of the consultation. All relevant facts are provided to those consulted so they can understand the nature and scope of the consultation.
Differences of opinion that occur among the engagement team or between the engagement quality control reviewer and me are to be resolved using Procedure 2 above. When the difference of opinion cannot be resolved, matters are adequately documented in accordance with professional standards. Differences of opinion within the firm as to the resolution of a consultation issue are resolved by me. Any party to the consultation who disagrees with the final conclusion may document his or her disagreement with the resolution of the matter. The firm does not issue the report until any differences of opinion are resolved.
All technical research due to differences of opinions and consultations is documented in the workpapers. All consultations involving difficult or contentious issues are agreed upon by both the individuals seeking consultation and the individuals consulted. Consultations and differences of opinion are sufficiently documented in accordance with professional standards.
MONITORING
It is the firm’s policy that the quality control system be monitored on an ongoing basis to provide the firm with reasonable assurance that the policies and procedures established by the firm for each of the elements of quality control are relevant, adequate, and operating effectively. Monitoring activities include engagement quality control review (EQCR), inspection, and post-issuance review. EQCR, performed prior to completion of the engagements, as deemed necessary, assists in providing ongoing consideration and evaluation of the firm’s QC system. The policies and procedures relating to EQCR are addressed in the Engagement Performance section of this document. The retrospective monitoring activities performed relate to inspection and post-issuance review (collectively referred to as inspection/review) and are the primary activities addressed in these monitoring policies and procedures.
As an integral part of the monitoring process, inspection/review procedures are performed on all elements of the firm’s quality control system at least annually to determine whether the firm has complied with professional standards, applicable legal and regulatory requirements, and its stated quality control policies and procedures. The firm ensures compliance with this policy by implementing the following procedures:
At least annually, I perform or select a team/individual to perform an inspection/review procedures on the firm’s quality control system. Individuals selected as monitoring team members possess adequate technical knowledge and experience and, when practical, are not directly involved in the administration, supervision, or performance of the QC procedures or engagements each will inspect/review. The monitoring process is planned, performed, and documented using the appropriate monitoring checklist found in the practice aid section of PPC’s Guide to Quality Control as a work program. The engagements selected for inspection are taken from the firm’s complete engagement population The monitoring procedures include review of administrative records to assess compliance relating to QC elements other than engagement performance.
At the conclusion of the inspection/review, the individual assigned is responsible for (a) identifying and summarizing the deficiencies noted and (b) discussing the results of the inspection/review with me and the supervisory personnel responsible for each of the engagements selected for review and determining whether any corrective action needs to be taken or improvements made with respect to those engagements. I consider whether any deficiencies noted in the monitoring team’s communication may affect other engagements.
The firm pursues one or more of the following actions resulting from its evaluation of the deficiencies noted during inspection/review—
Take appropriate remedial action directed toward the individual engagement or person.
Revise the firm’s quality control policies and procedures.
Communicate the findings to those responsible for training and professional development.
In addition, if a materially nonconforming engagement or other significant deficiency is identified, I take appropriate action that, depending on the severity of the deficiency(ies), may also include one or more of the following internal actions:
Take relevant CPE.
An EQCR is performed by a suitably qualified external individual on future engagements in the related industry or area.
I discontinue performing engagements in the related industry or area.
If monitoring procedures indicate that required engagement procedures were not performed or that an issued report is inappropriate, the firm determines what further actions are needed to comply with relevant professional standards and applicable legal and regulatory requirements. Depending on the specific situation, the firm may obtain legal advice.
At least annually, the firm prepares and distributes a formal monitoring report to all professional personnel. This annual monitoring communication provides a description of (a) the monitoring procedures performed, (b) the conclusions reached from such procedures, and (c) any systemic, repetitive, or other significant deficiencies noted and the corrective actions taken to resolve them. I consider whether any deficiencies noted in the firm’s communication may affect engagements.
In addition, the firm is subject every three years to a peer review in accordance with the requirements of the AICPA and the state of Florida Board of Accountancy. I am responsible for scheduling and coordinating that review. The firm elects to have its peer review count as its inspection for each year in which a peer review is performed.
The internal inspection/review results (including those specific to the firm’s governmental audit engagements selected for inspection/review) and annual monitoring communication are made available to the firm’s peer review team.
Based on the firm’s ongoing monitoring of the QC system, the annual inspection/review, the annual monitoring communication, and, when applicable, the results of the firm’s peer review, I determine any corrective actions that should be pursued to improve, amend, or rectify the QC system. I am responsible for monitoring and documenting the implementation of, and compliance with, any corrective actions.
I periodically remind personnel during staff meetings that any concerns regarding complaints or allegations may be communicated to the firm without fear of reprisal. The firm is particularly interested in complaints and allegations about the firm’s noncompliance with professional standards, applicable legal and regulatory requirements, or the firm’s system of quality control. The firm appropriately addresses complaints and allegations by—
Establishing channels of communication for complaints and allegations and communicating such information to employees and clients.
Investigating complaints and allegations and involving legal counsel if necessary.
Documenting all complaints and allegations.
The firm documents the performance of each element of its QC system on an ongoing basis, as well as in conjunction with documenting its monitoring of the system. The firm retains monitoring documentation evidencing the operation of its QC policies and procedures for a time sufficient to allow those monitoring the QC system, including peer reviewers, to evaluate the firm’s compliance with its system.