Although these COVID-19 relief measures are much needed, CAMICO recognizes that the accounting profession faces unique challenges as CPA firms may be perceived as the front line for assisting clients in navigating through and addressing the application of many of these relief measures. The challenge for CPA firms, of course, is how to do so when the information and rules related to the application and/or qualifications of many of the COVID-19 relief measures keep changing on an almost daily basis. In addition, as some of the relief measures being presented are outside of the scope and expertise of the accounting firm, what, if anything, should you be doing without putting the firm at potential liability risk?
From CAMICO's risk management perspective, it is critical now, more than ever, that firms take the appropriate loss prevention measures to "warn clients of risks" and "advise clients of opportunities and limitations" as well as "timely and thoroughly document discussions with clients." Be proactive, but understand that there are many moving parts during these early days so it is important to consider using appropriate disclaimer language in your written communications with your clients to not only protect your firm, but also to clarify the dynamic nature of these changes and that further clarifications and corrections may be forthcoming. Consider the illustrative disclaimer below:
This communication is intended to provide general information on legislative COVID-19 relief measures as of the date of this communication and may reference information from reputable sources. Although our firm has made every reasonable effort to ensure that the information provided is accurate, we make no warranties, expressed or implied, on the information provided. As legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that may modify some of the provisions in this communication. Some of those modifications may be significant. As such, be aware that this is not a comprehensive analysis of the subject matter covered and is not intended to provide specific recommendations to you or your business with respect to the matters addressed.
To further assist CPAs in navigating through these difficult and unique challenges, CAMICO has developed the following risk management guidance to help firms be prepared to provide information and services to their clients while proactively minimizing potential exposures. We update these FAQ documents as new information comes out, so we encourage you to check back frequently for the latest guidance.
COVID-19 A&A Frequently Asked Questions: This document addresses the impact of COVID-19 issues on financial statements (audit, review, compilation and preparation engagements) and will help a firm assess whether disclosure and/or report modifications are needed. Illustrative report and footnote disclosure language is provided.
COVID-19 Tax Frequently Asked Questions: This document addresses the impact of COVID-19 relief measures on certain tax compliance engagements given current guidance as promulgated.
COVID-19 Employment Practices Frequently Asked Questions: This document addresses the impact of COVID-19 relief measures and current guidance as they relate to a firm’s employment practices.
COVID-19 Paycheck Protection Program ("PPP") Frequently Asked Questions: This document addresses the risk management considerations when assisting clients with a PPP loan based on the current guidance as promulgated.
In addition to the resources listed above, CAMICO has also developed and posted on its pubic website (www.camico.com) under 'Coronavirus Resources', sample engagement letters designed for engagements in which you are asked to assist clients with Small Business Administration ("SBA") COVID-19 disaster loans, or relief through the CARES Act provisions of the Paycheck Protection Program. And for clients who may need assistance in determining which provisions of the CARES Act may be most advantageous, we’ve created a consulting engagement letter.