Client Records Policy Statement
When a client service engagement is completed, original client records used by us will be returned to the client and not retained in our files as soon as practicable. If we believe an item needs to be retained for engagement documentation purposes, we will make a copy of the original for the file.
You have an obligation to maintain your own original records and we do not assume any responsibility to maintain them.
is particularly important where a client submits copies to us; we expressly
assume you will maintain control over the original documents from which the
copies were made.
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Definition of Firm’s Engagement Records
Engagement working papers and files typically consist of the Firm’s original working papers, records of staff and client communications regarding the engagement, correspondence with clients and third parties pertaining to the engagement, copies of the work product provided to the client, and copies of client documents.
express agreement with a client
(for example, in an engagement to provide expert consulting services to an
attorney where the attorney requires the CPA to turn over all working papers at
the end of the engagement) Florida Statutes provide that the Firm’s working papers are the property of the
Firm. These records may exist in electronic form such as e-mails, spreadsheets
and even databases.
Because the types of records created or needed to perform an engagement vary substantially based upon the type of service rendered and the client’s industry, it is not possible to formulate a single record retention policy that can be used by all CPA firms.
However, the below
represent a fair approximation of the documents we believe properly belong to the
Firm and not to the client:
• Annual tax return working
paper files. These files may include information furnished by the client,
engagement letters, firm-prepared working papers including checklists, tax
research information developed in resolving tax return issues and questions, and
working papers containing calculations and other data prepared in support of the
• File containing the firm’s
copy of the final returns submitted to the client for filing with the tax
authorities and a diskette or other electronic storage media containing the
electronic files used to prepare and print the final returns.
• Permanent or carry-forward
file containing information that will be needed on future return preparation
engagements such as fixed asset depreciation schedules, copies of correspondence
to/from taxing authorities such as requests for rulings and responses thereto.
• File containing copies of all
correspondence and information sent to and received from the client and
memoranda prepared in connection with this client.
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PROFESSIONAL GUIDANCE AND STATE LAW
ET Section 501 of the AICPA Code of Professional Conduct, Interpretation 501-1, “Retention of Client Records,” provides guidance about what constitutes client records (a copy of this will be provided upon request).
§473.318 Florida Statutes “Ownership of working papers” states:
“all statements, records,
schedules, working papers, and memoranda made by a licensee or her or his
employee incident to, or in the course of, professional services to a client,
except the reports submitted by the licensee to the client and except for
records which are part of the client's records, shall be and remain the property
of the licensee in the absence of an express agreement between the licensee and
the client to the contrary.”
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· Member refers to a member of the American Institute of CPAs (we are Members of the AICPA).
· Client provided records are accounting or other records belonging to the client that were provided to the member by or on behalf of the client.
· Client records prepared by the member are accounting or other records (for example, tax returns, general ledgers, subsidiary journals, and supporting schedules such as detailed employee payroll records and depreciation schedules) that the member was engaged to prepare for the client.
· Supporting records are information not reflected in the client’s books and records that are otherwise not available to the client with the result that the client’s financial information is incomplete. For example, supporting records include adjusting, closing, combining, or consolidating journal entries (including computations supporting such entries) that are produced by the member during an engagement (for example, an Audit).
· Member’s working papers include, but are not limited to, Audit programs, analytical review schedules, and statistical sampling results, analyses, and schedules prepared by the client at the request of the member.
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Please call us at 407-812-8490 or
send an email to
if you would like more information on either of these very important policies.