We read with interest Vincent J. Love and Thomas R. Manisero’s article in the May 2017 CPA Journal, “Plain Paper Financial Statements Made Not So Plain: An Overview of SSARS 21.” While the authors have provided good advice on several matters, there are two issues that we take exception with.

At the end of the article, the authors provide six points that CPAs should consider. While we wholeheartedly agree with the first five, we feel that the sixth—avoid attaching a CPA’s name to the legend—should be a firm-by-firm decision based on the CPA’s understanding of the environment, the client situation, and the engagement facts and circumstances. The Accounting and Review Services Committee (ARSC) was very careful not to usurp the CPA’s professional judgment, taking a neutral view by neither requiring nor prohibiting attaching the CPA’s name.

In addition, the authors appear to be discrediting the quality work of CPAs because they use the preparation service. The opening quote, “We are what we pretend to be …,” along with the final paragraph that discusses the public image, seems to imply that a CPA who engages in preparation services is less professional or is somehow denigrating the CPA brand. If we have inaccurately inferred this tone, we apologize, but we know many high-quality CPA firms that perform preparation engagements as a valuable service for their clients. Because all members must comply with the General Standards of the Code of Professional Conduct (which the authors do mention), CPAs who perform preparation engagements should be as professional as CPAs who perform assurance services.

In summary, we think the article articulates many excellent points, and so we thank the authors for calling attention to SSARS 21; however, readers should use their own professional judgement regarding the legend. As for their public image, we encourage all CPAs to constantly work in the best interest of the public and the profession, regardless of the types of services they provide.

Charles E. Landes, CPA. AICPA Vice President, Professional Standards, Audit and Attest Standards New York, N.Y.
Michael P. Glynn, CPA. AICPA Senior Technical Manager, Audit and Attest Standards New York, N.Y.