Joint Ethics Enforcement Program (JEEP)
PICPA is a participating state society in the Joint Ethics Enforcement Program (JEEP), an agreement between the American Institute of CPAs and state CPA societies.
What is JEEP?
“The purpose of the JEEP agreement between the AICPA and a state society is to permit joint enforcement of their respective codes of professional conduct with respect to a member of either or both by means of a single investigation and, if warranted, a single settlement agreement or joint trial board hearing.” (JEEP Manual of Procedures, Dec. 2006)
Depending on the nature of the ethics complaint, and the individual’s membership in various CPA societies, either the PICPA Professional Ethics Committee or AICPA Professional Ethics Division will conduct the investigation. If prima facie evidence of a violation is found, the two organizations will concur on a decision, depending on the severity of the violation.
Summary of the JEEP Process
All ethics cases include these steps:
All respondents are offered the opportunity for an interview during the investigation. The interview allows the respondent to discuss the investigation and offer additional evidence. There are a few key points to consider about JEEP interviews:
1. The interview is optional; a respondent may decline the interview offer.
2. If accepted, representatives from the committee and the respondent (or a representative) will attend the interview. The respondent may be accompanied by legal counsel and representatives or legal council of the firm.
3. Interviews are:
a) Conducted on an informal basis
b) Conducted either by telephone or in person
c) Held a time, date, and location mutually agreeable to all parties
d) Subject to recording, with the respondent's approval
4. Respondents may decline to respond to any interrogatories during the interview. However, declining to respond may result in the committee subsequently posing the question in writing and requiring the respondent to make a substantive response.
After the interview, a draft written summary will be circulated to all attendants for comments and corrections. If no comments are received within a reasonable time frame, the written summary will be finalized and become a part of the evidence for the case.
Deferring an Investigation
An investigation may be deferred because the issues and parties involved are currently subject to:
a) Legal proceedings before a state or federal civil or criminal court
b) Proceedings or investigations by a state or federal regulatory agency or other organization authorized to regulate accountants (ex. Securities and Exchange Commission, State Board of Accountancy)
c) Appeals actually undertaken from a decision of a state or federal civil or criminal court or regulatory agency.
During a deferral, respondents will be required to periodically update the committee in writing regarding the status of the litigation or proceeding. Respondents, or a firm designee, will also be responsible for preserving all documents necessary to the investigation (ex. financial statements, working papers, memoranda, correspondence, litigation documents).
Upon the conclusion of the litigation or proceeding, the investigation will resume.
Possible Conclusions of an Investigation
After discussion, the committee may issue the following decisions:
All ethics investigations are conducted in a confidential manner. Names of complainants and respondents, along with any materials relating to the substance of the investigation will be kept confidentially and segregated from other office files.
There are two exceptions to the confidential nature of JEEP investigations:
1. Complainants will be informed of the results of the investigation. If the results are not otherwise published, the complainant will be reminded of the confidential nature of the investigation and the sensitivity of the information.
2. If prima facie evidence of a violation is found, and the respondent (a) is referred to the Joint Trial Board or (b) agrees to a settlement agreement specifying the results of the investigation will be published, then AICPA and PICPA bylaws allow for publication of the results of the investigation and disciplinary actions. Disciplinary actions are available though the organizations’ respective periodicals and Web sites.
JEEP Manual of Procedures
The complete JEEP Manual of Procedures
is available through the AICPA Web site. Print copies are also available from the PICPA Professional & Technical Standards team.