Dear Mr. Jackson:

After reading your letter in Accounting Today (Feb. 21-March 13, 2005, p. 6), Bob Bunting asked me to respond as the volunteer leader within the American Institute of CPAs who has observed the disciplinary process for many years and is familiar with its history.

Your letter expressed concern that "there has been a pattern for many years of enforcing ethics violations against members in smaller firms (as well as those in industry, education and government), but not giving equal enforcement to members of the Big Four firms."

As chair of the AICPA Professional Ethics Executive Committee, I must tell you that this statement is totally inaccurate and misstates the AICPA's enforcement process and the disciplinary actions taken against its members. PEEC, which is comprised of 17 volunteer CPA members (only four of whom are associated with Big Four firms) and three non-CPA public members, is responsible for investigating members who are alleged to have violated our Code of Professional Conduct and for sanctioning those who have been found to actually have done so.

First, I want to assure you that the AICPA Ethics Division investigates all matters that come to its attention alleging misconduct of AICPA members, regardless of the size of their firm or employer.

However, because we are a membership organization of individuals, disciplinary action is taken against the individual member rather than against his or her firm or employer. Consequently, it may not be as obvious when a disciplinary action is taken against a member of a Big Four firm as it is when action is taken against a sole practitioner or a named partner of a smaller firm.

Historically, when a member was admonished, suspended or expelled from the AICPA, the publication did not include the name of the member's firm or employer. Recently, however, this policy was revised to permit the publication of firm or employer names under guidelines established by PEEC.

Second, let me assure you that during my four-and-a-half years of service on PEEC, I have seen numerous disciplinary actions taken against members who were associated with Big Four firms. I have reviewed the disposition of ethics cases during the past few years, and can honestly say that, in my opinion, members associated with Big Four firms are treated no better or worse than members who practice in small or midsized firms, or who are employed in industry, education or government.

In your letter, you also manifest your understanding that the reason why actions are not taken against the Big Four firms is because "the AICPA representative who participated in the proceedings in each case insisted that no disciplinary action be taken against a member of a big firm, so that the reputation of those firms would not be besmirched."

You should be aware that the staff of the AICPA do not deliberate or vote on any of the cases under consideration by PEEC or either of its two subcommittees. Rather, it is the members of those committees - your peers - who determine the disposition of all disciplinary matters. If a member is found to have violated our Code of Professional Conduct, the committees apply uniform sanctioning guidelines approved by PEEC. I am personally satisfied that these sanctioning guidelines are applied equally and fairly to all members, regardless of firm or employer affiliation.

I hope this letter provides you with a better understanding of our disciplinary process and helps to restore your confidence in it. If you would like further information about the committee's activities, including its disciplinary efforts, please visit the Professional Ethics Division's Web site at

Bruce P. Webb

Chair, AICPA Professional Ethics Executive Committee

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