Pursuant to The CPA Law, Act of May 26, 1947, P.L. 318, as re-enacted and amended, 63 P.S. Sections 9.1 et seq., at Section 11 (63 P.S. Section 9.11), we consider all working papers and records prepared for a client engagement (Firm’s Working Papers), except reports submitted to a client and records or documents provided by a client (Client-Provided Records), to be the property of the firm in the absence of an agreement to the contrary which details specific work products to be generated as client-owned documents. In the event the firm produces any such client-owned documents under such an agreement, the firm always retains the right to maintain a copy of such documents in its files as part of the Firm’s Working Papers.
Further pursuant to said CPA Law, we provide a copy of the client’s tax return and a copy of any report or other document issued to the client at the time the document is prepared and issued. Upon specific request by a client, we will re-issue a copy of said tax returns or other prepared documents (Firm’s Work Products) or a copy of any portion of our working papers that would ordinarily constitute part of the client’s records and are not otherwise available to the client (Firm-Prepared Client Records), within a reasonable period of time after such request is made and no later than 45 days thereafter. In the event that fees are unpaid and due to us from our client at the time of the request for such re-issued Firm’s Work Products or Firm-Prepared Client Records, we require such unpaid fees to be paid prior to release of such documents. We also require reimbursement for the expense to provide such documents to be paid at the time of their delivery.
The working papers we have created to document the performance of our responsibilities in the completion of our client engagements (Firm’s Working Papers) are the property of our firm and will not be provided to our client or any other third party, except as may be required by state and federal statutes and regulations or other regulatory monitoring referenced within our engagement letter for the services to which they pertain.
Clarification as to the meaning of specific terms referenced above may be ascertained by reference to the following definitions:
Client-Provided Records: Accounting or other records belonging to the client that were provided to the firm. This might include original bank statements or other third-party documents, original client-prepared reconciliations to third-party documents, original vendor invoices, minute books, stock record books, and similar records.
Firm-Prepared Client Records: Information not reflected in the client’s books and records that, if otherwise not available to the client, would result in the client’s financial information being incomplete. This might include depreciation schedules and amortization schedules.
Firm’s Work Products: Deliverables that the firm was engaged to prepare for the client. This might include tax returns, reports, and unaudited or audited financial statements.
Firm’s Working Papers: Documents prepared by the firm or accumulated by the firm from other sources to (i) support client financial records, balances, obligations and calculations or (ii) document the performance of procedures provided by our firm as part of its diligence in performing audit, review, compilation, tax return preparation or other compliance services. This might include audit programs, analytical review schedules, statistical sampling results, analyses and schedules prepared by the firm, or schedules prepared by the client at the request of the firm.
See Client Records for firm policy regarding providing clients with Firm’s Work Products, Client-Provided Records and Firm-Prepared Client Records.