Retention of Peer Review Documents

AICPA Peer Review Board and PICPA Peer Review Committee guidance regarding working papers and other peer review materials require that all reviewers follow the retention policies below.

All peer review documentation prepared during a peer review should be retained by the reviewing firm, the administering entity, and the association (in an association formed review team) until one hundred and twenty (120) days after the peer review is completed.

After this time, the peer review documentation, with the exception of those documents described below, should be destroyed. The reviewing firm and the administering entity should retain the following documents until one hundred and twenty (120) days after the firm’s subsequentpeer review is completed:

  • Peer review report and the firm’s response, if applicable
  • Letter notifying the firm that its peer review has been accepted
  • Letter notifying the firm that its peer review documents have been accepted with the understanding that the firm agrees to certain corrective actions, if applicable
  • Letter notifying the firm that certain corrective actions have been completed, if applicable.
  • Findings for Further Consideration (FFC) forms, if applicable
  • Letter requesting the reviewed firm’s completion of an implementation plan, if applicable
  • Letter notifying the firm that the implementation plan has been completed, if applicable
  • Letter(s) relating to peer review document recall considerations
  • Written representations from management of the reviewed firm
  • Scheduling information

Note that the working paper retention policies are for electronic and paper documents.  When reviewing your documents for destruction, in accordance with the policy above, don’t forget about any electronic files that may still exist. 

This includes any e-mails sent to the firm and/or PICPA, with peer review documents, as well as backups of peer review documents on your firm’s network.

The PICPA Peer Review Committee or AICPA Peer Review Board may indicate that any or all documentation for specific peer reviews should be retained for a longer period of time then specified above because, for example, the review has been selected for oversight. If the Committee or Board believes it is necessary for a reviewer to retain documentation beyond the period specified above, it will so advise the reviewer by separate letter.

If you have any questions on these retention policies, please contact the Professional & Technical Standards Team at (215) 496-9272 or peerreview@picpa.org.